Social Sustainability

Seaborn has a long tradition of focusing on human rights and decent working conditions, which is well anchored in our procedures and guidelines. The adoption of the new Norwegian Transparency Act fortifies the pre-existing notion – that our corporate entity is responsible for safeguarding human rights, both within and beyond our value chain. Seaborn works actively to achieve the UN's sustainability target 8.7- Take immediate and effective measurestoeradicateforcedlabour,endmodernslavery and human trafficking and secure the prohibition and elimination of the worst forms of child labour, including recruitment and use of child soldiers, and by 2025 end child labour in all its forms. In addition to having carried out a due diligence assessment in accordance with OECDs guidelines for responsible business, we have also drawn up ethical guidelines (Code of Conduct) based on the 10 basic principles for social responsibility published bytheUnitedNations(The10 principles oftheUNGlobal Compact, UN Global Compact). The ethical guidelines describe what we expect and require of our employees, directors, and officers, as well as hired consultants acting on behalf of Seaborn. The guidelines are presented on page 15, and all employees have confirmed that they have been read understood and accepted.

To ensure that our ethical vision isalso adhered toby our suppliers, Seaborn has created a separate code of conduct that is distributed to all our suppliers, see page 15 About 95% of all suppliers of fish and transport have accepted these ethical guidelines. Protocols for endorsing novel suppliers have been defined and adapted. These include an inventory of criteria to assess the risks associated with the supplier’s activities and the prerequisite that our ethical standards are comprehended and assented to. The checklist with associated documentation must be fulfilled prior to integrating a supplier into our value chain our fish farmers and processors are certified under GlobalG.A.P (Good Agricultural Practices), GRASP (GlobalG.A.P Risk assessment on Social practice), ASC (Aquaculture Stewardship Council) or DEBIO (organic salmon and trout) ensuring that our subcontractors also comply with human rights. Seaborn works to ensure that the number of certified fish suppliers moves towards 100%, and when assessing new suppliers, preference is given to those who are already certified. This also applies our VAP (Value Added Products) suppliers, where the majority are located in Norway, but also in Iceland, Poland, the Netherlands, and Spain

Our suppliers of whole fish (fish farmers and processors) are located in Norway and Iceland, where legislation requires that human rights are protected. Over 70% of

Several of our transport suppliers are subject to taxation in Norway and are therefore required to comply with the Norwegian Transparency Act. These arethereforeconsideredtohavealowerriskofhuman rights violations, compared to transport suppliers that are not subject to taxation in Norway. All transport suppliers have provided confirmation of their compliance with our ethical guidelines. Seaborn have implemented a routine for annual audits, specifically focusing on compliance with the general application regulations (Allmenngjøringsforskriften). This will essentially affect all our transport suppliers, however, foreignsuppliersandsupplierswithsubcontractorswill be prioritized. For all the transport suppliers we work with, we distribute a supplier form that contains a number of requirements such as complying with rules on driving and rest period according to national and international transport legislation, ensure safety ofthe products and correct temperature for the products under transport.Wehaveensuredthat wehaveaccess to, or receive, necessary documentation during audits, or else when needed. To further ensure that our products are transported safely on Norwegian roads, Seaborn will demand that each packing site we receive fish from is a member of “Trygg Trailer”, a project organized by Statens Vegvesen which focus on safe transportation.

To ensure responsible operations and transparency in our value chain we encourage all our suppliers to become members of SEDEX (Supplier Ethical Data Exchange) and develop their own sustainability strategy that includes accessible information about their social sustainability goals. During 2023 a questionnaire will be distributed to our suppliers, with the aim of obtaining information about their sustainability measures. This questionnaire will be in accordance with the United Nations Principles on Business and Human Rights (Principles 7, 8, and 9).

Seaborn is not subject to reporting requirements under the antimoney laundering and sanctions regulations, pursuant to Section 4 oftheAnti-MoneyLaunderingAct(Hvitvaskingsloven§4).However, we conduct trade with a large number of foreign customers in a broad spectrum of countries, where some customers have their place of business in countries with higher risk of money laundering and corruption. It is of high importance to ensure that we have a conscious relationship with our customers, as well as an awareness of the corruption and money laundering risks affiliated with the funds they manage as a business.

Duetoour customer portfolio, wehaveassesseditasmoderaterisk for a breach of human rights principle number 10- Businesses should work against corruption in all its forms, including extortion and bribery. Therefore, we have decided to implement several customer measures to actively prevent such breaches. One of the measures is to revise our customer verification procedure so that it also includes obtaining a company certificate and verifying the ownership structure. This will be particularly important for our cash customers and costumers located in high-risk countries. We will also work to ensure that at all of our customers sign our framework agreements that are based on the 10 principles for social responsibility define by the UN. With such measures, we will eventually be able to achieve low risk for corruption, which is in line with our focus on promoting a responsible and sustainable value chain.

Seaborn supports the Dale Oen Experience Foundation

When World Champion Alexander Dale Oen died in 2012, his brother Robin, and his wife Vibeke, decided to realize the dream they both had: Create an arena where children and adolescents can experience mastery and discover strengths. The Dale Oen Academy offers a different school year for adolescents who for various reasons do not manage to follow the traditional school path. Since 2012 the Dale Oen Foundation has given over 100 000 children and adolescents the change to push personal boundaries and discover new strengths.

Seaborn supports the Dale Oen Experience Foundation by donations.