Wallenius Wilhelmsen

Board of Directors

The Wallenius Wilhelmsen's Board of Directors is a unitary board comprised of seven non-executive members with extensive experience in relevant sectors, including international energy, banking and finance, accounting, shipping, marine engineering, consumer goods, and logistics. The composition of the Board of Directors reflects the shared interests of all shareholders and aligns with the company's need for expertise, including industry and sustainability knowledge, geographical insights, diversity and overall capacity. Four of the seven board members, or 57 percent, are independent non-executive directors. There are no employee representatives on the Board, and none of the members of the Board or executive management team has held any positions in public administration in the preceding two years.

In 2024, a third-party consultancy assessed the Board's roles, skills, and competencies. Through one-on-one interviews and desk-top research, they investigated the level of experience and familiarity of the board member regarding sustainability, energy transition and the other material topics identified by Wallenius Wilhelmsen as especially relevant to the company. The consultancy concluded that, in addition to having familiarity with all relevant topics, the Board demonstrated strengths in relevant areas.

Competencies of Board of Directors:

• Sustainability: All 7 members have practiced competence
• Energy Transition: All 7 members have practiced competence
• Climate change: All 7 members have practiced competence
• Safe and secure operations: All 7 members have practiced competence
• Diversity, equal opportunities and inclusion: All 7 members have practiced competence
• Working conditions & human rights: All 7 members have practiced competence
• Corporate culture & governance: All 7 members have practiced competence

The Board of Directors are collectively responsible for overseeing sustainability impacts, risks and opportunities. The company's sustainability objectives, metrics and targets, and the annual report, are reviewed by all board members, who also approve the material sustainability topics. Moreover, the Board of Directors is accountable for the company's internal control and risk management frameworks. The Board reviews the company's risk matrix quarterly and evaluates the internal control arrangements at least annually.

Wallenius Wilhelmsen's governance framework is based on ISO 37000 and outlines the corporate governance principles and the company's governance model. The framework provides a clear set of requirements, guidelines, processes, and structures that help ensure that the company operates effectively, efficiently, and in alignment with its strategic ambitions, values, and compliance program.

Group Executive Management

The Executive Management Team is comprised of the CEO and nine executive managers who report to the CEO. Forty percent of its members are women. Collectively, the management team brings decades of extensive global experience in shipping, logistics, consulting sectors, along with deep expertise in the company's key markets in the EU, Middle East, USA, and Asia.

The executive management has primary responsibility for reviewing and approving the result of the company's double materiality assessment used to identify material impacts, risks, and opportunities.

The CEO and members of our executive management oversee group policies, approve management-level ESG policies, and conduct an annual review of metrics and setting targets for the upcoming year. The Chief Sustainability Officer, who reports to the CEO, is responsible for embedding sustainability in our governance and management systems as well as the integrity of the company's sustainability data collection procedures and reporting.

Executive management and the Board receive ESG information regularly throughout the year, including through the DMA annual review process, updates provided by the Chief Sustainability Officer, the Orcelle Accelerator team, and via the company's quarterly internal report, OneView.

Sustainability topics are included regularly in the board's agenda, and they are on the agenda for every Board Audit Committee meeting (at least once per quarter). The board also has access to third party experts and bespoke training.

Board meetings and sustainability

Sustainability is on the agenda of every board meetings with four deep dives during the year, covering the following topics: annual report, quality and environment policies, CSRD and biodiversity, governance framework, strategy, DMA process and outputs, and sustainability financing framework. Sustainability-related risks were also discussed four times during the reporting year. Similarly, sustainability-related compliance was covered in general compliance reviews, which occurred as part of the annual compliance update, and the review of the code of conduct.

The board also conducted dedicated sessions on specific topics:

• January: White paper on future fuels.
• February: Newbuilding options and green fuels sourcing strategy.
• March: People and remuneration, including safety and carbon targets.
• May: EU ETS - new fuels update and availability, newbuilding options including fuel study.
• June: Insights on future fuels (presented by McKinsey).
• June: People strategy, which includes values and diversity, equal opportunities and inclusion.
• September: Remuneration, including safety and carbon.
• December: Climate targets, emission model progress, reduced carbon service and bunker adjustment factor.

Management continuously monitors the company's impacts, risks, and opportunities. To ensure effective performance monitoring, the Board regularly reviews specific targets relevant to our business, the enterprise risk manager provides update on key risks and the CPO and VP compensation & benefit updates the People, Culture, and Remuneration Committee on the progress on the targets they have approved. The targets include climate, safety and #engage (employee engagement survey).

Material impacts, risks, and opportunities are considered by executive management and the Board through regular updates provided by the Chief Sustainability Officer and the Orcelle Accelerator team, and also in via the quarterly report on financial and sustainability performance. Executive management and the Board of Directors have reviewed specific IROs related to two of our most material topics, climate change and safety.

In 2024, for the first time, our material topics, impacts, risks, and opportunities were integrated into executive management's discussions during the annual strategy process. Going forward, the DMA and strategy review process will be further aligned.

Wallenius Wilhelmsen's sustainable strategy is reflected in our incentive schemes. Measuring how the company performs and connect this to bonus plans ensures correct and aligned priorities and sets clear direction.

Our fundamental salary policy is to be competitive, though not necessarily market-leading. This ensures a sustainable level of reward, performance benchmarks and remuneration policies whilst aligning incentives with environmental, social, and governance (ESG) and financial goals. This integration promotes responsible corporate behavior and long-term value creation.

The short-term incentive scheme covers relevant, clear targets derived from the overall strategic goals and includes sustainability targets such as safety and CO₂e intensity performance and #engage score. The variable pay scheme takes into consideration both key corporate and financial targets as well as individual targets. The sustainability targets account for 30 percent of the total of which CO₂e intensity accounts for 10 percent. The program applies to employees from senior manager and above. Employees must also sign the Code of Conduct and complete the Code of Conduct training to receive the remuneration.

To reflect the long-term view of our strategy, we also have a long-term incentive scheme for the executive management group. In this scheme, CO₂e intensity in our shipping operations is one of five KPIs.

The People, Culture, and Remuneration committee is responsible for preparing and facilitating the decision making in the Board with respect to remuneration and the variable remuneration scheme is approved by the board. Board members are not part of any of the incentive schemes.

Core Elements of Due Diligence

The corporate sustainability team is responsible for developing comprehensive group reports on sustainability issues and ESG metrics. Developing adequate reporting processes to align with the requirements of ESRS has been a top priority in 2024.

The primary challenges in creating unified sustainability disclosures across the organization include risks associated with incomplete or inconsistent data reporting. Risks related to data accuracy and manual errors in the reporting process, specifically in aggregating data from multiple systems into the corporate reporting tool have been identified, along with insufficient internal controls over data at various levels, from sites to corporate.

To minimize reporting errors, the corporate sustainability team manages a unified data framework for the entire group, employing a systematic risk prioritization methodology. This standardizes definitions, calculations, and critical metrics like emission factors in compliance with the GHG Protocol. This centralized approach to reporting also enables the department to function as an information hub, identifying and rectifying inconsistencies or errors in data submitted by the business units.

To enhance our reporting, Wallenius Wilhelmsen in 2021 implemented a specialized sustainability reporting tool to manage and structure data for reporting purposes and monitor adherence to reporting standards. The tool was updated in 2024 to comply with ESRS. We have also implemented the ESG module of our group reporting tool. To digitalize the reporting process and strengthen the internal control and efficiency of the reporting, APIs have been established between our HR system and the sustainability reporting tool, and between the sustainability reporting and the financial reporting tools. All sustainability data is now based on the accounting principles outlined by the ESRS.

To strengthen the internal control over sustainability reporting, the corporate sustainability team has developed a roadmap. In 2024, the priority was to establish the governance, perform risk assessment and scoping, and prioritize key entity-level controls. These controls cover strategy, metrics and targets, DMA, reporting boundaries, process, and disclosures. We are in the process of adopting the COSO Guidance on Internal Control Over Sustainability Reporting framework in our approach.

The risk assessment of the data flow identified the integrity of safety (LTIF) reporting in our logistics operations as a high risk. An internal audit was therefore conducted to review the governance, risk, and controls, including efficiency and effectiveness of the safety reporting process. The aim was to improve the overall reporting process and integrity of externally reported safety numbers. The audit concluded that there is uncertainty regarding the data and provided concrete recommendations to strengthen the reporting.

Our reporting of data for substances of (very high) concern in our shipping operation is also based on estimates. Currently available data is procurement of chemicals for 22 out of 125 vessels. Although the data relates to procured chemicals and not actual amounts released, we have extrapolated this data to the whole fleet to estimate our performance in 2024.

As a provider of global logistics solutions, Wallenius Wilhelmsen has three main services: ocean shipping, logistics, and government services. To provide these services, the company owns, leases and operates a significant amount of shipping and logistics assets. In 2024, the company added an additional service offering, integrated digital supply chain solutions. The company's key customer groups are automakers, manufacturers of heavy machinery, project cargo for OEMs (original equipment manufacturers), and the US Department of Defense.

Our shipping service is comprised of a fleet of 125 vessels uniquely constructed with ramps and movable decks for efficiently and safely moving rolling cargo (Ro-Ro) like trucks and cars from one port to another. The main inputs of shipping services are newbuild vessels, fuel, and labor (vessel crew, fleet planning and marine operations). The company works closely and long-term with newbuild yards to extend our future fleet.

The company also provides logistics services to a range of global OEMs. We create value for our customers by owning and/or operating a comprehensive land-based logistics network of port terminals, inland distribution, and service and processing centers located around the world. The main resources we use to provide logistics services are labor (for loading and unloading vessels, trucks and rail carriers, and processing cargo), land, equipment such as forklifts and heavy-duty trailers for moving cargo, and a fleet of trucks for inland distribution.

Value Chain

The main features of our value chain include:

• Our direct operations, i.e. inland distribution, ocean operations, ports, terminals and offices and processing centers
• Upstream activities such as new vessel and facility building, and
• Downstream activities i.e. vessel and infrastructure recycling at end of life.

The main business actors in our value chain are:

• Newbuild yards
• Energy providers
• Port authorities
• Terminal operators
• Stevedores
• Freight forwarders and inland transportation providers, and
• Customers.

Key suppliers include:

• Energy providers
• Port and canal authorities,
• Stevedores, and
• Tug operators.

The company's activities are all within the ESRS sector called "transportation." The company is neither active in the fossil fuel sector, chemicals production, controversial weapons nor the cultivation and production of tobacco. The company provides services to the US Department of Defense. However, we do not ship any of the controversial weapons that are specified in ESRS, i.e. anti-personnel mines, cluster munitions, chemical and biological weapons.

Wallenius Wilhelmsen is committed to engaging the company's stakeholders and responding to their interests and expectations. These interactions help shape our understanding of how to best manage our sustainability performance. The views of our stakeholders were essential for our double materiality assessment, and the development of our decarbonization strategy. Engagement involves many teams such as sustainability, marine operations, operational excellence, customer, the decarbonization accelerator team and investor relations in addition to our executive management and the Board of Directors.

