Sustainability Statement Seaborn 2023

Sustainability Statement

2023

Content

GENERAL INFORMATION

SOCIAL

Highlights 2023 -----------------------Statement CEO -----------------------Board -----------------------------------ESRS 2 -----------------------------------

ESRS S1 ----------------------------ESRS S2 -----------------------------

3.

4.

5.

6.-10.

ENVIRONMENT ESRS E1 --------------------------------ESRS E5 ---------------------------------

28.- 33.

34.-40.

GOVERNANCE 11.-22.

23.-27.

ESRS G1----------------------------

41.-44.

8,67%

78,2%

Revenue growth

Percentage of Certified Sustainable Fish

18,3%

18%

Overview

Highlights in 2023 VAP % of whole fish processed to VAP

CO2e reduction

INTRODUCTION FROM THE CEO Dag Aksnes As CEO, I would like to express my gratitude for the dedication and efforts of the team. We have achieved significant milestones this year and look forward to exciting opportunities in the years ahead.

We recognize the importance of transparency and sustainability in our reporting, and this year’s Sustainability Statement represents an important step towards delivering a fully integrated annual report in line with the CSRD requirements.

We are not yet fully compliant with all aspects of the Directive, but we are actively working to improve our processes and reporting practices. Our ambition is to achieve full compliance by the reporting year 2026, in line with the current timelines and frameworks.

This document reflects our commitment and progress to date, while also clarifying our focus on continuous improvement and accountability.

Our board

The board's task is to ensure that the company is run in a responsible and sustainable manner. This involves setting strategic goals, monitoring the company's performance, and ensuring that management complies with laws and regulations. The board is also responsible for protecting the interests of shareholders and ensuring that the company has a good governance structure.

Through regular meetings (4-6 times pr year), the board stays updated on the company's development and makes necessary decisions to ensure long-term success.

Vision Sustainability remains at the heart of everything that Seaborn does and is deeply rooted in every aspect of our operations. Throughout 2023 we have made significant strides in strengthening our focus on environmental, social and governance (ESG) factors while continuously aligning with the requirements of the CSRD framework. This sustainability statement outlines our priorities, actions, and progress, reflecting our commitment to responsible operations and long-term sustainable development.

The board has made ambitious choices to shape the company according to sustainable principles going forward and in 2023 began work on preparing to report according to the CSRD directive, two years ahead of its time to properly prepare for upcoming regulations as well as align our reporting framework for the future.

Seaborn is the fish farmers’ own sales company.

Mission statement

Seaborn is the link between production in Norway and the global market for salmon and trout.

Our Values

ESRS 2 - General disclosures

Changes in preparation or presentation of sustainability information

BP-2 - Disclosures in relation to specific circumstances The reporting year did not include any significant changes in the company’s operations or structure. Although Seaborn has fewer than 750 employees, the company has voluntarily chosen to report on relevant aspects under the ESRS framework. The determination of relevance has been guided by the double materiality assessment process.

Time horizons Seaborn operates with the same timeframe as defined in ESRS: "Short horizon" is defined as up to 1 year, "medium horizon" as 1 to 5 years, and "long horizon" as 5 years or more.

Data collection Seaborn strives to obtain high-quality data for its sustainability calculations to ensure that the data used is reliable and representative. Parts of the Scope 3 emissions are based on estimates, especially where direct data from suppliers is not available. This can lead to a certain degree of uncertainty in the reported emission data. When accurate data are not available or essential for the calculations, Seaborn uses estimates based on approximate amounts.

This means that the company can still achieve reliable and realistic results, even when exact figures cannot be obtained. In most cases, open and recognized factor sets are used, such as DEFRA (Department for Environment, Food & Rural Affairs) and NVE (Norway's Water and Energy Directorate).

When it comes to calculating emissions linked to the purchase of fish (Scope 3 – Category 1), Seaborn uses different approaches depending on the farmers' affiliation. Approximately 40% of the farmers have published their own green gas report for 2023 and/or is a part of Salmon group and for these farmers we have used an exact emission factor. For the rest of our farmers/suppliers, Seaborn uses an industry-specific emission factor published by SINTEF. This means that emissions from purchased fish contain a certain degree of uncertainty, but due to the lack of high-quality emission factors from suppliers outside the Salmon Group, Seaborn considers this to be the best approach.

We encourage all of our suppliers to provide an accurate emission factor, and we aim for more exact factors in the years to come due to more focus from all parts of the value chain.

This sustainability statement is part of Seaborn's preparation for compliance with the CSRD framework.

While the statement for 2023 is not fully aligned with the regulation, it reflects the ongoing process Seaborn is undertaking to meet the applicable requirements in the coming years.

However, we would like to highlight that we have previously published sustainability reports, including emissions figures. Since then, a new and improved method for calculating transport data has been implemented.

Consequently, we have revised the 2022 emissions data from transport, which serves as our base year, and the figures for 2022 in this statement may differ slightly from those in the previously published sustainability report.

Seaborn are not regulatorily obligated to report in accordance with CSRD until 2026, but have chosen to start the process to achieve compliance with the directive from 2023 to prepare our organization, management and board for the upcoming requirements.

ESRS 2 - General disclosures

IRO-1: Description of the process to identify and assess material impacts, risks and opportunities

In 2023, Seaborn decided to move towards reporting requirements in accordance with CSRD. This involves preparing a new double materiality analysis. Preparing a double materiality analysis is an important work and a process that extends over time. The work on the double materiality analysis started in 2023 and the process continues into 2024.

The process was structured around four steps, where step 1 Understand was initiated in 2023 and the subsequent three steps were planned for 2024. The process is designed to understand, identify, engage, and prioritize the material impacts, risks, and opportunities relevant to Seaborn’s operations.

1. Understand

2. Identify

This phase involves reviewing previous sustainability work and analysis, as well as understanding new criteria introduced by CSRD. A thorough review of ESRS is required here to align with Seaborn’s business context. Understanding the business and value chain builds on prior descriptions of activities and business relationships, with a particular focus on due diligence assessments.

This phase involves identifying Seaborn’s impacts, risks, and opportunities related to its activities, focusing on the topics defined in ESRS. This step is essential for gaining an in-depth understanding of internal and external factors that can significantly affect the company’s sustainability goals. By identifying relevant impacts, Seaborn can prioritize resources and efforts in areas that create the greatest value and reduce potential risks.

3. Stakeholder engagement

This phase involves gathering stakeholder perspectives through comprehensive surveys and in-depth interviews. Insights from customers, employees, suppliers, investors, and other relevant parties provide Seaborn with a more holistic understanding of critical sustainability issues. This also strengthens the company’s reputation and trust among stakeholders.

4. Mapping materiality

This phase involves a process of identifying and prioritizing the topics most material to Seaborn. Assessments are based on analyses from surveys, in-depth interviews, and internal discussions conducted with management and the board. The results form a prioritized list of material topics that provide the foundation for Seaborn’s sustainability strategy and reporting.

