Wallenius Wilhelmsen

Governance roles

Reference: pages 43-45; composition and diversity table page 50.

Wallenius Wilhelmsen has a unitary Board of seven non-executive members. Three are women (43 percent) and four (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 have held any positions in public administration in the preceding two years" (page 43).

Committees (pages 43-44): the Board Audit Committee (BAC) monitors sustainability reporting and related processes, the effectiveness of internal control, governance and risk management, and the assurance of the sustainability report. The People, Culture and Remuneration Committee prepares Board decisions on remuneration and strategic human capital management.

Executive management (pages 44-45): the CEO plus eight executive managers; 33 percent women, down from 40 percent in 2024. Executive management reviews and approves the DMA result. The Chief Sustainability Officer reports to the CEO and is responsible for embedding sustainability into governance and management systems and for the integrity of sustainability data collection.

The governance framework is based on ISO 37000 (page 43). A gamified governance-framework training was rolled out to senior managers and above in 2025, reaching a 94 percent completion rate (pages 43-44). A third-party consultancy assessed Board skills and competencies in 2024 (page 43).

Information provided to the administrative, management and supervisory bodies

Reference: page 45.

Executive management and the Board receive ESG information through the DMA review process, updates from the Chief Sustainability Officer and the Orcelle Accelerator team, and the quarterly internal report OneView (pages 45, 46).

"Sustainability topics are included regularly on the Board's agenda, and they are on the agenda for every Board Audit Committee meeting. The Board has also access to third party experts and bespoke training" (page 45).

Topics discussed by the Board during 2025 included human rights and modern slavery, the sustainability statements, governance and policy approvals, and decarbonization. Sustainability-related risks were covered in enterprise risk reviews by the internal auditor, and sustainability-related compliance in the annual compliance update and the code of conduct review (page 45).

"Executive management and the Board of Directors have reviewed specific IROs related to two of our most material topics, climate change and safety" (page 45).

The company discloses a gap in its own process: "Our due diligence process for major transactions and CapEx planning takes environmental issues into considerations, although a formal ESG due diligence methodology has yet to be developed" (page 45).

Sustainability in incentive schemes

Reference: page 46; metrics page 50.

Climate-related considerations are factored into both short-term and long-term remuneration, and senior managers and above are part of the schemes (page 46).

Short-term incentive: sustainability targets for safety, climate and employee engagement. "the KPI for safety is the Lost Time Injury Frequencies (LTIF) for both our shipping and logistics segments, the climate KPI is the CO2e intensity performance of our shipping operations which account for the majority of our total emissions, whilst the #engage score is used as the KPI to measure employee engagement. The targets have a weighing of 10% individually" (page 46).

Long-term incentive (executive management group): "CO2e intensity in our shipping operations and critical safety incidents are two of five KPIs" (page 46).

Disclosed metrics (page 50):

The variable incentive scheme is approved by the Board, and "Board members are not part of any of the incentive schemes" (page 46).

Statement on due diligence

Reference: page 47.

The statement is presented as a mapping table of the four core elements of due diligence against the sections of the sustainability statement and their page numbers (page 47):

• Embedding due diligence in governance, strategy and business model - Strategy and business model (34-35), Sustainability governance (43-46, 108-111), Material impacts, risks and opportunities (39).
• Engaging with affected stakeholders in all key steps - Our stakeholders (36-37), information provided to the administrative, management and supervisory bodies (45), Materiality assessment (37-42), Management of relationships with suppliers (109-110), Employee engagement survey (36-37).
• Identifying and assessing adverse impacts - Material impacts, risks and opportunities (39), Corruption and bribery risk assessment (109-110), Supplier screenings (108-110).
• Taking actions to address those adverse impacts - transition plan and climate actions (57-62), policies related to own workforce (89-90), action on value chain workers (106-107), business conduct policies (108-111), actions on pollution (76), actions on biodiversity (85-87).
• Tracking effectiveness and communicating - targets for own workforce (95-96), health and safety metrics (101-102), targets related to climate change (54-55), incidents and complaints (103), supplier screenings (108-110).

Risk management and internal controls over sustainability reporting

Reference: pages 48-49.

The corporate sustainability team runs a unified data framework for the group, standardising definitions, calculations and emission factors in line with CSRD and the GHG Protocol, and acts as an information hub that identifies and corrects inconsistencies in business-unit data (page 48). A sustainability reporting tool implemented in 2021 was updated in 2024; in 2025 a carbon accounting module and the ESG module of the group reporting tool were implemented, and APIs were established between the HR system, the sustainability reporting tool and the financial reporting tool (page 48).

"In 2025, we finalized a comprehensive COSO mapping on Internal Control over Sustainability Reporting. The mapping covered all five COSO components ... and integrated 17 principles and 82 points of focus into the ICSR structure" (page 48).

Disclosed data limitations (page 49):

• An internal audit found uncertainty in logistics safety (LTIF) data; most recommendations were addressed in 2025, but training and onboarding on the specific controls remain, so "the safety-related data for logistics will therefore be based on estimates for 2025".
• Substances of concern data in shipping is estimated from procurement of chemicals for 88 out of 127 vessels, extrapolated to the whole fleet.
• "we do not have pollution data for our logistics operations".
• Stevedores in union-managed pools are excluded from the reporting scope.

Strategy, business model and value chain

Reference: pages 34-35.

Four main services: ocean shipping, logistics, government services and supply chain services. Shipping operates "a fleet of 127 vessels with ramps and movable decks, designed for the safe and efficient transport of rolling cargo (Ro-Ro)" (page 34). Logistics runs a company-owned network of port terminals, inland distribution and processing centres.

Value chain (page 34): direct operations (inland distribution, ocean operations, terminals, offices, processing centres); upstream new vessel and facility building; downstream vessel recycling at end of life. Key suppliers are newbuild yards, energy providers, port and canal authorities, stevedores, tug operators and recycling yards (page 35).

"The group's activities are all within the ESRS sector called 'transportation.' The group is neither active in the fossil fuel sector, chemicals production, controversial weapons nor the cultivation and production of tobacco" (page 35). Services are provided to the US Department of Defense, but the company states it does not ship the controversial weapons specified in ESRS.

Disclosed figures (page 35): total employees 8,253 (2024: 8,626), of which EMEA 1,693, the Americas 5,757, Asia 574, Oceania 229. Revenue from the transportation sector was USD 4,212 million (2024: USD 4,106 million).

Strategic goal: "to make net-zero logistics available and affordable", with a net-zero end-to-end pilot service by 2027 and net-zero by 2040 (page 35).

Interests and views of stakeholders

Reference: pages 36-37.

Five stakeholder groups are set out in a table with engagement method and purpose (page 37): suppliers (supplier code of conduct, audits, due diligence, annual ESG reports, and "RoRo Rodeos" hosted at port and terminal operations on safety topics); employees (#engage survey twice a year, twice-yearly individual manager meetings, code of conduct training, CEO quarterly townhalls); customers (the semi-annual Customer Satisfaction survey launched in 2022, scored 1 to 5, covering five strategic topics); investors and bankers (quarterly presentations including ESG performance, sustainability-linked financing frameworks); and seafarers (biannual officers' conferences with the two largest ship managers).

"Executive management and the Board are informed about stakeholders' views and expectations through the double materiality assessment process and results" (page 36).