Executive management and the Board are informed about stakeholders' views and interests through the double materiality assessment process and results.

In 2023 and 2024, the company's strategy was updated to address stakeholders' views on climate change risks by adding a climate goal to its four strategic goals. To meet investors' expectations, we have also linked our financing to our carbon targets.

Our material impacts, risks and opportunities (IROs) were identified using a double materiality assessment (DMA) in 2023, and refined during our DMA annual review in 2024. The DMA process involved collaboration with a broad spectrum of stakeholders such as employees, suppliers, customers, investors, research institutions and NGOs, to pinpoint the company's significant sustainability issues.

In 2024, we developed and conducted our first DMA annual review, resulting in several changes to our material topics. It was deemed that E5 Resource Use and Circular Economy, and related subtopics, are not material due to Wallenius Wilhelmsen being a service provider and not a producer. It was also determined that E3 Water and Marine Environment is not material to our business, as none of the subtopics are relevant for our operations.

Many of our impacts are endemic to the industries we operate in and therefore not directly connected to our strategy, per se. Some of the impacts, such as biodiversity and pollution, may occur in the medium to long-term, whilst climate and diversity, equal opportunities and inclusion already affect the company. Our impacts relating to climate, compliance, safety and diversity and equal opportunities are all reflected in our strategy.

To test the resilience of our strategy in relation to climate change, we relied on two main activities: During our annual strategy review in 2024, executive management assessed potential strategic pathways and evaluated how our ESG material topics impact each of them. The Company has also conducted scenario analyses. These are aligned with the recommendations of the Task force on Climate-related Financial Disclosures (TCFD) and test our resilience against climate impacts.

Key insights from our scenario assessments:

• Managing technological transition risks will continue to be the focus area to mitigate financial impact of climate change.
• Preparing for a 1.5°C degree future will enhance resilience and mitigate impacts of climate-related financial risks.

Most of the company's actual and potential impacts on our own workforce do not directly originate from our strategy, but are endemic to our industry and not strictly a result of the company's business model. However, our strategy is designed to have workforce impacts, including "safety, security and compliance" and "one band of rockstars".

Material negative impacts are largely systemic in the shipping and logistics sectors. Some safety risks are related to individual incidents. Material safety risks to the company (fire and outbreak of contagious diseases) also arise from workforce dependencies. Attracting and retaining diverse talent is a material risk for the company, due to our reliance on labor in the shipping and logistics sector.

During our human rights due diligence, we identified four key groups of workers in our value chain who we materially impact: Workers at the shipyards, recycling, and dry-docking, and crew on time charter vessels. Safety and human rights impacts on workers at newbuild yards are integral to our strategy and business model, as we build and buy most of the ocean vessels in our fleet.

Wallenius Wilhelmsen has conducted a double materiality assessment (DMA) to determine our material ESG topics. The materiality assessment identifies the environmental, social and governance areas strategically important for Wallenius Wilhelmsen and the sustainability topics we are required to manage and disclose.

The double materiality assessment

Sustainability topics and Relevant ESRS topics:

1. Climate change - E1 Climate change
2. Waste and Circular economy - E5 Resource Use and Circular Economy
3. Biodiversity - E4 Biodiversity and Ecosystems
4. Pollution - E2 Pollution
5. Safe and Secure Operations - S1 Own workforce, S2 Workers in the Value Chain
6. Diversity, Equal opportunity and Inclusion - S1 Own workforce
7. Working conditions and human rights - S1 Own workforce, S2 Workers in the Value Chain
8. Freshwater - E3 Water and Marine Resources
9. Corporate culture and governance - G1 Business Conduct
10. Affected communities - S3 Affected communities
11. Trafficking - S2 Workers in the Value Chain

Topics marked in bold are considered material and will be reported in line with European Sustainability Reporting Standards.

Our double materiality assessment followed five steps:

1. Kick-start process and understand context The double materiality assessment was conducted in line with the CSRD requirements. The scope of our DMA included corporate, shipping and logistics operations. Desktop research was used to evaluate potential material topics.

2. Develop a long list of sustainability topics Positive, negative, potential, and actual impacts were identified across the value chain, supported by the desk research, and compiled into a long list.

3. Determine impact materiality of topics Relevant internal and external stakeholders across the value chain were identified. To assess impact materiality, stakeholders were engaged through interviews. A threshold was applied, and if 65 percent of stakeholders assessed a topic as 'significant' or 'very significant', it was deemed material.

4. Determine financial materiality of topics A workshop was held with internal stakeholders to assess the financial materiality of the topics. The stakeholders included representatives from finance, risk, strategy, internal control, sustainability and decarbonization.

5. Validate results The results were validated in a workshop with the participants from the financial materiality workshop. Final validation with executive management, the Board Audit Committee and the Board of Directors was confirmed in 2023 and again in 2024.

At Wallenius Wilhelmsen, we view the process of identifying, assessing, and prioritizing material topics and IROs as dynamic and we commit to annually revisiting the DMA process and further integrating it into the strategy process. In 2024, we developed and conducted our first DMA annual review. The process involves validating our value chain and changes to our material topics following regulatory changes or stakeholder input.

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To achieve our net-zero 2040 ambition, we developed a comprehensive transition plan. We have established 2022 as our baseline year and identified three key milestones; 2027, 2030, and 2040. These milestones are integral to our transition plan which will evolve as new technologies and low-carbon fuels become available at feasible prices. Driven by innovation, customer focus, and a commitment to reducing our climate impact and environmental footprint, we will adjust our operations and address unexpected risks and opportunities along the way. Executive management and the Board of Directors approved the net-zero 2040 target and transition plan in 2023.

By 2027, we aim to launch a net-zero end-to-end service pilot with selected customers and partners. This service will involve new vessels sailing on low-carbon fuels, green electricity-powered terminal operations, and net-zero trucking. This will enable net-zero transportation from the vehicle factory, via the terminal and processing services, to the end customer. The pilot will provide us with valuable insights for decarbonizing our value chain.

By 2030, we commit to cutting absolute GHG emissions from our shipping operations by 40 percent and achieving a 44 percent intensity reduction in well-to-wake (WTW) GHG emissions, driving a significant shift towards a decarbonized logistics network. For our land-based operations, the target is a 42 percent reduction in scope 1 GHG emissions, with terminals and processing centers running entirely on renewable energy.

By 2040, we commit to reach net-zero across all operations, on land and at sea. Our trucks, terminals, and vessels will run on renewable energy, reducing emissions to near-zero levels. Our shipping operations target an intensity reduction of 97.1 percent in well-to-wake GHG emissions and 96.4 percent in absolute GHG emission reduction, while our land-based operations will achieve a 90 percent reduction in scope 1 GHG emissions. Scope 3 GHG emissions from our value chain will be cut by 90 percent, ensuring alignment with our net-zero targets. We will source 100 percent renewable electricity and remove any remaining emissions through carbon removal certifications.

The Group Environmental Policy is our group-wide policy to manage our material environmental topics including climate change and decarbonization, biodiversity and ecosystems and pollution. The scope of the policy covers all activities within our Group, including ocean shipping, vehicle processing, terminal management, in-land distribution and upstream and downstream activities across our value chain, such as vessel newbuilds and vessel recycling. The Board of Directors has the ultimate responsibility for this policy, while the CEO has the ultimate responsibility to ensure compliance with this policy. The policy is publicly available on our website.

The policy specifically states that decarbonization is an essential part of our business strategy and we are committed to becoming net-zero by 2040. We embrace renewable energy, new fuels, electrification, and operational and technical improvements to drive our progress towards a net-zero future.

For all environmental topics, we shall continue to identify, assess, and control the environmental impacts of our value chain. We shall also establish and maintain a risk management system that includes regular risk assessments, identification, and control measures. We will strive to continuously improve how we monitor and manage our environmental risks with an ISO 14001-compliant integrated management system.

To ensure a common approach for our global operations, we are committed to the standards developed by the United Nation's Global Compact and the OECD's Guidelines for Multinational Enterprises on Responsible Business Conduct. We are also a member of the Ship Recycling Transparency Initiative.

During 2024, several achievements were made to enhance our climate efforts:

• Our near-term and net-zero science-based greenhouse gas emission reduction targets were validated by the Science Based Targets initiative (SBTi) and have been classified as in line with a 1.5c degrees trajectory.

• We developed a new sustainability financing framework to reflect our net-zero targets. The framework outlines the details of how Wallenius Wilhelmsen may raise financing through green bonds, loans, and derivatives, as well as sustainability-linked bonds, loans, and derivatives. We intend to allocate the green financing to new dual-fuel capable vessels that comply with the EU Taxonomy. The framework was launched in February 2025.

• Wallenius Wilhelmsen introduced a Reduced Carbon Service (RCS) in 2023 and issued our first customer declarations on reduced CO2e emissions to our first customer in the December that year. Today we have more than 20 customers signed up for the service, and we consumed roughly 140k tons of B30 biofuel blend in 2024. Transparency, accuracy, and accountability are critical to ensure trust and confidence in our services. Therefore, we used DNV as an independent third party to externally verify the RCS declarations. The process was conducted with a digital emission bank which was developed in-house. It records emission reductions from consuming biofuel, the allocated emission reductions to customers, and the remaining balance.

Our targets to achieve net-zero as validated by the Science-Based Target initiative:

The targets are set following the SBTi maritime guidance for all shipping related emissions. The SBTi Corporate guidance was used to set the targets related to our logistics and corporate emissions. The base year for the targets is 2022. Our targets have been validated by SBTi and are therefore science-based and support the goal of the Paris Agreement to limit global warming to 1.5c.

2030 Climate Targets validated by SBTi:

• Reduction of absolute scope 1 GHG emissions from Logistics operations: 42%
• Reduction of absolute well-to-wake scope 1 and 3 GHG emissions from Shipping operations: 40%
• Reduction of intensity well-to-wake scope 1 and 3 GHG emissions from Shipping operations per tonne nautical mile: 44%
• Annual sourcing of renewable electricity: 100%

Carbon performance:

• Total GHG emissions Scope 1, 2, 3 (Market-based): 5,254,001
• Total GHG emissions Scope 1, 2, 3 (SBTi coverage): 4,929,234
• % emissions reduction from 2022 to 2024 (SBTi trajectory): (7)%

Energy consumption and mix

Total energy consumption and split by source (2024)

Energy intensity (high climate impact sectors – transportation)

Scope and methodology:
Energy consumption covers the group's global operations. The company operates in the ESRS transportation sector. Renewable energy consumption in 2024 comprises biofuel and biofuel blends (e.g. B30, B100) consumed by the shipping fleet. The company reports 100% annual sourcing target for renewable electricity for land-based operations, but purchased renewable electricity consumption is reported as 0 MWh in 2024 (only fuel-based renewable energy is captured). Energy intensity is calculated using net revenue from high climate impact sector activities (transportation segment). The company does not provide multi-year comparatives for the energy mix table under E1-7, though 2023 and 2022 baselines exist for GHG emissions.