ESRS 2 General disclosures SBM-1: Strategy, business model and value chain At Seaborn, sustainability is a core element of our strategy and operations. As a sales organization, we act as a bridge between Norwegian and Icelandic fish farmers and the global market, enabling the sale of high-quality seafood that is responsibly sourced. Our commitment to sustainability ensures that the seafood we promote adheres to stringent environmental and ethical standards, supporting sustainable aquaculture practices.

We export to over 60 countries, contributing to the global availability of quality seafood. Our headquarters is in Bergen, Norway, with a sales office in Sweden and sales representatives in the United States. By focusing on sustainable practices, we aim to meet the growing global demand for responsibly sourced seafood while supporting the long-term health of the oceans and the livelihoods of the communities we work with.

Seaborn AS has 71 employees, and 2 employees is employed at Seaborn's subsidiary in Sweden; Seaborn AB All of Seaborn's total revenue is generated from the aquaculture sector.

As part of our ongoing efforts to integrate sustainability into our core processes, Seaborn is advancing its understanding of upstream and downstream impacts in the value chain. In 2024, we will revisit our materiality assessment to refine our understanding of these impacts and deepen our focus on addressing risks and opportunities within our key sustainability topics: GHG emissions (E1), resource efficiency (E5), employee well-being (S1), supply chain responsibility (S2), and ethical governance (G1).

By embedding sustainability into our strategy, business model, and value chain, Seaborn aims to create lasting value for all stakeholders while minimizing negative impacts on people and the planet.

ESRS 2 - General disclosures

Certification targets

Product target

Our suppliers of whole fish, including fish farmers and processors, are primarily located in Norway and Iceland.

Seaborn focuses on increasing the sale of Value-Added Products (VAP), as transporting VAP allows for more

Currently, 78% of our suppliers are certified under recognized standards such as GlobalG.A.P (Good

efficient use of transportation resources. VAP offers the advantage of transporting a larger volume of edible

Agricultural Practices), GRASP (GlobalG.A.P Risk Assessment on Social Practice), ASC (Aquaculture Stewardship

product within the same space compared to whole fish. Our target is to increase the ratio of VAP to total

Council), or DEBIO (organic salmon and trout). These certifications ensure that our partners adhere to human

volume processed to 30% by 2030, and it is currently 18,3%. This target is also described in E5-3.

rights standards and practice responsible aquaculture farming. We are committed to increasing this number, with a target of having 90% of our fish suppliers certified by 2030. In addition to setting certification requirements for fish farming operations, we are also establishing a target for our packing facility suppliers. By

2030, we aim for 90% of the deliveries from packing facilities to come from GFSI-certified (Global Food Safety Initiative) packing houses, further ensuring that the highest food safety standards are met throughout our supply chain. In 2023 65% of deliveries came from GFSI-certified suppliers.

Transportation target A significant portion of our emissions stems from the transportation of our products. To reduce these emissions, we are focusing on optimizing transportation routes for road freight. This includes reducing distances traveled, lowering fuel consumption, maximizing transportation capacity, minimizing time spent in congested areas, and avoiding high-traffic periods. Our goal is to increase the share of direct truck transportation to 50% by 2030. In the reporting year the share was 37%.

Food safety target Ensuring the safety and quality of our products are key priority for Seaborn. Our food safety target is aligned with industry best practices and are designed to continuously monitor and improve our performance in this area. By 2030, we are committed to achieving zero recalls related to food safety issues. In 2023, the number of recall cases was zero.

ESRS E1

E1 Climate change Overview of disclosure requirements E1-1 Transition plan for climatechange mitigation E1-2 - Policies related to climate change mitigation and adaptation E1-3 – Actions and resources in relation to climate change policies

E1-4 – Targets related to climate change mitigation and adaptation E1-5 - Energy consumption and mix E1-6 - Gross Scopes 1, 2, 3 and Total GHG emissions MDR-M – Own Key Performance Indicator (KPI)

E1-9 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

ESRS-E1 Climate change

E1-1 Transition plan for climate change mitigation As part of our commitment to sustainability and in response to emerging regulatory requirements under the CSRD, we are actively working to develop a robust climate transition plan.

We are currently in the process of updating our sustainability strategy for the period 2025–2030, and integrating climate-related risks, opportunities, and mitigation measures. This work includes assessing our current emissions (Scope 1, 2, and 3), identifying pathways for emission reductions, and establishing measurable targets that align with the global 1.5°C climate trajectory.

The development of this transition plan will involve collaboration with internal and external stakeholders, to ensure a comprehensive and actionable approach. This plan will outline specific measures Seaborn will take to reduce greenhouse gas emissions, enhance operational efficiency, and prepare for a low-carbon future.

A full description of the transition plan, including milestones, actions, and progress, will be presented in next year’s sustainability report. This reflects Seaborn’s commitment to transparency, accountability, and continuous improvement as we work towards our climate goals.

ESRS – E1 Climate change E1-2 - Policies related to climate change mitigation and adaptation Seaborn’s environmental policy outlines our ambition to promote a sustainable and transparent seafood value chain while actively addressing climate change. Through collaboration, clear requirements, and continuous improvements, Seaborn aims to reduce its environmental impact and influence its partners towards more sustainable practices.

Sustainable Value Chain Collaboration

Transportation Emissions

Sustainable Packaging

Seaborn recognizes the importance of

Given that transportation represents a significant

Seaborn acknowledges the impact of resource

cooperation across the seafood value chain. By

portion of our Scope 3 emissions, Seaborn is

use and waste generation within its packaging

engaging with both customers and suppliers, we

committed to optimizing the modes of

processes. Through innovative solutions and

are setting clear sustainability requirements in

transportation we use. By leveraging accurate

material optimization, we aim to minimize

future agreements. This includes targets to

emission calculation tools, such as the system

resource inflows and outflows, reduce packaging

address climate-related challenges, such as

provided by Maritech, we can assess and reduce

waste, and lower the environmental impact of

emissions reduction and improved environmental

CO₂e emissions associated with different logistics

our products.

performance throughout the value chain.

solutions. This enables us to make data-driven decisions that prioritize lower-emission transportation options and reduce the overall

climate footprint of our operations.

ESRS-E1 Climate change

E1-3 – Actions and resources in relation to climate change policies

E1-4 – Targets related to climate change mitigation and adaptation

•

Improving Scope 3 Emissions Data and Analysis

•

Reducing Transportation Emissions

•

Optimizing Packaging Solutions

•

Reduce Greenhouse Gas Emissions by 9.8% by 2030

•

Increase Use of Value-Added Products (VAP)

•

Optimize Transportation Efficiency

ESRS - E1 Climate change

E1-4 - Targets related to climate change mitigation and adaptation

Base year (2022)

2030

518 550 tCO2e

467 732 tCO2e

ESRS – E1 Climate change

E1-5 - Energy consumption and mix In 2023, Seaborn's total energy consumption was 172 MWh, all of which was electricity used in the office spaces Seaborn leases. This electricity was purchased without guarantees of origin, meaning it should not be specifically classified as coming from fossil, nuclear, or renewable sources. However, it's important to note that the majority of Norway’s electricity production comes from renewable sources, particularly hydropower.

