Sustainability statement

In line with the European Union's Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS), this sustainability statement offers a comprehensive overview of Odfjell's sustainability initiatives and business conduct. The CSRD aims to enhance corporate transparency and accountability by mandating detailed disclosures on environmental, social, and governance (ESG) factors, thereby facilitating informed decision-making among stakeholders.

This statement is structured to provide insights into our material impacts on people and the environment, as well as the significant effects of sustainability matters on our business operations. By adhering to the ESRS framework, we ensure that our reporting is consistent, comparable, and aligned with EU regulatory requirements.

The sustainability statement is organized into four distinct sections:

General information: This section complies with ESRS 2, offering an overview of our sustainability policies, management approaches, and outlining the context within which we operate.

Environmental information: Aligned with ESRS topical standards, this segment details our environmental performance, including disclosures pursuant to Article 8 of Regulation 2020/852 (EU Taxonomy), highlighting our contributions to environmental objectives.

Social information: This part addresses social aspects as per ESRS topical standards.

Governance information: Following ESRS topical standards, this section outlines our governance structures, policies, and the practices that underpin our commitment to ethical and effective management. This section also encompasses an entity-specific standard in ship recycling.

Through this structured approach, we aim to provide stakeholders with transparent and detailed information on our sustainability performance and demonstrate our dedication to responsible business practices and compliance with EU sustainability reporting standards.

ESRS content index

Content index - Disclosure Requirements in ESRS covered by the undertaking’s sustainability statement (Disclosure Requirement ESRS 2 IRO- 2 paragraph AR 19 & ESRS 2 Appendix C)

General information

ESRS 2 BP General basis for preparation

BP-1 General basis for preparation of the sustainability statement

This sustainability statement has been prepared on a consolidated basis, covering Odfjell SE and all its controlled subsidiary undertakings.

The scope of consolidation for this sustainability statement is the same as that applied in the consolidated financial statements prepared in accordance with IFRS Accounting Standards as adopted by the European Union.

The sustainability reporting is based on a double materiality assessment, risk assessments, and current standards. Odfjell SE (Odfjell) has recently developed a thorough sustainability reporting framework that incorporates our strategy, risk assessments, and performance. Risk assessments and materiality assessments set the priority for actions and reporting.

Odfjell is an integrated shipping company with stakes in terminals located in the United States, Belgium, and South Korea. The terminals in the United States and South Korea are structured as joint ventures with Odfjell holding a 50% ownership stake, while the terminal in Belgium is an associated company. In our financial reporting, Odfjell Terminals (Terminals) are accounted for using the equity method rather than through full consolidation.

Although these terminals support the value chain for chemical storage and transportation, they are independently operated and are public terminals, not specifically integrated into Odfjell’s shipping activities. Governance of these terminals is managed through shareholder agreements, which allocate equal control among the shareholders and establish a board with equal representation from each shareholder. As a result, Odfjell does not have operational control over these terminals and, therefore, does not serve as a controlling owner. Due to this lack of operational control, Our JV terminals are not consolidated in our financial statements nor are they included in our sustainability reporting. Instead, these terminals as other terminals are considered part of the upstream value chain for Odfjell’s activities and are accounted for as such. Our own terminals are only accounted for in scope-3, cat 15, investments.

In December 2025, Odfjell established a joint venture with Nissen Kaiun Co., Ltd. for the operation of chemical tankers. The joint venture, Odfjell Hakata Maritime AS, will initially comprise ten stainless steel vessels, contributed equally by Odfjell and Nissen Kaiun. Odfjell holds a 45% ownership interest in the joint venture and does not exercise operational control. Accordingly, the joint venture is not included within the scope of Odfjell’s Sustainability Statement, except for the scope-3 cat 15.. Odfjell Tankers, Odfjell’s chartering organisation, will act as the commercial manager for the vessels. The vessels will be fully integrated into Odfjell’s commercial fleet and will operate across major deep-sea trade lanes and global shipping hubs. For reporting purposes, the vessels will be included in Odfjell’s controlled fleet and operated fleet where applicable, in accordance with the defined reporting boundaries.

This sustainability statement addresses material sustainability matters across Odfjell's upstream and downstream value chain as identified through the double materiality assessment conducted in accordance with ESRS 1 section 5.1.

The statement includes material impacts, risks, and opportunities related to suppliers of goods and services, bunker fuel suppliers, terminal operators (including non-consolidated terminal investments), shipyards, and other business partners that provide inputs to Odfjell's operations. The statement addresses material sustainability matters related to customers utilizing Odfjell's chemical tanker services

A comprehensive value chain analysis (VCA) has been developed as the foundation for evaluating sustainability topics at all value chain stages. The VCA has been the basis for scope 3 greenhouse gas emissions calculations, human rights due diligence, and supplier relationship management. The extent of value chain coverage for specific disclosures is detailed in the relevant ESRS topic standards where applicable.

In accordance with ESRS 1 section 7.7, Odfjell has applied the option to omit specific information corresponding to intellectual property, know-how, and results of innovation where disclosure would seriously prejudice the commercial position of the undertaking. Specifically, this applies to:

• Detailed fleet transition strategies and specific vessel investment plans identified in climate-related opportunity assessments
• Proprietary technological solutions and innovations under development for emissions reduction
• Specific commercial arrangements and competitive positioning elements identified in climate and nature-related opportunity assessments
• These omissions are limited to forward-looking strategic and commercial information where disclosure could undermine Odfjell's competitive position. All omitted information has been assessed as not prejudicing the overall understanding of Odfjell's sustainability performance, impacts, risks, and opportunities.

BP-2 Disclosures in relation to specific circumstances

Time horizon

In accordance with ESRS 1 section 6.4, Odfjell applies the following time horizon definitions:

• Short-term: Aligned with the financial reporting period (calendar year)
• Medium-term: From the end of the financial year to 5 years
• Long-term: More than 5 years

Deviation for climate and nature-related impacts, risks, and opportunities (IROs):

For the assessment and disclosure of climate and nature-related IROs specifically, Odfjell has applied modified time horizons:

• Near-term: 0-5 years (equivalent to short and medium-term combined)
• Long-term: 5-25 years (subset of the standard long-term definition)

Rationale for deviation:

1. Climate scenario consistency: Climate science scenarios show minimal variance in the near-term (0-5 years), making granular short/medium-term distinction of limited analytical value for climate-related IROs
2. Asset lifecycle alignment: The upper bound of 25 years reflects the typical economic lifetime of chemical tanker vessels, beyond which projections become speculative
3. Risk assessment practicability: The simplified two-horizon framework enables more robust scenario analysis aligned with industry practice for long-term capital-intensive maritime assets

For all other sustainability impacts (social, governance, non-climate environmental), Odfjell applies the standard ESRS 1 three-horizon framework.

General disclosures

Odfjell SE reports in accordance with the European Sustainability Reporting Standards (ESRS) as a Wave 1 company. This means our disclosures for the 2025 financial year align fully with the requirements applicable to companies in the first wave of implementation under the Corporate Sustainability Reporting Directive (CSRD). Odfjell reported in line with this standard also for 2024.

The European Commission has advanced an Omnibus Regulation intended to streamline and refine the implementation of the CSRD and ESRS. The intention behind this initiative is to reduce complexity and reporting burden — while safeguarding the robustness and integrity of sustainability information. Over recent months, several drafts and proposals have circulated, accompanied by extensive commentary and speculation about potential adjustments to the standard-setting framework. As at the date of this report, the amended standards and associated delegated acts have not yet been fully adopted. Accordingly, Odfjell will continue to report in line with the current ESRS framework for the 2025 reporting year, consistent with our 2024 approach.

Nevertheless, in recognition of the interim Delegated Act on the ESRS “quick-fix”, released 11 July 2025, we have incorporated relevant guidance (for example, temporary reliefs for Wave 1 companies on certain disclosures). By doing so, we ensure our reporting remains aligned with the most current regulatory interpretations and positions, and position ourselves well for adoption of any finalised amendments once the Omnibus Regulation has entered into force.

Given the complexities inherent in this initial reporting cycle, it will include some interpretations. As we implement these standards, we anticipate certain uncertainties in specific reporting details, especially in the interpretation of new regulatory requirements, the reliance on estimates, and adjustments that may arise from the limited assurance process. There will also be challenges related to data collection, as we need data that is produced outside our control, uncertainty in estimates, and areas where we have to recalculate older data to match new data requirements. We have seen interpretations in the new ESRS drafts, but these have not been fully adopted as the new standards yet.

Moreover, decarbonization in shipping entails significant capital investment in an industry marked by competition, market fluctuations, and unpredictable pricing and availability of alternative fuels. We aim to provide transparency in this report while acknowledging these factors which influence our sustainability journey, and will likely continue to shape our reporting in the coming years.

Odfjell has previously included Terminals in selected ESG metrics until 2024 reporting. Following ESRS and disclosure under BP-1, Terminals will not be included in the reporting in 2025, same as for 2024, except for scope 3 cat 15..

Emission reporting and fleet categorization

Emissions from our vessels include all GHG emissions through all of the ships operations. Odfjell’s fleet is categorized based on criteria related to control, responsibility, operations, and ownership of individual ships. Historically, Odfjell has reported fleet emissions data according to two primary categories: the controlled fleet and the operated fleet, in alignment with the Greenhouse Gas (GHG) Protocol. With the introduction of the European Sustainability Reporting Standards (ESRS), new fleet categorization criteria have been established, differing from Odfjell’s previous reporting practices before 2024.

To ensure transparency and consistency, Odfjell has aligned its reporting with both industry standards and the ESRS definitions of responsibility. These definitions have been fully integrated into our Scope 1 emissions reporting.

Carbon intensity reporting is entity-specific; therefore, Odfjell reports carbon intensity exclusively for the controlled fleet. The controlled fleet consists of vessels for which Odfjell can influence carbon intensity through both operational and technical measures. In contrast, for the operated fleet, Odfjell can primarily influence carbon intensity only through operational measures, as the company neither owns nor has control over technical measures for a significant portion of this fleet. The calculations of carbon intensity follows industry standard developed by the International Maritime Organization (IMO).

For clarity, the fleet categories are defined as follows:

*Odfjell has one vessel, Flumar Brazil, that is time chartered out from Odfjell to Petrobras mainly for storage in Brazil. The vessel is owned by Odfjell but excluded from IMO DCS reporting and, therefore, not reported as Odfjell’s controlled fleet The vessel is included in Operational controlled fleet in 2025, as it is under Financial control iaw ESRS. The vessel represent 0.58% difference of Operated Control and Odfjell Operated fleet.