Gross Scopes 1, 2, 3 and Total GHG emissions

Climate accounting

The following table summarises Wallenius Wilhelmsen's GHG emissions across Scope 1, 2, and 3 for 2024, with comparative data for 2023 and 2022 (baseline year), and milestones/target years:

Biogenic emissions

Energy consumption and mix

Energy intensity based on net revenue in high climate impact sectors

Internal carbon pricing

Methodology and assumptions

Scope and boundaries:

• The scope includes material scope 3 emission categories, including spend on fuel and stevedoring services. Categories 8-15 are deemed immaterial but will be assessed in the upcoming Scope 3 project.
• Scope 2 baseline includes electricity consumption from all sites and estimates for offices.
• Baseline aligned with GHG Protocol and relevant ISO standards, with adjustments for CSRD compliance.
• Baseline value will be periodically reviewed and updated for significant changes.

Emission factors and calculation:

• In 2024, all maritime CO2e factors were updated from GLEC to FuelEU's emission factors for well-to-tank (scope 3), tank-to-wake (scope 1) and well-to-wake (scope 1 and 3) for 2023 and 2024.
• Scope 3 emissions use Exiobase spend-based factors for categories 1, 2, 4, and 6.
• Scope 2 emissions for office employees are estimated using Odysee-Mure Emission factors for electricity consumption per employee in offices. Emission factors for location and market based emissions are from AIB and IEA.
• A comprehensive scope 3 mapping project is planned for 2025 to review all scope 3 emissions.

Data limitations:

• Reporting of HFCs in shipping operations is based on estimates. Currently available data covers procurement of refrigerants for 22 out of 125 vessels, extrapolated to the whole fleet for 2024. Substances procured in 2024 may have a life-span longer than a year, so this does not reflect actual amounts emitted.
• Limited primary data for certain scope 3 categories requires reliance on industry averages or proxies.
• Measurement granularity challenges for regional or business-unit-specific analysis.

Scope 1 sub-breakdown: Not disclosed by stationary/mobile/process/fugitive emissions categories.

EU ETS: 20% of Scope 1 GHG emissions from regulated emission trading schemes (EU ETS) in 2024.

Regulated emissions: Shipping was included in the EU Emission Trading Scheme (EU ETS) from 2024. The group is exposed to EU ETS through its operations in Wallenius Wilhelmsen Ocean, American Roll-On Roll-Off Carrier and EUKOR Car Carriers. A provision of USD 3.1 million pertaining to Pillar Two top-up tax was recorded. A provision of USD 13 million for emission trade allowances was recognized in other current liabilities. USD 14 million in EU ETS emission allowances is included in the fuel/lube oil balance at year-end 2024.

Shadow carbon price: The group has implemented a shadow carbon price based on the EU Emission Trading Scheme (EU ETS), visualizing how much direct carbon emissions would cost globally if subject to the same fee as shipping emissions in the European continent. The scope includes global business operations with shadow price on scope 1 emissions from Shipping, Government and Logistics segments (approximately 4,160,000 tonnes CO₂e). The shadow carbon price is based on the quarterly average cost of EU Allowances (EUA) contracts using the ICE EUA Daily Future index. The shadow price is reviewed quarterly and visualized per business segment in the OneView report to management and the Board. The accumulated cost can be factored into investment and management decisions.

GHG intensity: Total GHG emissions Scope 1 & 3 (Well-to-wake) from shipping operations per tonne nautical mile (EEOI) was 60.56 gCO2e in 2024 (2023: 62.15; 2022 baseline: 66.55). Tank-to-wake scope 1 intensity per tonne km (EEOI) was 27.91 gCO2e in 2024 (2023: 28.64; 2022 baseline: 30.38).

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

Use of phase-in exemption

The company is using the phase-in exemption for ESRS E1-9 disclosures. According to the ESRS index table:

• E1-9-66 (Assets at material financial risk): Phased in - Not applicable
• E1-9-69 (Financial opportunities - cost savings, market size and changes to net revenue from climate change actions): Phased in - Not applicable

Note: E1-9-67(c) relating to carrying amount of real estate assets by energy efficiency classes is marked as "No" for materiality and "Not applicable" for page number.

Key insights from scenario assessments

The company conducted scenario assessments using SSP1-1.9 and SSP5-8.5, representing future global temperatures of 1.5°C and 4°C respectively, with projected climate data sourced from CMIP6 for the years 2030 and 2050.

Key insights identified:

• Managing technological transition risks will continue to be the focus area to mitigate financial impact of climate change
• Preparing for a 1.5°C degree future will enhance resilience and mitigate impacts of climate-related financial risks

Workforce transition impacts

While the company has developed a transition plan to reach net-zero goals, it has not yet thoroughly assessed the impacts of that plan on the entire workforce. However, specific transition risks have been identified:

• Transporting EVs and starting to use new fuels (particularly batteries in EVs and ammonia fuel) represent new safety risks for the workforce
• LNG as a new fuel requires establishing processes to ensure the workforce has necessary equipment and training for safe bunkering

The Group Environmental Policy is our group-wide policy to manage our material environmental topics including climate change and decarbonization, biodiversity and ecosystems and pollution. The scope of the policy covers all activities within our Group, including ocean shipping, vehicle processing, terminal management, in-land distribution and upstream and downstream activities across our value chain, such as vessel newbuilds and vessel recycling. The Board of Directors has the ultimate responsibility for this policy, while the CEO has the ultimate responsibility to ensure compliance with this policy. The policy is publicly available on our website.

For all environmental topics, we shall continue to identify, assess, and control the environmental impacts of our value chain. We shall also establish and maintain a risk management system that includes regular risk assessments, identification, and control measures. We will strive to continuously improve how we monitor and manage our environmental risks with an ISO 14001-compliant integrated management system.

To ensure a common approach for our global operations, we are committed to the standards developed by the United Nation's Global Compact and the OECD's Guidelines for Multinational Enterprises on Responsible Business Conduct. We are also a member of the Ship Recycling Transparency Initiative. These international networks and initiatives support continuous improvement of managing business' impact on environmental matters.

Actions and resources related to pollution

Actions in shipping activities

Sulfur emissions compliance and reduction

• What: Compliance with IMO regulations through use of scrubbers or low-sulfur fuels (VLSFO <0.5% or LSMGO 0.1% max). Scrubbers bring exhaust gases into contact with seawater, transforming sulfur and releasing it to sea as sulfates. The company is investigating how to measure the impact from scrubber wash water release on water quality
• Scope: Own operations (vessels)
• Outcome: Scrubbers significantly reduce SOx emissions to air and Particulate Matter (PM)
• Time horizon: Ongoing

Operational efficiency initiatives

• What: Energy efficiency measures to reduce fuel consumption
• Scope: Own operations
• Outcome: Further reduction in sulfur emissions
• Time horizon: Ongoing

Future fuel and engine technology transition

• What: Consideration of different fuel and engine technologies, including shift to biofuels or zero emission fuels (methanol or ammonia)
• Scope: Own operations (vessels)
• Outcome: Would drastically reduce and potentially eliminate SOx and PM emissions to air
• Time horizon: Future (no specific dates provided)

Chemical management and replacement program

• What: Use of chemical "blends" with concentrations within risk factor levels; continuous monitoring and phase-out of non-compliant chemicals. Specific actions include:
  • Replacement of Unitor Fuelpower Soot Remover with ROCOR NB Liquid
  • Updating refrigerants from R-404A to R-407f
• Scope: Own operations (vessels)
• Outcome: Estimated 52% reduction in carbon footprint from refrigerants
• Time horizon: Ongoing

ISM Code compliance and monitoring

• What: Designated persons ashore with direct access to highest management level to monitor safety and pollution-prevention aspects. Regular internal safety audits conducted on board and ashore to verify compliance with safety management systems. Corrective action plans identified according to internal procedures
• Scope: Own operations (vessels and shore)
• Outcome: Verify compliance with pollution prevention activities
• Time horizon: Ongoing

Actions in logistics activities

Safety 1st program and HAZMAT safety plans

• What: Established measures to control and monitor chemicals and pollutants used by logistics sites
• Scope: Own operations (logistics sites)
• Resources: Operational resources allocated to Safety 1st program (no specific amounts disclosed)
• Time horizon: Ongoing

ISO 14001 and 45001 certification program

• What: 80% of logistics sites achieved ISO 14001 and 45001 certification, establishing stronger framework for monitoring and measuring environmental and safety performance. ISO 14001 requires each site to have impact assessment to identify material topics with concrete measures, covering pollution where material
• Scope: Own operations (logistics sites)
• Outcome: Stronger framework for monitoring chemicals and pollutants; maintain safe and compliant workplace
• Time horizon: Ongoing
• Note: Consolidated approach and results not available

Targets related to pollution

We currently do not have targets related to pollution. However, in 2024, we completed a mapping of procured pollutants and substances of (very high) concern for shipping. The mapping focused on substances found in chemicals, refrigerants and welding electrodes for 22 vessels. We currently do not track the effectiveness of policies and actions of material impacts and risks for pollution.

Our reporting of data for substances of (very high) concern in our shipping operation is also based on estimates. Currently available data is procurement of chemicals for 22 out of 125 vessels. Although the data relates to procured chemicals and not actual amounts released, we have extrapolated this data to the whole fleet to estimate our performance in 2024. We will collect data for the remaining vessels in 2025. Moreover, we do not have pollution data for our logistics operations and this will also be mapped in 2025. For 2024, the data for shipping on pollution of particulate matter is estimated.

Substances of concern and substances of very high concern

During the mapping exercise of substances of (very high) concern in chemicals, refrigerants and welding electronics the following were identified:

Measurement methodology

Our reporting of data for substances of (very high) concern in our shipping operation is based on estimates. Currently available data is procurement of chemicals for 22 out of 125 vessels. The data relates to procured chemicals, refrigerants and welding, however not actual amounts released. We have extrapolated this data to the whole fleet to estimate our performance in 2024. External density conversion factors have then been applied where relevant.

Although the substances have been procured in 2024, this does not reflect actual amounts emitted as the products may have a life-span of longer than a year. When a substance falls under multiple hazard classes, its full amount is reported in each relevant class. This results in double-counting of the total substances of (very high) concern and the estimations are therefore over-reported.

Where the density conversion factor is not available, we have a used a 1:1 conversion from liters to kg. In reality, there could be some deviation to this conversion factor.

We will continue to work on our mapping of substances of concern and very high concern in shipping. This will then be incorporated into ISO 14001 management system during 2025. The development of reporting and internal control procedures will follow suit.

How we will proceed

In 2025, we plan to initiate a mapping of pollutants and substances of (very high) concern for logistics. Based on the results, we will assess if targets should be established.

We shall establish and maintain a risk management system that includes regular risk assessments, identification, and control measures. We strive to continuously improve how we monitor and manage our environmental risks with an ISO 14001 conformant integrated management system.

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

Integration in Corporate Strategy and Business Model

Biodiversity is considered one of the most material topics in the Double Materiality Assessment (DMA). The company operates globally across all regions, and recognizes the importance of managing nature and biodiversity in a way that does not lead to natural disruptions but rather environmentally-sustainable value creation and conservation.