"To meet investors' expectations, we have also linked our financing to our carbon targets" (page 36).

The company describes how workforce and value chain worker views feed strategy: in 2024 and again in 2025 executive management reviewed strategic paths against the material topics during the annual strategy process, and an annual human rights due diligence assesses impacts on own workers and on value chain workers, informing people policies, the code of conduct and the supplier code of conduct (page 36).

Material impacts, risks and opportunities

Reference: pages 37-42; IRO table page 39.

"Material impacts are concentrated in our own operations and relate primarily to safety and security, GHG emissions, pollution and impacts on biodiversity. Material risks and opportunities arise mainly from the shipping-based business model and are associated with safety, fragmented regulations, access to low carbon fuel and cost recovery, compliance with biodiversity and pollution regulations, as well as working conditions, human rights and governance" (page 37).

The IRO table on page 39 lists 18 rows across the seven material topics, each labelled by type and mapped to upstream, own operations or downstream and to short, medium or long term. Climate change carries five rows (one actual negative impact, three risks, one opportunity); pollution four; biodiversity three; safe and secure operations one; diversity, equal opportunities and inclusion one; working conditions and human rights two; corporate culture and governance two.

Annual review (page 37): "An annual review was conducted on the DMA in 2025 ... It was confirmed that our value chain had not significantly changed and no amendments were therefore made to our material topics. In 2025, however, we improved our IROs to make them more specific."

"We have not yet identified the financial effects of our material ESG risks and opportunities and apply EU's 'Quick-fix' amendments to the ESRS" (page 39).

Climate-specific risk identification, scenario analysis and resilience are also presented under E1-2 and E1-3 (2025 ESRS numbering).

Process to identify and assess material impacts, risks and opportunities

Reference: pages 41-42.

The DMA scope "includes corporate, shipping and logistics operations" and engaged employees, suppliers, customers, investors, research institutions and NGOs through desktop research, interviews and workshops (page 41).

Five steps (page 41):

1. Kick-start and understand context - desk research, prior materiality and value chain assessments, peer analysis, framework screening, media scan.
2. Develop a long list of sustainability topics across the value chain.
3. Determine impact materiality - "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 - a workshop with finance, risk, strategy, internal control, sustainability and decarbonization representatives; "Existing risk management frameworks were used as thresholds to assess likelihood and financial consequence"; consequence and likelihood multiplied for a final score.
5. Validate - results, materiality thresholds and topics with opposing views validated in workshop, then by executive management, the Board Audit Committee and the Board.

Activities and business relationships were assessed against ESRS 1 paragraph AR 16; topics that did not align with the business model were excluded (page 41). ESG risks are integrated into enterprise risk management and the corporate risk register (page 42). The DMA is subject to annual review; the 2025 review confirmed no changes to material topics (page 42).

Disclosure requirements covered by the sustainability statement

Reference: ESRS Index pages 114-115; data points from other EU legislation pages 116-117.

The report prints a genuine ESRS Index listing each disclosure requirement, the section it sits in and its page numbers, grouped by standard: ESRS 2 General Disclosures (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2), E1 Climate Change, E2 Pollution, E4 Biodiversity and ecosystems, S1 Own workforce, S2 Workers in the value chain and G1 Business conduct (pages 114-115).

Several DRs are split into more than one index row to separate shipping from logistics, for example E1-6 (shipping, logistics, corporate), E2-2, E2-4, E2-5, E4-3, E4-4 and S1-14.

Two entries carry no page number: E4-5 impact metrics related to biodiversity and ecosystems change, for both shipping and logistics, is listed as "Not available" (page 114).

The separate table of data points derived from other EU legislation (pages 116-117) gives, for each datapoint, the SFDR, Pillar 3, Benchmark Regulation and EU Climate Law columns, a materiality flag and a page reference. The E1-9 rows (assets at material financial risk, carrying amount of real estate by energy efficiency class, financial opportunities from climate actions) are marked "Not applicable", and E4-2-24(d) policies to address deforestation is likewise "Not applicable" (page 116).

G1-6 Payment practices is written up on page 110 under its own heading but does not appear in the ESRS Index.

Transition plan for climate change mitigation

Reference: pages 57-62 (index); resources and financing page 63.

The plan is built on a 2022 baseline with milestones at 2027, 2030 and 2040 and a commitment to net-zero by 2040. "Executive management and the Board of Directors approved the net-zero 2040 target and transition plan in 2023" (page 54), and "The transition plan is reviewed annually and approved by both executive management and the Board of Directors" (page 62).

Emissions split (page 57): shipping operations, which include government activities, are responsible for 96 percent of group emissions; land-based logistics about 1 percent; office operations the remaining 3 percent, on the 2022 baseline.

Shipping (pages 58-61): main-engine upgrades and part-load optimisation, auxiliary power saving and LED retrofits, bulbous bow and propeller retrofits, shaft generator reconfiguration, wind-assisted propulsion trials; vessel-to-trade allocation, slow steaming, weather routing, hull and propeller cleaning, trim and ballast optimisation. 14 Shaper class vessels of 9,300 to 11,700 CEU were ordered in 2023 and 2024 for delivery between 2026 and 2028, seven with dual-fuel LNG engines (tanks capable of carrying ammonia) and seven with dual-fuel methanol engines, "enhance energy efficiency by up to 40 percent compared to our existing fleet" (page 61).

Logistics (pages 61-62): terminal electrification, shore-to-ship power, renewable fuels for forklifts, cranes and tugmasters, and asset replacement with electric, green hydrogen or green biogas equipment.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate IRO-1 section, where this content is disclosed in the FY2025 report (pages 39-40, 52-54). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Risk identification (pages 52-53). Climate risks were first identified in 2021 following the TCFD recommendations, expanded in 2022, then ranked over short, medium and long term in a risk and opportunities register that fed the DMA. The register "covers both physical and transition risks. Physical risks include increased rate of weather-related accidents, incidents such as flooding of ports and facilities and heat stress for workers, whilst transition risks relate to market, technology, reputational, policy and regulatory risks" (page 53), so the physical and transition classification is explicit. The top three risks named are transition to low-emitting propulsion technologies of uncertain long-term viability, lock-in of emitting fuels, and rising climate compliance costs (page 52).

Scenario analysis (pages 39-40, 53). "In 2023, we conducted two climate risk scenarios based on the Intergovernmental Panel on Climate Change (IPCC) Representative Concentration Pathways (RCP) 2.6 and 8.5. These represent a future global temperature of 1.5C and 4C respectively and provide both a structured and a disorganized scenario. Projected climate data has been sourced from CMIP6 for the years 2030 and 2050. The scenarios are considered to remain valid."

Gaps. Both a high-emission physical scenario and a 1.5C-aligned pathway are named with their temperature projections and horizons. The report does not set out the methodology for how assets and activities in own operations and the value chain were assessed for exposure and sensitivity, nor the assumptions on policy, macroeconomics, energy mix or technology. The analysis dates from 2023 and was not re-run in 2025.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (pages 39-40). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"To assess the resilience of our strategy in relation to climate change, we relied on two main activities: During our strategy review in 2024, executive management assessed potential strategic pathways and evaluated how our material topics impact each of them. The group has also conducted scenario analyses to test our resilience against climate impacts" (page 39).