Scope-3 Category 3 encompasses emissions associated with the fleet for which Odfjell holds responsibility for fuel procurement, in accordance with industry standards and the Greenhouse Gas (GHG) Protocol.

We note that in the 2025 draft update to ESRS, the TC out vessels will be reported as Downstream Scope 3, and not scope 1.

See the illustration of the fleet definitions:

Transition plan for climate change mitigation

The sustainability statement includes a Transition Plan for Climate Change Mitigation in accordance with ESRS E1-1. A key component of this plan is the identification of actions and targets aimed at mitigating climate change and contributing to the 1.5°C goal of the Paris Agreement.

As sectoral pathways for the shipping industry have not yet been defined by public policy, it is not currently possible to determine whether Odfjell’s targets are explicitly aligned with a 1.5°C trajectory. However, Odfjell has developed a transition plan to achieve net-zero emissions, outlining concrete measures to reduce carbon intensity in the short term. While these efforts support decarbonization, Odfjell does not assert that its targets are explicitly aligned with a 1.5°C pathway.

Value chain estimation – emissions in scope 3

Odfjell applies a structured and transparent approach to scope 3 emissions reporting, ensuring consistency with internationally recognized greenhouse gas (GHG) accounting frameworks. The methodology aligns with the GHG Protocol and employs spend- and activity-based calculation methods where applicable.

Scope and methodology

Odfjell reports absolute scope 3 emissions across upstream and downstream activities. These emissions are categorized into 15 distinct groups, of which nine are relevant to Odfjell. The primary calculation method relies on a spend-based approach, supplemented with activity-based data for specific categories such as business travel, employee commuting, and waste management.

The spend-based approach is applied where supplier-specific, hybrid, or average-data methodologies are not feasible due to data limitations. This method involves collecting financial data on purchased goods and services and applying environmentally extended input-output (EEIO) emission factors to estimate associated emissions. For categories where direct measurement is possible, such as fuel consumption in category 3 (Fuel and Energy-Related Activities), business travel, commuting, and waste disposal, an activity-based approach is used.

Reporting and data sources

Odfjell has reported scope 3 emissions to the Carbon Disclosure Project (CDP) for several years. Since 2022, the company has disclosed emissions for categories 1 (Purchased Goods and Services) and 3 (Fuel and Energy-Related Activities) in its annual report. The data collection and calculation for these categories have been supported by ReFlow.

Odfjell employs a spend-based method for estimating emissions from procurement activities under category 1 (Purchased Goods and Services), and a well-to-tank emissions approach for category 3 (Fuel and Energy-Related Activities). These methodologies align with the GHG Protocol and ensure a comprehensive assessment of the company’s indirect emissions.

Emission factor application

For purchased goods and services, the spend-based method estimates emissions per unit of expenditure in different categories using a spend-based EEIO approach with EXIOBASE v3.9.4 emission factors adjusted to 2025 price levels. Data for this category was sourced from Odfjell’s procurement records, covering ship management, provisions, IT infrastructure, and port costs. These expenditures were mapped to the most relevant EXIOBASE sectors, ensuring methodological consistency. Where direct, maritime-specific categories were unavailable, emissions were allocated to the closest industry benchmarks, such as shipbuilding, port services, food supply, and IT services. Additionally, mixed-use procurement categories were allocated proportionally, food emissions were weighted based on varying climate impacts, and IT spending was distinguished between hardware and cloud services. The mixed-use procurement represents non-material volumes.

For fuel and energy-related activities, the methodology follows IPCC 2021 GWP100 factors, which provide internationally recognized data on well-to-tank (WTT) emissions. This category accounts for the supply-chain emissions from fuel extraction, refining, and transportation but excludes combustion-related emissions (tank-to-wake, TTW), ensuring compliance with GHG Protocol guidelines. Data was sourced from Odfjell’s Bunker Purchase List, which details the quantity of each fuel type used in the company’s shipping operations. The corresponding IPCC 2021 GWP100 emission factors were applied to each fuel type to calculate WTT emissions.

Business travel, employee commuting, and waste management

Business travel emissions are calculated using data provided by Odfjell’s travel agent, employing the distance-based method in accordance with the GHG Protocol. Employee commuting and office waste emissions are estimated using a combination of distance-based and average-data methods.

Capital goods

Odfjell has a mixed fleet structure, comprising vessels under various ownership arrangements within its controlled fleet, as well as time chartered vessels within its operated fleet. For certain vessels, Odfjell holds purchase options and may also repurchase vessels previously subject to financial lease arrangements. As a result, vessels that changed ownership during 2025 are accounted for under Scope 3, Category 2 (Capital Goods).

Odfjell does not have access to vessel-specific emissions data related to the original construction of these ships. This is due to the age of the vessels and the fact that they may have had multiple previous owners. In addition, accounting for production-related emissions under Scope 3, Category 2 inherently involves a risk of double counting, as each owner is required to include the production emissions of an asset at the time of acquisition.

To estimate these emissions, Odfjell has applied a life cycle assessment conducted by ReFlow in 2023 for a Kværner-class vessel, Bow Clipper. To derive representative production emissions, Odfjell used the assessed emissions intensity per laden tonne from the Bow Clipper assessment and applied this factor to the laden tonnes of the vessels for which ownership was acquired in 2025.

Odfjell also acquired ownership of vessels in 2024 that should have been included in Scope 3, Category 2 emissions for that reporting year. However, as this requirement was not identified at the time, the associated emissions were not included in the 2024 reporting. The Scope 3 -Cat 2 for three ships that changed category from lease to own in 2024 were 174 670 tonnes.

Emissions related to recycled vessels are included in Scope-3 category 2 capital goods.

Continuous improvement and methodological refinements

Odfjell is committed to continuously improving its scope 3 reporting methodology. As supplier data availability increases, the company aims to transition from spend-based calculations to activity-based measurements for enhanced accuracy. Improved data means that in most cases the reported scope-3 emissions will be reduced.

Although a full scope 3 analysis was not available in 2021, historical data has been recalculated based on the average scope 3-to-scope 1 ratio observed in 2022 and 2023 to have a baseline from 2021. As a high percentage (about 80% in average) of scope 3 emissions are directly correlated with scope 1 emissions, fleet decarbonization remains a key focus area in Odfjell’s sustainability strategy.

Odfjell remains committed to transparent, accurate, and methodologically sound scope 3 reporting, ensuring alignment with regulatory expectations and industry best practices.

Sources of estimation and outcome uncertainty

Our most material focus area is climate change mitigation, with a clear emphasis on emission reduction. A material metric is scope 1 carbon emissions. This number has been externally certified by DNV as part of the Sustainability-Linked Financing Framework, as well as the EU MRV and IMO DCS reporting systems. While we have reliable, verified scope 1 emissions data based on years of consistent tracking, uncertainties arise regarding scope 3 data, which relies on a spend-based and volume approach and carries inherent limitations. As data access and availability of data from suppliers improve, we might find areas of scope 3 that have not been previously included. Scope 2 emissions data is particularly uncertain due to the variability in electricity sourcing across multiple operational geographies, but the volume is not material.

As scope 3 is mainly based on a spend-based approach, it will have some uncertainty. There is also a risk that not all factors have been included. But most of scope 3 is in fuel production, where we have reasonable accurate data. Reference see also link; Risk management and internal controls over sustainability reporting (ESRS 2 GOV-5).

The ESRS framework requires the disclosure of forward-looking transition plans and projections. This represents a complex undertaking for Odfjell, given that the company operates in a highly regulated and globally competitive sector. Odfjell is subject to an evolving set of international, regional, and national regulations addressing climate change mitigation, and anticipates that further regulatory measures will be introduced over time. These developments add to the complexity of planning and executing the decarbonisation of the shipping industry.

Odfjell’s sustainability strategy is anchored in regulatory compliance while also reflecting the company’s ambition to go beyond minimum requirements where feasible. At the same time, as a global operator in a competitive market, Odfjell must carefully balance its climate ambitions with cost considerations to avoid sustained competitive disadvantage relative to peers. This dynamic underscore the importance of ambitious, globally harmonised regulations that create a level playing field across the industry.

The International Maritime Organization’s (IMO) Net Zero Framework is expected to significantly influence both Odfjell’s transition pathway and that of the wider shipping industry. However, as the implementation of this framework has been postponed, Odfjell will continue to align its actions and investments with regulations that have been formally adopted and approved. The absence of fully defined global regulatory mechanisms, combined with the ongoing development of key technologies, fuels, and market-based measures, introduces material uncertainty regarding the timing, cost, and structure of the transition.

These factors—many of which are beyond Odfjell’s direct control—affect the company’s ability to precisely forecast the future trajectory and costs of decarbonisation. Odfjell therefore applies scenario-based assessments and continuously reviews its transition plans to remain responsive to regulatory developments while progressing toward its long-term climate objectives.

Planned actions to improve accuracy of metrics in future

Improving data availability and quality is an ongoing process, particularly the data provided by sources upstream and downstream in the value chain. As more companies and suppliers comply with reporting requirements for their scope 1 emissions, it will become easier to obtain product-specific emissions data from our suppliers, which constitute Odfjell’s scope 3 emissions.

To address this, we have requested our suppliers to prepare and share such data. However, we have noted significant variability in both the maturity of their reporting practices and the materiality of the data provided. As a result, we will prioritize engagement with our largest suppliers, as they represent the most substantial impact on our scope 3 emissions profile.

In addition to direct engagement, we have initiated the use of a third-party qualification and due diligence platform, Achilles. This platform enables our suppliers to report their ESG data in a standardized manner, thereby enhancing the quality and consistency of upstream ESG data.

Looking ahead, our strategic objective is to transition from spend-based scope 3 data to activity-based scope 3 data as soon as sufficient, reliable data become available. This shift will provide a more accurate and actionable understanding of our value chain emissions and support our broader sustainability goals.

Changes

Odfjell has updated the Double Materiality Assessment (DMA) in 2025, and reclassified two sub-topics under E-4 Biodiversity as material. This means that Odfjell will report on E4 in line with the ESRS standard for 2025. Background for the reclassification is related to increased attention to Biodiversity from our stakeholders, new regulations (ie the High Seas Treaty in September 2025), peer reviews, and an updated nature-risk assessment.

In our DMA, we have adopted a stricter approach to what constitutes a positive impact. Previous positive impacts have been reclassified as actions and activities that reduce negative impact. This is explained under SBM-3.