TNFD Framework Application

In 2024, the company conducted a biodiversity impact assessment using the guidelines and methodology recommended by the Task force for Nature-related Financial Disclosures (TNFD). The assessment was structured in line with the LEAP-process defined by TNFD:

1. Locate: Mapped global shipping routes using AIS data in a GIS platform, overlaying data layers such as Marine Priority Areas (MPAs), Ecologically and Biologically Significant Marine Areas (EBSAs), Marine Wilderness, and Human Impact on the Oceans

2. Evaluate: Identified case locations including High Seas (North and West Atlantic Ocean), Straits/Channels (Malacca Strait and Panama Channel), Near Shore (Cape Hope and Melbourne to Brisbane coastline), and Harbours (Yeosu and Baltimore). Conducted stakeholder dialogue with biologists, research institutions, NGOs, peers and investors. Used Science-Based Targets Network's Sector Materiality Tool to evaluate drivers of biodiversity loss

3. Assess: Examined material nature-related risks and opportunities through scenario planning using TNFD recommended approaches. Physical risks for direct shipping operations considered small, but transition risk somewhat higher as sector-specific topics such as protection from invasive species, conservation of maritime territories and underwater radiated noise may become more regulated

4. Prepare: Results shaped strategy and ambitions and guided reporting on nature and biodiversity topics

Geographic and Value Chain Scope

The initial scope focused on shipping operations, representing the largest business segment. The remainder of the value chain, including land-based operations, and the upstream and downstream parts will be assessed in the coming years.

The company did not consult affected communities during the process, as the primary focus was on the global commons.

Biodiversity Strategy

The company developed a biodiversity strategy in 2024 based on the outcome of the global biodiversity assessment on ocean operations. The strategy is structured and informed by the mitigation hierarchy of the TNFD and the Global Montreal-Kunming Biodiversity Framework.

The company does not have a biodiversity transition plan and does not plan to develop this in the near future as they consider their initiatives on managing risk of adverse impacts to be sufficient. The biodiversity strategy will be reviewed annually and include elements from land-based operations as well as upstream and downstream value chain, if material.

Ambition: Actively protect biodiversity and improve ocean knowledge through:

• Protect and avoid important ocean territories

  • Managing risk of invasive species: Reduce risk through ballast water management, biofouling management, cargo inspection and treatment
  • Conservation of important territories: Avoid the arctic territory, avoid/minimize operations in biodiversity sensitive areas and particularly areas important for cetaceans

• Minimize impact on marine ecosystems

  • Manage pollution: Reduce air pollution through operational and technical efficiencies and by transitioning to alternative fuels; reduce risk of spills into ocean through detection, monitoring and training; reduce noise pollution across operations

• Increase insight to restore ocean health

  • Collect and share data for research: Engage with research institutions in need of ocean data, contribute with data collection to support research needs, promote partnerships that publicly share data

The company will not use any biodiversity credits to offset adverse impacts in their strategy.

Linkage to Nature-Related Risk Assessment

The most important impacts across ocean operations identified include:

• Invasive species in cargo, ballast water and through hull fouling
• Vessels' impact on whales and other cetacean species
• Noise pollution impacting life under water

Scenario Analysis

Four scenarios were developed in line with TNFD's proposed approach, aligned with Intergovernmental Platform on Biodiversity and Ecosystem Services (IPBES) assessments, assessed on different time horizons towards 2030, 2040 and 2050:

Scenario 1: Ahead of the game - Regulations aligned across geographies, world on track to reach biodiversity conservation target to protect at least 30 percent of the ocean by 2030, High Seas Treaty about to be ratified

Scenario 2: Go fast or go home - Loss of nature sudden and disruptive, shipping activities banned in certain areas, immediate action on invasive species creating delays and costs, reputational damage risk

Scenario 3: Sand in the gears - Nature slips down corporate risk priorities, CSRD implemented in Europe but reporting remains high-level, conflicting directions in government response

Scenario 4: Back of the list - Conflicting signals prevent systematic corporate action, governments fail to follow up on Global Biodiversity Framework and High Seas Treaty ambitions, shortage of raw materials disrupts supply chains

Sites Adjacent to Biodiversity Sensitive Areas

The company assessed land-based operations using biodiversity hotspot data. Sites adjacent to or overlapping biodiversity hotspots:

The company considers adverse impacts from overlapping with or being located adjacent to biodiversity-sensitive areas to be immaterial in both shipping and logistics operations, as they diligently adhere to international and local regulations.

Policies

The Group Environmental Policy is the group-wide policy to manage material environmental topics including biodiversity and ecosystems. The scope covers all activities including ocean shipping, vehicle processing, terminal management, in-land distribution and upstream and downstream activities across the value chain. The Board of Directors has ultimate responsibility for this policy, while the CEO has ultimate responsibility to ensure compliance.

The policy establishes commitment to:

• Do our part in halting and reversing biodiversity and nature loss
• Protect endangered species on land and in oceans
• Improve understanding of impacts on biodiversity and mitigate negative impacts on natural environments across the value chain

Land-based issues regarding sustainable land, agriculture and deforestation are not material topics for the company's activities.

When the full biodiversity assessment is completed, the company will evaluate whether to revise the Group Environmental Policy and consider specific biodiversity and ecosystem policies.

The company does not purchase, supply, or use minerals sourced from conflict-affected areas, and conflict minerals are prohibited from use in the supply chain.

Future Plans

Value chain assessment: Going forward, the company will analyze land-based operations further and set material thresholds for sites adjacent to or located on biodiversity sensitive zones. They will also start planning the assessment of upstream and downstream value chain.

Target setting: Setting measurable and quantifiable targets requires globally recognized target-setting guidance and defined sector-pathways. Once guidance is applicable, the company aims to adopt targets within a medium-term time horizon based on the latest recommended methodology.

The company has not yet adopted action plans related to biodiversity and ecosystems. They are awaiting guidelines on setting science-based targets that they then aim to follow up with specific actions and allocation of resources.

The Group Environmental Policy is our group-wide policy to manage our material environmental topics including climate change and decarbonization, biodiversity and ecosystems and pollution. The scope of the policy covers all activities within our Group, including ocean shipping, vehicle processing, terminal management, in-land distribution and upstream and downstream activities across our value chain, such as vessel newbuilds and vessel recycling. The Board of Directors has the ultimate responsibility for this policy, while the CEO has the ultimate responsibility to ensure compliance with this policy. The policy is publicly available on our website.

For all environmental topics, we shall continue to identify, assess, and control the environmental impacts of our value chain. We shall also establish and maintain a risk management system that includes regular risk assessments, identification, and control measures. We will strive to continuously improve how we monitor and manage our environmental risks with an ISO 14001-compliant integrated management system.

To ensure a common approach for our global operations, we are committed to the standards developed by the United Nation's Global Compact and the OECD's Guidelines for Multinational Enterprises on Responsible Business Conduct. We are also a member of the Ship Recycling Transparency Initiative.

Actions and resources related to biodiversity

The company states it has not yet adopted action plans related to biodiversity and ecosystems, and is awaiting guidelines on setting science-based targets to follow up with specific actions and allocation of resources.

Following the biodiversity impact assessment guided by LEAP and the strategy process, the company has not identified a need to expand mitigation measures already in place. Instead, it aims to structure biodiversity efforts more holistically and integrate them with existing processes and management systems.

Existing mitigation measures in place

The company has several measures connected to goals and strategy for ocean operations to mitigate impacts from invasive species, disturbances and pollution:

1. Managing risk of invasive species

Biosecurity management plan

• Description: Established to reduce the risk of invasive species (e.g., brown marmorated stink bug, snails, bugs, seeds) in cargo
• Scope: Own operations (vessels and cargo)
• Key activities:
  • Heat treatment or fumigation process for cargo travelling to Australia, New Zealand, Papeete, Reunion and Nouméa during bug season
  • Inspection for BMSB findings during treatment sessions before shipment
  • Counting findings onboard vessels during sea voyages
  • Cargo inspections during voyage
• Link to targets: Corresponds to Kunming-Montreal Biodiversity Framework target 6 to "reduce alien species spread by at least 50 percent by 2030"; supports company goal to "protect and avoid important ocean territories" as stated in biodiversity strategy
• Resources: Not quantified

Ballast water management

• Description: Ensure high quality ballast water management
• Scope: Own operations (vessels)
• KPIs: Percentage of vessels with Ballast Water Treatment Management Exchange to ensure compliance with Ballast Water Convention
• Resources: Not quantified

Biofouling management

• Description: Manage hull cleaning and antifouling
• Scope: Own operations (vessels)
• Key activities:
  • Procedures for cleaning anchors and chains when heaving up
  • Hull cleaning per year (frequency tracked)
  • Piloting new technologies to address biofouling
  • Antifouling policy specifying niche areas for monitoring
  • Tracking number of inspections conducted on vessels
• Resources: Not quantified

2. Conservation of important territories

Whale habitat protection measures

• Description: Adherence to mandatory and voluntary speed reduction regimes
• Scope: Own operations (vessels on Americas' east and west coasts)
• Key activities:
  • Reporting when entering key whale habitats (Americas' east coast - mandatory)
  • Fixed and temporary speed reduction and slow zones (Americas' east coast - mandatory)
  • Voluntary speed reduction measures (west coast of USA)
• Expected outcomes: Conservation of marine mammals
• Recognition: Received Sapphire award in 2024 by the Blue Whales [text appears truncated]
• Resources: Not quantified

Arctic operations

• Description: No operations in arctic territory
• Scope: Own operations
• Resources: Not applicable

Targets related to biodiversity and ecosystems

Wallenius Wilhelmsen has not yet set specific quantified targets related to biodiversity and ecosystems.

Future Target-Setting Intentions

The company states the following intentions regarding biodiversity targets:

• Approach: Following a complete biodiversity assessment, the company seeks to set targets based on the latest recommended methodology and globally recognized target-setting guidance.
• Timeline: Once guidance is applicable, the company aims to adopt targets within a medium-term time horizon.
• Priority scope: Biodiversity targets will be prioritized for ocean transportation, which is the company's largest business segment.
• Methodology consideration: The company will consider setting science-based targets for nature.

Current Mitigation Measures

While no specific targets are set, the company reports having several important measures in place to mitigate actual and potential impacts from:

• Invasive species
• Disturbances
• Pollution

These measures include:

• Managing risk of invasive species
• Conserving important territories for species
• Managing risk of pollution
• Supporting research with data collection

The company has set several goals as part of its renewed ocean strategy that will be quantified and monitored, though specific quantified biodiversity targets have not been disclosed.

Value Chain Assessment Plans

• 2024 focus: Assessment of ocean operations
• Going forward: Analysis of land-based operations and upstream/downstream value chain
• Material thresholds will be set for sites adjacent to or located on biodiversity sensitive zones

Impact metrics related to biodiversity and ecosystems change

Not disclosed.

The company's biodiversity assessment in 2024 focused on ocean operations using the TNFD LEAP process. The assessment mapped global shipping routes against biodiversity-sensitive areas including Marine Priority Areas (MPAs), Ecologically and Biologically Significant Marine Areas (EBSAs), Marine Wilderness, and Human Impact on the Oceans using AIS data and GIS platforms.

