Code of Conduct

CODE OF CONDUCT LERØY SEAFOOD GROUP ASA AND SUBSIDIARIES

Approved by the Group’s Board of Directors of Lerøy Seafood Group ASA 12. juni 2026 Last revised 12. juni 2026

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Dear colleagues at Lerøy, At Lerøy, we do not just manage a global seafood group. We also manage natural resources, jobs and a business built on trust, responsibility and a long-term vision. That comes with obligations. As a leading seafood group, we have a responsibility for how we generate results, exercise corporate social responsibility and conduct ourselves in our dealings with other parties.

Lerøy’s values – openness, honesty, responsibility and creativity – should shape everything we do.

The Code of Conduct applies to all of us and expresses our joint obligation to behave with integrity, respect and a sense of responsibility.

We shall be honest and transparent, comply with laws and regulations, safeguard human rights, help create a safe working environment and take responsibility for our impact on the environment and climate.

Lerøy is built on trust, which we must earn every single day through our actions and decisions. This makes it important for us to know our Code of Conduct and use it to help us make challenging decisions.

No Code of Conduct can give an answer to everything. If in doubt, I encourage you to seek advice, ask questions and tell someone. A strong corporate culture is created by taking responsibility – for our own actions and for the collective good.

Together, we will continue to build a Lerøy that delivers sustainable, high-quality seafood, while meeting high standards for ethics, responsibility and respect.

Thank you for helping to put our values into practice.

You are an important part of Lerøy. We are unique alone and stronger together – One Lerøy.

Henning Beltestad CEO

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Contents 1. PRINCIPLES AND COMPLIANCE..............................................................................................................................................4

1.1

Basic principles........................................................................................................................................................... 4

1.2

Scope.............................................................................................................................................................................. 4

1.3

Responsibilities and compliance........................................................................................................................... 4

1.4

Disciplinary procedures............................................................................................................................................ 4

2. PEOPLE AND THE ENVIRONMENT .........................................................................................................................................4

2.1

Health and safety........................................................................................................................................................ 4

2.2

Working environment................................................................................................................................................. 4

2.3

Human rights and decent working conditions................................................................................................... 4

2.4

Impact on local environment and community engagement ........................................................................ 5

2.5

Domestic and international environmental laws and regulations................................................................ 6

3. RESPONSIBLE BUSINESS PRACTICE..................................................................................................................................... 6

3.1

Anti-corruption activities.......................................................................................................................................... 6

3.2

Gifts, entertainment and corporate hospitality................................................................................................. 6

3.3

Expenses....................................................................................................................................................................... 6

3.4

Sanctions, anti-money laundering, export controls.......................................................................................... 6

3.5

Fair competition.......................................................................................................................................................... 6

3.6

Proper business and financial reporting.............................................................................................................. 6

3.7

Inside information and securities trading.............................................................................................................7

3.8

Conflicts of interest....................................................................................................................................................7

3.9

Political activity and debates...................................................................................................................................7

3.10 Use of social media....................................................................................................................................................7 3.11 Drug and alcohol use..................................................................................................................................................7 3.12 Ban on sexual services..............................................................................................................................................7 4. DUTY OF CONFIDENTIALITY, INFORMATION PROCESSING AND IT SYSTEMS.........................................................7

4.1

Duty of confidentiality ..............................................................................................................................................7

4.2

Information and confidentiality................................................................................................................................7

4.3

Data protection............................................................................................................................................................ 8

4.4

IT systems, logging and checking.......................................................................................................................... 8

4.5

Use of artificial intelligence (AI)............................................................................................................................. 8

5. WHISTLEBLOWING.......................................................................................................................................................................8 6. ENQUIRIES FROM THE PRESS AND OTHER PARTIES........................................................................................................8 7. THE ETHICS TEST..........................................................................................................................................................................8

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1. Principles and compliance

1.4

1.1

Any breach of LSG’s Code of Conduct or relevant statutory provisions can result in disciplinary action or dismissal.

Basic principles

Lerøy has a responsibility that goes beyond its current activities – a responsibility to shape an ethical, sustainable future that benefits society. The Code of Conduct is an expression of Lerøy’s beliefs and aims to inspire employees and business partners to take decisions that build trust, add value and ensure good principles underpin everything Lerøy does.

