TheNorwegianTransparencyAct by Fjord Line AS

THE NORWEGIAN TRANSPARENCY ACT

Fjord Line is required to conduct annual due diligence assessments in accordance with the Transparency Act and publish a report on these assessments. The purpose of the Transparency Act is to promote companies' respect for fundamental human rights and decent working conditions. This report includes Fjord Line’s account of the due diligence assessments we conducted in 2023.

The report applies to Fjord Line AS, Fjord Lines parent company and Fjord Lines subsidiaries ("Fjord Line"); see the appendix on page 7 for an overview of which companies are included.

Fjord Line’s headquarter is located at Elganeveien 1 in Egersund, and the company is based in Norway. Several of the Fjord Line companies are subject to reporting requirements, but they are included in the due diligence assessments to ensure a comprehensive evaluation. Only Fjord Line AS and Fjord Line Denmark AS/ are operating companies with employees; the remaining companies are primarily ship owning companies with limited activity and few suppliers.

Inquiries about this report can be directed to: transparency@fjordline.com

INTRODUCTION ABOUT FJORD LINE

Fjord Line is a limited liability company owned indirectly by Ferd AS, Kontrari AS and West Coast Invest AS.

Fjord Line operates the cruise-ferry vessels MV Bergensfjord and MV Stavangerfjord, sailing between Bergen, Stavanger, Hirtshals, and Kristiansand, and the newly built HSC Fjord FSTR sailing between Kristiansand and Hirtshals. All vessels fly the Danish flag. Until October 2023 Fjord Line also operated the vessel MV Oslofjord between Sandefjord and Strömstad. MV Oslofjord was sold in May 2024.

Fjord Line's 650 employees transported 1.2 million passengers and 30,000 freight units in 2023. Fjord Line is headquartered in Egersund with offices in Hirtshals, Bergen, Stavanger, and Kristiansand.

Being a link between Norway and Europe has always been important throughout Fjord Line’s history. We are proud of the role Fjord Line plays in society by providing services between coastal communities and in connecting Norway and Continental Europe.

Stavanger Bergen

Langesund

Hirtshals

Kristiansand

Strømstad

Sandefjord

Oslo

Stavangerfjord

HSC Fjord FSTR

MV Oslofjord

4 VESSELS – 5 ROUTES

BERGEN–STAVANGER

STAVANGER–HIRTSHALS

HIRTSHALS–KRISTIANSAND

KRISTIANSAND–HIRTSHALS

SANDEFJORD–STRØMSTAD

30min

CODE OF CONDUCT

Our code of conduct, which is subject for regular reviews by the board of directors, is founded on human rights as well as the value of diversity and inclusion. It sets out the standards defining how we operate every day and everywhere. The code of conduct governs our relationships with clients, suppliers, stakeholders and each other. It requires all employees to adhere to the highest levels of professional conduct and underpins the reputation and trust Fjord Line commands. Whistleblower policy and a whistleblower channel for reporting any breach of our codes of conduct are in place and available for all employees. Whistleblowers are protected through this policy to ensure that there are no hindrances or risks to filing a report. The reports are to be investigated promptly and thoroughly.

ANTI-CORRUPTION

Fjord Line has anti-corruption policy in place. Corruption is a risk especially related to large procurements. We reduce this risk for corruption through our procurement policy that calls for tender processes for large purchases and an approval process that ensures that all such purchases are evaluated objectively and by several people. The whistleblower function is open for reports on suspected corruption related to procurement or otherwise.

SUPPLIER CODE OF CONDUCT

Fjord Line has over 1200 suppliers and business partners with our supply chain organization supporting all facets of our business both on-board and land-based operations. We recognize that our impact extends beyond our own company and that we can impact sustainability topics through our supplier selection and management. Therefore, in 2021 we launched our supplier code of conduct to govern our relationship with our suppliers to ensure that our suppliers operate with high business operational standards & practices based on strong commitment towards sustainability, high business ethical standards, and human rights. We aim for the suppler code of conduct to be adhered to and signed by all of our suppliers and if not adhered to that the supplier demonstrates their own code of conduct based on the same values as ours.