Six case locations were evaluated: High Seas (North and West Atlantic Ocean), Straits/Channels (Malacca Strait and Panama Channel), Near Shore (Cape Hope and Melbourne to Brisbane coastline), and Harbours (Yeosu and Baltimore). Impacts were evaluated using Science-Based Targets Network's Sector Materiality Tool based on scale, scope, and irremediability.

The company explicitly states in the disclosure index that E4-5 Impact metrics for both shipping and logistics are 'Not available' (page 130).

Land-based operations and upstream/downstream value chain assessments are planned for future years. The company has not yet set quantitative biodiversity targets pending globally recognized sector-specific guidance.

Policies related to own workforce

Wallenius Wilhelmsen has implemented several policies addressing material impacts on its own workforce across three material topics: safe and secure operations, working conditions & human rights, and diversity, equal opportunities and inclusion.

Health and Safety Policy

Scope: Applies to all employees working in Wallenius Wilhelmsen, including temporary staff, contractors and agency staff.

Governance: The Board of Directors has the ultimate responsibility for the existence of the policy, whilst the CEO has the responsibility to ensure organizational compliance with its content.

Key content: The policy specifies that safety is everybody's responsibility and to stop unsafe acts and behaviors. It covers identification and management of safety risks, emergency preparedness, training, reporting and investigation. The company's ambition is to build a resilient safety culture which will stand as a core element of identity and way of working, with the belief that all accidents and injuries can be avoided.

Standards alignment: The policy conforms with ISO 45001.

Public availability: Posted internally and externally to provide access for all stakeholders.

Monitoring: The company has implemented a health and safety management system according to ISO 45001. Worldwide more than 80% of land-based operations are certified to this standard. Safety performance is tracked through LTIF (loss time injury frequency) targets for shipping and logistics, reviewed on an annual basis and tracked on a continuous basis.

Code of Conduct

Scope: Applies to all employees working at or on behalf of Wallenius Wilhelmsen.

Governance: Approved by the Board of Directors. Operational responsibility lies with the Chief Executive Officer. Day-to-day responsibility for implementation rests with all managers, who are expected to lead by example and drive the culture of integrity across the company.

Key content: The code is employees' guide to making the right decisions and outlines the behaviors expected from them on topics such as human and labor rights, discrimination & harassment and equal opportunities. It prohibits any form of workplace bullying, harassment or discrimination, promoting a workplace with equal opportunities for employment and striving to achieve diversity throughout the company.

Standards alignment: Based on the United Nations (UN) Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, the core conventions that underpin it, and the International Labour Organization's Declaration on Fundamental Principles and Rights at Work.

Public availability: Publicly available on the company website.

Monitoring: All IT-enabled employees must sign off on the code of conduct annually and managers are held accountable to ensure their direct reports do so. Digital training courses are required for all IT-enabled employees. Employees must also sign the Code of Conduct and complete the Code of Conduct training to receive variable remuneration. The Compliance function provides minimum quarterly status updates to Board Audit Committee and annually to Board of Directors.

People Policy

Scope: Group-wide policy.

Governance: Approved by the Board, whilst the Chief People Officer has operational responsibility.

Key content: A new group policy which declares commitment to fostering, cultivating and preserving an inclusive workplace culture where people are safe, their rights respected, and diversity appreciated. The policy is foundational to implement strategic pillars of: expertise and leadership shaping the future; value driven culture and organization; future-ready workforce; and attractive employee experience.

The policy outlines commitments to:

• Safe, healthy, and decent working conditions
• Enable every employee to maximize their talents
• Promote diversity by promoting equal opportunities and inclusion for all employees
• A work environment free of discrimination, harassment, intimidation, or coercion
• Work/life balance through reasonable working hours and living wages and benefits
• Respect the human and labor rights of employees
• Equip people with training and development opportunities and attract new talent

Standards alignment: Based on the United Nations (UN) Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, the core conventions that underpin it, and the International Labour Organization's Declaration on Fundamental Principles and Rights at Work.

Public availability: Publicly available on the company website.

Monitoring: Efficiency primarily monitored through the annual engagement survey (#engage).

Human Rights Policy

Scope: Applies to all activities within the company's operations. Everyone working at or on behalf of Wallenius Wilhelmsen is required to comply with the policy. Expectations extend across the supply chain through the Supplier Code of Conduct.

Governance: The Chief People Officer has approved the human rights policy. The Chief Sustainability Officer is responsible for ensuring an effective human rights due diligence and to provide governance and advisory to facilitate the implementation of necessary governance processes and procedures.

Key content: Outlines commitment to respecting human rights in all activities. Addresses working conditions, living wages, discrimination, right to privacy, and modern slavery such as trafficking, forced labor, servitude and slavery.

The company's duty and commitment to respect human rights requires that Wallenius Wilhelmsen:

• Avoid causing or contributing to adverse human rights impacts throughout own activities and prevent or address such impacts when they occur
• Seek to prevent and/or mitigate adverse human rights impacts that are directly linked to operations and services or connected to business relationships

Standards alignment: Based on the United Nations (UN) Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, the core conventions that underpin it, and the International Labour Organization's Declaration on Fundamental Principles and Rights at Work.

Public availability: Publicly available on the company website.

Monitoring: The company conducts an annual human rights due diligence process where impacts on workers are assessed. Results inform people-related policies and code of conduct. Digital training courses are required for all IT-enabled employees, with a re-launched mandatory human rights training in 2024. The policy is updated on a regular basis to ensure continued relevance and drive continued improvement.

Bullying and Harassment Policy

Scope: Group-wide guideline.

Governance: The Chief People Officer is responsible for the policy execution through involvement and delegation to relevant managers.

Key content: Establishes a group guideline on how to prevent and handle bullying and harassment. The aim is to ensure a positive and constructive working environment which promotes organizational effectiveness and employee well-being. The company has a zero tolerance policy for bullying and harassment, and allegations shall be investigated fairly, objectively and confidentially.

Monitoring: Not specified.

Talent and Acquisition & Selection Policy

Scope: Applies to recruitment processes.

Governance: Chief People Officer is responsible.

Key content: Promotes fair and equal opportunities by providing guidelines on attracting diverse candidates and making all stages of the recruitment process objective, inclusive and free from bias.

Grounds of discrimination covered: The policies specifically cover racial and ethnic origin, color, sex, sexual orientation, gender identity, disability, age, religion, political opinion, national extraction and other forms of discrimination. As a global company, other forms of discrimination may be covered in local policies in accordance with local laws and regulations.

Monitoring: Primarily through the annual engagement survey.

Whistleblowing Policy

Scope: Applicable to all employees of all companies within Wallenius Wilhelmsen, as well as external third parties that may be in contact with the group, such as job applicants, former employees, consultants, or other business partners.

Key content: Establishes the Alert Line, a group-wide global whistleblowing system where stakeholders can submit concerns about potential non-compliance. The policy defines that concerns raised in good faith and in line with good principles shall not be met with retaliatory actions. The channel is hosted by an independent third party and employees can report with due process related to confidentiality and anonymity.

Monitoring: All reports are treated with sensitivity and investigated promptly and objectively. The Compliance Team analyzes all complaints and grievances to understand trends. The Chief Ethics and Compliance Officer reports Alert Line cases quarterly to the Board Audit Committee. A new e-learning module with a specific section on the whistleblowing channel was implemented during the year.

Content referenced as being reported but not fully provided in the available text.

Content referenced as being reported but not fully provided in the available text.

Taking action on material impacts on own workforce

Safe and Secure Operations

Safety Management System (ISO 45001)

• Scope: Own operations (land-based operations, shipping operations, corporate functions)
• Status: Worldwide more than 80% of land-based operations are ISO certified; working to certify shipping operations and corporate functions
• Planned: Reviewing options to start a group-wide certification, which will include 45001
• Outcome: Managing risks that threaten the safety and security of workforce

Safety 1st (Logistics safety management system)

• Scope: Logistics operations
• Action: Provides workers with guidelines to help reduce the risk of injury and illness through identification and evaluation of hazards
• Responsibility: Management ensures health and safety policies communicated; supervisors and lead personnel enforce them

"Dare to be aware" campaign (2023)

• Scope: Front-line workers
• Time horizon: Launched 2023
• Action: Communication campaign focusing on safety in tasks front-line workers perform
• Expected outcome: Raise awareness of safety in work environment, reducing likelihood of accidents
• KPI: LTIF (loss time incident frequency) provides indication of effectiveness

"See It, Say It, Stop It!" campaign (2024)

• Scope: Front-line workers
• Time horizon: Launched 2024 (follow-up to "Dare to be aware")
• Action: Communication campaign focusing on safety in tasks front-line workers perform
• Expected outcome: Raise awareness of safety, reducing likelihood of accidents
• KPI: LTIF monitoring

Safety Culture Program (Shipping)

• Scope: ~5000 participants including employees in Shipping and Government services, vessel crew, ship management companies, parts of Logistics Services involved in cargo operations, several terminals, sales organization
• Time horizon: Launched 2024
• Resources (non-financial): Cultiv8 Application digital tool
• Action: Implements eight safety leadership behaviors: Trust, Care, Open, Learn, Feedback, Speak up, Promote team, Managing dilemmas
• Expected outcome: Build a culture where people feel safe to admit mistakes, share safety concerns and work together to reduce likelihood of serious incidents and accidents
• Tool: Cultiv8 Application - interactive app using simulation games and quizzes to strengthen safety leadership behaviors

Working Conditions & Human Rights

Data Quality Improvement Initiative

• Time horizon: Planned from 2025
• Action: Assess how to improve quality of reporting for data collected and stored locally (cases of discrimination, harassment, potential fines)
• Approach: Review existing systems, leverage them, assess whether shortcomings need to be addressed with new digital tools or systems

Diversity, Equal Opportunities and Inclusion

Diversity, Equal Opportunity and Inclusion Roadmap

• Time horizon: Starting from 2025
• Action: Set roadmap for creating measurable and transparent KPIs
• Resources (non-financial): People & Organizational Development team (expected to be in place during 2025)
• Team role: Provide global standards, guidelines and processes for company-wide organizational development; enablers of diversity, equal opportunities and inclusion
• Expected outcome: Standardize recruitment procedures, gain data from recruitment processes to form data-driven decisions

Workday Learnings Implementation

• Time horizon: Implementation 2025, rollout starting 2025
• Action: Learning platform integrated into Workday people system
• Scope: All IT-enabled employees and managers
• Expected outcome: Provide easy access to training and development programs including diversity and equal opportunities; ability to push trainings centrally and track them
• Target: Rolling out training to managers and staff from 2025

Targets related to own workforce

Safe and secure operations

To monitor safety performance and the effectiveness of health & safety policy and initiatives, the company has set loss time injury frequency (LTIF) targets for shipping and logistics. The targets are reviewed on an annual basis and apply for the financial year 2024. LTIF performance is tracked on a continuous basis.

LTIF Shipping

LTIF Logistics

Diversity, equal opportunities and inclusion

The company primarily tracks and assesses the effectiveness of its actions and initiatives by measuring annual global employee engagement scores which ask specific questions related to diversity and inclusion. Overall, in 2024 engagement scores have increased when it comes to diversity & equal opportunities, health & well-being and employee engagement.