When looking at Seaborn’s emission from a location-based perspective, we can use NVE’s declaration for physical delivered power, stating that 83% is from hydro power, wind power 11%, fossil fuel sources 5% and other renewables equalling the remaining 1%.

ESRS – E1 Climate change

E1-6 - Gross Scopes 1, 2, 3 and Total GHG emissions The calculation of Seaborn’s climate footprint is based on the framework specified in the GHG protocol and calculated using climate accounting software GHG123 . The emissions factors used to calculate the climate impact of our activities are based on several sources.

For Scope 2, both the market-based and location-based methods use emissions factors from the National Product Declaration provided by NVE (2023). Emissions factors for travel, waste, and IT purchases are sourced from DEFRA (2023). For the seafood industry, industry-specific emissions factors are drawn from SINTEF (2022), while transportation calculations and factors are provided by Maritech . Additionally, emissions factors specific to our fish suppliers are also incorporated into the calculations.

In the table to the right, we present our gross Scope 2, and 3 emissions, covering direct emissions, energy consumption, and emissions from our entire value chain. Notably, Seaborn has no direct emissions under Scope 1.

GHG intensity per net revenue Seaborn’s GHG intensity per net revenue for 2023 was 48.5 tCO2e/MNOK. The net revenue amounts used in this calculation align with those published in the financial statements.

ESRS – E1 Climate change

MDR-M – Own Key Performance Indicator (KPI)

E1-9 - Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Seaborn tracks its sustainability progress using a KPI that measures total greenhouse gas (GHG) emissions per kilogram of purchased fish. This KPI includes both Scope 2 and Scope 3 emissions and is calculated by dividing Seaborn’s total emissions for the reporting year by the total kilograms of fish purchased during the same period. This provides an emissions intensity metric that accounts for fluctuations in business activity, ensuring that Seaborn can monitor its sustainability performance consistently as its operations evolve.

Seaborn's operations face material physical risks as identified through the Double Materiality Analysis:

Seaborn’s internal emissions reporting, which follows the guidelines of the GHG protocol. Seaborn’s emission data is externally validated by Emisoft.

Since this KPI is directly influenced by all emission-related initiatives, we see no need to define separate actions specifically targeting the KPI. Any climate mitigation efforts, such as energy efficiency improvements or supplier engagement to reduce emissions, will naturally be reflected in the emissions per kilogram of purchased fish. The table presents the results of our KPI, tracking total emissions per kilogram of purchased fish.

Acute Physical Risks: Extreme Weather Events: Increasing frequency and intensity of storms, heavy rainfall, and flooding can disrupt fishing and aquaculture operations, damage transportation routes, and delay product deliveries.

These disruptions pose immediate financial risks, such as lost revenue due to delayed shipments, increased costs for alternative logistics solutions, and higher insurance premiums.

Chronic Physical Risks: Rising and Fluctuating Sea Temperatures: Long-term shifts in ocean temperatures can alter fish populations, impacting both species availability and abundance. This may lead to higher procurement costs as Seaborn adapts to sourcing challenges, including increased competition for available stock or reliance on alternative sources.

To mitigate these financial risks, Seaborn is working on strategies to increase the resilience of its supply chain, including close collaboration with suppliers to anticipate disruptions and identify diversified sourcing options.

Land-Based Aquaculture: Expanding land-based aquaculture facilities provides a strategic opportunity to reduce the reliance on seabased farming, thereby supplementing fish supplies during disruptions caused by extreme weather or changing ocean conditions. Although not a full replacement, land-based operations can help stabilize sourcing, reduce volatility, and secure revenue streams.

Growing Demand for Sustainable Protein: Fish, as a protein source, is recognized for its significantly lower carbon footprint compared to red meat. This positions Seaborn favorably to capture market opportunities. As societal and regulatory focus on climate mitigation grows, Seaborn anticipates an increase in demand for sustainably sourced fish, which can enhance revenue and market positioning.

Transistion Risks: Seaborn has not identified any material transition risks directly related to its operations, as the company's activities are not heavily carbon-intensive. However, indirect risks such as evolving regulations on Scope 3 emissions reporting and expectations for climate disclosures are areas of ongoing assessments.

ESRS-E1 Climate change

Our Climate Impact

As part of our sustainability strategy, Seaborn is committed to establishing specific emission reduction targets by the end of 2024, focusing on Scope 3 emissions. We are currently conducting a double materiality analysis in accordance with the Corporate Sustainability Reporting Directive (CSRD).

Our official sustainability report, in accordance with CSRD, is scheduled for publication in the fall of 2024.

In 2023, Seaborn has undertaken an extensive process of collecting quality data from our suppliers, with a focus on Scope 3 as the majority of our emissions fall within our value chain. During this process, we worked closely with our suppliers to ensure the accuracy and completeness of the data. By enhancing the transparency and reliability of our data, we were able to identify key areas for improvement. This will be important for our strategy and for setting relevant targets.

We made significant progress in reducing our overall emissions in 2023, achieving an important decrease from the previous year, and our base year, 2022. Our total emissions dropped 18% from 518 552 tCO2e in 2022 to 426 081 tCO2e in 2023. This reduction was mainly due to reduced volume of purchased fish and improved data accuracy from suppliers.

600 000 500 000 400 000

tCO2e

The purpose of this report is to provide a comprehensive overview of Seaborn's greenhouse gas emissions for the year 2023.

This report outlines our total emissions across various scopes and categories, compares them with previous years, and details the methodologies used for data collection and reporting.

300 000 200 000 100 000 -

Scope 1*

Scope 2

Scope 3

2022

-

2

518 550

2023

-

3

426 078

* The cells in the table marked (-) indicate no relevant data

ESRS-E1 Climate change - Detailed Climate Accounting

Category

2023 (tCO2e)

Scope 2 (location-based)

3.27

Electricity without Guarantee of origin

3.27

Scope 3

426 077.54

01. Purchased goods and services

306 514.47

03. Fuel- and energy-related activities 04. Upstream transportation and distribution

0.57

0.01

06. Business travel

135.20

07. Employee commuting

26.19

08. Upstream leased assets

40.79

10. Processing of sold products0

01. Purchased Goods and Services 2023: 306 514.47 tCO2e 2022: 409 302.24 tCO2e Decreased emissions by 25% due to reduced volume of purchased fish, and improved data accuracy from suppliers.

117 953.49

05. Waste generated in operations

09. Downstream transportation and distribution

Scope 2 - Purchased Energy 2023: 3.27 tCO2e 2022: 1.70 tCO2e Increased emissions due to 8% higher energy consumption in 2023, and the location- based emission factor from NVE (Norges vassdrags- og energidirektorat) increased by 73%.