The Code of Conduct is Lerøy’s top-level policy document. It shall establish joint principles and ethical rules for the personal and business relationships of people in production, administrative and management roles at Lerøy Seafood Group ASA and its subsidiaries, hereafter jointly referred to as LSG. LSG respects and promotes fundamental human rights and the fundamental conventions of the ILO. LSG strives to follow the UN’s Guiding Principles on Business and Human Rights and OECD Guidelines for Multinational Enterprises. LSG is a member of the United Nations Global Compact.

1.2

Scope

The Code of Conduct applies to all parts of LSG and covers employees, Board members and contract staff (hereafter referred to “LSG Personnel”).

1.3

Responsibilities and compliance

Managers at all levels shall inform LSG Personnel of all applicable laws, regulations and regulatory frameworks, be good role models and ensure that the Code of Conduct is understood and complied with, and that tasks are performed in accordance with LSG’s requirements and standards.

LSG Personnel shall familiarise themselves with and understand the Code of Conduct. Everyone is to have a basic understanding of the requirements established by the Code of Conduct, and a particularly good understanding of the parts that are relevant to their own role and area of responsibility.

Individuals are responsible for raising questions and concerns relating to the Code of Conduct with their manager, and for being familiar with the whistleblowing channels for reporting suspected breaches.

Everyone shall recognise that business results are never more important than adhering to the Code of Conduct.

Senior management shall identify risks of breaches of the Code of Conduct and implement actions to mitigate them. In the event of any breach, the manager responsible shall act swiftly to ensure an appropriate response and proper reporting and take any necessary disciplinary action.

LSG Personnel with responsibility for suppliers and other business partners shall inform them of LSG’s Code of Conduct for Suppliers.

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Disciplinary procedures

2. People and the environment 2.1

Health and safety

LSG has a goal of zero accidents and strives actively to provide safe and healthy workplaces for LSG Personnel and other people present on LSG’s sites.

Systematic health and safety work forms an integral part of LSG’s management system. Preventive measures aim to promote a healthy working environment, avoid personal injuries and accidents, and reduce negative impacts on the environment. Health and safety work builds on continuous improvement processes in health and safety, including risk assessments and responses to nonconformities. LSG encourages open communication and the participation of all employees when developing health and safety activities.

LSG shall ensure compliance with relevant requirements set by customers, government authorities and other stakeholders.

LSG Personnel will receive regular, documented health and safety training.

Suppliers and sub-contractors performing work on LSG’s sites shall have the necessary training before performing the contracted work.

2.2

Working environment

LSG Personnel shall help to create a safe, healthy working environment based on tolerance and respect.

LSG Personnel shall conduct themselves in a socially conscious and professional manner and treat colleagues and business partners with respect.

2.3

Human rights and decent working conditions

LSG respects internationally recognised human rights and decent working conditions in its own operations and in its value chain. LSG shall comply with applicable laws and regulations, including internationally recognised conventions to uphold human rights and decent working conditions.

LSG shall support efforts to ensure human rights are respected, in particular in relation to preventing child labour and protecting labour rights, both at LSG and in its value chain, including its supply chain and business partners.

In addition to the above principles, LSG has a particular focus on the following topics relating to human rights and decent working conditions:

a. Standard employment

f. Forced labour

In accordance with international conventions, domestic laws and rules on standard employment, obligations to employees shall not be circumvented by using short-term contracts to employ e.g. contract staff, casual labourers, day labourers, subcontractors or people with other employment relationships.

There shall be no form of forced labour, slavery or involuntary labour.

All employees are entitled to an employment contract in a language they understand. The duration and nature of apprenticeships shall be clearly defined.

b. Child and youth labour LSG shall respect and support children’s rights in accordance with internationally recognised human rights and relevant domestic legislation. Child labour is unacceptable anywhere in LSG or its supply chain.

Child labour is defined as any form of work which deprives children of their childhood, potential and dignity, and which is harmful to physical and mental development. This includes work that is dangerous, harmful or interferes with children’s schooling or education.

People under the age of 15 shall not be employed or used for work, irrespective of the type of work or employment contract.

People under the age of 18 shall not perform work that endangers their health or safety, including night work.

Apprentices shall perform whatever tasks the business has at any given time and follow its working hours.

c. Wages Employee wages shall at least comply with national minimum wages or the industry standard, and always be sufficient to meet basic needs.

Wages and wage payments shall be agreed in writing before work begins.

The contract shall be comprehensible to the employee.