No specific quantified targets disclosed for diversity metrics.

Working conditions and human rights

No specific quantified targets disclosed.

Although seafarers report to external ship management companies, they are considered our "non-employee workforce," and we view them as our own employees. In collaboration our two largest ship managers, we arrange biannual "officers conferences." Typically, more than 100 officers and representatives of Wallenius Wilhelmsen and our ship managers attend these conferences. High on the agenda is safety, health and wellbeing as well as training to contribute to our carbon target. We also arrange family days for seafarers and their families. Moreover, seafarers contribute to our annual employee engagement survey.

Stevedores that are directly employed by Wallenius Wilhelmsen are included in the scope of the reporting. However, the majority of stevedores belong to pools contracted and managed by unions. We have agreements with the unions to provide stevedore services for our cargo operations services. It is optional to report on these workers and they are consequently not included in the scope.

Collective bargaining coverage and social dialogue

Collective bargaining agreements

Wallenius Wilhelmsen has established collective bargaining agreements in the EEA. The collective agreement reported is based on headcount at the end of reporting period, representing the information for that point of time, without capturing fluctuation during the reporting period. The data quality is dependent on the data availability in Workday. Due to local laws and regulations, currently the registration of collective agreements in Workday is not a global mandatory field. In 2024, Wallenius Wilhelmsen did not have more than 10 percent of its workforce employed in countries in the EEA.

Workforce engagement processes

The company engages with its workforce through:

• Annual engagement survey (#engage) launched twice yearly (full survey and pulse survey) sent globally to all employees apart from a few unionized sites
• For production workers, annual salary review is determined at local level, either via collective bargaining agreements with unions, or via a structured salary review process
• Employees at unionized sites have representative arrangements through local collective bargaining structures

Gender diversity:

• Women in top management: 40%
• Women in our workforce: 25%
• Women on the Board: 43%

Adequate wages

Statement: All employees are paid an adequate wage, in line with applicable benchmarks.

Methodology:

• Office workers: The company utilizes Hay Job Evaluation methodology for office workers and has established a job architecture to determine the job size across the organization. The objective method ensures fair and equitable comparisons both within the company and with external benchmarks. External resources used include Korn Ferry, Hay Rating, World at Work to ensure adequate and fair pay.
• Production workers: Do not implement a hierarchical job structure, but maintain local systems and structures to ensure market alignment. Annual salary review is determined at the local level, either via collective bargaining agreements with unions, or via a structured salary review process which bases wages on external labor market benchmarks.

Compliance: "Across our global operations, we follow all local minimal wage laws."

Policy commitment: The human rights policy addresses "living wages" and commits to "promoting living wages and benefits." The people policy commits to "Work/life balance through reasonable working hours and living wages and benefits."

Effectiveness tracking: The #engage survey includes questions on whether employees feel they are fairly rewarded in relation to pay, promotion and training for their contributions.

Remuneration metrics (2024):

• Global gender pay gap (male:female): -4.96% (women earn 4.96% more than males on average)
• Annual total compensation of the highest paid individual: USD 743,000
• Median annual total compensation for all employees: USD 36,200
• Remuneration ratio (high to median): 2,052.49%

Coverage: Not disclosed what percentage of workforce was assessed against living wage benchmarks.

Geographic scope: Global operations.

Targets: No specific targets disclosed for living wage coverage.

Methodology limitations: The company acknowledges it does not yet have a standardized method of calculating total compensation. The gender pay gap calculation compares pay without considering the complexity, responsibilities and skills required for different jobs, which can lead to incorrect and misleading comparisons.

Health and safety metrics

Coverage of health and safety management system

Work-related accidents and injury rates

Fatalities

Methodology:

• Shipping LTIF: Calculated as the number of fatalities, permanent disability, partial disability and lost work-day cases per 1,000,000 exposed hours. Based on OCIMF marine injury reporting guidelines. Exposure hours = 24 hours per day while serving onboard. For ARC, cadets and unlicensed apprentices onboard are excluded.

• Logistics LTIF: Calculated as the number of fatalities and lost work-day cases per 1,000,000 work hours for production workers globally. Direct hours measured via time monitoring systems; indirect hours for office workers at logistics sites are estimated.

• Corporate: For office workers, total hours worked per year are estimated using 40-hour work weeks with 48 work-weeks per year. Days lost or injuries are not reported for corporate office workers.

Limitations: Data accuracy for logistics is subject to internal audit findings regarding incomplete reporting of injuries and working hours. An internal audit in 2024 identified uncertainty in safety data for logistics operations; safety-related data for 2024 is therefore based on estimates. The company does not currently collect data on work-related ill health.

Compensation metrics

Pay gap

The gender pay gap identified that on average women earn 4.96 percent more than males, the main driver being the production workers. Males have approximately 75 percent production workers whereas females have approximately 50 percent production workers, thus bringing the male average down due to this weighting.

Remuneration ratio

The measure between highest paid and median paid is for annual base salary in USD.

Methodology

To calculate the gender pay gap and remuneration ratio, salaries were initially converted to USD to calculate the overall base pay average between all female to male office and production workers. To calculate the global gender pay gap, the annual working hours data was estimated using external sources.

A limitation of the methodology includes comparing pay without considering the complexity, responsibilities and skills required for the different jobs which can lead to incorrect and misleading comparisons. For internal use, the company uses Hay Job Evaluation methodology which is a systematic process for assessing the relative value of different jobs within an organization.

The company does not have a standardized method of calculating total compensation yet, however is currently looking at how to calculate this. The measure between highest paid and median paid is thus for annual base salary in USD.

Incidents, complaints and severe human rights impacts

Overview

Wallenius Wilhelmsen monitors incidents, complaints and severe human rights impacts through its Alert Line (group-wide whistleblowing channel) and grievance mechanisms. The company acknowledges risks of underreporting due to potential fear of retaliation and cases handled locally by HR or line managers that may not be reported through the Alert Line.

Work-related incidents and complaints

Status of complaints

Of the 62 complaints filed through the Alert Line in 2024, 39 cases related to the category "bullying, harassment and discrimination", with some cases still under investigation at end of 2024.

Remediation approach

The company commits that if it directly causes or contributes to harmful human rights impacts through its actions, it will seek to promote access to and/or provide fair remediation. In 2024, no material impacts were identified through the grievance mechanism.

Grievance mechanisms

For seafarers, both Wilhelmsen Ship Management and Wallenius Marine have official grievance mechanisms, including their own whistleblowing systems. All received cases are registered in the whistleblowing systems. The company recognizes a risk of underreporting from ship managers onboard vessels and plans to further dialogue with ship managers in 2025 on how to raise awareness of grievance mechanisms.

Norwegian Transparency Act communication channel

The company established a dedicated communication channel for information requests as required by the Norwegian Transparency Act. No queries were received in 2024.

Policies related to value chain workers

Wallenius Wilhelmsen discloses its commitment to value chain workers through several policies that extend expectations to suppliers, subcontractors, and business partners.

Human Rights Policy

Scope and coverage:

• Extends across the supply chain to suppliers, subcontractors, and business partners
• Requires Wallenius Wilhelmsen to avoid causing or contributing to adverse human rights impacts through its own activities, and prevent or address such impacts when they occur
• Requires the company to seek to prevent or mitigate adverse human rights impacts directly linked to operations and services or connected to business relationships

Key content and principles:

• Commitment to respect human rights across the supply chain
• Based on and implemented through the company's human rights due diligence process and procedures
• Commitment to providing ways for affected individuals to come forward with human rights grievances
• If the company directly causes or contributes to harmful human rights impacts, it will promote access to and/or provide fair remediation

International standards alignment:

• Acknowledges the UN Universal Declaration of Human Rights
• Acknowledges the ILO Declaration on Fundamental Principles and Rights at Work
• Due diligence process aligned with the UN Guiding Principles on Business and Human Rights
• Aligned with the OECD Guidelines for Multinational Enterprises
• Aligned with the Norwegian Transparency Act

Governance:

• The Chief People Officer (CPO) is accountable for the human rights policy

Public availability:

• Publicly available on the company's webpage
• Stakeholders may request information and raise concerns through the company's Alert Line

Monitoring:

• Updated in 2024
• Annual human rights due diligence assessment conducted by a dedicated task force led by the Chief Sustainability Officer (CSO) with members from human resources, legal, compliance, safety, risk, emergency & security, procurement, and operations
• Process based on OECD Guidelines for Multinational Enterprises and UN Guiding Principles on Business and Human Rights

Supplier Code of Conduct

Scope and coverage:

• Applies to suppliers, subcontractors, and business partners
• Presented and agreed upon before new contracts are established
• Company is working to integrate requirements into supplier contracts

Key content and principles:

• Requires suppliers shall not engage in nor tolerate any form of modern slavery including forced or compulsory labor or human trafficking
• Suppliers may not use any exploitative, unsafe or discriminating working conditions and practices, nor children under the legal working age
• Specifies environmental commitment
• Workers across the value chain are positively impacted by requirements within the Supplier Code of Conduct

International standards alignment:

• Acknowledges the UN Universal Declaration of Human Rights
• Acknowledges the ILO Declaration on Fundamental Principles and Rights at Work
• Guided by the Norwegian Transparency Act, OECD Guidelines for Multinational Enterprises, UN Global Compact, and UN Guiding Principles on Business and Human Rights

Governance:

• The Chief Financial Officer (CFO) is the most senior-level executive accountable for the supplier code of conduct

Public availability:

• Publicly available on the company's webpage
• References the Alert Line whistleblowing channel for raising concerns

Monitoring:

• Updated in 2024
• Supplier audits conducted
• Due diligence processes in place
• Annual ESG reports from suppliers
• Supplier assessment questionnaire for key suppliers with operations in high-risk countries
• Integrity due diligence performed on all tonnage providers in 2024
• Company working to include ESG clauses in contracts with time charter vessels

Procurement Policy

Scope and coverage:

• Extends to all procurement activities exceeding USD 50,000
• Guides procurement activities and is the basis of the Supplier Code of Conduct
• Applies to all Wallenius Wilhelmsen entities

Key content and principles:

• Unified approach establishing common framework for purchasing
• Comprehensive coverage of procurement activities
• Suppliers expected to comply with Supplier Code of Conduct and sustainability requirements
• Dedicated to mitigating Environmental, Social, and Governance (ESG) risks across supply chain
• Requires purchasers to identify and address ESG risks collaboratively with suppliers
• Priority granted to suppliers demonstrating commitment to sustainable practices, ethical conduct, and minimized adverse environmental effects
• Detailed risk assessment (including ESG risk) compulsory before engaging with any supplier
• Due diligence is mandatory and essential part of sustainable procurement approach

Governance:

• The Chief Financial Officer (CFO) is the most senior-level executive accountable for the procurement policy

Monitoring:

• Documented procurement procedures mandatory in every office, branch and site
• Supplier contract templates reference Supplier Code of Conduct
• Business partner integrity due diligence for onboarding new suppliers includes adverse media check covering human and labor rights and environmental issues

Content referenced as being reported but not fully provided in the available text.

Content referenced as being reported but not fully provided in the available text.