1 327.89 74.97

12. End-of-life treatment of sold products

3.91

Total (location-based)

426 080.81

Scope 2 (marked-based)

86.56

KPI 2023 Emissions from purchased fish

3.4 kg CO2e/kg

Emission from transported fish

1.3 kg CO2e/kg

Total emission per kg fish

4.7 kg CO2e/kg

03. Fuel- and Energy-related Activities 2023: 0.57 tCO2e 2022: 0.56 tCO2e Emissions have remained constant over the two years.

04. Upstream Transportation and Distribution 2023: 117 953.49 tCO2e 2022: 109 161.79 tCO2e Increased emissions by 8%, primarily due to improved data accuracy and updated measurement methods. 5% decrease in tkm in 2023.

05. Waste Generated in Operations 2023: 0.01 tCO2e 2022: 0.01 tCO2e Emissions have remained constant over the two years.

06. Business Travel 2023: 135.20 tCO2e 2022: 11.83 tCO2e Significantly increased emissions in 2023 due to higher travel activities. The main contributor is our participation in The Global Seafood Marketplace in Barcelona.

07. Employee Commuting 2023: 26.19 tCO2e 2022: 41.40 tCO2e Decreased emissions by 37% due to an increase in the use of electric cars by employees, and a reduction in fossil fuel cars.

08. Upstream Leased Assets (location-based) 2023: 40.79 tCO2e 2022: 32.46 tCO2e Increased emissions by 26% due to higher registered amount on energy consumption.

09. Downstream Transportation and Distribution 2023: 1 327.89 tCO2e 2022: Not registered Emissions were first registered in 2023.

10. Processing of Sold Products (location-based) 2023: 74.97 tCO2e 2022: Not registered Emissions were first registered in 2023.

12. End-of-life Treatment of Sold Products 2023: 3.91 tCO2e 2022: Not registered Emissions were first registered in 2023.

ESRS-E1 Climate change – Material Categories Category

Material

Scope 1 - Direct emissions

Not relevant - no own vehicles or processes

Scope 2 - Purchased energy

Included - electricity consumption from office premises

DOWNSTREAM

UPSTREAM

Scope 3 01. Purchase goods and services

Included - purchased fish from all suppliers and IT equipment

02. Capital goods

Not relevant – no investments in capital goods

03. Fuel- and energy-related activities

Included - calculated from energy consumption

04. Upstream transportation and distribution

Included - purchased transport from all suppliers (air, sea and road)

05. Waste generated in operations

Included - waste from office operations (residual, organic and recycled)

06. Business travel

Included - flights and hotel stay from all employees

07. Employee commuting

Included - employee commuting habits (survey conducted in 2024)

08. Upstream leased assets

Included - energy consumption from our rented storage facilities (location-based)

09. Downstream transportation and distribution

Included - transportation of sold products by customers' vehicles (Norway and Europe)

10. Processing of sold products

Included - total energy consumption from our main fish processing partner (location-based)

11. Use of sold products

Not included this year - plan to include estimate in next year's reporting

12. End-of-life treatment of sold products

Included - disposal of sold product (packaging) based on material and disposal method

13. Downstream leased assets

Not relevant – do not lease any assets to customers

14. Franchises

Not relevant – do not have any franchises

15. Investments

Not relevant – do not have any investments or shares in other companies

ESRS-E1 - Climate change - Methodology In this section, we provide insights into Seaborn's methodology for measuring and climate impact.

Scope 3, Category 1 – Fish Suppliers Our biggest emission source in 2023 was the purchase of fish.

With nearly 100 different fish suppliers, we acquired over 90 000 tones of whole fish. As part of our ongoing effort to reduce emissions, we have conducted a comprehensive assessment of all our fish suppliers and categorized them based on their affiliation with the Salmon Group. The Salmon Group represents a network of fish farmers who share our sustainability vision and adhere to stringent environmental standards.

During 2023, we maintained our practice of using precise calculations for CO2e emissions instead of relying on generalized standard data. Specifically, we gathered detailed CO2e emissions data from our fish suppliers, with a particular focus on those affiliated with the Salmon Group.

Scope 3, Category 4 – Transport Suppliers Since transportation is a major source of greenhouse gas emissions, it is crucial for us to use a method that interprets data in a simple yet quality-assured manner. That is why we have continued to use Maritech. By leveraging their expertise, we have been able to shift our focus from merely gathering data to conducting in-depth analyses. This shift allows us to allocate more time and resources towards analyzing the information at hand, thereby enhancing our decision-making processes.

Due to improved data accuracy and updated measurement methods from Maritech, we have also revised our 2022 transportation data, and updated our climate accounting.

System, calculation and emission factors All equations and calculations in GHG123 are quality assured together with the relevant emissions factors and data types.

Emissions factors used to calculate climate impact of our activity: • Emissions factors for market-based method and location-based method Scope 2 are taken from NVE (National Product Declaration) (2023).

• Emissions factors for calculating emissions from traveling, waste and IT purchase are taken from DEFRA (2023).

• Industry-specific emission factors for the seafood industry are taken from SINTEF (2022).

Calculations and factors for transportation are provided by Maritech.

• Fish supplier specific emissions factors

GHG123 emission software With decades of experience, Emisoft provides us with GHG123, a transparent climate accounting system in accordance with the GHGprotocol. The solution offers comprehensive data analysis and a detailed emissions overview. By using GHG123, Seaborn gains improved accuracy and insight into setting targets and identifying improvements.

References DEFRA (2023), «Greenhouse gas reporting: conversion factors 2023» https://www.gov.uk/government/publications/greenho use-gas-reporting-conversion-factors-2023 NVE (2022), https://www.nve.no/energi/virkemidler/opprinnelsesga rantier-og-varedeklarasjon-forstroemleverandoerer/varedeklarasjon-forstroemleverandoerer/ NVE (2022), https://www.nve.no/energi/energisystem/kraftproduks jon/hvor-kommer-stroemmen-fra/ SINTEF (2022), «Greenhouse gas emissions of Norwegian salmon products» https://sintef.brage.unit.no/sintefxmlui/bitstream/handle/11250/3044084/Rapport_klim afotavtrykk.pdf?sequence=1&isAllowed=y

Maritech software Maritech is a leading supplier of seafood software related to transportation data. The solution is based on automatic data flow from Seaborns trading system and provides a detailed overview of emissions based on the route, country, type of vehicle, distance, and other parameters.

ESRS E5

E5 Resource use and circular economy Overview of disclosure requirements ESRS 2 IRO-1 – Description of the processes to identify and assess material resource use and circular economy-related impacts, risks and opportunities E5-1 – Policies related to resource use and circular economy E5-2 – Actions and resources related to resource use and circular economy E5-3 – Targets related to resource use and circular economy E5-4 – Resource inflows E5-5 – Resource outflow E5-6 – Anticipated financial effects from material resource use and circular economy-related risks and opportunities

ESRS E5 - Resource use and circular economy

ESRS 2 IRO-1 – Description of the processes to identify and assess material resource use and circular economy-related impacts, risks and opportunities The process of identifying and assessing material impacts, risks, and opportunities related to resource use and circular economy was conducted alongside the procedure outlined in IRO-1. This involved a review of Seaborn’s operations and value chain, particularly focusing on product composition and packaging choices, to identify areas for improvement in resource efficiency and circularity. However, consultations with local communities were not conducted, as these impacts were not deemed material in this context.

