The Norwegian Transparency Act
1. Fjord Line's report pursuant to the Transparency Act 2025
1.1 INTRODUCTION
This statement has been prepared in accordance with the requirements of Section 5 of the Norwegian Transparency Act concerning enterprises’ transparency and work on fundamental human rights and decent working conditions ("the Transparency Act").
Fjord Line AS is a limited liability company owned indirectly by Kontrari AS and West Coast Invest Holding II AS. The company is a large enterprise with headquarters at Elganeveien 1, 4373 Egersund in Norway and with offices in Hirtshals, Bergen, Stavanger, and Kristiansand. Fjord Line provides services both within and outside of Norway. The provisions of the Transparency Act apply to Fjord Line. In line with the requirements of the Transparency Act, and based on the OECD Guidelines for Multinational Enterprises and the OECD Due Diligence Guidance for Responsible Business Conduct, Fjord Line conducts due diligence assessments to identify actual and potential adverse impacts on fundamental human rights and decent working conditions.
Although Fjord Line AS is the reporting entity, this statement also includes information relating to its parent company and subsidiaries. These entities are referred to collectively as “Fjord Line”. Please see the appendix on page 15 for an overview of which companies are included. The statement encompasses Fjord Line´s own operations, suppliers, and business partners (referred to as suppliers hereafter). The statement covers the period from January 2025 to December 2025. The statement is based on information collected from our own operations, information from suppliers, and recognized publicly available sources.
The statement has been approved and signed by the members of the board of directors and the group CEO of Fjord Line AS. The statement will be available on our website and will be updated on an ongoing basis if there are significant changes to Fjord Line’s risk assessments. A reference to the statement is also included in our 2025 annual report.
1.2 CONTACT INFORMATION
Any inquiries in connection with this report can be directed to: transparency@fjordline.com
In line with the requirements of the Transparency Act, and based on the OECD Guidelines for Multinational Enterprises and the OECD Due Diligence Guidance for Responsible Business Conduct, Fjord Line conducts due diligence assessments to identify actual and potential adverse impacts on fundamental human rights and decent working conditions.
1.3 DUTY TO ACCOUNT FOR THE DUE DILIGENCE
Fjord Line AS is subject to reporting requirements under the Transparency Act. All group companies are however included in the due diligence assessments to ensure a comprehensive evaluation. Only Fjord Line AS and Fjord Line Denmark A/S are operating companies with employees.
We operate the cruise-ferry vessels MV Bergensfjord and MV Stavangerfjord, sailing between Bergen, Stavanger, Hirtshals, and Kristiansand, and HSC Fjord FSTR sailing between Kristiansand and Hirtshals. All vessels fly the Danish flag (DIS).
Our 649 employees transported 948.200 passengers and 54.400 freight units between Norway and Denmark in 2025. Being a link between Norway and Europe has always been important throughout our history. We are proud of the role we play in society by providing services between coastal communities and in connecting Norway and Continental Europe.
2. About our operations
2.1 OUR ORGANISATION AND AREA OF OPERATIONS
We are organised as a Group with Fjord Line Holding AS as parent company, Fjord Line AS as commercial operating entity, Fjord Line Denmark A/S as shipping company and Danish subsidiaries as vessel owning companies. Organisational chart for the group is attached to this report.
As the second largest cruise ferry company in Norway, we provide passenger and freight transport services between Norway and Denmark. We operate a modern fleet of vessels powered by more sustainable fuel alternatives, including LNG (liquefied natural gas), and are committed to reducing emissions and promoting green maritime transport.
We place a strong focus on safe and decent working conditions, fair labor practices, and environmental performance. As a company with complex maritime and international supply chains, we are aware of the potential risks associated with procurement and subcontracting, particularly in areas involving manufacturing, shipbuilding, textiles, food and beverage supply, and technology. We have implemented a due diligence framework aligned with the Transparency Act, including supplier screening, risk prioritization, and preventive and corrective measures.
Our commitment to responsible business conduct is reflected in our sustainability policy, supplier code of conduct, and engagement with stakeholders to promote respect for human rights and decent labor standards throughout its operations and supply chain.