Results carried into strategy (pages 40, 53): "Managing technological transition risks will continue to be the focus area to mitigate financial impact of climate change" and "Preparing for a 1.5C degree future will enhance resilience and mitigate impacts of climate-related financial risks."

How the transition plan feeds resilience. The report links resilience to fuel and asset flexibility rather than to a quantified resilience analysis: the 14 Shaper class newbuilds are split seven dual-fuel LNG (with ammonia-capable tanks) and seven dual-fuel methanol so that the group "will be able to source all types of conventional fuels, including bio-based and electricity based fuels like methanol and ammonia in the future" (page 61), and the seven chartered dual fuel LNG vessels "can operate on conventional and drop-in fuels, as well as LNG and bio-LNG, enhancing our flexibility to switch between types of fuel based on availability and cost" (page 56).

Policies related to climate change mitigation and adaptation

Reference: page 54.

The group environment policy is the group-wide policy covering 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 policy is publicly available on our website. It is approved by the Board of Directors and the CEO is responsible for ensuring it is complied with" (page 54).

"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" (page 54).

For all environmental topics the policy commits the group to identify, assess and control environmental impacts across the value chain and to maintain a risk management system with regular risk assessments, identification and control measures, supported by an ISO 14001-compliant integrated management system (page 54).

Adaptation is addressed by exception rather than by policy: "Given that our significant IRO relate to climate change mitigation as opposed to adaptation, we are prioritizing this and do not currently have an action plan in relation to climate change adaptation" (page 62).

Actions and resources in relation to climate change policies

Reference: pages 62-65 (index); 2025 actions pages 56, 62.

"Our actions to mitigate climate change are to implement the initiatives for the technical and operational levers described in the transition plan above (E1-1). As mentioned, the scope of these actions is global and affects both downstream and upstream activities." No adaptation action plan exists: "Given that our significant IRO relate to climate change mitigation as opposed to adaptation, we are prioritizing this" (page 62).

2025 actions (page 56):

• 89 technical retrofits and upgrades commissioned on 61 vessels. Morning Lady and Morning Laura took new propellers and post-swirl energy saving devices, new bulbous bows, LED lighting and engine upgrades, and "are now sailing out of dock around 7 percent more energy-efficient from these initiatives alone".
• BAF2.0, a re-engineered multi-fuel bunker surcharge, now the default for all new and renewed ocean business, through which "we have successfully reached our 2025 recovery target of 250,000 metric tonnes of biofuel".
• Seven dual fuel LNG vessels operated on medium-term charter at year end, and a customer-facing carbon calculator released.
• Brunswick terminal took delivery of 42 electric forklifts and reach stackers, with nine 120 kW and four 60 kW EV chargers being installed (page 62).

Resources (page 63): incurred 2025 CapEx of approximately USD 113 million and OpEx of around USD 179 million; planned 2026 to 2030 investment of approximately USD 386 million CapEx and USD 1.2 billion OpEx, stated to be incremental costs not comparable with the EU Taxonomy figures. A USD 1 million green incentives grant was received in 2025 (2024: USD 4.8 million) from the Korean Ocean Business Corporation. The Orcelle Accelerator team oversees implementation.

Targets related to climate change mitigation and adaptation

Reference: pages 54-55.

Base year 2022; milestones 2027, 2030 and 2040. "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" (page 55). SBTi maritime guidance was used for shipping emissions and SBTi corporate guidance for logistics and corporate emissions.

Science-based targets table (page 55):

For context, total scope 3 in the 2022 base year was 1,289,752 mt CO2e (page 68), so the scope 3 target covers a defined "remaining" subset rather than the whole of scope 3.

Removals: "To achieve our net-zero 2040 ambition, Carbon Dioxide Removals (CDR) will be needed to compensate for the residual hard-to-abate emissions ... These residual emissions will be neutralized in accordance with the SBTi net-zero criteria" and "In 2026, we will continue developing our CDR strategy and initiate our first trials of CDR solutions" (page 55).

Energy consumption and mix

Reference: page 67.

Share of fossil sources in total energy consumption: 96 percent in 2025. Share of renewable sources: 4 percent in 2025, up from 3 percent in 2024 (page 67). Nuclear is nil.

The near forty-fold rise in natural gas fuel consumption, from 9,304 to 362,743 MWh, sits alongside the seven dual fuel LNG vessels taken on medium-term charter during 2025 (page 56).

Energy intensity in high climate impact sectors (page 67): total energy consumption from activities in high climate impact sectors was 15,587,866 MWh against net revenue from those activities of USD 4,212 million; total net revenue was USD 5,240 million, of which USD 1,028 million was other revenue.

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 68-70.

Scope 3 categories reported (page 68): 1 purchased goods and services 133,125; 2 capital goods 80,376; 3 fuel and energy-related activities 761,888; 4 upstream transport and distribution 48,799; 5 waste 4,091; 6 business travel 3,494; 7 employee commuting 10,643; 13 downstream leased assets 35,532 (new in 2025, capturing chartered-out owned vessels, page 69). Categories 8 to 12 and 14 to 15 "are deemed immaterial but will nonetheless by assessed in the upcoming Scope 3 project" (page 69).

Biogenic CO2 not included in Scope 1: 182,323 tonnes (2024: 120,173; 2023: 1,252) (page 68). 18 percent of Scope 1 was covered by regulated emission trading schemes in 2025 (2024: 20 percent).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: ESRS Index page 114, which lists E1-7 against pages 68-70.

The company's ESRS Index lists E1-7 as covered by the climate accounting section on pages 68-70. Those pages carry no GHG removals line and no carbon credit line: the climate accounting table reports gross Scope 1, 2 and 3 emissions, well-to-wake shipping emissions, EEOI intensity and biogenic emissions of 182,323 tonnes CO2 reported separately outside the scopes, and nothing is disclosed as a removal or as a mitigation project financed through carbon credits (page 68). The data points table likewise lists "E1-7-56 GHG removals and carbon credits" with a page reference of 68-70 (page 116).

What the report does say about removals is forward-looking and sits under the targets disclosure: "To achieve our net-zero 2040 ambition, Carbon Dioxide Removals (CDR) will be needed to compensate for the residual hard-to-abate emissions from our operations ... These residual emissions will be neutralized in accordance with the SBTi net-zero criteria, which require the use of high-quality, durable CDR solutions", and "In 2026, we will continue developing our CDR strategy and initiate our first trials of CDR solutions" (page 55). That places the first CDR activity after the reporting period.

On the biodiversity side the company states the opposite intention for credits: "we will not use any biodiversity credits to offset adverse impacts in our strategy" (page 85).

Internal carbon pricing

Reference: pages 65-66.

"We have implemented a shadow carbon price based on the EU Emission Trading Scheme (ETS) in our management system, and visualized how much our direct carbon emissions would cost globally, if we had the same fee as we must pay for our shipping emissions in the European continent" (page 65).

Scope: global business operations. "In 2025, we adjusted the scheme to include well-to-wake emissions (Scope 1 and 3 emissions) from Shipping and Government in the shadow price, but maintain direct emissions (Scope 1) for Logistics" (page 65).