It is not permitted to use deductions from regular agreed wages as a disciplinary measure.

d. Working hours Arbeidstiden skal være i tråd med nasjonale lover og samsvare med gjeldende internasjonale konvensjoner.

e. Trade unions and collective bargaining Employees shall without exception be entitled to join or establish trade unions of their own choosing, as well as have the right to collective bargaining. The employer shall not discriminate against trade union representatives or prevent them from performing their trade union activities.

Employees shall not have to pay a deposit or hand over their identity papers to the employer and shall be free to terminate their employment upon giving reasonable notice.

g. Discrimination and harassment There shall be no workplace discrimination or harassment based on ethnicity, religion, age, language, disability, gender, marital status, sexual orientation, union membership or political beliefs.

Measures shall be taken to prevent sexually aggressive, intimidating, abusive or exploitative conduct, discrimination and unfair dismissal.

h. Violent treatment Physical abuse or punishment, or threats of physical abuse, are forbidden. The same applies to sexual abuse and other forms of abuse or humiliation.

i. . Equal opportunity and diversity At LSG, diversity and inclusion entail a commitment to ensuring that every employee is treated with equal respect and fairness, regardless of sex, background, ethnicity, language, sexual orientation, gender identity, religion or beliefs.

2.4

Impact on local environment and community engagement

LSG shall make a positive contribution to maintaining a good environment for the local communities where LSG operates. The local environment and production site shall be protected against harmful pollution.

LSG shall take a transparent and inclusive approach to engaging with local communities associated with LSG’s operations and value chain.

All forms of environmental crime or inconsiderate exploitation of local natural resources is strictly forbidden.

LSG shall neither directly nor indirectly undermine the livelihoods of marginalised communities, for example by occupying large sites or other natural resources on which these communities depend.

Chemicals and other hazardous substances shall be handled safely. The production and use of raw materials for production shall not cause the destruction of natural resources.

If these rights are limited by law, the employer shall facilitate, and under no circumstance obstruct, parallel mechanisms for free and independent association and negotiation.

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2.5

Domestic and international environmental laws and regulations

Production activities shall not contravene domestic or international environmental laws and regulations. The relevant permits shall be obtained where necessary.

Environmental issues shall be taken into consideration throughout the production and distribution chain, from raw material extraction through to sales, and not just in LSG’s own operations. The aim shall be to include local, regional and global environmental issues.

When making animal products, animal ethics shall be taken into account throughout the value chain.

3. Responsible business practice 3.1

Anti-corruption activities

LSG has zero tolerance for corruption of any kind, including bribes and facilitation payments, and complies with applicable domestic and international anticorruption laws. Facilitation payments are unofficial payments made to obtain or speed up routine services provided by the authorities.

LSG will take active steps to ensure that corruption does not occur in conjunction with LSG’s business operations.

It shall run its operations openly and transparently, with the aim of promoting openness in the industry and supporting efforts to combat corruption.

LSG Personnel must never engage in, approve or tolerate corruption or offer any party anything of value in order to achieve an unfair advantage in connection with LSG’s business operations.

Particular caution shall be exercised when making payments through intermediaries, including agents, brokers or other third parties. The contractual arrangements shall be documented and reported to a manager.

3.2

Gifts, entertainment and corporate hospitality

LSG Personnel shall neither offer nor accept gifts, benefits or entertainment that might compromise, or appear to compromise, the recipient’s integrity or business decisions.

Symbolic gifts of low value (promotional items, flowers, gifts in connection with anniversaries or special occasions) may be exchanged within the bounds of what is customary and appropriate.

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3.3

Expenses

LSG Personnel shall be cost conscious and avoid incurring unnecessary expenses for LSG, including in connection with travel and entertainment.

3.4

Sanctions, anti-money laundering, export controls

LSG shall comply with applicable rules on exports, imports, sanctions, export controls and anti-money laundering in all of the countries where it operates. This includes the sanctions programmes of the UN, EU, UK, USA (OFAC) and Norway.

LSG does not sign agreements or undertake transactions with people, entities or jurisdictions that are subject to relevant sanctions. Customers, suppliers and business partners shall be screened against up-to-date sanctions and restriction lists.

As part of its anti-money laundering efforts, LSG shall have sufficient knowledge about its counterparties (“know your customer”) and document that relevant checks have been made. LSG Personnel with responsibility for customers, suppliers or transactions shall receive regular training on sanctions, anti-money laundering and export controls.