THE NORWEGIAN TRANSPARENCY ACT

The Norwegian Transparency Act went into effect in Norway on the 1st of July 2022 and aim promote enterprises’ respect for fundamental human rights and decent working conditions in connection with the production of goods and the provision of services and ensure the general public access to information regarding how enterprises address adverse impacts on fundamental human rights and decent working conditions.

1: Due diligence process & supporting measures

COMMUNICATE HOW IMPACTS ARE ADDRESSED

IMPLEMENTATION AND RESULTS IDENTIFY & ASSESS ADVERSE IMPACTS IN OPERATIONS, SUPPLY CHAINS & BUSINESS RELATIONSHIPS

FOR OR COOPERATE IN REMEDIATION WHEN APPROPRIATE

Figure

RISK ASSESSMENT PROCESS

The purpose of the act is well aligned with our long-term focus at Fjord Line and part of how we conduct business. We have a formalized process for classification and risk assessment of our suppliers and business partners to address adverse impacts on fundamental human rights and decent working conditions. The due diligence process is carried out in accordance with the OECD guidelines for Multinational Enterprises in accordance with §4 in the

Norwegian transparency act. The assessment evaluates both the direct relationships and the underlying supply chain. From the starting block our assessments are based on a desktop approach based on publicly available information as well as our direct knowledge based on our former relationships, and we are further developing the process to include questionnaires, interviews etc.

We are evaluating each supplier or business partner in up to seven different categories.

To secure data for the assessment the following databases are incorporated in the evaluation tool:

• Number of transactions: Received number of invoices

• Product risk: High-risk list defined at dfo.no

• Human rights: ITUC-CSI 2022 defined at globalrigthsindex.org

• Decent work conditions: CLR defined at labourrightsindex.org

RISK ASSESSMENT

All business partners are subject to an individual relation classification. Depending on the classification of each business partner the assessment will be conducted at different levels as defined below:

* Business partner that supplies goods that are

and onshore

** Business partner that supplies indirect services e.g. banking, insurance

*** Business partner that are related to State & Government

The risk assessments are conducted by the Procurement Department, and the resulting risk is subject to a classification as; Low, Medium Low, Medium High, High.

Figure 2: Fjord Line assessment model

Figure 3: Fjord Line supplier collaboration level

IDENTIFIED RISKS

The following areas have been identified as potential risks within our operations and supply chain:

1. Human Rights Violations:

• Risk of forced labor, child labor, and other forms of exploitation among subcontractors, particularly in high-risk countries.

• Inadequate working conditions, including unsafe work environments and lack of proper health and safety measures.

2. Labor Rights Violations:

• Non-compliance with local labor laws, including unfair wages, excessive working hours, and denial of the right to unionize.

• Subcontractors failing to provide employment contracts and necessary benefits to their employees.

3. Environmental Impact:

• Practices that lead to environmental degradation, such as improper waste disposal and pollution.

• Use of non-sustainable materials and methods in operations.

4. Ethical Business Conduct:

• Corruption, bribery, and unethical practices within the supply chain.

• Lack of transparency and accountability among subcontractors.

Out of our 1226 suppliers 93 have been classified as medium high and high risk in 2023. With a few exceptions all suppliers are based in Scandinavia or Europe.

RISK MITIGATING MEASURES

If the risk related to a supplier is assessed to be at an undesirable level, we assess how we can influence the risk level in a positive manner, either through direct interaction, or by investigating other methods such as change of specifications or sourcing. We also mitigate risk through strengthening supplier agreements including inter alia supplier code of conduct.

Business partners classified as High or Medium High will be subject to further actions, with primary focus on those clasified as High. First, we will evaluate if further actions can reduce the preliminary risk assessment. If the risk level still is at an undesirable level, we will assess how we can influence the risk level in a positive manner, either through direct interaction, or by investigating other methods such as change of specifications or sourcing.

The due diligence process and working with supporting measures is a continuous process to ensure that we properly address potential adverse impacts on fundamental human rights and decent working conditions.

We have initiated risk mitigating measures towards seveal suppliers and are continously assessing and evaluating our business partnes. No adverse impacts of Human Rights or Decent Working Conditions have been identified in the reporting year of 2023.

Egersund, 28 June 2024