2.2 CODE OF CONDUCT
We have established internal procedures for embedding respect for human rights and decent working conditions, in line with and anchored in our Code of Conduct. The Code of Conduct was revised and formally adopted by our Board of Directors on 30 April 2025. It has been communicated to all employees and is readily accessible via our intranet.
The Code of Conduct also contains information about our whistleblowing channels that are meant to uncover adverse impact on fundamental human rights and decent working conditions linked with our activities.
We also have a separate Supplier Code of Conduct which defines our minimum requirements for suppliers in areas including fundamental human rights, workers' rights, health and safety, and the environment. It is based on the same principles as the internal Code of Conduct and serves as the reference point for our expectations of suppliers and for the follow-up work described in this statement.
The Supplier Code of Conduct is communicated to suppliers during the onboarding process and – to the extent reasonably achievable - referenced in relevant commercial agreements.
We place a strong focus on safe and decent working conditions, fair labor practices, and environmental performance.
2.3
AMBITIONS AND PROGRESS
2.3.1 Overall ambitions and progress
We work continuously to implement measures to achieve our ambitions relating to the identification, assessment and mitigation of risks associated with our activities, and to engage suppliers and business partners in these efforts. See items 3 and 4 of the report for guidance on the work done in the reporting year.
2.3.2 Ambitions for the coming year
We have set several concrete ambitions for the future. For instance, there is an ongoing effort to further improve our due diligence process for key suppliers. Furthermore, we are aiming to obtain signed Supplier Codes of Conduct from all key suppliers. We aim for exceptions to be made only if a supplier presents an equivalent and satisfactory Code of Conduct that we can rely on.
3. The due diligence
3.1 FOCUS FOR OUR DUE DILIGENCE
In line with the requirements of the Transparency Act, we conduct due diligence assessments based on the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct and the OECD Due Diligence Guidance for Responsible Business Conduct. As illustrated below, our due diligence process follows the OECD’s risk-based due diligence framework, which provides a structured approach to identifying, assessing, preventing, mitigating and accounting for actual and potential adverse impacts on human rights and decent working conditions throughout the company’s operations, supply chain and business relationships.
The practical implementation of this framework is supported by a digital platform developed by Ignite Procurement AS (hereafter referred to as the “platform”), which enables the systematic mapping, risk assessment and follow-up of suppliers, business partners and other known subcontractors.
We continuously make assessments of the risk of adverse impact on fundamental human rights and decent working conditions linked with our activities and business relationships, hereunder we track any violations of human rights or violations of decent working conditions that are connected with our activities. Our activity refers to both our own operations and the activities of our suppliers and business partners.
Through the platform, we have obtained a systematic overview of first-tier suppliers, business partners, and other known subcontractors. Based on this overview, the platform has conducted initial assessments of the risk of negative impact on fundamental human rights and decent working conditions. The steps in this assessment are explained in the following:
1. Based on supplier data obtained from our ERP system, a complete overview of our first- tier suppliers is created. We have manually added business partners and other known subcontractors in the platform. The overview of our first-tier suppliers is continuously updated through the platform.
2. In the platform, supplier information is enriched through thirdparty collaborations. The platform gathers information and financial details about the our suppliers, such as industry codes (NACE) and company structure.
Through the platform, we have obtained a systematic overview of first-tier suppliers, business partners, and other known subcontractors.
3. Through steps 1 and 2, we obtain an overview of firsttier suppliers, business partners, and other known subcontractors, along with their corresponding supplier information.
4. The classification tool in the platform has conducted an initial risk classification of our first-tier suppliers, business partners, and other known subcontractors based on classification rules created within the platform. In the platform tool the classification rules are as follows: industry risk, social risk and geography risk. In addition, we have included acceptance of our Supplier code of conduct as a parameter for our assessment. Through the classification tool, suppliers that meet defined risk parameters are classified as having high, medium, or low risk of negative impact on fundamental human rights and decent working conditions.
5. Manual assessments and evaluations are conducted for suppliers which are considered high risk. We can also use the platform to request documentation and certifications from first- tier suppliers, business partners, and other known subcontractors. This procedure is in the process of being implemented.