The stated purpose is to "raise awareness and visualize the financial impact of adding emissions in different business segments, mitigate against regulatory transition risk, enable insights that foster low carbon culture and management, and improve data quality" (page 66). The price is modelled quarterly per business segment and "can be factored in when making investment decisions" (page 66), which stops short of a binding role in capital allocation.

Policies related to pollution

Reference: page 75.

"Our environment policy specifies pollution-related risks and impacts as one of our environmental topics. The scope of the policy is all activities within our group, including ocean shipping, vehicle processing, terminal management activities and in-land distribution. Upstream and downstream activities across our value chain such as vessel newbuilds and recycling, are also included" (page 75).

"The policy recognizes that emissions to air from our ships and land-based operations have a broader impact than climate change, and we take responsibility to mitigate these emissions. The policy specifies the commitment to reduce air and water pollution from our ocean fleet and to comply with global regulations regarding the emissions of these gases. The policy specifically notes our commitment to reducing SOx, NOx and particulate matter" (page 75).

Accountability (page 75): the Board of Directors has ultimate responsibility for the policy, the CEO is responsible for ensuring compliance, and the policy applies to directors, officers, personnel including temporary personnel, consultants and others acting on behalf of the company, and to employees of all subsidiaries. Policies are posted internally and externally, and the supplier code of conduct is agreed before new contracts are established.

Actions and resources related to pollution

Reference: page 76.

Shipping (page 76). "Wallenius Wilhelmsen complies with IMO regulations by using scrubbers, or bunkering either very low sulfur fuel oil (VLSFO, <0.5 percent) or low sulfur marine gas oil (LSMGO, 0.1 percent max) on ships without scrubbers." The company discloses the trade-off openly: "In addition to sulfates, the scrubber washwater may also contain elevated concentrations of other pollutants, including heavy metals and organic substances", with continuous monitoring and recording of washwater parameters, sampling and periodic laboratory analysis to verify compliance with IMO discharge limits. "We are investigating how we can measure the impact from the release of scrubber wash water on the water quality."

Under the ISM Code, designated persons ashore with direct access to top management monitor the safety and pollution-prevention aspects of each ship's operation, and regular internal safety audits on board and ashore verify compliance, with corrective action plans where needed. "These key actions occur on an ongoing basis" (page 76).

Logistics (page 76). The Safety 1st programme and HAZMAT safety plans control and monitor chemicals and pollutants at logistics sites, with most sites holding ISO 14001 and 45001 certification. The company qualifies the result: "Pollution will then be covered where material, however a consolidated approach and results are not available." Operational resources have been allocated to Safety 1st; no monetary amount is disclosed.

Targets related to pollution

Reference: page 76.

The company reports that it has set no pollution targets and states why: "We have set ambitious targets for Scope 1 emissions and plan to set targets for other forms of pollution when the accuracy of the baseline has been improved. We currently, therefore, do not track the effectiveness of policies and actions of material impacts and risks for pollution" (page 76).

This is a complete answer under MDR-T rather than a silence, but it is an unfavourable one: the company acknowledges that neither targets nor effectiveness tracking exist for a topic its own DMA found material, with four pollution IROs on the IRO table (page 39).

The stated blocker is baseline accuracy, which is corroborated elsewhere in the statement. Substances of concern data covers "procurement of chemicals for 88 out of 127 vessels", extrapolated to the whole fleet, and the company notes that when a substance falls under multiple hazard classes its full amount is reported in each class, so "the estimations are therefore over-reported" (pages 49, 77-78). The company also discloses that "we do not have pollution data for our logistics operations" (page 49).

The PM10 calculation method changed in 2025 and the SOx figures for 2022 to 2024 were restated on an updated calculation method (page 77), which is consistent with a baseline that is still moving.

Timing for target-setting is not given, and no interim milestone is disclosed.

Pollution of air, water and soil

Reference: page 77. Index rows cover pollution of air (shipping) and pollution of water (shipping); no logistics figures are given.

Methodology (page 77). SOx was calculated from fuel consumption and sulfur content in bunker delivery documentation, per fuel type and vessel, then aggregated to fleet level. "For vessels equipped with exhaust gas cleaning systems, sulfur emissions were allocated between emissions to air and sulfur discharged to sea based on scrubber operation and time spent in emission control areas", which is how the water limb of E2-4 is addressed: the sulfur captured by scrubbers and discharged to sea is separated from the SO2 emitted to air, though the quantity discharged to sea is not itself tabulated. "In 2025, we updated the SOx emissions figures for 2022-2024 based on a updated calculation method."

NOx was calculated on an energy basis in line with MARPOL Annex VI and the NOx Technical Code, using tier- and engine-speed-dependent emission factors applied to fuel-derived energy consumption, with default SFOC values where measured engine power data were unavailable and fleet-average factors where certification data were missing.

No soil pollution figures are reported, and the company states it holds no pollution data for logistics operations (page 49).

Substances of concern and substances of very high concern

Reference: pages 77-78.

Caveats the company itself states (pages 77-78). The data is "estimated based on supplier data and thus represent what has been procured as opposed to consumed"; it covers procurement of chemicals, refrigerants and welding consumables for 88 of 127 vessels, extrapolated to the whole fleet; "Although the substances have been procured in 2025, this does not reflect actual amounts emitted as the products may have a life-span of longer than a year"; and "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 a density conversion factor was unavailable, a 1:1 litres-to-kilograms conversion was applied.

Transition plan on biodiversity and ecosystems

Reference: pages 83-85.

The company reports that it has no biodiversity transition plan and gives its reason: "We do not have a biodiversity transition plan and do not plan to develop this in the near future as we consider our initiatives on managing risk of adverse impacts to be sufficient" (page 84).

The strategy is set out as one ambition, "We shall actively protect biodiversity and improve ocean knowledge", under three levers (page 85):

• Protect and avoid important ocean territories - managing the risk of invasive species through ballast water management, biofouling management, cargo inspection and treatment; conservation of important territories, avoiding the arctic and minimising operations in areas important for cetaceans.
• Minimize impact on marine ecosystems - reducing air pollution through operational and technical efficiencies and alternative fuels, reducing spill risk through detection, monitoring and training, and reducing noise pollution.
• Increase insight to restore ocean health - engaging with research institutions, contributing data collection and promoting partnerships that publicly share data.

Two limits are stated plainly: "We have also not yet adopted action plans related to biodiversity and ecosystems. We are awaiting guidelines on setting science-based targets" (page 85), and "we will not use any biodiversity credits to offset adverse impacts in our strategy" (page 85).

Policies related to biodiversity and ecosystems

Reference: pages 83-85.

The group environment policy is the operative policy; there is no separate biodiversity policy. "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" (page 84).

"For biodiversity specifically, the policy underscores that protection and sustainable management of biodiversity and ecosystems is essential to ensuring long-term social and economic stability. It establishes our commitment to do our part in halting and reversing biodiversity and nature loss and protecting endangered species on land and in our oceans" (page 84).

Scope exclusions stated (page 84): "Land-based issues regarding sustainable land, agriculture and deforestation are not material topics for our activities." This is carried into the EU legislation datapoints table, where E4-2-24(b) sustainable land and agriculture practices is marked not material and E4-2-24(d) policies to address deforestation is marked "Not applicable", while E4-2-24(c) sustainable oceans and seas practices or policies is marked material at pages 83-85 (page 116).