For 2025 the scope 3 emissions in category 2 Capital goods, which represents all upstream emissions from acquired capital goods like purchased vessels, are calculated with a approx. emission factor per dwt of acquired vessels as described earlier in this chapter.

As Odfjell recycled one vessel in 2025, this vessel is included in the category 2 Capital goods of scope 3 emissions. Vessels are capital goods under the GHG Protocol when owned and used to provide services (transport). Category 2 is defined to cover “cradle to grave emissions of capital goods purchased by the company”. Odfjell treat the vessels as a capital good throughout its entire life cycle, so we include the end of life recycling of vessels in Category 2. In 2023 we included the carbon emissions from one ship recycling in category 12 End-of-life treatment of sold products of scope 3 emissions.

For 2025 carbon accounting from the smaller offices in the USA, South Korea, South Africa, Dubai and China is included in reporting on scope 1, scope 2 and scope 3 emissions category 5 Waste generated in operations, category 6 Business travel and category 7 Employee commuting.

For 2025, the scope 3 emissions in category 15 Investments include only scope-1 and scope-2 emissions from JV terminals in the USA and South Korea as per the GHG protocol. The 2024 data was estimated from the reported data in 2023; however, it is now updated in 2025 with reported numbers.

In 2025 the calculation of nitrogen oxides (NO₂) is calculated more precisely based on engine type and motor rotational speed from the technical file of each ship, still following the 2023 guidelines set out in NO_X-fondet, as specified in Forskrift om særavgifter § 3-19-9. (1) and (2), and the Norwegian Maritime Authority.

For 2025, we computed the gender pay gap and remuneration ratio for S1-16 based on the nationality or their company as they have different wage scales and bargaining agreements.

Odfjell changed its sustainability auditor from EY to KPMG in 2025, as part of a mandatory rotation of financial auditors. KPMG is also the financial auditor for Odfjell for 2025.

Other reporting or by reference

Norwegian companies have to report in accordance with the Transparency Act of Human Rights Due Diligence. This report is a separate one. Odfjell also issues the executive remuneration report required by Directive 2007/36/EC, which is also subject to audit.

Entity-specific disclosures

Given the diversity and complexity of Odfjell’s workforce categories and employment types, turnover rates and employees who left are reported in Chapter S1-6 using both the mandatory ESRS method and the industry-specific INTERTANKO method. This dual approach ensures an accurate and comprehensive representation of turnover rates and employee departures. For detailed figures and methodology, refer to ESRS S1-6. Odfjell also report on Carbon Intensity iaw IMO standard as a KPI. Odfjell has also included reporting of scope-1 for Odfjell’s controlled fleet as entity specific and operated and financially controlled fleet in line with ESRS.

Entiy-specific KPI's are

• Annual Efficiency Rate according to IMO (AER, defined in Transition plan for climate change mitigation see link; E1-1 About the targets
• Scope-1 emissions Operated fleet (defined in Gross Scopes 1, 2, 3 and Total GHG emissions see link; E1-6 Gross scopes 1, 2, 3 and total GHG emissions
• Turnover rate according to INTERTANKO method (defined in Characteristics of the company’s employees see link; S1-6
• Absence rate (defined in Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities see link; S1-5
• Total Recordable Case Frequency according OCIMF (TRCF, defined in Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities see link; S1-5

ESRS 2 GOV Governance

GOV-1 The role of the administrative management and supervisory bodies

The board of directors (BoD) is committed to upholding the highest standards of corporate governance. It holds supreme responsibility for the oversight of Odfjell's management, operations, and the establishment of control systems. The BoD is tasked with setting the independent overarching direction and strategic objectives for the company, providing oversight, and ensuring accountability. The functions and proceedings of the BoD are dictated by its rules of procedure and the relevant legislation that outlines its responsibilities, duties, and administrative processes i.e. the Norwegian Company Act and Code of Corporate Governance. The BoD also approves significant sustainability strategies, objectives, and targets. It routinely reviews, monitors, and deliberates on the group's sustainability and climate-related strategy, targets, performance, risks, and reporting. The BoD has six directors, where the chair is dependent and the majority owner, and five directors are independent (83% independent). The BoD has a 50/50 gender diversity. All directors are non-executive. Employees are not represented on the board in line with the regulations of SE-companies in Norway.

In 2023, the scope of the board audit committee (AC) was broadened to encompass sustainability issues. The AC serves as an advisory body to assist the BoD in its supervisory role regarding sustainability and ESG reporting. Committee members possess the requisite knowledge and expertise in sustainability matters.

Odfjell executive management consists of the chief executive officer (CEO), chief financial officer (CFO), chief sustainability officer (CSO), chief technical officer (CTO), chief commercial officer (CCO), and managing director Terminals (MD Terminals). All executive managers are male and have long experience in the sector, services, and locations.

The CEO is authorized to ensure that our sustainability ambitions and priorities are monitored, managed, and seamlessly integrated into our corporate strategy and ethos. The operational lines of business are responsible for enacting the agreed-upon strategy, and for managing associated risks and performance metrics. Decarbonization is a material topic in Odfjell. The technology section of the Ship Management division is responsible for ensuring compliance and driving energy efficiency and decarbonization initiatives in the fleet.

Odfjell established the CSO role in 2020 as an integral part of the executive management team, ensuring that sustainability remains a focal point in executive discussions. The CSO updates the BoD and AC on sustainability-related matters at all board and AC meetings, focusing on targets, KPI’s, reporting, regulatory updates , among other updates. The CSO is responsible for ESG reporting. Additionally, the CSO leads the DMA and IRO processes. The CSO also drives relevant sustainability training.

The chief compliance officer (CComO) is a function allocated to CSO, and in this role reports to both the CEO and the BoD via the AC.

Details regarding the governance and composition of the BoD can be found in the corporate governance section and the BoD report within the annual report.

Odfjell follows national and international regulations regarding employee representation. For Odfjell Management AS, we have a works council (WC) with representation from management and elected employees to ensure dialogue and alignment of relevant topics and decisions. Odfjell also has a working environment council (AMU), a Norwegian regulation, with employee representation. Our offices and companies outside of the EU follow local regulations.

Oversight of impacts, risks, and opportunities

The BoD holds ultimate responsibility for oversight of Odfjell’s IROs. Management is responsible for presenting the BoD with updated and relevant assessments of IROs, facilitating thorough discussion, review, and strategic alignment. These assessments are integrated into our corporate risk assessment process and included in the double materiality assessment (DMA) review to ensure alignment with Odfjell’s overarching sustainability strategy.

The Audit Committee (AC) plays a key role in the frequent follow-up of ESG reporting and progress. It conducts in-depth reviews of specific reporting elements, monitors internal controls over sustainability reporting, and advises the Board of Directors (BoD) on ESG disclosures. The AC liaises with management and the sustainability auditor to ensure the accuracy and accountability of sustainability disclosures. However, the BoD retains full responsibility for reviewing and approving the ESG reporting. Key sections of the reporting, such as risk assessments, materiality analysis, transition planning, strategy, and targets, are addressed in separate cases at the board level to ensure a comprehensive governance approach.

Responsibilities in terms of reference, mandates, and related policies

Board responsibilities are defined in alignment with the Norwegian Company Act and the Norwegian Code of Corporate Governance. The AC operates under a dedicated charter, available on Odfjell’s website, which defines its role in ESG reporting oversight. The responsibilities of the CEO and the CSO are outlined in their job descriptions, with the CSO also designated as CComO to reinforce alignment with regulatory and ESG requirements.

Management’s role in governance processes, controls, and procedures

The CSO, as part of the executive management team, is pivotal in overseeing and managing impacts, risks, and opportunities within Odfjell’s risk review and strategy sessions. The CSO also facilitates focused discussions on relevant IROs and aligns them with the organization’s strategic goals. The CSO reports directly to the CEO and, in the capacity of CComO, also reports to the AC, ensuring a direct line of accountability for compliance and sustainability matters.

Dedicated control functions for managing sustainability-related IROs are currently in development, with integration into broader internal functions to ensure consistency and accountability in governance. Reference see also link; Risk management and internal controls over sustainability reporting (ESRS 2 GOV-5). As the reporting standard and required datapoints will change from 2026 due to the EU Omnibus, some development of controls have been put on hold until we get more clarity on requirements.

Management is responsible for preparing and updating medium-term targets and goals, which are subject to BoD approval and monitored closely to ensure alignment with Odfjell’s IROs as identified through the DMA process.

Description of skills and expertise for sustainability oversight

Odfjell conducts its own annual review across the BoD and management to ensure sustainability-related expertise is current and sufficient. Key roles, such as the chair of the AC and the CSO, regularly participate in external training programs to enhance their knowledge in emerging sustainability practices. In addition, periodic reviews and consultations with the ESG auditor are valuable for tapping into current trends and expertise.

Odfjell’s organizational review processes evaluate the adequacy of skills and expertise for managing sustainability-related IROs. The organization prioritizes tailored training, professional development, and competence-building initiatives to meet the evolving demands of sustainability governance. This approach ensures that Odfjell’s oversight bodies are equipped to respond effectively to material sustainability IROs in a complex and highly regulated shipping environment.

GOV-1-G1 The role of the administrative, management and supervisory bodies – governance

The BoD holds ultimate responsibility for overseeing business conduct within the organization, ensuring alignment with Odfjell’s ethical standards and regulatory requirements. However, oversight of business conduct has been delegated to the AC as part of its ESG mandate. Management conducts an annual integrity risk assessment to evaluate potential risks associated with business conduct, and the outcomes—including reported actions and improvement plans—are presented to the AC for review and discussion. This process reinforces transparency and accountability within Odfjell and its approach to maintaining high standards of business conduct.

To further support comprehensive oversight, any relevant external reviews, ratings or assessments concerning business conduct are presented to both the management team and the BoD. This practice ensures that the BoD remains informed of industry benchmarks and best practices, and is positioned to make decisions grounded in a thorough understanding of Odfjell’s business conduct obligations and performance.

The expertise of Odfjell’s oversight bodies regarding business conduct is reinforced through regular training and professional development initiatives. Key figures, such as the chair of the AC and the CSO, engage in specialized training programs to stay updated on evolving regulations and best practices in business conduct and ethics. This expertise is periodically evaluated and developed further as part of Odfjell’s annual organizational review to ensure our leadership can effectively navigate business conduct matters relevant to the company’s IROs.

By embedding business conduct within the broader ESG governance framework and prioritizing expertise development, Odfjell is committed to maintaining a responsible, transparent, and ethically robust organization. This alignment with regulatory expectations and industry standards further strengthens Odfjell’s commitment to sustainable and ethical operations in a complex global environment.