6. Based on the findings in points 4 and 5, we have assessed which actions should be taken to investigate potential negative consequences for fundamental human rights and decent working conditions. The prioritization is aligned with our connection to and responsibility for the risk and should be proportionate to the size, nature, and context of the business.
7. We have involved stakeholders, suppliers, and business partners in the implementation of actions.
In the analysis tool within the platform (interactive dashboard), analyses of the supply chain have been developed based on supplier data, the outcome of risk classification, and gathered information from the supply chain. In section 3.3, the following information generated by the analysis tool in the platform is provided:
a. The number of first-tier suppliers, business partners, and other known subcontractors.
b. Further classification of our first-tier suppliers, business partners, and other known subcontractors based on risk profiles high, medium, and low.
Relevant factors for the due diligence related to our activities and business conditions include, among other things:
• The context of the company’s operations
• The company's business model
• The company’s position in the supply chain
• The type of product and services
We have in 2025 not identified any significant risk of adverse impact on human rights or decent working conditions nor uncovered violations of human rights or decent working conditions through our due diligence assessments.
3.2 THE DUE DILIGENCE ASSESSMENTS OF OUR OWN OPERATIONS
During the reporting period, we continued to strengthen our efforts to prevent and address harassment and other unacceptable conduct, both internally and in interactions with customers. Initiatives included promoting a speak-up culture, enhancing reporting mechanisms, and conducting targeted training programmes across different parts of the organisation. Increased awareness and reporting have contributed to the identification of cases requiring followup. In certain instances, investigations have resulted in disciplinary measures, including termination of employment, while other cases have been addressed through corrective actions in accordance with company policies. No cases were reported through our formal whistleblowing channel in 2025.
3.3 SUPPLY CHAIN AND BUSINESS PARTNERS
We have commercial relationships with 994 direct suppliers and business partners in the reporting year. Our suppliers are located in the following country/geographic area:
The classification tool in the platform displays the following classification of our first-tier suppliers, business partners, and other known subcontractors:
i. 994 suppliers evaluated based on Country, VAT ID & NACE.
a. Majority of suppliers evaluated through the platform, remaining manually by the procurement department.
ii. 0 suppliers were ultimately classified as High Risk following manual review and risk calibration carried out by our procurement department.
iii. 379 suppliers as Medium risk.
iv. 615 suppliers as Low risk.
We have in 2025 actively sought to limit the number of suppliers in order to ensure thorough and meaningful quality assurance and follow-up of our suppliers. By maintaining a manageable supplier base, we are better able to conduct effective evaluations, monitor compliance, and maintain close dialogue with suppliers regarding quality, sustainability, HSE, and other compliance requirements.
3.4 THE RESULT OF OUR DUE DILIGENCE ASSESSMENT
We operate a complex supply chain encompassing multiple industries and tiers. While many of our direct suppliers are based in regions traditionally considered low-risk—such as the Nordics, Western Europe, and Central Europe—potential risks emerge further down the value chain. These risks primarily relate to sub-suppliers and raw material producers, especially in sectors historically associated with labor rights and human rights challenges.
Identified Risk Areas:
• Fuel: The global fuel supply chain presents several inherent risks related to labor rights and human rights. These risks stem from the geographical complexity of the industry, the nature of extraction and refining processes, and the regulatory environments in which any suppliers operate.
• Food and Beverage Products: Raw materials like coffee, tea, cocoa, fruit, and sugar carry known risks of forced labor, child labor, and inadequate health and safety standards at the production level.
• IT Equipment: Manufacturing in certain Asian countries raises concerns about labor conditions, including low wages, excessive overtime, misuse of student labor, and limited union rights.
• Furniture: Component production in parts of Asia and Eastern/ Southern Europe may involve child labor, forced labor, and poor working conditions. Union suppression, low pay, and unpaid overtime are additional concerns.
• Office Supplies: Products such as pens, staplers, paper goods, and disposable items have been identified as high-risk categories for potential human rights violations throughout their life cycle.