Actions and resources related to biodiversity and ecosystems

Reference: pages 85-87.

"Following the nature and biodiversity impact assessments guided by LEAP and the strategy process, we have not identified a need to expand the mitigation measures already in place. Instead, we aim to structure our biodiversity efforts more holistically and integrate them with existing processes and management systems" (page 85).

Invasive species (pages 85-86). A biosecurity management plan covers the brown marmorated stink bug: "All cargo travelling to Australia and New Zealand during the BMSB season must undergo either heat treatment or fumigation, conducted prior to loading by a provider approved under AusTreat", with crews conducting BMSB inspections through the cargo holds during voyages to Oceania. The company links this to "target 6 'reduce alien species spread by at least 50 percent by 2030'" of the Kunming-Montreal framework. "All owned vessels have Ballast Water Treatment Management Exchange in place and comply with the most stringent requirements." Biofouling management tracks anchor and chain cleaning, hull cleaning frequency and inspections, under an antifouling policy specifying niche areas for monitoring.

Pollution and noise (page 86). Spill risk is managed through detection, monitoring and training; "All our vessels are fitted with scrubbers which can run in closed-loop setting for minimum 10 days"; noise is addressed through stricter pressure-pulsation requirements in newbuilds, propeller design in retrofits and speed adjustments.

Targets related to biodiversity and ecosystems

Reference: page 87.

The company reports that it has no measurable biodiversity targets and gives the reason: "Setting measurable and quantifiable targets related to biodiversity and ecosystems requires globally recognized target-setting guidance and defined sector-pathways. Following our complete biodiversity assessment, we seek to set targets based on the latest recommended methodology. Once the guidance is applicable, we aim to adopt targets within a medium-term time horizon and we will prioritize setting biodiversity targets for ocean transportation, which is our largest business segment" (page 87).

In the absence of targets it points to the measures in place instead: "Even if we have not yet set specific targets on biodiversity and ecosystems, we still have several important measures in place to mitigate actual and potential impacts from invasive species, disturbances and pollution which are important drivers of biodiversity loss. These measures include managing risk of invasive species, conserving important territories for species, managing risk of pollution and supporting research with data collection. We have already set several goals that we will work to quantify and monitor as part of our renewed ocean strategy" (page 87).

Value chain gap acknowledged (page 87): ocean operations were prioritised in 2024 and land-based site proximity to protected areas was assessed in 2025; "Going forward, we will start planning the assessment of our upstream and downstream value chain."

Policies related to own workforce

Reference: pages 89-90. The index splits S1-1 into health and safety, diversity, and working conditions and human rights.

Health and safety (page 89). "Our group health and safety policy is supported by a structured management system aligned with ISO 45001. We believe that all accidents and injuries are preventable." "The Board oversees the policy, while the CEO ensures compliance. Key updates in 2025 included expanding the policy's scope and integrating climate-related risks assessments."

Working conditions and human rights (pages 89-90). "Our people and human rights policies are 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 including the International Labour Organization's Declaration on Fundamental Principles and Rights at Work." The human rights policy "addresses working conditions, living wages, discrimination, right to privacy, right to life and all forms of modern slavery including trafficking, forced labor, servitude and slavery". It is approved by the Chief People and Corporate Affairs Officer, with the Chief Sustainability Officer responsible for human rights due diligence.

Diversity (page 90). A zero-tolerance bullying and harassment policy and a talent acquisition policy setting global standards for unbiased hiring. Grounds of discrimination covered: "racial and ethnic origin, color, sex, sexual orientation, gender identity, disability, age, religion, and political opinion."

Processes for engaging with own workforce and workers' representatives

Reference: pages 90-91.

#engage survey (page 90). "Employee well-being and engagement are assessed through the confidential #engage survey, conducted globally twice a year (one full and one pulse survey). The survey measures health and safety, working conditions, human rights, and diversity, equal opportunities and inclusion, aligned with local laws and practices." Production employees answer additional questions on safety rules and training, physical working conditions and the handling of unsafe conditions. In 2025 questions on psychological safety were added and scores rose from 7.9 in the pulse survey to 8.0 at year end. "In 2025, the full survey achieved an 88% response rate", the highest to date, with an engagement score of 8.0, up 0.2 on 2024.

Seafarers (page 91). Officers' conferences are held twice a year with the two key ship managers, Wallenius Marine and Wilhelmsen Ship Management. "In 2025, 170 officers and staff participated in the Officers Conference in Seoul, Korea, and 120 participated in the Officers Conference in Goa, India." Themes included safety leadership, the "See It, Say It, Stop It" campaign, fire safety and speaking-up culture.

Workers' representatives (page 91). "Global framework agreements with unions are established at certain sites, but are not uniform across the group." The code of conduct and human rights policy recognise the right to organise and bargain collectively. The company discloses a gap: "The effectiveness of engagement with employee representatives is not measured."

Processes to remediate negative impacts and channels to raise concerns

Reference: pages 91-92.

"Our whistleblowing channel, the Alert Line, enables our workforce to raise concerns or complaints. In the event that the group should cause or contribute to a material negative impact on our own workforce, we apply a structured approach to provide or contribute to appropriate remedies" (page 91).

"The Alert Line is handled by a third party. All reports are treated with due care, and confidentiality is protected as far as possible. When a grievance is received, we conduct a due diligence process to establish the relevant facts. Should concerns be verified, we seek to remedy any adverse impacts" (page 91). Handling is set out in the whistleblowing policy and the procedure for reporting and managing concerns, and "The compliance function analyzes trends and reports quarterly to the Board Audit Committee" (page 91).

Awareness and its measured shortfall (pages 91-92). Awareness is promoted at onboarding and in regular training, and in 2025 "a new e-learning module was introduced with a specific section on the whistleblowing channel. A compliance survey was also conducted among IT-enabled employees to assess awareness of and trust in the whistleblowing process. The survey results indicated a need to further increase awareness of the grievance mechanism."

Taking action on material impacts on own workforce

Reference: pages 92-95, with forward actions page 96.

Safety (pages 92-93). Risks are managed through an ISO 45001 safety management system; "In 2025, our logistics operations in the Australia/Oceania region achieved ISO 4001 certification, and more than 90% of our land-based operations are now ISO certified". Logistics rolled out Dare to Be Aware 2.0 alongside the Safety 1st management system. A safety culture programme launched in 2024 across about 5,000 people implements eight safety leadership behaviours; "In 2025, significant progress was made on the safety culture program, with the first four fundamental behaviors addressed. This resulted in more than 500 team workshops conducted both onshore and onboard", supported by the Cultiv8 app, whose rollout is planned to complete by end 2026. "The most recent assessment in October 2025 shows improved overall culture maturity compared to 2024, alongside a reduction in serious accidents, indicating the program is effective."

Human rights (pages 93-94). The annual HRDD follows the OECD Due Diligence Guidance. Eleven salient risks are listed for 2025, including injury handling heavy equipment, crew safety linked to drug trafficking on vessels, discrimination and harassment, long working hours, freedom of association, privacy, unsafe conditions in shipbuilding and dry-docking, and trafficking via stowaways. By 2025, 90 percent of the target group had completed mandatory human rights training.

Targets related to own workforce

Reference: pages 95-96.