GOV-2 Information provided to and sustainability matters addressed by the business’s administrative, management and supervisory bodies

Frequency and process for informing governance bodies on material impacts, risks, and opportunities (IROs)

In alignment with Disclosure Requirement IRO-1, Odfjell has established a robust process for regularly informing the BoD and the AC on material impacts, risks, and opportunities related to sustainability:

BoD: CSO provides a sustainability update at each of the seven annual board meetings, ensuring that sustainability remains an integral part of board discussions throughout the year. Climate and nature risks, as well as human rights impact assessments, and integrity risk assessments are included in the BoD’s annual review of IROs, forming a key component of the DMA process. These IROs serve as the basis for the board’s annual strategic review and the setting of sustainability-related goals and targets, and they are also fundamental to management’s annual priorities, which the BoD reviews. Essential IROs are listed in Odfjell’s corporate risk register, which is reviewed at each board meeting to ensure ongoing alignment with Odfjell’s strategic and sustainability ambitions and targets.

AC: The AC has a standing agenda item dedicated to ESG reporting, with the CSO present at each meeting to provide updates. The AC has the mandate to conduct in-depth reviews of specific IROs throughout the year, allowing for comprehensive evaluation of critical sustainability topics.

Management: Sustainability IROs are reviewed at all management meetings, with corporate risk discussed and assessed across departments. The management team also prepares the annual risk assessment and DMA, aligning IROs with operational priorities. The CSO is responsible for ensuring effective due diligence, monitoring the results, and assessing the effectiveness of sustainability policies, actions, metrics, and targets adopted to address these IROs. A cross-reference assessment of short-term incentives, short-term targets/priorities and IROs is an integrated part of management reviews

Consideration of impacts, risks, and opportunities in strategic and operational decisions

Odfjell integrates sustainability IROs and ESG considerations into its strategic planning, decision-making processes, and risk management. Key sustainability matters are embedded in the strategy preparation, and all major transactions, investments, and target-setting activities consider these IROs. As an integral member of the executive management team, the CSO ensures that sustainability issues are addressed in relevant meetings and that these considerations guide Odfjell’s approach to potential trade-offs.

In cases where trade-offs are required, the BoD and management evaluate factors such as compliance obligations, the materiality of specific ESG investments, and the expected return on these initiatives. For instance, decisions may involve determining whether to exceed compliance requirements or to proceed with less material ESG investments that may yield a lower or negative return. This balanced approach enables Odfjell to make informed, strategic decisions that align with its sustainability commitments while considering the broader business impact.

The list of the material impacts, risks and opportunities has been aligned with the administrative, management and supervisory for the relevant reporting period. No specific IROs have been identified by governance bodies that have not already been addressed by management (see also SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model, see link; SBM-3).

GOV-3 Integration of sustainability-related performance in incentive schemes

Odfjell statement on incentive schemes linked to sustainability performance

Odfjell integrates sustainability-related performance metrics into its incentive schemes for all shore-based employees, including members of executive management, to ensure alignment with our strategic sustainability goals, specifically in safety and decarbonization. These incentive programs are structured to reinforce Odfjell's commitment to environmental and social responsibility within the organization. Members of the BoD are not included in the incentive schemes.

Key characteristics of the incentive schemes

Odfjell offers two primary incentive programs: a short-term incentive plan (STIP) for all shore-based employees and a long-term incentive plan (LTIP) for members of executive management. Since 2018, the STIP has offered eligible employees an annual bonus of up to four months’ salary based on performance, with the executive management eligible for up to six months. The LTIP offers executive management the opportunity to earn shares vested over three years, with a target bonus of up to 33% of their annual salary (50% for the CEO).

Performance assessment against specific sustainability-related targets

Both the STIP and LTIP include specific sustainability-related targets to promote safe and sustainable operations:

• For the shipping division, 17% of the STIP is dedicated to decarbonization objectives.
• For headquarters and terminal operations, 22% of the STIP is linked to safety and spill-prevention metrics.
• The LTIP dedicates 33% of its target to decarbonization performance, specifically aligned with Odfjell’s annual efficiency ratio (AER) targets, measuring the degree to which emissions reductions align with Odfjell's climate commitments.

Inclusion of sustainability metrics in remuneration policies

Sustainability-related metrics, including safety and decarbonization, serve as key performance indicators within both the STIP and LTIP frameworks. These metrics are incorporated into Odfjell's annual executive remuneration policy and reflect the company's strategic focus on reducing environmental impact and ensuring safe operations.

Approval and updating of incentive scheme terms

The terms and metrics of both the STIP and LTIP are subject to annual review and approval. The Odfjell General Meeting approves guidelines for the incentive programs, while specific KPIs and targets are reviewed by BoD’s Renumeration Committee and approved by the Board of Directors to ensure that they remain aligned with current sustainability ambitions and targets.

For additional information on the STIP and LTIP and other executive compensation details, please refer to the executive remuneration report available at Odfjell.com.

ESRS 2 GOV-3-E1 Integration of climate change-related performance in incentive schemes

Climate change-related considerations are integrated into the remuneration of Odfjell’s administrative and management bodies through short-term and long-term incentive plans. Specifically, decarbonization performance, tied to Odfjell's AER and GHG emission reduction targets, and adaptation of green corridors are core components of these incentive programs.

For shore-based employees and executive management, 17% of the short-term incentive plan (STIP) is linked to decarbonization goals within the shipping division, while the long-term incentive plan (LTIP) for executive management dedicates 33% to decarbonization-related performance. Performance is hence linked to climate targets.

GOV-4 Statement on due diligence

GOV-5 Risk management and internal controls over sustainability reporting

a. Scope, main features, and components of the risk management and internal control processes and systems in relation to sustainability reporting

Odfjell’s risk management and internal control processes over sustainability reporting are based on the COSO Internal Control–Integrated Framework, addressing five key components:

Control environment: Odfjell fosters a strong ethical foundation and clear governance structures, supported by the AC and BoD. The AC oversees the effectiveness of sustainability reporting controls, ensuring alignment with regulatory requirements (e.g., EU Taxonomy, ESRS).

Risk assessment: Risks, including data inaccuracies and regulatory non-compliance, are systematically identified and prioritized, through a risk assessment process described in our enterprise risk management (ERM) framework. Internal control risk over sustainability reporting is assessed in the process and aligned with the AC.

Control activities: Policies, automated system checks, validation procedures, and regular internal audits mitigate identified risks.

Information and communication: Effective communication systems ensure that internal functions and external stakeholders receive timely and accurate sustainability data.

Monitoring: The internal audit team regularly evaluates control effectiveness, reporting its findings to the AC, which informs the BoD. External auditors provide assurance over ESG reporting to further enhance credibility.

b. Risk assessment approach and risk prioritization methodology

Odfjell employs a structured methodology to assess and prioritize sustainability reporting risks:

Defining objectives: Objectives align with ESRS requirements and other sustainability and emission reporting standards and regulations (e.g., CDP, Poseidon Principles, IMO DCS, EU MRV).

Identifying risks: Comprehensive reviews identify risks such as errors in scope 1, 2, and 3 data, pollution reporting inaccuracies, and recycling compliance gaps.

Prioritizing risks: Risks are ranked based on their potential financial, reputational, and operational impact. Priority is given to regulatory compliance and high-impact areas like emissions and financial disclosures.

The AC reviews the company’s risk assessment methodologies, ensuring they adequately address sustainability reporting requirements.

c. Main risks identified and their mitigation strategies

The identified risks are then scored on the probability of not achieving the internal control objective, and the impact if objective is not achieved.

Legend: 1 Climate change mitigation and Energy consumption | 1a Scope 1 | 1b Scope 2 | 1c Scope 3 | 2 Pollution | 3 Biodiversity | 4 Own workforce | 5 Workers in the value chain | 6 Business conduct | 7 Ship recycling

d. Integration of risk assessment and internal controls into internal functions and processes

Odfjell integrates risk assessment findings into internal functions and processes through:

• Embedding control activities, such as emissions monitoring and supplier evaluations, into routine operations.
• Leveraging internal audit findings to refine policies and procedures, ensuring alignment with ESRS and other standards.
• Using IT systems for secure and accurate data collection, with automated validation checks and audit trails.
• Establishing a feedback loop where risk assessment results inform operational adjustments and continuous improvement.

The AC discusses the findings with management, ensuring compliance and the effectiveness of internal controls.

e. Periodic reporting of findings to administrative, management, and supervisory bodies

Odfjell has established robust mechanisms for reporting findings related to sustainability reporting:

AC Oversight:

• The AC reviews and evaluates the internal control framework, discussing sustainability reporting standards (e.g., ESRS, EU Taxonomy) and their assurance processes with management

.

• The AC reviews the results of annual external assurance and ensures compliance with relevant standards and regulations.

BoD:

• The AC informs the BoD about assurance results, explaining their role in ensuring the integrity of sustainability reporting. The BoD provides strategic oversight and monitors progress against sustainability ambitions and targets.

Internal audit:

• The internal audit team conducts periodic evaluations of corporate risks and control processes, reporting findings to the AC and senior management.

External assurance:

• Annual assurance reviews by external auditors are discussed and reviewed by the AC to ensure data credibility and compliance.

Through these reporting mechanisms, Odfjell upholds transparency and accountability, ensuring sustainability reporting meets the highest standards of accuracy and reliability.

ESRS 2 SBM Strategy, business model and value chain

SBM-1 Strategy, business model and value chain

Odfjell’s strategy is to provide safe, reliable and efficient transportation and storage of hazardous and sensitive bulk liquids, primarily chemicals, which are essential inputs to a wide range of global value chains. The company’s core activities comprise specialised chemical tanker shipping and terminal operations in strategic global hubs, enabling the safe movement and temporary storage of products between production sites and end markets.

Odfjell operates a globally diversified business model, serving more than 600 customers, including major chemical producers and industrial manufacturers, across all major geographic regions. The fleet is predominantly composed of vessels equipped with stainless steel tanks, enabling the carriage of a wide variety of chemical products and supporting flexibility in deployment across trades and market cycles. This technical specialisation is a defining feature of Odfjell’s competitive positioning.

Sustainability considerations are integral to Odfjell’s strategy and business model. The safe handling of hazardous liquids, prevention of pollution, protection of seafarers and communities, and reduction of greenhouse gas emissions are fundamental prerequisites for maintaining the company’s license to operate and long-term commercial viability.