3.5

Fair competition

LSG shall compete in a fair and ethical manner within the framework of prevailing competition law in the markets where it operates.

LSG shall not engage in, or tolerate others engaging in, anti-competitive behaviour in the markets for LSG’s products, such as illegal price-fixing and bid-rigging, market allocation or misuse of market power.

Amongst other things, this means that LSG shall neither enter into agreements or understandings with competitors on prices, margins, volumes, capacities, customers, bids or geographical markets, nor exchange commercially sensitive information about such matters.

Nevertheless, this does not prevent LSG from cooperating with other entities where this is consistent with competition law, for example on procurement, technology or operational matters, provided that this cooperation complies with relevant regulations and internal guidelines.

3.6

Proper business and financial reporting

Corporate hospitality shall have a clear business purpose, be moderate and not seem inappropriate in its frequency or value.

All information issued by LSG about its business shall be accurate, complete and verifiable. Accounting, reporting and other forms of information dissemination shall comply with applicable laws, regulations and relevant standards, including those which follow from being listed on a stock exchange.

Particularly strict rules apply to contact with government authorities, public servants and people in a position to influence licensing, supervisory or procurement processes. In such cases, prior approval is required from a manager.

Periodic financial reporting and other external communications shall be complete, clear, accurate and comprehensible. LSG Personnel shall not omit, distort or delay information which may be relevant to proper reporting or to LSG’s compliance with stock exchange

and securities trading legislation. LSG shall be a responsible, transparent taxpayer in all of the countries where it operates. LSG pays tax in accordance with applicable laws and regulations, and in accordance with the spirit of the rules.

LSG’s global tax policy has been adopted by the Group Management and Board of Directors. All employees involved in tax-related processes shall be familiar with and comply with this Code of Conduct.

3.7 Inside information and securities trading As a listed company, LSG has a duty to follow relevant stock exchange regulations and Securities Trading Act. No one shall use, or help others to use, sensitive or confidential information about LSG or other companies to trade securities – neither in a personal capacity nor on behalf of LSG. If in doubt, contact your manager.

3.8

Conflicts of interest

LSG shall respect the right of individuals to privacy and personal interests. LSG Personnel are expected to be loyal to LSG and its interests.

LSG Personnel shall avoid financial and business dealings that could create a conflict of interest between LSG’s interests and their own interests or those of their related parties. Related parties include the person’s partner, close relatives and other people with whom they have a close relationship. The same applies to other circumstances that could undermine trust in the ability of the individual to safeguard LSG’s interests in a loyal and independent manner. Potential conflicts of interest shall be reported to a manager.

Full-time employees shall have their role at LSG as their main job. Personal business activities, directorships and other roles of some significance shall be disclosed to the employer in advance.

Organisational structures and reporting lines shall be designed to avoid role conflicts. This is particularly relevant where there is a close personal relationship between LSG Personnel.

3.9

Political activity and debates

LSG does not support individual political parties or individual politicians. LSG can participate in the public debate where this is in the interests of LSG. LSG Personnel are free to participate in democratic political activity, provided that such activities are not associated with their role at LSG. LSG Personnel who represent LSG at debates or similar events shall obtain the prior approval of the CEO or another representative of the Group Management.

3.10 Use of social media LSG Personnel shall be mindful of how they conduct themselves on social media, both in a personal capacity and on behalf of their employer through official Lerøy

accounts. Social media refers to websites and apps such as Facebook, TikTok, LinkedIn and Instagram. Official Lerøy accounts refers to any account operated in the name of a company in the group or one of LSG’s brands.

LSG Personnel shall conduct themselves with care and uphold LSG’s values, as well as respect their duty of confidentiality and loyalty. Content from e.g. careers or trade fairs and operational activities is to be cleared with a manager prior to publishing.

Some employees have roles that link them more closely to LSG, e.g. through a particular area of responsibility or a high media profile. Those people shall be particularly mindful of their own conduct in personal accounts, even in matters not directly related to LSG.

3.11 Drug and alcohol use LSG operates a drug- and alcohol-free workplace. We do not accept anyone being under the influence of drugs or alcohol when working for LSG. In connection with entertainment and at events outside working hours, moderate alcohol consumption is permitted. This shall always be done responsibly, without pressure and in a manner consistent with LSG’s values, security requirements, professionalism and upholding LSG’s reputation.

3.12 Ban on sexual services LSG considers any actions that involve the purchase, arrangement or acceptance of sexual services unacceptable.