E5-1 – Policies related to resource use and circular economy Seaborn’s approach to resource use and circular economy is guided by a commitment to reducing environmental impact and promoting sustainable practices throughout our value chain. This includes improving packaging solutions, minimizing waste, and finding innovative ways to utilize byproducts.

Our long-term policy goal is to make packaging fully recyclable so that we can unlock the full environmental benefits of these materials. High-quality, sustainable packaging plays a critical role in reducing food waste and ensuring product quality, aligning with Seaborn’s broader circular economy ambitions.

Seaborn actively works to reduce food waste across its operations and value chain. This aligns with UN SDG target 12.3, which aims to halve per capita global food waste by 2030 and reduce food losses across production and supply chains, including post-harvest losses. To support this goal, Seaborn collaborates with Value-Added Product (VAP) suppliers who focus on reducing waste and repurposing byproducts. For example, by-products from seafood production are redirected to companies such as Biomega, which utilize them to produce salmon oil and pet food. This process ensures that resources are maximized, benefiting both the environment and the economy.

ESRS E5 - Resource use and circular economy E5-2: Actions and Resources Related to Resource Use and Circular Economy

Value-Added Products (VAP) Seaborn has prioritized increasing the production and sale of Value-Added Products (VAP), as outlined in SBM-1 and E5-3. This initiative enhances resource use efficiency by optimizing the volume of edible products transported and ensuring the full utilization of raw materials. By processing fish into VAP, Seaborn achieves the following: Waste Reduction Byproducts from processing are redirected to suppliers who use them to produce valuable secondary products, such as salmon oil and pet food, preventing waste generation in the downstream value chain.

Fish Crate Management and Circular Design To advance circular economy principles, Seaborn is conducting an initiative to gather documentation from suppliers and customers on how fish crates are managed throughout the supply chain. This project aims to: 1.

Assess how fish crates are reused, recycled, or disposed of.

1.

Identify opportunities for circular design solutions, such as crate reuse programs or improved recycling processes.

1.

Improved Resource Control Compared to selling whole fish, VAP production allows Seaborn greater control over how resources are utilized and managed, ensuring higher resource efficiency.

Transportation Optimization Increased VAP sales contribute to more efficient transport, as processed products allow for better volume utilization and lower emissions per unit.

Develop strategies to ensure crates align with sustainability principles across all touchpoints in the value chain.

Sustainable Packaging Solutions Seaborn uses environmentally friendly packaging made from renewable materials, such as green polyethylene, which is partly derived from plants like sugarcane. This material significantly reduces CO₂ emissions compared to conventional oil-based plastics. Key actions in this area include ●

Increasing the use of renewable and recyclable packaging for all Seaborn products.

●

Exploring opportunities to transition towards fully recyclable packaging solutions to further reduce resource outflows and waste.

ESRS E5 - Resource use and circular economy

E5-3 – Targets related to resource use and circular economy Seaborn has set a strategic target to increase production and sale of ValueAdded Products (VAP). 30% of whole fish volume should by 2030 be processed to VAP. This share was 18 % in 2023. The increase in VAP can maximize the use of raw materials and ensure that a higher proportion of the fish is utilized. When processing fish into VAP, Seaborn gains greater control over the management of byproducts, enabling us to sell components like heads, entrails, and skin to partners who use them for other purposes.

This practice reduces waste and supports more sustainable resource management, compared to selling whole fish, where we have less visibility over the use of non-edible parts. Seaborn tracks progress toward this target by using data for total VAP sold compared to total fish sold, ensuring a clear measure of the company’s progress over time. The target is based on internal analysis of our production capabilities and suppliers will play a key role in achieving the target.

30%

90%

Increase volume of VAP products (%VAP compared to HOG)

Utilization rate of VAP

90%

100%

Certified fish

Use of I-am-green film

A summary of targets in the medium term is presented on the right.

2030 Targets

ESRS E5 - Resource use and circular economy

E5-4 – Resource inflows

E5-5 – Resource outflows

In 2023, Seaborn purchased a total of 90 026 tonnes of fish. This represents the primary raw material used in our operations and highlights our significant resource consumption. Additionally, we procured 184 tonnes of plastic packaging, which is utilized in our product distribution and storage processes.

For Seaborn, resource outflows include both the fish sold and the packaging materials used, as described under E5-4. Seaborn is committed to enhancing the sale of VAP which supports circular economy by optimizing the use of fish, including non-edible parts.

Waste Regarding electrical equipment, we acquired 0.43 tonnes during the reporting year.

This figure is based on an estimate, which was derived from the number of technical purchases made by the company throughout 2023.

For Seaborn, the focus on biological materials in the context of this disclosure relates primarily to the fish it sells, which is the core biological material in its operations. In terms of sustainable sourcing, Seaborn is committed to ensuring that a significant portion of its fish suppliers are certified under recognized sustainability standards such as GlobalG.A.P., ASC, GRASP, or DEBIO, as described in SBM-1. Currently, 78% of Seaborn’s fish suppliers in 2023 adhered to these certification schemes.

Seaborn’s operations are limited to the purchase and resale of fish, with its waste generation primarily arising from office activities. The following table provides a detailed breakdown of Seaborn's waste management for the reporting year 2023: Given that the total waste generated was 1 000 kg, the percentage of non-recycled waste is 50%.

The data provided is based on estimations derived from the number of employees. Standard waste classification practices were used to categorize and report the waste.

ESRS S1

S1 Own workforce Overview of disclosure requirements ESRS S1 SBM-2 – Interests and views of stakeholders ESRS S1 SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model S1-1 – Policies related to own workforce S1-2 – Processes for engaging with own workforce and workers’ representatives about impacts S1-3 – Processes to remediate negative impacts and channels for own workforce to raise concerns S1-4: Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions S1-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities S1-6 – Characteristics of the undertaking’s employees S1-9 – Diversity metrics S1-10 – Adequate wages S1-15 – Work-life balance metrics

S1-16 – Remuneration metrics (pay gap and total remuneration) S1-17 – Incidents, complaints and severe human rights impacts

ESRS S1 - Own workforce

ESRS S1 SBM-2 – Interests and views of stakeholders Seaborn’s employees are our most important source of innovation, development, and growth. Competent employees are a lasting competitive advantage and the key to building loyal and satisfied customers. Our ambition is to strengthen employee satisfaction, engagement, and joy at work through meaningful tasks, good leadership, a motivating work environment, opportunities for development, and trust in management. Our leaders are expected to set clear direction and encourage employees to collaborate in achieving both shared and individual goals.

Transparency is essential for motivation, trust, and security.