Key elements of general strategy affecting sustainability matters

a. Products, markets, and workforce:

Products and services: Odfjell’s services are concentrated in one primary operating segment: deep-sea transportation of chemicals and other bulk liquid products. Cargoes primarily consist of specialty and easy chemicals, vegetable oils, and, in limited cases, clean petroleum products. While the fleet does not specialise in fossil fuel transportation, such cargoes are occasionally carried and represent a minor share of total revenues.

Terminal activities are conducted primarily through joint ventures where Odfjell does not exercise operational control, and revenues from these activities are received mainly in the form of dividends.

This focused sector exposure shapes Odfjell’s sustainability profile, particularly in relation to climate transition risks, safety performance, hazardous substance management, and regulatory compliance.

Significant markets and customer base: We operate on a global scale, serving key markets across the Americas, EMEA, Asia, and the Pacific. This global reach connects us with a broad spectrum of customers, including major chemical producers, and industrial manufacturers, supporting essential sectors from food production to construction.

Workforce composition: The composition of Odfjell’s workforce reflects the nature of our operations, divided between seafarers and shore-based employees, as shown in the table below. Further details on workforce composition are provided in ESRS 2-SBM-3-S1.

Workforce composition

b. Revenue breakdown by sector:

Odfjell only operates in one sector, as our revenues from terminals are dividend from joint ventures where we do not have operational control. Gross revenue from sea transport in 2025 was USD 1,113.1 million

Notably, while our fleet does not specialize in transporting fossil fuels, we occasionally transport them. Fossil fuel revenue for 2025 was USD 17 million, up from USD 13million in 2024, representing 1.8 % of total revenues.

Odfjell has no other material sources of revenue beyond those disclosed above. The Group does not generate revenue from additional ESRS sectors, including activities that give rise to intercompany revenues, activities in which the undertaking develops significant operations, or activities through which Odfjell is, or may be, connected to material sustainability impacts. Accordingly, no further sectoral disclosures are applicable.

c. Sustainability-related goals:

Odfjell’s sustainability-related goals apply uniformly across our services, customer categories, geographical areas, and stakeholder relationships. These objectives center on decarbonization, safety, and reducing our environmental impact, in line with our overarching climate targets outlined in the sections, see links; Climate Targets and Progress in E1-1.

d. Assessment of products, markets, and customers in relation to sustainability goals:

Shipping remains the most energy-efficient mode of transporting large volumes over long distances. Odfjell’s specialized chemical shipping operations play a vital role in supporting industries that produce essential goods, including food ingredients, pharmaceuticals, and fertilizers. These products are fundamental to global food security, healthcare, and agriculture.

Our commitment to sustainability is reflected in our adherence to stringent safety and environmental standards. By optimizing our fleet operations, reducing emissions, and continuously improving efficiency, we enable the safe and responsible transport of critical products while aligning with global sustainability goals.

e. Strategy elements impacting sustainability:

Odfjell’s vision is to be a world-class, preferred provider of transportation and storage for specialty bulk liquids. Sustainability is a core pillar of our strategy, ensuring the safe and efficient handling of hazardous liquids while supporting industries essential to global development.

A key challenge in achieving our sustainability goals is the decarbonization of shipping. This requires navigating evolving regulations, securing access to sustainable fuels, and overcoming technological and financial barriers—all while maintaining the highest safety standards. As regulations tighten and market expectations shift, we must continuously adapt to ensure compliance, operational efficiency, and long-term resilience.

Odfjell’s business model is highly dependent on external sustainability-related factors, including:

• Access to compliant and increasingly low-carbon marine fuels,
• The availability of safe and technologically advanced vessels,
• International, regional and national environmental and safety regulations,
• Customer requirements related to emissions performance, safety standards and transparency.

Decarbonisation of shipping represents a central strategic challenge. While Odfjell seeks to reduce emissions intensity and prepare for future low-carbon solutions, the pace and cost of transition are strongly influenced by factors outside the company’s direct control, including fuel availability, infrastructure development and global regulatory frameworks. Odfjell aims to balance regulatory compliance with its own sustainability ambitions and to go beyond minimum requirements where feasible. However, as a global operator in a highly competitive market, the company’s ability to absorb higher costs associated with unilateral action is limited. This reinforces Odfjell’s support for ambitious, globally harmonised regulations that ensure a level playing field across the shipping industry.

Our approach prioritizes sustainability as a competitive advantage, embedding it into every aspect of our operations. By leveraging innovation, strategic partnerships, and our expertise in safe and responsible shipping, we are committed to driving meaningful change in the industry and contributing to a more sustainable future.

Business model and value chain

Odfjell operates an integrated business model centered on chemical tanker shipping and terminal storage, positioning us as a key link within the broader supply chain. Our business model allows for flexibility in product handling and rapid adaptation to market changes, contributing to stability within the cyclical tanker segment. See also our chapter in Resilience under SBM-3.

a. Inputs:

Our primary inputs include fuel and vessels designed for safe chemical transport, produced and maintained by shipyards that meet our stringent quality standards. Terminals and voyage materials also form part of our upstream value chain, essential for supporting our transportation and storage operations.

b. Outputs and outcomes:

Odfjell provides various services, from chemical storage and ship management to reliable and cost-effective product transport. These services yield benefits for customers by ensuring safe, compliant delivery of essential chemicals, contributing to investor confidence and supporting sustainable growth within the chemical shipping sector.

c. Value chain overview:

Our value chain consists of upstream activities, such as ship production and fuel supply, and downstream activities, such as shore-based cargo transport, terminal operations, and ship recycling. Our close relationships with key suppliers and customers, vital to Odfjell’s value chain, enable us to serve as a lynchpin in the global chemical supply network. This integrated structure supports a sustainable business model, providing transparency and resilience across all aspects of our operations.

SBM-2 Interests and views of stakeholders

At Odfjell, we are committed to developing and implementing our strategy and business model by considering the interests and perspectives of all our stakeholders. Our approach to sustainability is shaped through proactive engagement with our stakeholders, including employees, investors, banks, customers, tonnage providers, suppliers, regulators, and communities. This engagement fosters a comprehensive understanding of their interests, views, and expectations, which we integrate into our strategic decisions.

Our key stakeholders comprise employees, possible employees, investors, banks, customers, regulators, and local communities. Engagement with each group occurs through regular dialogue, facilitated by our commercial, technical, finance, and administrative teams. These interactions are organized to cover key topics, ranging from safety, sustainability and ethics, to efficiency, quality, and business terms. Relevant environmental, social, and governance (ESG) topics are always covered. Specifically:

Commercial team: Engages continuously with customers and tonnage providers on efficiency, safety, and sustainability expectations. Our commercial team with our technical team also interact with the shipyards that are building vessels that will be on charter to Odfjell, to ensure that the vessels are efficient and meet Odfjell’s standards for sustainability both in building and operations phase

Technical team: Regularly interacts with ships, suppliers, and service providers to drive sustainable practices in our operations. Procurement is an integrated part of technical and commercial teams, who work with suppliers to Odfjell.

Finance and administrative teams: Maintain a constructive dialogue with banks, investors, and community representatives, focusing on sustainable finance and ESG commitments.

Local offices: Actively involve local stakeholders and communities to ensure our operations meet regional expectations and contribute to local sustainability.

Each engagement is designed to not only understand stakeholder interests but also to translate them into actionable insights. Our commitment to integrating these insights is reflected in our DMA and identified IROs, ensuring a holistic consideration of stakeholder needs in our decision-making.

Understanding stakeholder interests and incorporation in strategy

Through ongoing stakeholder engagement and our due diligence processes, we gain valuable insights that inform Odfjell’s strategy and business model. We benchmark our materiality assessments against industry peers and align our approach with inputs gathered through participation in industry groups and events. We address regulatory requirements proactively, adjusting our strategy in response to transition risks and evolving regulations. This ongoing benchmarking and regulatory responsiveness reinforce our competitive position while addressing stakeholder concerns.

Our structured engagements have revealed that our stakeholders are particularly focused on:

Sustainable operations: Emphasis on minimizing environmental impact through innovative practices.

Compliance and ethics: A commitment to uphold the highest standards of safety and integrity.

Operational efficiency: Delivering quality and timely services in line with global standards.

Feedback from stakeholders is regularly presented to management and incorporated into our DMA and IROs. In addition, feedback from multiple ESG ratings, including those from banks, analytics and ratings companies, informs our updates across reporting, communication, and key business elements. Odfjell also participates in reporting through different parties like EcoVadis, CDP, UNGC Communication on Progress, SHE, Euronext, Position Green, and DNV, and using guides and focus in these disclosures as a basis for continuous improvement.

Strategic amendments in response to stakeholder views

Odfjell’s strategy is dynamically updated to reflect stakeholder feedback. For instance, we have committed to expanding our sustainability initiatives by increasing investment in green technologies and pursuing industry partnerships for sustainable solutions. We recognize that these steps, to be implemented over the next five years, will strengthen our relationship with stakeholders and meet their expectations for sustainable growth. We anticipate enhanced stakeholder satisfaction and alignment with our strategic objectives by fostering transparent and active engagement.

Governance and stakeholder feedback

Odfjell’s BoD and management are frequently informed of stakeholders’ views, especially concerning our sustainability impacts. Management receives regular updates, which are then used to refine our strategy and prioritize sustainability goals. This inclusive governance approach allows us to proactively respond to stakeholder expectations and work towards our sustainability ambitions.

SBM-2-S1 Interests and views of stakeholders – own workforce

We engage with our employees in various ways, including intranet updates, town halls, workers’ councils, working environment councils, officers’ (seafarers’) councils, employee boards, social interests/ sports committees, annual individual performance dialogues, and bi-annual employee engagement surveys. Outcomes from our employee engagement survey are analyzed and integrated into decision-making processes.

Our commitment to gender equality, and the prevention of discrimination, is carried out systematically and continuously and in collaboration with employee representatives. In our drive to prepare our workforce for the future, we have clear objectives: retain and develop our current employees, establish a diverse talent pool, and create an inclusive workplace for all. Diversity is not the objective in itself, though. Research has shown it may promote well-being, contribute to improved decision-making, and help attract and retain talent. In the long run, that will contribute to the safety and quality of our operations.

Safety is more than a priority at Odfjell. It is a core value and part of our license to operate. We are relentless about ensuring the safety of our employees, our contractors and surrounding communities by improving the way we operate as a company. We continuously develop and monitor our safety training, and we do not compromise on safety.