When at work, on business travel or engaged in other activities for LSG, LSG Personnel shall refrain from such conduct.

4.

Duty of confidentiality, information processing and IT systems

4.1

Duty of confidentiality

LSG Personnel have a duty to keep confidential any information of a sensitive or confidential nature about LSG, customers, suppliers or business partners. The duty of confidentiality applies both during and after their term of employment.

4.2

Information and confidentiality

Information is a valuable asset to LSG, and its confidentiality, integrity and accessibility shall be protected.

Sensitive and confidential information shall be handled responsibly, stored securely and processed in accordance with current legislation and LSG’s guidelines, including its security procedures.

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Information that people gain access to through their work shall not be used for their personal gain or that of other people.

4.3

Data protection

Data protection regulations shall protect the personal information of individuals. LSG undertakes to process personal data in accordance with current legislation and only for reasonable and necessary purposes.

LSG Personnel shall familiarise themselves with and comply with requirements governing the processing of personal data in their work.

4.4

IT systems, logging and checking

LSG’s IT systems shall be used for business purposes.

Limited personal use is permitted, but only if it does not have a negative impact on costs, information security or productivity. All use of IT systems and data shall adhere to current regulations and internal requirements.

LSG Personnel have a duty to report any discrimination or harassment towards colleagues, as well as any circumstances which could pose a danger to human life or human health.

Whistleblower reports can be sent with a full name or anonymously and should preferably be submitted through LSG’s whistleblower portal in Lerøy Connect.

They can also be sent to an immediate line manager, the captain of the vessel, HR, a safety representative, union representative or Group Management. All whistleblower reports are recorded and investigated. See LSG’s whistleblowing poster for further information.

Whistleblowers are protected against retaliation.

Retaliation refers to any unfavourable action, practice or omission which is a result of, or a reaction to, the employee whistleblowing.

Stakeholders and other external parties can report issues of concern through the whistleblowing portal on LSG’s website.

LSG Personnel shall only use approved systems and software, shall protect their user accounts and shall not share passwords or circumvent security measures.

6.

Systems shall not be used for illegal or unethical activities. Copyright and licensing terms shall be respected.

Enquiries from financial analysts and investors shall be addressed to LSG’s CEO, CFO or IR officer.

Cyberattacks and other malicious activities constitute a genuine threat. LSG Personnel shall be vigilant about this and report any incidents without undue delay.

Enquiries from the media shall be forwarded to LSG’s Head of Communication and Public Affairs.

Use of LSG’s systems and equipment may be logged and monitored in order to protect the business, manage security incidents and ensure compliance with rules.

7.

In the event of suspicion of serious breaches of LSG’s Code of Conduct, security procedures or statutory requirements, LSG may access systems, logs or stored information in order to conduct checks. This shall only be done when it is objectively justified, necessary and proportionate, and as permitted by the relevant legislation.

4.5

1.

LSG Personnel who become aware of, or suspect, any breach of legislation, this Code of Conduct or internal rules are encouraged to report them, so that any issues of concern can be investigated, dealt with and prevented from recurring in an appropriate manner.

Is it legal?

– Am I breaking any laws or am I contravening LSG’s Code of Conduct?

2.

Is it ethical?

– Could I tell a colleague about it?

– Is it reasonable towards the affected parties?

– What might the consequences be?

Contents produced by AI tools must be critically reviewed before being used as a basis for decisionmaking or external communication.

5. Whistleblowing

The ethics test

Ethical dilemmas may arise during day-to-day work. If in doubt as to whether a decision or action aligns with LSG’s Code of Conduct, the ethics test can be used.

If it is still unclear, the matter should be raised with a manager.

Use of artificial intelligence (AI)

LSG Personnel shall use AI tools responsibly and in accordance with LSG’s AI guidelines and security procedures. Business-sensitive information shall not be entered into public or external AI tools without prior approval.

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Enquiries from the press and other parties

– Is there a better alternative?

3.

Is it defensible?

– Would it put LSG’s reputation at risk if the matter were made public?

– How would I feel if the decision was made public through the media?

– Do I feel good about this, and can I be proud of it?

Lerøy Seafood Group ASA

Thormøhlens gate 51 B N - 5006 Bergen leroyseafood.com Lerøy Seafood Group ASA

Thormøhlens gate 51 B N - 5006 Bergen leroyseafood.com