All employees should feel they can raise issues with management and others within the organization

ESRS S1 SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model At Seaborn, we recognize the pivotal role our employees play in the success and sustainability of our business. In alignment with ESRS S1 SBM3, we have identified two key areas of material impact under working conditions and equal treatment and opportunities for all: work-life balance and training and skills development.

Ensuring a healthy work-life balance for our employees is a priority at Seaborn. We understand that fostering a balance between work responsibilities and personal well-being enhances productivity, reduces absenteeism, and improves overall employee satisfaction. A lack of work-life balance can result in increased burnout, reduced morale, and challenges with talent retention, ultimately impacting operational efficiency and company performance.

Investing in training and skills development is essential to maintaining Seaborn’s competitiveness and adaptability in the evolving seafood industry. By prioritizing continuous learning and professional growth, we equip our employees with the skills necessary to optimize operations, adopt new technologies, and contribute to our sustainability goals.

At Seaborn we treat everyone equal and strive to have an inclusive work environment for all employees. Satisfaction within our own workforce is crucial for Seaborn long term success, and we view equality and inclusion as integral part of our business model.

ESRS S1 - Own workforce

S1-1 – Policies related to own workforce

Seaborn’s policies for our workforce reflect our commitment to creating a safe, inclusive, and respectful work environment where all employees can thrive. Our policies are designed to promote fairness, diversity, and well-being, aligning with both our core values and the principles of responsible business conduct.

Seaborn remains committed to continuously improving our workforce policies to support employee well-being, promote equal opportunities, and ensure a safe and respectful workplace for all. These principles are integrated into our long-term strategy, reflecting our belief that a thriving workforce is essential to sustainable business success.

ESRS S1 - Own workforce

S1-2 – Processes for engaging with own workforce and workers’ representatives about impacts

S1-3 – Processes to remediate negative impacts and channels for own workforce to raise concerns

At Seaborn, we recognize the importance of open and constructive dialogue between management and employees to address impacts related to working conditions, well-being, and professional development.

Maintaining clear communication channels ensures that the voices of our workforce are heard and that concerns and opportunities are addressed effectively.

At Seaborn, we are committed to fostering a safe, healthy, and respectful workplace while providing robust processes for identifying, addressing, and remediating negative impacts on our employees. Our approach ensures that all employees have access to formal mechanisms to raise concerns and that these concerns are addressed transparently and effectively.

Seaborn has established formal and informal processes for engaging with employees and their representatives, fostering a culture of transparency, collaboration, and trust:

By maintaining multiple channels for raising concerns and fostering a proactive approach to remediation, Seaborn ensures a safe, supportive, and respectful work environment. These processes not only address negative impacts but also build trust, empower employees, and reinforce our commitment to ethical business practices and employee well-being.

Health and Safety Group (Working Environment Committee) Safety Representatives Annual Employee Appraisal Meetings

Working Environment Committee The Working Environment Committee plays a key role in ensuring a fully responsible and sustainable working environment. This committee consists of both employee representatives and management, fostering a collaborative approach to health, safety, and environmental work.

Safety Representatives Seaborn’s safety representatives are responsible for monitoring and safeguarding occupational health and safety in the workplace.

Workplace Surveys

Seaborn conducts regular workplace surveys to assess employee satisfaction, well-being, and workplace conditions. These surveys provide valuable insights into potential negative impacts, such as challenges related to workload, workplace safety, and overall employee experience. Feedback from surveys allows management to proactively address concerns and implement targeted improvements to the working environment.

ESRS S1 - Own workforce

Targets S1-4: Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actions Seaborn has set clear targets to manage the impacts, risks, and opportunities related to its workforce. One key target is the completion of mandatory e-learning courses for all new employees. These courses cover health and safety sustainability, food safety, and digital security. New employees in sales and procurement also receive additional training on anti-corruption and competition law. This training is essential as it equips employees with knowledge crucial to maintaining Seaborn's ethical standards, ensuring compliance with legal requirements, and fostering a sustainable and safe work environment.

S1-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities The materiality assessment identified working conditions and equal treatment and opportunities for all as material topics, with work-life balance and training and skills development as key sub-topics. These areas are critical for ensuring a positive and productive work environment at Seaborn while supporting the company’s long-term success.

Seaborn’s approach to working conditions and skills development is integrated into its broader commitment to employee well-being and inclusion Targets related to work-life balance and employee development are presented on the right, and employees are encouraged to provide feedback through annual appraisals, workplace surveys, and dedicated reporting channels, enabling continuous improvement.

Seaborn remains committed to advancing these priorities by fostering an inclusive, supportive work environment and equipping employees with the tools and opportunities they need to succeed. This approach not only mitigates risks but also strengthens Seaborn’s position as an employer of choice while driving long-term business resilience and performance.

1,5%

100%

Sick leave

Employee satisfaction

5

50%

Number of completed nanolearning sections

Gender balance all employees

50% Gender balance senior management

0

Number of work-related injuries and sickness absence

ESRS S1 - Own workforce

Metrics and characteristics S1-6 – Characteristics of the undertaking’s employees Gender

Number of employees (number)

Male

34

Female

37

Total

71

Description

Female

Male

Total

37

34

71

Permanent employees

S1-9 – Diversity metrics Gender

Number

Distribution (%)

Men

34

48

Women

37

52

Total

71

100

S1-15 – Work-life balance metrics Total Proportion (Partial parental leave)

Men

Women

7%

5,8%

8,1%

S1-13 – Training and skills development metrics Gender

Employees who participated in regular training (%)

Male

90%

Female

90%

Total

90%

ESRS S2

S2 Workers in the value chain Overview of disclosure requirements ESRS 2 SBM-2 Interests and views of stakeholders ESRS 2 SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model S2-1 – Policies related to value chain workers

S2-2 – Processes for engaging with value chain workers about impacts S2-3 – Processes to remediate negative impacts and channels for value chain workers to raise concerns S2-4 – Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions S2-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

ESRS S2 - Workers in the value chain

ESRS 2 SBM-2 Interests and views of stakeholders

Stakeholder Engagement Approach

Insights from Workers in the Supply Chain

Supplier and Customer Relationships Seaborn maintains close relationships with suppliers and customers, ensuring that sustainability principles are embedded in all agreements through our Supplier Code of Conduct and contractual frameworks. These agreements prioritize ethical behavior, environmental responsibility, and respect for human rights.

Promoting Fair Labor Practices Our engagement with workers has reinforced the need for strict adherence to fair labor standards. This feedback has informed policies such as mandatory supplier adherence to our Supplier Code of Conduct, which encompasses the UN Global Compact’s principles on human rights and labor conditions.

Compliance and Risk Management Annual risk assessments of suppliers focus on human rights, labor conditions, and compliance with laws and regulations. For transporters and suppliers, these evaluations include monitoring wage conditions in accordance with the Allmenngjøringsforskriften (General Application of Collective Agreements) and identifying risks of non-compliance within the value chain.