The company has no corporate assembly. The interests of the employees are safeguarded through an agreement between the employees and Odfjell. The employees have established a permanent employee representative body consisting of up to six representatives from the main office in Bergen and the maritime officers' council. Employee involvement at corporate level, and in most subsidiaries abroad, is also secured by various committees and councils in which management and employee representatives – both onshore personnel and seafarers – meet to discuss relevant issues.

As a central group of stakeholders, engagement with our employees drives key aspects of our people strategy. Our people's health, safety, well-being, and rights are vital to us and our business. Respect for human rights is integral to our organization.

Employees can also raise concerns through our independent whistle-blowing mechanism see link; G1-1.

SBM-2-S2 Interests and views of stakeholders – workers in the value chain

We also recognize that our business impacts people in our supply chain. As such, we have set out clear standards and expectations for our suppliers and partners in our corporate supplier conduct principles to ensure people's safety and human rights. We have dedicated functions in the organization responsible for communications with our suppliers and partners including agents, external ship managers, T/C vessel owners and shipyards, which employ most of our value chain workers.

Workers in the value chain can also raise concerns through our independent whistle-blowing mechanism see link; G1-1.

SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model

Since 2020, Odfjell has conducted materiality assessments, transitioning to the concept of double materiality in 2022. In 2024, we refined this process to comply fully with ESRS standards, leveraging extensive stakeholder engagement and internal evaluations. This systematic approach enabled us to identify material IROs, their origins, and potential effects on our business model, strategy, and financial performance.

Brief description of material IROs and their concentration in the business model and value chain

Through our double materiality assessment, we identified key material IROs affecting our operations, upstream supply chain, and downstream activities. The IROs are presented in the following table, and specified under relevant topical standard.

Legend: R – Risk, O – Opportunity

Current and anticipated financial effects of material IROs and strategic responses

Current Effects: Transition risks associated with climate change and compliance with evolving regulations, such as the EU ETS, create financial implications in the short term. Transition costs related to scope 1 decarbonization are being managed through targeted investments and operational efficiencies and further described in our transition plan.

Anticipated Effects: Medium- to long-term impacts include capital allocation to low-carbon technologies, resilience investments, and potential financial penalties for non-compliance. Strategic responses include robust mitigation plans, outlined in our transition plan (see link; ESRS E1-1), and enhanced governance oversight.

Adaptations: Odfjell has integrated sustainability risks into corporate strategy, driving adjustments in fleet operations, procurement, and workforce management.

Approach to the identification of positive and negative impacts

In the 2024 reporting period, Odfjell SE identified certain positive impacts related to climate change mitigation, primarily associated with actions taken to improve energy efficiency and reduce greenhouse gas emissions from our operations.

Following the 2024 reporting cycle, and informed by the amended ESRS exposure drafts, Odfjell SE has reassessed its interpretation of what constitutes a positive impact under ESRS. While the amended standards are not yet formally adopted and will not be applicable before FY2027, they provide material clarification of existing principles in ESRS 1 General Requirements. In the absence of updated official guidance, Odfjell SE has elected to apply this clarified interpretation already in FY2025 to enhance conceptual consistency, comparability and decision-usefulness.

Definition of positive impacts applied by Odfjell

In accordance with the amended ESRS 1, paragraph 36, Odfjell SE applies the following principles when identifying positive impacts:

• Positive impacts are assessed in their own right and are not netted against negative impacts.
• The results of prevention, mitigation or remediation actions addressing negative impacts caused or contributed to by the undertaking, including actions taken to comply with laws and regulations, do not constitute positive impacts.
• Positive impacts may arise from the undertaking’s business activities, products or services that mitigate or remediate negative impacts of another party, provided that Odfjell SE is not connected to those impacts through its own operations or value chain.
• Identified positive impacts must be relevant and decision-useful, in line with the qualitative characteristics of information set out in ESRS 1 Appendix B.

This interpretation is consistent with EFRAG Q&A guidance and addresses the risk of presenting actions, controls or compliance measures as impacts.

Reclassification of climate-related impacts

Under this clarified definition, Odfjell SE has reassessed the classification of climate-related impacts.

Measures undertaken to reduce greenhouse gas emissions from our own fleet, including energy efficiency initiatives, fuel optimisation, operational improvements and compliance with regulatory requirements, are considered to address negative environmental impacts associated with our operations. While these measures contribute to reducing harm and are strategically and operationally material, they do not constitute positive impacts as defined above.

Accordingly, from FY2025 onward:

• Emissions from Odfjell SE’s operations are reported as material negative impacts on climate change.
• Actions and investments aimed at reducing these emissions are reported as mitigation measures and performance outcomes, not as positive impacts.

This change does not reflect a reduction in ambition or performance, but a stricter application of ESRS impact definitions.

Identification of positive impacts going forward

Odfjell SE identifies positive impacts only where its activities, products or services generate stand-alone beneficial effects for the environment or society that are not limited to the reduction of its own negative impacts or compliance with regulation.

Positive impacts may include, subject to the outcome of the double materiality assessment:

• Activities that enable third parties to reduce environmental harm or emissions beyond what would otherwise occur, where Odfjell SE is not connected to the underlying negative impact.
• Contributions to humanitarian, emergency or relief operations, where Odfjell SE’s services directly support the protection of life or essential societal functions.
• Services that contribute to the reduction or prevention of significant health or environmental harm affecting communities or ecosystems outside Odfjell SE’s own operational footprint.

All potential positive impacts are assessed through the double materiality assessment, considering impact severity and likelihood, and are reported only where they meet the qualitative requirements of relevance and decision-usefulness for users of the sustainability statement.

Implications for the 2025 reporting period

As a result of applying the clarified interpretation of positive impacts:

• Certain impacts previously classified as positive in the 2024 reporting period no longer qualify as positive impacts in FY2025.
• The distinction between negative impacts and related mitigation actions is more explicitly articulated.

The presentation of impacts more clearly separates outcomes from management responses. In our tables, we use the term outcome to refer to activities that mitigate negative impact and cannot be classified as positive impact.

Although the amended ESRS standards are not yet mandatory, Odfjell SE considers this approach to represent best practice and to strengthen the credibility, consistency and transparency of its sustainability reporting.

Material impacts on people and environment and connection to business model

The following table provides a high-level overview of the material IROs identified through our materiality assessment. These topics are regarded as having actual and/or potential positive and negative impacts on people and the environment. Reference to our interpretation of positive impact vs outcomes. Reference table above for further description of the IROs. Climate-related impacts are further described in the climate risk assessment (CRA). They are further elaborated upon in the sections under IRO-1, see link; IRO-1. This table outlines the alignment of these IROs with our strategy and business model, focusing on their implications for Odfjell.

Financial effects of material risks and opportunities

Financial position: Current risks impact financial performance through cost of regulatory compliance (e.g. EU MRV, IMO DCS) and emission-related penalties. Opportunities arise from enhanced ESG ratings and access to sustainable finance.

Phase in: For the 2025 reporting period, Odfjell has incorporated financial assessments of material IROs; however, the specific financial impact assessment for each IRO is subject to a phase-in period that is also extended due to the EFRAG Quick Fix guidance. During this phase-in, we have used a guiding scale to evaluate anticipated financial effects, focusing primarily on qualitative assessments for this reporting cycle. Detailed financial assessments of individual IROs are still under development and will be completed in subsequent reporting periods. This approach aligns with the phase-in provisions outlined in ESRS 1 Appendix C and ESRS 2 SBM-3. Additionally, capital expenditure (CapEx) plans related to our transition strategies are included in the transition plan and provide further insights into our financial planning.

Short-term effects: Increased operational costs due to regulatory requirements and decarbonization measures.

Medium- to long-term effects: Expected shifts include enhanced revenue streams from sustainable shipping services and improved access to green finance. Investments in fleet modernization and CapEx for decarbonization initiatives are planned and will be funded through sustainable financing.

Resilience of strategy and business model

Odfjell’s business model for seaborne chemical transportation has demonstrated resilience through decades of operational expertise, strategic market positioning, and adaptability to evolving global dynamics. This resilience is assessed through a combination of qualitative and quantitative evaluations, incorporating historical data, market analysis, and climate scenario modeling.

In 2024, Odfjell conducted a comprehensive assessment of its business model’s ability to address material impacts, risks, and opportunities. These evaluations, which are subject to continuous review, apply the previously defined time horizons and consider potential regulatory shifts, decarbonization trajectories, and economic fluctuations. Scenario modelling indicates that Odfjell’s strategy remains robust under multiple plausible futures, with no identified risk of stranded assets. Fleet modernization efforts ensure compliance with evolving regulatory requirements while maintaining operational flexibility to adapt to market developments.

A key pillar of Odfjell’s resilience lies in the flexibility of its fleet and commercial strategy. The company’s stainless steel chemical tankers are fitted with advanced systems for heating, cooling, inert gas application, and cleaning, enabling the transportation of a wide range of chemical and specialty liquid products. This versatility makes the fleet highly robust to shifts in customer demand, ensuring continued relevance across a broad customer base of more than 600 clients. Furthermore, Odfjell’s global fleet operations provide agility in adapting to route disruptions, supply chain bottlenecks, and geopolitical shifts.

This flexibility extends to Odfjell’s commercial model, which balances long-term contracts with spot market exposure, allowing the company to optimize market opportunities while managing commercial risks effectively. The ability to adjust to fluctuations in demand, shifting trade patterns, and emerging market needs has been a cornerstone of Odfjell’s business success. Highly trained crews, experienced in handling diverse and complex cargoes, further enhance operational resilience and ensure best-in-class service reliability.

Odfjell’s long-term resilience is further supported by its industry’s strong historical correlation with GDP growth and recovery patterns during economic downturns. While future uncertainties remain, the chemical transportation market is deeply integrated into global supply chains, and no fundamental risks to the continuity of core markets have been identified. The company’s track record of successfully navigating geopolitical shifts, economic volatility, and external disruptions reinforces confidence in its ability to adapt to changing conditions.

Recognizing the inherent uncertainties in forward-looking projections, Odfjell remains committed to continuous monitoring and adaptation. By integrating quantitative scenario analysis with qualitative risk mitigation strategies, the company aims to sustain its resilience and ability to capture emerging opportunities, while addressing material risks, in an evolving regulatory and environmental landscape.

Changes to the material impacts, risks and opportunities compared to 2024

Odfjell conducts continuous work to identify and assess impacts, risks, and opportunities in order to ensure that the Double Materiality Assessment (DMA) remains up to date, reflects the company’s business activities and operating context, and is aligned with the views of management and the Board of Directors. Throughout the year, Odfjell gathers internal input, updates identified risks, consults external experts, and performs peer reviews. As a result, the DMA and the associated impacts, risks, and opportunities (IROs) are subject to regular review.