Taking action on material impacts on value chain workers

Wallenius Wilhelmsen conducts an annual human rights due diligence assessment based on the OECD Guidelines for Multinational Enterprises and UN Guiding Principles on Business and Human Rights. The process is led by a dedicated task force headed by the Chief Sustainability Officer (CSO) with members from human resources, legal, compliance, safety, risk, emergency & security, procurement, and operations in key geographies.

Key scenarios and mitigating actions identified in 2024:

1. Human rights breaches in our supply chain

Actions:

• Strengthening supplier management with human rights issues included in business partner integrity due diligence procedure for onboarding new suppliers
• Adverse media checks covering human and labor rights and environmental issues
• Implementing a supplier assessment questionnaire for key suppliers with operations in high-risk countries
• Creating a dashboard of all suppliers to enable live overview of largest high-risk suppliers
• Performed integrity due diligence on all tonnage providers in 2024
• Working to include ESG clauses in contracts with time charter vessels outside of fleet management control
• Continuing to operationalize human rights in the procurement process and supplier monitoring

Scope: Upstream value chain (suppliers)

Expected outcomes: Identify and follow high-risk suppliers

2. Human and labor rights being breached at the shipyards we use

Actions:

• Conducted sustainability due diligence during shipyard selection process in 2023 for new vessel orders
• External expert audits covering human and labor rights conducted at shipyards
• During 2024, audit findings included in contractual agreements
• Monitoring plan agreed with shipbuilding yards
• Monitoring plan to be followed up during building period

Scope: Upstream value chain (shipbuilding yards)

Expected outcomes: Ensure safer working conditions and respect for human and labor rights at key suppliers

Note: Company did not recycle any vessels in 2024

3. Stowaways on vessels

Actions:

• Following IMO Resolution 13 (42): FAL Convention guidelines when stowaways found
• Consulting P&I clubs to ensure safety of stowaways when considering ports for disembarkation
• Cooperating with port and terminals to prevent illegal activity
• Mitigating actions at high-risk areas including:
  • Clearly visible crew
  • ID checks
  • Security guards at vessel entry points
  • CCTV-systems
  • Manual cargo inspections
  • Thermal screening cameras

Scope: Own operations and downstream (ports/terminals)

Performance: Four stowaways experienced in 2024

4. Migrants in distress picked up at sea

Actions:

• Following practices as per IMO, including 1982 UN Convention on the Law of the Sea and 1974 International Convention for the Safety of Life at Sea
• Advise from local coast guards

Scope: Own operations

Performance: No migrants in distress encountered during 2024

Cross-cutting actions:

Human rights training and awareness

Actions:

• Updated human rights training module
• Relaunched on UN Human Rights Day as required training for all IT-enabled employees
• CSO updated legal department, management and Board of Directors on human rights work

Resources (non-financial): Training for all IT-enabled employees

Integration into company processes

Actions:

• Integrating human and labor rights considerations into key company activities and processes
• Integration into company risk management processes
• Integration into procurement and supply chain management

Link to policy: Systematic approach linked to Human Rights Policy and Supplier Code of Conduct

Engagement activities supporting value chain worker actions:

Supplier engagement (RoRo Rodeos)

Actions:

• Annually hosting events (RoRo Rodeos) at port and terminal operations
• Engaging suppliers on safety topics

Scope: Upstream value chain

Expected outcomes: Strengthen value chain by lowering ESG risks, improve safety and working conditions for workers in value chain, ensure emissions targets are met together

Seafarer engagement

Actions:

• Biannual officers' conferences in collaboration with two largest ship managers
• Typically more than 100 officers and representatives attend
• Arranging family days for seafarers and their families
• Seafarers contribute to annual employee engagement survey

Scope: Non-employee workforce (value chain workers)

Focus areas: Safety, health and wellbeing, training for carbon target contribution

Expected outcomes: Value and appreciate seafarer contributions, receive feedback on challenges and support needs, provide input into business strategy and management related to safety, health and wellbeing

Targets related to value chain workers

Wallenius Wilhelmsen has not disclosed quantified targets related to value chain workers under ESRS S2-5.

The company outlines qualitative ambitions and planned actions for managing impacts on value chain workers:

• Continuing to raise awareness of the group's human rights policy and implement it in all parts of the company and towards suppliers
• Continuing to expand stakeholder engagement to a wider group of internal stakeholders and consult external stakeholders such as NGOs or industry networks
• Further strengthen assessment and monitoring of risks in the supply chain by conducting integrity due diligence on all high-risk suppliers
• Continue to further operationalize human rights in the procurement process and supplier monitoring
• Consider developing specific targets as the company gains more insight into its supply chain and explores how to track effectiveness of policies and actions

The company explicitly states: "We will consider developing specific targets as we gain more insight into our supply chain and explore how to track effectiveness of policies and actions."

Business conduct policies and corporate culture

Wallenius Wilhelmsen has established several policies addressing business conduct and corporate culture:

Code of Conduct

• Approval and oversight: Approved by the Board of Directors. The Chief Executive Officer is responsible for operational implementation and ensuring organizational compliance. The Chief Ethics and Compliance Officer is responsible for monitoring implementation and annual review.
• Scope: Applies to all employees and others working for and on behalf of Wallenius Wilhelmsen
• Key content: Sets out ethical guidelines for business conduct and employee behavior. Addresses:
  • Human and labor rights
  • Discrimination and harassment prohibition
  • Equal opportunities
  • Business transparency
  • Anti-corruption compliance
  • Export controls and sanctions laws
  • Personal data protection
  • Environment, health and safety
  • Advocacy, political engagement and donations (prohibits use of company funds to support political parties or candidates)
  • Fair competition and anti-trust compliance
  • Anti-money laundering
  • Tax evasion
  • Conflict of interest
• Links to international standards: Acknowledges the UN Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work. Due diligence process aligned with UN Guiding Principles on Business and Human Rights and OECD Guidelines for Multinational Enterprises.
• Public availability: Publicly available on company website
• Monitoring implementation:
  • Mandatory training for all new employees during onboarding and continuously throughout employment
  • Updated mandatory e-learning training rolled out in 2024 for all IT-enabled employees
  • Refresher trainings on risk-based approach for different teams
  • Mandatory for all employees to acknowledge the Code in the HR system
  • Board Audit Committee oversees compliance with minimum quarterly status updates from Compliance function
  • Annual report to Board of Directors
  • Leaders must ensure activities within their area of responsibility are carried out in accordance with the Code
  • Code of Conduct training made available to the Board

Anti-Corruption and Anti-Bribery Policy

• Approval and oversight: Board-approved (as part of Code of Conduct framework). Chief Ethics and Compliance Officer responsible for oversight.
• Scope: All employees
• Key content: Sets out commitment and responsibilities to prevent bribery in all activities under effective control
• Links to international standards: Consistent with United Nations Convention Against Corruption
• Monitoring implementation:
  • Updated anti-corruption and gifts & hospitality e-learning training in 2024
  • Required for functions at risk on annual basis
  • 74% of employees in functions-at-risk (2,473 of 3,335) completed training in 2024
  • Periodic in-person workshop-based training for office workers, executive management and Board members
  • Company is member of Maritime Anti-Corruption Network (MACN)

Gifts and Hospitality Procedure

• Key content: Defines what is regarded as permissible gifts and hospitality
• Monitoring implementation: Covered in anti-corruption training programs

Whistleblowing Policy

• Approval and oversight: Chief Ethics and Compliance Officer responsible
• Scope: Applicable to all employees of all companies within Wallenius Wilhelmsen, as well as external third parties (job applicants, former employees, consultants, business partners)
• Key content: Establishes Alert Line, a global whistleblowing system hosted by independent third party where stakeholders can submit concerns about potential non-compliance including bribery, corruption, theft, sanctions, anti-trust, fraud, bullying and harassment, modern slavery and other human rights breaches. Ensures confidentiality and anonymity. Protects against retaliatory actions for concerns raised in good faith.
• Public availability: Referenced in Code of Conduct which is publicly available
• Monitoring implementation:
  • All reports investigated promptly and objectively
  • Chief Ethics and Compliance Officer reports Alert Line cases quarterly to Board Audit Committee
  • Compliance Team analyzes all complaints and grievances to understand trends
  • Information about Alert Line provided in onboarding process and management touchpoints
  • New e-learning module implemented in 2024 with specific section on whistleblowing channel
  • Compliance survey conducted to assess employee awareness and trust in the process

Human Rights Policy

• Approval and oversight: Approved by Chief People Officer. Chief Sustainability Officer responsible for ensuring effective human rights due diligence and providing governance and advisory.
• Scope: All activities within operations and extends across supply chain
• Key content: Outlines commitment to respecting human rights including:
  • Avoiding or addressing adverse human rights impacts caused by own activities
  • Preventing or mitigating impacts linked to operations or business relationships
  • Working conditions
  • Living wages
  • Discrimination
  • Right to privacy
  • Modern slavery (trafficking, forced labor, servitude and slavery)
• Links to international standards: Based on UN Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, core conventions that underpin it, and ILO Declaration on Fundamental Principles and Rights at Work
• Public availability: Publicly available on company website
• Monitoring implementation: Annual human rights due diligence assessment conducted by dedicated task force

People Policy

• Approval and oversight: Approved by Board of Directors. Chief People Officer has operational responsibility.

• Scope: All employees working within Wallenius Wilhelmsen, including temporary staff, contractors and agency staff

• Key content: Declares commitment to fostering, cultivating and preserving an inclusive workplace culture where people are safe, their rights respected, and diversity appreciated. Foundational to strategic pillars:

  • Expertise and leadership shaping the future
  • Value driven culture and organization
  • Future-ready workforce
  • Attractive employee experience

  Outlines commitments to:

  • Safe, healthy, and decent working conditions
  • Enable every employee to maximize their talents
  • Promote diversity through equal opportunities and inclusion
  • Work environment free of discrimination, harassment, intimidation or coercion
  • Work/life balance through reasonable working hours and living wages and benefits
  • Respect human and labor rights
  • Training and development opportunities
  • Attract talent with necessary competencies

• Links to international standards: Based on UN Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, core conventions that underpin it, and ILO Declaration on Fundamental Principles and Rights at Work

• Public availability: Posted internally and externally

• Monitoring implementation: Primarily through annual engagement survey (#engage)

Bullying and Harassment Policy

• Approval and oversight: Chief People Officer responsible for execution through involvement and delegation to relevant managers
• Scope: All employees
• Key content: Group guideline on preventing and handling bullying and harassment. Zero tolerance policy. Allegations investigated fairly, objectively and confidentially.
• Monitoring implementation: Through annual engagement survey

Talent Acquisition & Selection Policy

• Approval and oversight: Chief People Officer responsible
• Key content: Promotes fair and equal opportunities by providing guidelines on attracting diverse candidates and making recruitment process objective, inclusive and free from bias
• Monitoring implementation: Through annual engagement survey