Improving Operational Sustainability Worker feedback has highlighted areas where resource utilization and transport logistics can be optimized, driving changes that reduce costs and emissions while maintaining ethical standards.

Worker Feedback Mechanisms Workers in our supply chain have access to clear reporting mechanisms for raising concerns, including the whistleblowing channels required by Norwegian law (Arbeidsmiljøloven §2A). These mechanisms ensure grievances are addressed promptly and effectively.

Strengthening Supplier Collaboration Insights from workers have encouraged greater collaboration with suppliers to monitor working conditions, provide training, and implement corrective actions where needed, enhancing trust and accountability across the value chain.

ESRS S2 - Workers in the value chain

ESRS S1 SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model Seaborn's materiality assessment has highlighted several key risks and negative impacts associated with working conditions in the supply chain. Secure employment is a significant risk, as a lack of job stability for workers can lead to reduced productivity and operational reliability. To mitigate this, Seaborn enforces its Supplier Code of Conduct, requiring suppliers to uphold clear labor rights and conducting regular audits to ensure compliance.

Working time is another critical risk, as excessive or poorly regulated hours can result in worker fatigue and safety concerns. Seaborn addresses this by collaborating with suppliers to ensure that working hours comply with national labor laws, such as Norway’s Allmenngjøringsforskriften, and are carefully monitored through supplier reviews.

Adequate wages present a further risk, as insufficient pay can lead to dissatisfaction among workers and reputational damage for Seaborn. Through its supplier audit processes, Seaborn ensures that wage practices align with the principles of the UN Global Compact, promoting fair pay for all workers within the value chain.

Work-life balance is identified as a negative impact, where insufficient attention to workers' personal needs can lead to burnout, reduced morale, and lower productivity. Seaborn works closely with its suppliers to promote better balance by encouraging reasonable shifts and flexible working arrangements where feasible.

Finally, poor health and safety standards in the supply chain can result in workplace accidents, operational disruptions, and harm to workers. Seaborn proactively reviews health and safety practices across its supply chain, with a particular focus on transporters and processing facilities. The company also encourages training and awareness programs to ensure safe working environments.

By addressing these risks and impacts, Seaborn strengthens its supply chain resilience, upholds ethical labor practices, and ensures that its operations align with sustainability and human rights principles. These efforts are integral to Seaborn’s broader strategy of fostering a responsible and sustainable seafood value chain.

Seaborn integrates the management of these impacts, risks, and opportunities into its strategy and business model by: Seaborn requires all suppliers to sign the Supplier Code of Conduct, ensuring alignment with the company’s ethical and sustainability principles.

Regular Audits and Risk Assessments: Comprehensive reviews of suppliers’ practices are conducted annually to monitor compliance with labor standards and human rights.

Promoting Transparency and Accountability: Seaborn publishes findings from its due diligence processes and actively communicates improvements in supply chain working conditions.

ESRS S2 - Workers in the value chain

Disclosure Requirement S2-1 – Policies related to value chain workers

The work and process around the Transparency Act is firmly rooted in our management and our board. We have routines for approval and regular follow-up and audits of our suppliers. Where among others all suppliers of fish and transport must sign our Supplier Code of Conduct before trade can take place. The ethical guidelines, which all our partners must follow, take into account all the principles from the UN Global Compact's guidelines for human rights.

As Seaborn orders transportation of goods, we are also responsible for informing and ensuring that drivers who drive for Seaborn have generalize wages and working conditions in accordance with regulations on information and duty of care for clients. In addition, we have implemented warning routines in line with §2A of the Working Environment Act.

ESRS S2 - Workers in the value chain

S2-2 – Processes for engaging with value chain workers about impacts

S2-3 – Processes to remediate negative impacts and channels for value chain workers to raise concerns

Seaborn’s feedback and communication with our value chain workers are primarily conducted through an established dialogue with the accounts representative.

We have an open line of communication with the workers in our value chain whenever possible, and we strongly support a company culture where everyone’s opinion matters.

Seaborn is committed to promoting a responsible and sustainable seafood value chain. As a vital link between seafood producers and customers, we take responsibility for addressing and remediating negative impacts within our value chain. Recognizing the importance of collaboration and transparency, Seaborn has established processes and mechanisms to identify, mitigate, and address concerns raised by value chain workers, ensuring that all parties are treated fairly and ethically.

Quality and Compliance Manager has the main responsibility of making sure that inspections in our facilities are being conducted on an annual basis, with corresponding reporting lines directly to the management group and board.

Seaborn requires all suppliers to adhere to our Supplier Code of Conduct, which outlines strict guidelines for ethical behavior, respect for human rights, and compliance with labor laws. Regular audits and inspections are conducted to ensure adherence to these standards, allowing us to identify potential negative impacts and address them proactively.

We actively collaborates with suppliers, workers, and external stakeholders to develop solutions for any identified issues. This collaboration enables us to build trust, share knowledge, and establish best practices for addressing labor-related concerns in the value chain.

We maintain close communication with our suppliers to ensure they provide channels for their workers to raise concerns. Seaborn actively supports suppliers in developing and maintaining grievance mechanisms that align with international standards, ensuring that workers’ voices are heard.

ESRS S2 - Workers in the value chain

S2-4 – Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions Seaborn’s proactive management of risks related to value chain workers mitigates potential disruptions, reputational damage, and compliance violations. At the same time, our actions create opportunities to build stronger relationships with suppliers, improve operational efficiency, and enhance our reputation as a responsible and sustainable seafood company.

By prioritizing fair wages and job security for workers in our supply chain, we help ensure a stable and motivated workforce, which directly contributes to the reliability and efficiency of our operations. Similarly, promoting health and safety standards and encouraging work-life balance among supply chain workers enhances their well-being, reduces turnover, and supports consistent productivity across the value chain.

Actions to Address Material Impacts Supplier Code of Conduct All suppliers are required to comply with Seaborn’s Supplier Code of Conduct, which incorporates principles from the UN Global Compact and international labor standards. This ensures that workers in the value chain are afforded fair wages, reasonable working hours, and a safe working environment.

Regular Audits and Monitoring Seaborn conducts annual audits and risk assessments to evaluate supplier compliance with labor laws and ethical standards. These audits focus on critical aspects such as health and safety, wage practices, and job security, enabling the identification and resolution of issues.

Supplier Approval Program Seaborn conducts audits and on-site visits to terminals as part of its comprehensive supplier approval program. These audits focus on evaluating and monitoring transporters to ensure compliance with Seaborn's Supplier Code of Conduct, ethical standards, and applicable regulations. The inspections cover critical aspects such as health and safety measures, working conditions, wage practices, and adherence to labor laws.

Worker Engagement: Seaborn requires suppliers to establish clear and accessible channels for workers to raise concerns, such as whistleblowing systems and grievance procedures. This ensures that workers feel empowered to report unethical practices or unsafe conditions without fear of retaliation.

ESRS S2 - Workers in the value chain

S2-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Seaborn has outlined clear targets to enhance supplier follow-up routines across short-, medium-, and long-term horizons.