The 2024 reporting year represented Odfjell’s first Sustainability Statement prepared in accordance with the ESRS. During the course of 2024 and 2025, Odfjell has gained additional experience with ESRS reporting and has further considered guidance issued by EFRAG. This has informed refinements to both the assessment process and the resulting disclosures.

Accordingly, the IROs were reviewed and updated during 2025. While most changes represent minor refinements, two material changes have been identified compared to the 2024 reporting:

1. Odfjell has applied a more restrictive approach in assessing positive impacts. This refinement is aligned with emerging EFRAG guidance, including the EFRAG consultative draft on ESRS updates, and reflects a more conservative interpretation of what constitutes a positive impact under the ESRS framework. See SBM-3.
2. Odfjell has reassessed impacts, risks, and opportunities related to biodiversity and ecosystems. As a result of this reassessment, biodiversity has been determined to be a material topic, and Odfjell has therefore included disclosures in accordance with ESRS E4 – Biodiversity and Ecosystems.

IROs covered by ESRS disclosure requirements vs. entity-specific disclosures

Entity-Specific Disclosures: Ship Recycling, reflecting unique operational challenges in end-of-life vessel management.

ESRS 2 IRO Impacts, risks and opportunities

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

Odfjell undertook a thorough process in 2023 to identify, assess, and prioritize material IROs, adhering to the principles of double materiality as outlined in the European Sustainability Reporting Standards (ESRS). The process ensured that the organization’s impacts on people and the environment, and the financial implications of sustainability-related risks and opportunities, were fully considered. This process has been an integrated part of our risk assessments and strategy work, which means that the initial IROS are also updated as reassessed throughout the year. This disclosure outlines the steps taken, methodologies applied, and integration mechanisms used to align with the ESRS framework.

Five phases

Odfjell conducted the DMA in five structured phases:

1. Understanding and mapping: Defined the context and scope of Odfjell’s operations and value chain.
2. Identification: Pinpointed actual and potential impacts, risks, and opportunities.
3. Assessment: Evaluated the materiality of identified IROs using qualitative and quantitative criteria.
4. Decision-making and strategy integration: Prioritized and consolidated material IROs into strategic ESG focus areas.
5. Reassessment: Conducted reviews and refinements to ensure accuracy and relevance.

The different IRO’s are also linked to our strategy map, and the relevant medium- and short-term targets.

Process to identify, assess, prioritize, and monitor IROs

The first phase involved understanding and mapping Odfjell’s operational context, including its activities, value chain, and business relationships. All business segments and geographic regions were analyzed to identify areas of potential impact. This phase also included updating the stakeholder analysis to incorporate both qualitative and quantitative feedback. Stakeholder engagement was critical to understanding Odfjell’s significant impacts on people and the environment, and in identifying new sustainability matters.

In the second phase, Odfjell identified actual and potential impacts, risks, and opportunities through consultations with internal and external stakeholders. The activities were mapped against ESRS topics, sub-topics, and sub-sub-topics to ensure alignment with the reporting framework. Past materiality assessments provided a foundation for this process, which also incorporated sector-specific and geographic considerations.

We have also considered the connections between our impacts and dependencies and the risks and opportunities identified from these. We have not identified any clear dependencies where the dependency itself is identified as a risk. We have integrated dependency assessments into our risk assessment in the DMA process.

In the third phase, Odfjell assessed the materiality of the identified impacts, risks, and opportunities (IROs). The assessment was designed to ensure strong alignment with Odfjell’s enterprise risk management (ERM) framework, including established risk categories and impact thresholds, in order to promote internal consistency and management ownership.

Impact materiality was assessed on a gross basis, meaning that impacts were evaluated before taking into account any existing prevention, mitigation, or remediation measures. This approach ensured that the inherent severity of impacts on people and the environment was fully understood, in line with ESRS requirements. The assessment considered the scale, scope, irreversibility, and likelihood of each impact.

The scoring of impacts was not treated as a purely binary exercise. Instead, a graduated scoring methodology was applied, reflecting the fact that sustainability impacts often exist along a continuum. As a general threshold, impacts scoring 3 or higher were considered to indicate potential materiality and were subject to further qualitative assessment and validation. This threshold was aligned with Odfjell’s ERM impact thresholds and ensured consistency between sustainability and financial risk assessments.

In parallel, Odfjell also assessed impacts and risks taking into account existing mitigation and control measures. This allowed management to understand both the inherent (gross) and residual risk profile and to assess the effectiveness of current actions. However, the determination of materiality was primarily based on the gross assessment, with residual considerations used as a supplementary input to decision-making.

Financial materiality was assessed by analysing the magnitude, likelihood, and nature of potential financial effects on Odfjell’s financial position, performance, and cash flows. Climate- and nature-related risks were assessed using scenario analysis to evaluate physical and transition risks across short-, medium-, and long-term time horizons.

In the fourth phase, decisions were made to prioritize material IROs. This process involved multiple discussions with senior management, the audit committee, and the board of directors. Material IROs were consolidated into eight strategic ESG focus areas, which informed Odfjell’s corporate strategy. Internal controls and governance processes ensured that the prioritization adhered to ESRS requirements and aligned with Odfjell’s sustainability goals.

The fifth and final phase involved reassessment to validate and refine the materiality assessment. Peer reviews and consultations with industry experts were conducted to benchmark findings. Minor adjustments were made to reflect evolving regulatory and market contexts. This reassessment ensured that the identified IROs remained accurate and relevant.

Methodologies and assumptions applied

Odfjell’s double materiality assessment applied methodologies consistent with ESRS 1. Impact materiality was evaluated by assessing the scale, scope, irreversibility, and likelihood of impacts on people and the environment. Financial materiality was determined by analyzing the potential magnitude, likelihood, and nature of financial effects on Odfjell’s position, performance, and cash flows. Specific thresholds for short-, medium-, and long-term impacts were defined, drawing on Odfjell’s enterprise risk management (ERM) system to ensure consistency with corporate risk practices.

The criteria applied by Odfjell SE to distinguish positive impacts from mitigation of negative impacts, including changes introduced from FY2025, are described in ESRS 2 SBM-3

Stakeholder engagement

Stakeholder engagement played a crucial role in the DMA. Internal stakeholders provided insights into potential impacts and risks across Odfjell’s operations, while external stakeholders, including suppliers and industry experts, contributed perspectives on value chain risks and opportunities. Interviews and workshops were conducted to gather input, with particular focus on high-impact areas such as ship recycling and dry-docking processes. This engagement ensured that the materiality assessment reflected a diverse range of perspectives and addressed the most significant sustainability matters. For more on stakeholder engagement, see link ESRS 2 SBM-2.

Odfjell also took the initiative to collaborate with industry peers through the Norwegian Shipowners’ Association in the development of a joint industry report. As part of this collaboration, Odfjell both shared insights from its own Double Materiality Assessment (DMA) and received structured input from other companies within the sector. This peer dialogue provided valuable benchmarking and contributed to a broader understanding of sector-specific impacts, risks, and opportunities. The outcomes of this work were particularly relevant to Odfjell’s reassessment and update of biodiversity-related IROs.

Integration with risk management processes

The process to identify and assess IROs was fully integrated into Odfjell’s broader risk management framework. ESG risks identified through the DMA were incorporated into corporate risk assessments and reviewed quarterly by the board of directors and senior management. Internal control measures were developed to ensure accurate and consistent reporting of material IROs. The audit committee oversaw the alignment of ESG risks with corporate governance processes, ensuring that sustainability considerations were embedded in decision-making.

Integration of opportunities into management processes

Opportunities identified during the DMA were incorporated into Odfjell’s strategic planning and management processes. These included opportunities such as transitioning to low-carbon operations, leveraging green finance, green corridors and adopting innovative technologies. Each opportunity was evaluated for its alignment with Odfjell’s long-term business goals and integrated into operational and financial planning.

Resilience and monitoring

The outcomes of the DMA demonstrated the resilience of Odfjell’s business model in addressing sustainability-related risks and opportunities. Scenario analyses were conducted to anticipate potential impacts under different sustainability scenarios as part of the climate risk assessments, and periodic reassessment ensured the continued relevance of identified IROs. This approach enabled Odfjell to adapt proactively to emerging challenges and opportunities.

Future steps

Odfjell remains committed to refining its processes for identifying and managing IROs. Annual reviews will be conducted to ensure that the DMA reflects the latest regulatory, market, and stakeholder developments. Plans are underway to integrate double materiality findings into Odfjell’s ERM and management systems, further strengthening the alignment of sustainability considerations with corporate decision-making. This iterative process underscores Odfjell’s commitment to sustainability and its alignment with ESRS standards.

IRO-1-E1 Description of the processes to identify and assess material climate change-related impacts, risks and opportunities

Screening of activities and identification of GHG emission sources

We have comprehensively screened our activities and plans to identify actual and potential sources of GHG emissions and other climate-related impacts. This process involved:

Value chain mapping: We analyzed our business model and mapped all activities across our operations and the value chain. This value chain map provided a detailed overview of our operational footprint and was instrumental in identifying IROs through a DMA. All ESRS topics and subtopics have been evaluated for all activities in the value chain and in our business and assessed with regard to impact. We have included all GHG emissions, black carbon, and potential other emissions for the climate-related impact.

Scenario analysis: Parallel to the value chain mapping, we conducted a climate change scenario analysis, assessing direct and transitional risks across short-, medium-, and long-term horizons. This enabled us to evaluate our business's resilience under varying climate and policy scenarios.

Assessment of impacts on climate change

We employed a rigorous methodology aligned with international frameworks such as the GHG Protocol to assess our actual and potential impacts on climate change. Key aspects of this assessment included:

Scope 1 emissions: Scope 1 emissions, stemming from the direct operations of our ships in the fleet, represent the largest source of GHG emissions. Emissions are quantified based on fuel consumption. We have categorized our fleet as described under BP-2 Emission reporting and fleet categorization see link; BP-2.

Scope 2 emissions: constituting less than 0.1% of our total emissions, are linked to energy use in our offices.

Scope 3 Emissions: Scope 3 emissions comprise 41.7% of our total GHG emissions, with 36.8% of these attributed to fuel production and transport of fuel. These were calculated using a spend-based and volume-based approach and relevant carbon factors, acknowledging a degree of uncertainty.

GHG categorization: In line with the GHG Protocol, we focused on emissions of carbon dioxide (CO₂), nitrous oxide (N₂O) and methane (CH₄). Other GHGs were deemed irrelevant to our operations.