Supplier Code of Conduct

• Approval and oversight: Chief Financial Officer is most senior-level executive accountable
• Scope: All suppliers, subcontractors and business partners
• Key content:
  • Specifies environmental commitment
  • Prohibits modern slavery including forced or compulsory labor or human trafficking
  • Prohibits exploitative, unsafe or discriminating working conditions and practices
  • Prohibits use of children under legal working age
  • Sets ESG standards as minimum requirements
• Links to international standards: Acknowledges UN Universal Declaration of Human Rights and ILO Declaration on Fundamental Principles and Rights at Work. Due diligence process aligned with UN Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Enterprises and Norwegian Transparency Act.
• Public availability: Publicly available on company webpage. Presented and agreed upon before new contracts are established.
• Monitoring implementation:
  • Engaged through supplier audits, due diligence processes, annual ESG reports
  • Being integrated into supplier contracts
  • Business partner integrity due diligence for onboarding includes adverse media check covering human and labor rights
  • Supplier assessment questionnaire for key suppliers in high-risk countries
  • Dashboard being created for live overview of largest high-risk suppliers
  • In 2024, integrity due diligence performed on all tonnage providers
  • ESG clauses being included in contracts with time charter vessels

Procurement Policy

• Approval and oversight: Chief Financial Officer accountable
• Scope: All procurement activities exceeding USD 50,000
• Key content: Establishes sustainable procurement approach including:
  • Unified framework for purchasing
  • Comprehensive coverage of all procurement activities over USD 50,000
  • Supplier Code of Conduct and sustainability integration requirements
  • Mandatory detailed risk assessment including ESG risk before engaging suppliers
  • Dedication to mitigating ESG risks across supply chain
  • Priority to suppliers demonstrating commitment to sustainable practices, ethical conduct and minimized environmental effects
  • Commitment to being responsible partner (payment according to contract terms, majority less than 45 days)
• Links to international standards: References OECD Guidelines for Multinational Enterprises, UN Global Compact and Guiding Principles on Business and Human Rights
• Monitoring implementation: Documented procurement procedures mandatory in every office, branch and site

Safety, Health & Environment Policy

• Approval and oversight: Approved by Board of Directors. CEO has ultimate responsibility to ensure compliance. All employees responsible for understanding and conducting work in accordance with policy.
• Scope: All employees working within Wallenius Wilhelmsen, including temporary staff, contractors and agency staff
• Key content: Conforms with ISO 45001 for occupational health and safety
• Public availability: Posted internally and externally
• Monitoring implementation: Over 80% of logistics sites achieved ISO 14001 and 45001 certification

Governance Framework

• Approval and oversight: Board of Directors
• Key content: Based on ISO 37000. Outlines corporate governance principles and governance model including:
  • Delegation and limitation of authority
  • Governance and management
  • Stakeholder engagement
  • Sustainability
  • Internal control and risk management
  • Policy hierarchy
  • Constituting documents and group policies (people, safety, environment)
• Monitoring implementation: Board reviews enterprise risk matrix quarterly and evaluates internal control arrangements at least annually

Content referenced as being reported but not fully provided in the available text - appears in sections 125-126.

Prevention and detection of corruption and bribery

Wallenius Wilhelmsen is committed to preventing the occurrence of bribery wherever we have effective control. This is outlined in our Code of Conduct and supported by our anti-bribery and corruption policy, and a gifts & hospitality procedure. All stakeholders can raise concerns regarding bribery or corruption through an independent whistleblowing system.

Code of Conduct

Key content and principles:

• Sets out ethical guidelines for how the company conducts business
• Affirms commitment to preventing the occurrence of bribery in all activities under effective control
• Regulates areas such as anti-money laundering, fair competition, tax evasion and conflict of interest
• Requires employees not to use company funds or resources to support political candidates or political parties

Governance:

• The Board of Directors is responsible for approving the Code of Conduct
• The Chief Ethics and Compliance Officer is responsible for monitoring implementation
• Reviewed annually and updated as needed

Scope:

• All employees are required to complete Code of Conduct training as part of onboarding and continuously throughout employment
• Made available to the Board (several members have completed the training)
• In 2024, updated mandatory e-learning training rolled out for all IT-enabled employees

International standards:

• Not explicitly stated in the excerpts

Monitoring:

• Chief Ethics and Compliance Officer monitors implementation
• Compliance function reports each quarter to Board Audit Committee (BAC)
• Training completion tracked (74% of 3,335 employees in functions-at-risk completed training in 2024)

Anti-Corruption and Anti-Bribery Policy

Key content and principles:

• Sets out the company's commitment and all employees' responsibilities in ensuring that no attempt of bribery or corruption takes place
• Addresses corruption risks particularly in dealings with public officials, customers, and through high-risk partners such as agents and intermediaries

International standards:

• Consistent with the United Nations convention against corruption

Scope:

• All employees
• Anti-corruption and anti-bribery training required for functions at risk on an annual basis
• In 2024, updated anti-corruption and gifts & hospitality e-learning training made available to IT-enabled employees

Monitoring:

• Training completion tracked
• Quarterly reporting to Board Audit Committee

Gifts & Hospitality Procedure

Key content and principles:

• Defines what the company regards as permissible gifts and hospitality
• Updated e-learning training in 2024 includes examples of business situations which could present a bribery or corruption risk and tests employees can apply to different scenarios

Scope:

• All IT-enabled employees (current and new employees required to perform the training)

Whistleblowing Policy

Key content and principles:

• Group-wide Alert line is a global whistleblowing system where stakeholders can submit concerns about potential non-compliance, including bribery, corruption, theft, sanctions, anti-trust, fraud, bullying and harassment, modern slavery and other human rights breaches
• Hosted by an independent third party
• Employees can report with due process related to confidentiality and anonymity and as per regulations in relevant jurisdictions
• Concerns raised in good faith shall not be met with retaliatory actions
• All reports submitted are investigated promptly and objectively

Scope:

• Applicable to all employees of all companies within Wallenius Wilhelmsen
• External third parties that may be in contact with the group, such as job applicants, former employees, consultants, or other business partners

Governance:

• Concerns assessed by a third-party company to determine whether they come under the scope of the whistleblowing policy
• Compliance function assesses who is to be involved in further processing of a case
• High or medium risk incidents referred to Chief Ethics and Compliance Officer (CECO)
• CECO requests mandate from Compliance Committee for high-risk incidents
• CECO together with HR requests mandate from relevant business or staff area manager for medium risk incidents

Monitoring:

• Compliance function reports each quarter to Board Audit Committee on cases raised through the whistleblowing system including cases related to bribery, corruption or other breaches
• All received cases registered in the whistleblowing system

Detection and performance

The company periodically carries out in-person workshop-based bribery and corruption training for office workers, executive management and Board members, to reflect the different roles and responsibilities at these levels.

Wallenius Wilhelmsen is a member of the Maritime Anti-Corruption Network (MACN), a global business network which works to combat corruption within the global maritime industry. MACN has over 220 member companies globally.

In 2024, the company had zero convictions for violation of anti-corruption and anti-bribery laws and zero fines. No legal action relating to corruption and bribery was underway.

The company acknowledges risks of underreporting as cases may be handled by local HR or line managers and not reported to the Alert Line, and employees may fear retaliation. There is also a risk of underreporting among seafarers to ship managers' alert lines.

Incidents of corruption or bribery

Confirmed incidents

Wallenius Wilhelmsen reports zero confirmed incidents of corruption or bribery for the year 2024.

Convictions and fines

The company reports:

The company explicitly states: "We have not received any convictions or fines for violation of anti-corruption or anti-bribery laws during the year, nor are we subject to any legal action relating to corruption and bribery."

Disciplinary actions

Not disclosed.

Contracts terminated

Not disclosed.

Investigation and speak-up mechanisms

Wallenius Wilhelmsen operates a group-wide Alert Line, a global whistleblowing system where stakeholders can submit concerns about potential non-compliance including bribery, corruption, theft, sanctions, anti-trust, fraud, bullying and harassment, modern slavery and other human rights breaches. The whistleblowing channel is hosted by an independent third party and employees can report with due process related to confidentiality and anonymity as per regulations in relevant jurisdictions.

All reports submitted via the whistleblower system are investigated promptly and objectively. When a report is received, the company conducts due diligence to collect facts about the case, determine whether the allegations have merit and clarify if the company or its suppliers are involved. Where merit is established, the company will seek to remedy adverse impacts where possible.

The Compliance function assesses who is to be involved in the further processing of a case and of the measures to be implemented, depending on the type and nature of the case. If an incident is classified as high or medium risk, the matter is referred to the Chief Ethics and Compliance Officer (CECO) who will review the matter and determine the need for and the potential scope of an investigation.

The Compliance function reports each quarter to the Board Audit Committee (BAC). The Committee receives reports on cases raised through the whistleblowing system including cases related to bribery, corruption or other breaches of the Code of Conduct or policies.

The company notes a risk of underreporting: "For employees, there is a risk of underreporting as there are cases which may be handled by local HR or line managers and are not reported to the Alert Line. Additionally, employees may fear retaliation when raising concerns." There is also acknowledged risk of underreporting among seafarers through ship managers' alert lines.

Political influence and lobbying activities

Political engagement approach

Wallenius Wilhelmsen makes its position known on important industry matters through proactive engagement with international institutions, government policy makers and other stakeholders, such as the media and civil society.

The company believes in being transparent in its advocacy efforts and ensures that what it advocates for is consistent with its publicly stated objectives.

All those who work for, or otherwise represent Wallenius Wilhelmsen, are free to participate in democratic political activities, but this must be without reference to or connection with their relationship to Wallenius Wilhelmsen.

Ethical standards and guidelines

Advocacy, political engagement and donations is specifically addressed in the Code of Conduct:

• The company will not use company funds to make gifts, donations or otherwise support political parties or political candidates
• The company may be members of representative organizations relevant to its industry that advocate for certain policy positions
• Any hiring of lobbyists will be in accordance with applicable law and subject to full disclosure to any external party they wish to influence that the lobbyist represents Wallenius Wilhelmsen

The Code of Conduct highlights:

• Do not use company funds or resources to support any political candidates or political parties
• Never use your position in Wallenius Wilhelmsen to try to influence any person, group or entity to make political contributions
• Ensure that all contracts with lobbyists impose an obligation to disclose to any external party they wish to influence that the lobbyist represents Wallenius Wilhelmsen

Political contributions

The company does not use company funds to make gifts, donations or otherwise support political parties or political candidates.

Trade association memberships

The company may be members of representative organizations relevant to its industry that advocate for certain policy positions. No specific amounts or memberships are disclosed.

EU Transparency Register

The company is not registered in the EU Transparency Register or an equivalent transparency register in a Member State.

Board and executive management positions in public administration

None of the members of the Board or executive management team has held any positions in public administration in the preceding two years.

Payment practices

Wallenius Wilhelmsen is committed to being a responsible partner for suppliers. Payment practice is standardized in the procurement policy and the company aims to pay all suppliers according to contract terms.

Standard contractual payment terms

The majority of payment terms are less than 45 days and according to contract terms.

Data availability

Performance data regarding payment practices is currently not available.

Policy context

Wallenius Wilhelmsen does not have a policy to prevent late payment specifically to SMEs. The Procurement Policy guides procurement activities and forms the basis of the Supplier Code of Conduct.