Short-Term Goals (±1 year): By 2025, Seaborn aims to ensure a minimum of 5 suppliers undergo routine follow-up assessments to improve value chain oversight and collaboration.

Medium-Term Goals (±5 years): Between 2025 and 2027, Seaborn targets steady progress, increasing the number of suppliers with routine follow-ups. The goals include 10 follow-ups in 2025, ten in 2026, and twenty by 2027, reflecting Seaborn’s commitment to continuous improvement.

Long-Term Goals (>5 years): Seaborn aspires to establish itself as a best-in-class company in supplier value chain fulfillment, setting a benchmark for excellence in supplier engagement and accountability.

ESRS G1

G1 Business conduct Overview of disclosure requirements ESRS 2 GOV-1 – The role of the administrative, management and supervisory bodies SRS 2 IRO-1 – Description of the processes to identify and assess material impacts, risks, and opportunities

G1-1 – Business conduct policies and corporate culture G1-3 – Prevention and detection of corruption and bribery G1-4 – Incidents of corruption or bribery G1-5 – Political influence and lobbying activities G1-6 – Payment practices

ESRS S2 - Workers in the value chain

ESRS 2 GOV-1 – The role of the administrative, management and supervisory bodies

G1-1 – Business conduct policies and corporate culture

G1-2 – Management of relationships with suppliers

The board and senior management is responsible for the day to day management of Seaborn. They must ensure proper organization of the business, supervise the daily management, adopt plans, budgets and necessary guidelines. Our ethical guidelines have been approved by the board and describes how we should relate to each other and to our surroundings.

We have established our ethical guidelines, which set the framework for how we interact with each other and our surroundings. All other policies and procedures in Seaborn should be based on these principles. Seaborn chooses to collaborate with customers and suppliers who share the same values and ethical commitments.

Our shareholders are our product managers. Seaborn is engaged in production and export of farmed salmon and fjord trout. Our shareholders own 54 licenses for farming of salmon and trout in Norway. Our producers have extensive experience, expertise and tradition in farming during generations.

The document outlines the expectations for directors, officers, customers, suppliers, employees, and hired consultants acting on behalf of Seaborn. These guidelines also apply to all Seaborn subsidiaries. Our ethical guidelines are based, among other things, on the 10 principles for social responsibility published by the UN (The UN Global Compact).

Sustainability at all levels is necessary to ensure long-term value creation. Seaborn has an important position as a link between producers and consumers of seafood. This gives us the opportunity to promote a focus on sustainability at all stages of the value chain. Our ambition is to influence our customers and suppliers towards a more sustainable value chain for seafood by cooperating and setting clear requirements for all dimensions of sustainability in future agreements with them.

SRS 2 IRO-1 – Description of the processes to identify and assess material impacts, risks, and opportunities The process of identifying and assessing material climaterelated impacts, risks, and opportunities was conducted alongside the procedure outlined in IRO-1. This involved conducting in-depth interviews, as part of the double materiality assessment, to evaluate customers' perceptions of Seaborn's business conduct, and to identify related impacts, risks, and opportunities.

The etichal guideline ensure that we operate in accordance with international standards for human rights, labor conditions, environmental protection, and anti-corruption, and reflect Seaborn's commitment to responsible business practices at all levels.

ESRS S2 - Workers in the value chain

G1-3 – Prevention and detection of corruption and bribery Although we are not subject to reporting requirements under the anti-money laundering and sanctions regulations, presuant to Section 4 of the Anti-Money Laundering Act (Hvitvaskingsloven §4), it is of high importance to ensure that we have a conscious relationship with our customers. We have therefore implemented routines to prevent and address corruption and money laundering. These routines are designed to assess the risks associated with corruption and money laundering, especially considering that some of our foreign clients operate in higher-risk counties. Hence, we have established guidelines that include a zero-tolerance for corruption, ensuring all employees and customers comply with anti-corruption and anti-bribery regulations. Additionally, the company employs credit insurance for its clients and performs due diligence checks on higher-risk transactions.

Our senior management is responsible for managing risk and ensuring that anti-corruption and anti-money laundering procedures are followed. The management are tasked with ensuring that the risk assessment is applied to daily operations and reported to the board when necessary. In addition, they are tasked with keeping the risk assessment updated and reporting significant changes to the board for approval at least once every 12 (twelfth) month.

G1-4 – Incidents of corruption or bribery Furthermore, our anti-corruption guidelines and ethical policies are communicated to all employees. We ensure that every employee has read and accepted the ethical guidelines, which includes a zerotolerance policy for corruption and bribery. During the development process of our policies, the policies were discussed and control treated with the entire organization, and we work continuously with assessing and implementing plans to reduce the threat of corruption and bribery.

All sales and procurement employees at Seaborn receive training on anti-corruption, and we plan to repeat this training in 2024 to reinforce its principles. Employees involved in procurement and sales, areas at higher risk of corruption, are trained. In addition, when establishing a customer relationship and continuously throughout the relationship, we conduct a risk assessment of the customer. The risk assessment regarding money laundering and terrorist financing shall be assessed based on risk factors such as, but not limited to, the type of customer, customer relationship, product, service, or transactions. In addition, the assessment shall include geographical factors, sales and communication channels.

Seaborn must, in each case, specifically consider whether other risk factors should be evaluated.

In 2023 90% of all employees completed the annual training session. 100% of all relevant employees has red and understood the policy for anti corruption and bribery.

Zero incidents of corruption have been reported in 2023

G1-5 – Political influence and lobbying activities Seaborn has clear guidelines regarding political contributions.

Contributions given in full transparency that cannot be perceived as a means to gain influence or undue advantage are acceptable. Our employees are not allowed to make any contributions that could be linked to Seaborn being granted a license, concession, permit, or contracts from public authorities. This includes, but is not limited to, financial support, gifts, and other forms of promoting political causes or undue advantage.

Furthermore, it is expected that all our employees have read and accepted our guidelines regarding anti-corruption. All benefits, including in-kind contributions, must be given in line with transparency, and employees are expected to exercise good judgement and adhere to Seaborn’s ethical guidelines.

We do not tolerate influence peddling or any form of corruption, lobbying that should be considered illegal or undue influence is prohibited.

ESRS S2 - Workers in the value chain

Our guidelines cover the most important aspects that our employees need to be aware of regarding corruption. However, the guidelines are not exhaustive in the sense that they do not specify what is right or wrong in every situation. Should our employees be in doubt about what he or she should do, they are encouraged to raise the issue with their superiors. In case our employees suspect that actions, carried out by either customers or employees, are in violation of our policy, they must report it immediately to our compliance officers.

G1-6 – Payment practices We apply different payment terms for different customers based on their individual profiles and needs. A risk assessment is conducted for each customer at the start of the business relationship and periodically throughout the duration of the relationship. This ensures that we maintain a balanced and secure financial partnership while adapting to any changes in the customer’s circumstances or risk profile