• Textiles: Items like uniforms, bedding, towels, and interior fabrics can pose risks across various production levels—from assembly to raw material sourcing—including child labor and serious safety and health deficiencies. Risks also extend to laundry and maintenance services.
• Tobacco Products: Items such as cigarettes and snus carry known risks at the agricultural level, including child labor, low wages, and inadequate safety conditions.
• Maritime-Related Goods and Services: Shipbuilding and related services, particularly at certain shipyards, present significant risks due to the potentially severe consequences of poor occupational health and safety standards.
4. Measures to cease, prevent or mitigate the adverse impact
We are committed to addressing these risks through our due diligence process:
• Supplier Engagement: We actively gather information from suppliers based on risk assessments and will engage in dialogue to address identified issues. We also assess suppliers' own transparency reporting, where available.
• Origin: We encourage all suppliers to adhere to our Supplier Code of Conduct. Where suppliers have their own code of conduct, we assess whether it reflects equivalent principles and standards. We also encourage suppliers to promote similar standards throughout their supply chains.
• Code of Conduct: Acceptance of Fjord Line’s Supplier Code of Conduct is required for all suppliers (exceptions are primarily made for suppliers with their own code of conduct which is satisfactory), requiring them to ensure equivalent standards among their sub-suppliers.
• Centralized Procurement: Our procurement department has standardized purchasing processes to enhance oversight.
• Whistleblower Mechanism: We have an external whistleblower channel in collaboration with a legal firm, allowing for confidential reporting of concerns about unethical conduct or breaches of applicable requirements. Reports received through whistleblowing channels are handled in accordance with applicable law and the company's internal procedures.
• Internal Initiatives: We continue to focus on equality and diversity within our organization, utilizing system tools to monitor and promote a safe and inclusive work environment.
• Stakeholder Engagement: Regular dialogues with organizations and stakeholders are conducted as part of our sustainability efforts.
Through these measures, we strive to uphold and strengthen our commitment to human rights and decent working conditions across our supply chain, aligning with the principles of the Transparency Act.
We strive to uphold and strengthen our commitment to human rights and decent working conditions across our supply chain.
5. Communication with affected stakeholders and rights-holders
Apart from the matters described in section 3.2 above, we have not uncovered any violations of human rights or decent working conditions in the reporting year. Nor have we uncovered any significant risk of violations as mentioned.
6. Remediation and compensation
We have not identified any cases requiring remediation or compensation measures beyond the corrective actions described in section 3.2.
Egersund, 22.06.2026
Fjord Line AS
Peter Frølich Chairman
Heidi Nag Flikka Group CEO
Jan Erik Sivertsen Board member
Anne Renate Hægeland Board member
Dag Magne Vedvik Board member
Stine Betten Neteland Board member
Appendix
Fjord Line AS is the reporting entity. The scope of this report includes the following companies:
• Fjord Line AS
• Fjord Line Holding AS
• Fjord Line Denmark AS
• Hirtshals LNG A/S
• Fjord Line Holding I AS
• Fjord Skibsholding III AS
• Fjord Skibsholding IV AS
• Fjord Skibsholding V AS
FJORD LINE HOLDING AS Elganeveien 1, 4373 Egersund, Norway Org. nr. 928 026 329
Fjord Skibsholding III AS Dalsagervej 9, 9850 Hirtshals, Denmark Org. nr. 33040644
Fjord Skibsholding I AS Dalsagervej 9, 9850 Hirtshals, Denmark Org. nr. 30826434
Fjord Line Danmark AS Dalsagervej 9, 9850 Hirtshals, Denmark Org. nr. 28870515
Fjord Skibsholding IV AS Dalsagervej 9, 9850 Hirtshals, Denmark Org. nr. 33040695
Fjord Skibsholding V AS Dalsagervej 9, 9850 Hirtshals, Denmark Org. nr. 38594877
Hirtshals LNG AS Dalsagervej 9, 9850 Hirtshals, Denmark Org. nr. 35643265
FJORD LINE AS Elganeveien 1, 4373 Egersund, Norway Org. nr. 910 310 895