Safety (page 95). LTIF targets are set for shipping and logistics. "Annual targets are set after reviewing the previous year's performance and monitored quarterly via real-time incident reporting systems."

• Shipping: LTIF calculated per 1,000,000 exposed hours. "In 2025, LTIF for shipping resulted in 0.6, which is well within our target of 0.75. Although it has increased from our 0.41 result in 2024, it is still within the year-end target."
• Logistics: LTIF calculated per 1,000,000 work hours for land-based employees, scoped to all production workers globally. "In 2025, LTIF for logistics was 10.26, which is well below our target of 11.74, and down from the 2024 result of 12.19."

Diversity, equal opportunities and inclusion (page 96). Effectiveness is tracked through the #engage score rather than a representation target. "Overall, the company achieved its target for 2025. It scored 8.0 out of 10, thereby exceeding its target of 7.9 for 2025. The participation rate of 88% ensured a high level of score accuracy." The mental health score was 8.5 at year end, up 0.1 on the June 2025 pulse; the diversity, equal opportunities and inclusion score "remained at 8.2, which is above the benchmark for the transportation industry".

"In March 2024, the Company signed the WISTA Norway '40 by 30' pledge ... By the end of 2025, women represented close to 40% of senior leadership positions in Norway. Due to local legal and regulatory considerations, the pledge has been implemented only in Norway" (page 96).

Characteristics of the undertaking's employees

Reference: page 97.

Total headcount was 8,253 in 2025 against 8,626 in 2024 (page 35). "In 2025, countries with significant employment (over 10% of total workforce) were Mexico and the United States" (page 97), which together account for 5,217 of the 8,253 employees.

Turnover of 38 percent is high in absolute terms and is not commented on in the disclosure, though it fell from 44 percent in 2024.

Methodology (page 97): "Employee numbers are reported as end-of-period headcount based on data extracted on January 1, excluding subsequent backdated events. Turnover includes all employees who left during the reporting period and were registered as such by the extraction date. Backdated terminations after this date are excluded."

The own-workforce scope is defined on page 97 as employees (regular, fixed term or temporary, expatriate and trainee or apprentice) plus non-employees (contractor, consultant, agent, seafarers).

Characteristics of non-employee workers

Reference: page 98. The index lists S1-7 twice, once generally and once for seafarers.

Non-employees are close to half the size of the 8,253-strong employee headcount, and seafarers are the larger part of them.

Methodology and scope (page 98). "Non-employee workers are reported in headcount at the end of reporting period, representing the information for that point of time, without capturing fluctuation during the reporting period. It covers external consultants, contractors and agencies that are registered in our global HR system. Non-employees also includes active seafarers in the pool. All owned and bare boat chartered vessels are managed by Wilhelmsen Ship Management (WSM), Wallenius Marine (WM) and American RoRo Carrier (ARC)."

Counting differs by ship manager: WSM reports the total number of active seafarers in the pool, marking seafarers inactive on voluntary resignation, termination, contract expiry or expiry of unpaid leave; WM includes all seafarers in the pool on legal requirements; ARC includes all officers in the headcount (page 98).

A stated exclusion (page 49): stevedores directly employed by Wallenius Wilhelmsen are in scope, but "the majority of stevedores belong to pools contracted and managed by unions ... It is optional to report on these workers and they are consequently not included in the scope." No number is given for the excluded population.

Collective bargaining coverage and social dialogue

Reference: page 98.

"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. In 2025, Wallenius Wilhelmsen did not have more than 10 percent of its workforce employed in countries in the EEA" (page 98).

The disclosure is limited to the EEA and gives coverage as a share of the global workforce rather than by country or by region, so no non-EEA coverage rate is reported. That matters for a workforce whose two largest countries are the United States and Mexico, together 5,217 employees (page 97), and for the production workers whose salary reviews are "conducted locally through collective bargaining agreements with unions, or structured processes based on external labor market benchmarks" (page 94), which implies collective agreements outside the EEA that are not quantified here.

On social dialogue, the company states that "Global framework agreements with unions are established at certain sites, but are not uniform across the group", that it recognises the right to form and join trade unions and bargain collectively without fear of reprisal, and that "The effectiveness of engagement with employee representatives is not measured" (page 91).

Diversity metrics

Reference: page 99.

"Top management is defined as the executive management team as of December 31. For the purposes of reporting on the age distribution among employees, we have covered all employees registered in the global human resources management system as of December 31, 2025 regardless of the time, type or employment form" (page 99).

Female representation in top management fell for the second consecutive year, from 50 percent in 2023 to 40 percent in 2024 and 33 percent in 2025, as the executive team went from ten members to nine and the number of women went from four to three (pages 50, 99). The company notes the fall in its governance section without setting a group-wide target: "33 percent of executive management are women, a reduction from forty percent in 2024" (page 44).

Board gender diversity is reported separately: three women of seven members, 43 percent, unchanged from 2024 (page 50). Women were 27 percent of the total workforce in 2025, up from 25 percent (page 6).

The only representation commitment disclosed is the WISTA Norway "40 by 30" pledge, implemented in Norway only (page 96).

Adequate wages

Reference: page 102.

"All employees are paid an adequate compensation, in line with applicable benchmarks. The group 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. For production workers, we do not implement a hierarchical job structure. However, we maintain local systems and structures to ensure market alignment. Additionally, we offer competitive benefits to enhance the overall total remuneration package" (page 102).

The human rights policy "addresses working conditions, living wages, discrimination" among other matters (page 89).

The disclosure is a qualitative assurance against applicable minimum wage regulation and market benchmarks. No percentage of employees paid at or above an adequate wage benchmark is given, and no country-level exception is identified, so the reader cannot verify coverage against the ESRS datapoint. Effectiveness is monitored through the #engage survey, "which includes questions on perceived fairness of pay and promotion" (page 94).

Training and skills development metrics

Reference: page 100.

The company discloses that the figures understate reality (page 100): "The group implemented a new Learning Management System (LMS) in June 2025, strengthening the ability to consistently track employee training hours ... Average training hours currently include only fully completed courses recorded in the Learning Management System (LMS). Time spent in courses that are ongoing, as well as certain training programs and learning activities not captured in the LMS, are excluded. As a result, reported training hours are materially understated and do not yet reflect the full scope of learning activities across the organization."

An ambition is attached: an average of 30 training hours per employee per year by the end of 2027, "to be formalized in a Learning & Development Policy currently under development" (page 100).

Health and safety metrics

Reference: pages 101-102. The index reports S1-14 separately for shipping, logistics and corporate.

Zero fatalities in 2025 against one in shipping in 2024. Shipping accidents rose from 7 to 12 and shipping LTIF from 0.41 to 0.60; logistics accidents fell from 196 to 160 and logistics LTIF from 12.19 to 10.26.

Data limitations the company states (pages 101-102, 49). "Wallenius Wilhelmsen does not manage the health and safety data itself, as the data is provided by each ship management company. Under normal circumstances we do not carry out audits to verify the data." Exposure hours are estimated from crew numbers and days in operation where actual hours are unavailable, and turnover days are treated differently between ARC and the other two managers. For logistics, an internal audit found uncertainty in LTIF reporting, and "the safety-related data for logistics will therefore be based on estimates for 2025".

Compensation metrics (pay gap and total compensation)

Reference: page 102. The index lists S1-16 twice, for pay gap and for remuneration ratio.

The pay gap is negative, and the company explains why: "The gender pay gap identified that on average women earn 5.4 percent more than males, the main driver being the production workers. Approximately 75 percent of male employees are production workers, whereas approximately 50 percent of female employees are production workers, thus reducing the male average compensation" (page 102).

Stated limitation (page 102): "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, we use the Hay Job Evaluation methodology which is a systematic process for assessing the relative value of different jobs within an organization." Salaries were converted to USD to calculate the average base pay of female against male office and production workers, and annual working hours were estimated using external sources.

Incidents, complaints and severe human rights impacts

Reference: page 103.

"We have a complete overview of number of cases reported through the alert line. Of the complaints filed through the channels for own workers to raise concerns, we have received in total of 94 reported cases in 2025. 29 of these are related to the category 'bullying, harassment and discrimination', with some cases still under investigation" (page 103).

The 29 bullying, harassment and discrimination complaints sit alongside a reported zero confirmed incidents of discrimination for the group, the difference being between complaints received and cases substantiated, with some still open at year end.

Underreporting risk stated (page 103): "There is a risk of underreporting as employees may have a fear of retaliation. During 2025 we have had awareness training and raised awareness of the Alert Line to encourage employees to report any potential breaches." For seafarers, "There remains a risk of underreporting onboard vessels, and in 2025 we continued dialogue with ship managers to strengthen awareness of grievance mechanisms".

Policies related to value chain workers

Reference: pages 104-105.

The commitment "is anchored in our code of conduct and specified in our human rights policy", requiring the group to avoid causing or contributing to adverse human rights impacts and to seek to prevent or mitigate impacts directly linked to its operations, services or business relationships (page 104).

"These commitments extend across our supply chain, and we communicate these expectations to our suppliers, subcontractors, and business partners through our procurement policy and supplier code of conduct. Both documents acknowledge the UN Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work, and our due diligence process is aligned with the UN Guiding Principles on Business and Human Rights and the OECD Guideline for Multinational Enterprises" (page 104).

Workers covered (pages 104, 40). The value chain includes ship managers, shipyards for construction, maintenance and recycling, energy providers, equipment manufacturers and suppliers, stevedores and contracted labour at ports, terminals and processing centres, and IT providers. The human rights due diligence identified "four key groups of workers in our value chain who we materially impact: Workers at the shipyards, i.e. newbuild yards, recycling and dry-docking facilities, and crew on time-charter vessels" (page 40).

Processes for engaging with value chain workers

Reference: page 105.

"To consider the perspectives of value chain workers and to understand our impact on them, we conduct desktop research and seek insight from internal and external experts and NGOs. Also, our employee relations and HR teams engage with agent workers and labor unions. Direct conversations with employees and contractors at the newbuild shipyard will be held by our external expert who will follow-up up that ESG standards are met" (page 105).

The company then states the limits of that engagement in its own words: "However, we do not have a systematic engagement approach and have not yet started assessing the effectiveness of this engagement with value chain workers" (page 105).

This is a nil-progress answer rather than an omission: the process described is indirect, run through experts, NGOs and unions rather than with workers themselves, with the one direct channel (conversations at the newbuild shipyard) still in the future tense and delegated to an external consultant. The 2025 follow-up on the shipyard monitoring plan was carried out by "a specialist consultant" (page 106).

No named worker representatives, no engagement frequency and no coverage of the four identified worker groups are given, and no stage of the engagement is attributed to a senior manager beyond the CPCAO's accountability for the human rights policy (page 105).

Value chain workers are also reached through the alert line, which "is available to stakeholders, including workers in our value chain", though the company adds that "we do not assess how well the workers are aware of this system" (page 105).

Processes to remediate negative impacts and channels for value chain workers

Reference: page 105.

"The alert line is available to stakeholders, including workers in our value chain, for raising concerns ... We also have a dedicated channel for information requests relating to the Norwegian Transparency Act" (page 105).

"When a grievance is received, we conduct due diligence to collect facts about the case, determine whether the grievance has merit and clarify if we or our business partners are involved. Should merit be established, we will seek to remedy adverse impacts where possible. Our grievance mechanism and position on remediation will be reviewed on a regular basis to ensure continued relevance and to drive continuous improvement" (page 105).

The company discloses a specific weakness in the channel: "Whilst we inform about the alert line in our supplier code of conduct, we do not assess how well the workers are aware of this system" (page 105). Awareness of the mechanism among value chain workers is therefore unmeasured, and the channel reaches them indirectly, through the supplier code rather than through the workers' own employers or representatives.

Outcomes for the year are reported under S2-4: "We have also not received any reports of severe human rights issues through our alert line, nor any inquiries via the information channel required under the Norwegian Transparency Act" (page 106). No value chain grievance volume is disclosed, and the S1-17 complaints table on page 103 covers own workforce and ship management rather than the wider value chain.

Taking action on material impacts on value chain workers

Reference: pages 106-107.

"We have not identified any breaches of internationally recognised instruments in our upstream or downstream value chain in 2025" (page 106).

Named actions (pages 106-107):

• Supply chain. Human rights issues added to the business partner integrity due diligence procedure at onboarding, including adverse media screening covering human and labour rights and environmental issues, with findings feeding a risk scoring tool. "By 2025, all our time charter vessels contracts include our supplier code of conducts", and ESG clauses are being expanded in contracts with one key ship manager.
• Shipyards. ESG due diligence audits by an external expert during newbuild yard selection. "Although no material findings were identified, our requirements have been included in contractual agreements and a monitoring plan was agreed with the shipbuilding yard. In 2025, a specialist consultant was engaged to follow up the monitoring plan." "We did not recycle any vessels in 2025."
• Stowaways. "We experienced two stowaways in 2025", handled under IMO Resolution 13 (42) FAL Convention with P&I club consultation on disembarkation ports; mitigations include visible crew, ID checks, security guards, CCTV, manual cargo inspections and thermal screening cameras.
• Migrants at sea. "We did not encounter any migrants in distress at sea in 2025."

Targets related to value chain workers

Reference: page 107.

Wallenius Wilhelmsen sets no measurable targets for value chain workers and states so directly. The S2-5 section is framed as commitments rather than targets (page 107):

• "Continuing to raise awareness of the group's human rights policy and implement it in all parts of our company and towards suppliers."
• "Continuing to expand our stakeholder engagement to a wider group of internal stakeholders and consult external stakeholders such as NGOs or industry network."
• "Further strengthen our assessment and monitoring of risks in our supply chain by conducting integrity due diligence on all our high-risk suppliers. We will also continue to further operationalize human rights in the procurement process and supplier monitoring."
• "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."

The last bullet is the material admission: neither targets nor effectiveness tracking are in place, and the company commits only to consider them, with no date.

The nearest thing to a tracked measure is the qualitative supplier work reported under S2-4: integrity due diligence at onboarding, a supplier assessment questionnaire for key suppliers in high-risk countries, and the shipyard monitoring plan followed up by a specialist consultant in 2025 (page 106). None of these carries a coverage percentage or a completion target.

Business conduct policies and corporate culture

Reference: pages 108-109.

"The cornerstone of our governance framework is the board-approved code of conduct, which sets out the ethical standards guiding how we conduct our business. Updated in 2025, the code applies to all employees and others working for or on behalf of Wallenius Wilhelmsen" (page 108). It covers transparent business conduct, anti-corruption, export controls and sanctions, personal data protection, environmental responsibility, health and safety, and human rights, and also addresses "anti-money laundering, fair competition, tax evasion, and conflicts of interest" (page 108).

Alert line (pages 108-109). A group-wide channel hosted by an independent third party, open to employees and external stakeholders, covering bribery and corruption, theft, sanctions and antitrust violations, fraud, bullying and harassment, modern slavery and other human rights breaches. Reports can be confidential and, where permitted, anonymous. The whistleblowing policy protects reporters from retaliation and extends to job applicants, former employees, consultants and other business partners.

Accountability (page 109). The Board approves the code; the Chief Ethics and Compliance Officer implements and monitors it, with annual review. Oversight sits with the Board and the Board Audit Committee, and "The compliance function provides regular reporting, including at least quarterly updates to BAC and an annual update to the Board." Code of conduct training was made available to the Board, "with several members having completed the training".

Management of relationships with suppliers

Reference: pages 109-110.

The procurement policy guides procurement activity and is the basis of the supplier code of conduct, which "states expectations and policy objectives to suppliers and subcontractors" (page 109). "Due diligence is a mandatory and essential part of the sustainable procurement approach, and supplier contract templates also reference our supplier code of conduct. Our procurement policy addressed the mitigation of ESG risks across the supply chain. The organization requires purchasers to identify and address these risks collaboratively with relevant suppliers. Priority should be granted to suppliers who can demonstrate their commitment to sustainable practices, ethical conduct, and minimized adverse environmental effects across their operations and supply chains" (pages 109-110).

Vulnerable suppliers. The company discloses a specific gap against the ESRS datapoint: "Wallenius Wilhelmsen's procurement policy guides our procurement activities although it does not specify the prevention of late payment specifically to SMEs" (page 109).

Practical supplier screening is reported under S2-4: business partner integrity due diligence at onboarding including adverse media screening on human and labour rights and environmental issues, a risk scoring tool that can place partners on monitoring, and a supplier assessment questionnaire for key suppliers with operations in high-risk countries (page 106). ESG due diligence audits were run by an external expert during newbuild yard selection, with contractual requirements and a monitoring plan following (page 106).

Prevention and detection of corruption and bribery

Reference: pages 110 and 111.

Framework (page 110). "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 gifts & hospitality procedure. We ask all employees, contractors and suppliers to raise any concerns regarding bribery or corruption through our independent whistleblowing system. Concerns submitted through the system are assessed by a third-party company to determine whether they come under the scope of the whistleblowing policy."

Training (pages 110-111). E-training on the code of conduct for the workforce, with periodic in-person workshop-based bribery and corruption training for office workers, executive management and Board members. In 2025 the anti-corruption and gifts and hospitality e-learning was updated.

"Functions at risk include all IT-enabled employees. Anti-corruption and anti-bribery training is required for functions at risk on an annual basis" (page 111).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Wallenius Wilhelmsen discloses no measurable outcome-oriented business conduct target. The G1 chapter contains no target table, no target value and no target year, and the ESRS Index lists only G1-1 to G1-5 for business conduct (page 115).

Consistent with the second limb of MDR-T, effectiveness is tracked in the absence of a target:

• Training coverage is measured year on year. Employees in functions-at-risk covered by anti-corruption training rose from 74 percent in 2024 to 87 percent in 2025 (2,392 of 2,738 employees), and "Anti-corruption and anti-bribery training is required for functions at risk on an annual basis" (page 111).
• Outcome metrics are reported: zero convictions and zero USD in fines for violation of anti-corruption and anti-bribery laws in both 2025 and 2024, with the company adding that it is not subject to any legal action relating to corruption and bribery (page 111).
• Governance cadence is fixed: "The compliance function provides regular reporting, including at least quarterly updates to BAC and an annual update to the Board" (page 109), and the Board Audit Committee receives reports on whistleblowing cases including bribery and corruption (page 110).
• The code of conduct "is reviewed annually and updated as necessary to reflect legislative and regulatory developments" (page 109), and was updated in 2025.

Incidents of corruption or bribery

Reference: pages 111-112.

Detection basis (page 111). "We have an overview of the number of cases reported through the Alert Line. For seafarers, both ship managers have official grievance mechanism, including their own whistleblowing systems. All received cases are registered in the whistleblowing system."

Underreporting stated by the company (pages 111-112). "For employees, there is a risk of underreporting as cases may be handled by local HR or line managers and not reported to the alert line. Additionally, employees may fear retaliation when raising concerns. There is also a risk of underreporting of cases among seafarers to our ship managers' alert lines. In 2026, we plan to further our dialogue with ship managers how to raise awareness of the grievance mechanisms, including our own Alert Line."

The two zero rows cover convictions and fines. The number of confirmed incidents of corruption or bribery, and the number of confirmed incidents in which own workers were dismissed or disciplined, are not reported, so the disclosure covers the legal-outcome datapoints rather than the incident datapoints. The company is exposed by its own account to corruption "in our dealings with public officials, customers, and through high-risk partners such as agents and intermediaries acting on our behalf" (page 108).

Political influence and lobbying activities

Reference: pages 110-111.

"In 2025, Wallenius Wilhelmsen worked to have our position known on important industry matters through proactive engagement with international institutions, government policy makers, and other stakeholders, such as media and civil society. We are members of relevant industry organizations and advocate for policies that ensure a global level-playing field and a transition to net-zero shipping. In 2025, engagement on US port fees and IMO climate regulations were top priorities" (page 110).

"We will not use company funds to make gifts, donations or otherwise support political parties or political candidates. 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" (page 110).

Two ESRS datapoints answered directly (page 111): "The group is not registered in the EU Transparency Register or an equivalent transparency register in a Member State. None of the members of the Board of Directors or the executive management team have held any positions in public administration in the preceding two years."

No financial or in-kind political contributions are reported, consistent with the stated prohibition, and no amount of lobbying expenditure is disclosed. The senior person responsible for oversight of these activities is not named. Advocacy positions are described elsewhere in the statement, including advocacy for "a global carbon price to accelerate the decarbonization transition by ensuring a level playing field" (page 53).

Payment practices

Reference: page 110.

"We are committed to being a responsible partner for our suppliers. Our payment practice is standardized in our procurement policy and we aim to pay all suppliers according to contract terms, with the majority of payment terms being less than 45 days. Performance data regarding payment practices is currently not available" (page 110).

The section is printed in the sustainability statement under its own heading, "G1-6 Payment Practices", but G1-6 does not appear in the company's ESRS Index, which lists only G1-1, G1-2, G1-3, G1-4 and G1-5 for business conduct (page 115). The index omission looks like an error in the index rather than an absence of disclosure, since the DR is written up under its own code.

Measured against what G1-6 asks for, the disclosure gives the standard contractual payment term qualitatively and nothing else. No average number of days to pay an invoice is given, no percentage of payments aligned with standard terms, and no number of outstanding legal proceedings for late payment. The company says the performance data does not exist yet, which is an explicit nil return rather than silence.

A related gap is disclosed under G1-2: the procurement policy "does not specify the prevention of late payment specifically to SMEs" (page 109).