Black carbon and non-GHG pollutants: We also evaluated emissions of NO_X, SO_X, and black carbon due to their broader environmental impacts, including climate change, acidification, and pollution. We also noted the reduced impact of SO_X emissions due to the widespread adoption of very low sulphur fuel oil (VLSFO). Emissions of black carbon were examined due to their potential contribution to climate change and pollution.

Climate adaptation challenges: Transitioning to alternative fuels such as e-fuels will require significant green energy inputs. This presents challenges, as increased demand for renewable energy in shipping could displace its availability for other sectors, potentially leading to replacement emissions.

Through our systematic analysis of activities and value chain impacts, Odfjell has identified the primary sources of GHG emissions and potential drivers of climate-related risks in our business and value chain and for the identification of IROs.

Climate scenarios

To adopt a scientific and structured approach to climate-related risk and opportunity assessment, Odfjell applies climate scenario analysis. Projecting climate developments over long time horizons inherently involves substantial uncertainty; structured scenarios remain indispensable for evaluating a range of plausible futures driven by differing emissions trajectories, policy interventions, and physical climate responses.

Odfjell continues to draw on scenarios developed by the Intergovernmental Panel on Climate Change (IPCC), the International Energy Agency (IEA), and the Network for Greening the Financial System (NGFS) to guide its analysis of physical and transition risks. These scenario sets provide complementary insights into climate change hazards, transition pathways, and economic implications.

IPCC scenarios

We use scenarios from the IPCC Sixth Assessment Report (AR6) to inform assessments of climate-related hazards, physical risk exposures, and potential long-term impacts under different socioeconomic and emissions pathways. The scenarios applied include those aligned with intermediate and higher warming pathways. These IPCC scenarios provide the scientific backbone for understanding future temperature trajectories, extremes, and risk drivers relevant to physical climate risk assessments.

These were used to identify climate-related hazards. From the AR6 synthesis report, we selected:

• Intermediate scenario (SSP2-4.5) - This scenario represents a “middle-of-the-road” socioeconomic pathway in which current development trends broadly continue, and climate policies are implemented at a moderate pace. Emissions peak around mid-century and decline thereafter, resulting in a stabilisation of global warming at approximately 2.5–3.0°C by 2100. The scenario implies moderate physical climate risks and reflects a future where mitigation and adaptation efforts are uneven across regions.
• High scenario (SSP3-7.0) - This scenario is characterised by fragmented international cooperation, strong regionalisation, and limited climate policy ambition. Emissions continue to rise for much of the century, leading to global warming of approximately 3.5–4.0°C by 2100. Physical climate risks are high, with increased frequency and severity of extreme weather events and significant challenges for adaptation, particularly in vulnerable regions.
• Very high scenario (SSP5-8.5) - This scenario assumes rapid economic growth driven by energy-intensive development and continued reliance on fossil fuels, with minimal climate policy intervention. Emissions increase substantially throughout the century, resulting in global warming of approximately 4.5–5.0°C or higher by 2100. The scenario is associated with very high physical climate risks, severe environmental impacts, and widespread disruption to natural and human systems.

Consideration of a 1.5°C climate scenario

In accordance with ESRS 2 IRO-1, Odfjell has assessed climate-related transition risks and opportunities considering scenarios consistent with limiting global warming to 1.5°C with no or limited overshoot. The assessment formed part of the company’s internal scenario analysis and strategic planning processes used to evaluate the resilience of its business model and transition strategy.

The analysis concluded that a 1.5°C transition scenario would primarily reflect the regulatory and technological transition that the maritime sector is already expected to follow. In particular, the decarbonisation pathway assumed in Odfjell’s transition plan, including improvements in operational efficiency, fleet renewal, deployment of energy-saving technologies and gradual adoption of lower-carbon fuels, broadly reflects the direction of international climate policy and the ambition of the IMO 2023 GHG Strategy, which aims for net-zero emissions from international shipping by or around 2050.

As a result, the transition risks associated with a 1.5°C scenario are largely reflected in the company’s existing transition planning and climate targets, as described in ESRS E1-1 (Transition Plan), E1-3 (Actions and resources) and E1-4 (Targets). Odfjell therefore expects its planned transition measures to address the main transition risks associated with such a pathway, although the company does not claim that its targets represent a formally validated science-based 1.5°C trajectory.

For the purposes of the scenario analysis presented in this report, Odfjell has therefore focused on higher-temperature climate scenarios to assess potential physical and indirect risks that may have a greater impact on maritime operations and global trade patterns. These scenarios provide additional insight into potential operational and financial exposures beyond those already addressed through the company’s transition strategy.

A 1.5°C transition scenario has thus been considered in the company’s internal assessments but is not presented separately in this report, as it does not materially change the conclusions of our climate risk and resilience analysis.

IEA scenarios

Odfjell’s transition risk analysis continues to reference IEA scenarios, including those featured in the World Energy Outlook (WEO) 2025. The scenarios have therefore been updated in 2025. The WEO-2025 includes exploratory and normative pathways, such as:

• CPS – Current Policies Scenario: A baseline “starting conditions” scenario built on policies and measures that are already enacted in law/regulation. It is not a “business-as-usual” label so much as a disciplined accounting of what existing legislation implies for the energy system.
• STEPS – Stated Policies Scenario - An exploratory scenario reflecting the prevailing direction of travel based on a detailed reading of current policy settings plus stated policy intentions/targets that are backed by credible implementing measures (i.e., it goes beyond enacted-only policies, but does not assume all pledges are fully achieved). In WEO 2025, STEPS is one of the main scenarios used to explore how the system evolves under today’s policy momentum.
• NZE – Net Zero Emissions by 2050 Scenario - A normative scenario that maps a pathway consistent with achieving net-zero energy-related CO₂ emissions by 2050, aligned with limiting warming to around 1.5°C (as framed by IEA). WEO 2025 also notes an update: NZE is described as no longer a limited-overshoot case, with warming peaking above 1.5°C for decades before falling back below by 2100.
• APS – Announced Pledges Scenario (context for WEO 2025) - APS models a future in which all announced national energy and climate targets (including NDCs and net-zero pledges) are met in full and on time. However, IEA states that WEO 2025 does not include APS, because many countries had not yet submitted/updated the next round of targets, meaning an APS update would have been incomplete; IEA indicates these will be reflected in future analysis.
• ACCESS – Accelerating Clean Cooking and Electricity Services Scenario (new in WEO 2025) A normative scenario introduced in WEO 2025 that maps a pathway to universal access to modern energy services, building on the best examples of rapid historical progress. This scenario is not so relevant for Odfjell, and has therefore not been included.

These IEA scenarios help frame potential future changes in energy markets, fuel mix evolution, and emissions trajectories under differing policy landscapes, informing Odfjell’s strategic risk and decarbonisation planning.

NGFS scenarios

Odfjell has applied the Network for Greening the Financial System (NGFS) Phase V climate scenarios as part of its climate risk assessment. The NGFS scenarios are widely used reference scenarios designed to support the assessment of climate-related physical and transition risks by integrating climate pathways with macroeconomic and financial variables. They provide internally consistent assumptions on emissions trajectories, temperature outcomes, policy developments, and economic impacts over short-, medium-, and long-term horizons.

The Phase V update incorporates enhanced representations of physical climate risks, updated socioeconomic assumptions, and refined modelling of transition dynamics. The scenarios span a range of plausible futures, including orderly transitions aligned with climate goals, delayed or disorderly transitions with higher transition risks, and scenarios characterised by limited climate action and elevated physical risks. As such, they are well suited for stress testing and forward-looking risk analysis.

The NGFS Phase V scenarios were used as an input to Odfjell’s climate risk assessment, supporting the identification and qualitative evaluation of potential climate-related risks and their transmission channels. They were applied primarily to ensure consistency with internationally recognised risk assessment practices and to supplement insights derived from IPCC and IEA scenarios.

However, while the NGFS scenarios informed the underlying risk assessment, they are not highlighted separately in the reported results. This is because the assessment focuses on scenario-agnostic risk drivers and outcomes that are robust across multiple scenario frameworks, rather than on scenario-specific quantitative outputs. The NGFS scenarios therefore served as a methodological reference and validation tool, rather than as a standalone basis for disclosed scenario results.

Sustainability, dependency, and climate risk

While comprehensive, IPCC scenarios are not industry-specific and require interpretation for our industry’s unique impacts. These scenarios highlight highly interdependent risks, emphasizing the interconnectedness of sustainability challenges.

Odfjell incorporates insights from the World Economic Forum Risk Report, which underscores the interconnected nature of risks such as climate change, hunger, migration, and security. Recognizing that most climate models inadequately address non-linear impacts and risk interdependencies, we have sought to capture these complexities in our own analyses.

Identification of climate risks and hazards relevant to Odfjell

For each IPCC scenario, we identified climate impacts and adaptation challenges, as summarized in the following table.

Subsequently, we analyzed the implications of these impacts on our business model and geographic locations. This assessment is detailed in the table below.

Further, we examined the temporal dimensions of these scenarios—short-term, mid-term, and long-term—using tools such as the Climate Impact Explorer by Climate Analytics. This analysis helped identify regions and operational areas prone to direct climate risks. The same scenarios were employed to evaluate nature-related risks and value chain vulnerabilities, with a focus on ports and terminals due to limited visibility into upstream production sites.

Time horizon

The IPCC scenarios define three temporal perspectives for climate impacts:

• 2021–2040 (Near-term): Represents immediate impacts and challenges.
• 2041–2060 (Mid-term): Encompasses mid-range projections of climate risks.
• 2081–2100 (Late century): Captures long-term implications under varying warming scenarios.

In Odfjell's climate risk analysis, we have adopted a time horizon that aligns with our operational and strategic planning:

• Near-term (0-5 years): This period aligns with our financial statement timelines and captures immediate risks and opportunities.
• Long-term (5-25 years): Reflects impacts on vessel lifetimes and strategic planning. Notably, this includes the mid-term impacts projected by IPCC scenarios.

For our IRO assessment, we have used the following three time-horizons (Anticipated financial effects assessment is a phase-in requirement under ESRS, and not disclosed Ref ESRS2 -BP2):

• short-term (the period used in financial statements),
• medium-term (from the end of the short-term reporting period to 5 years), and
• long-term (more than 5 years).

The rationale for using these horizons lies in the limited variability in short-term climate scenarios and the need to account for vessel lifetimes, which can extend up to 32 years. For instance, our youngest ships will operate well into the IPCC’s mid-term scenario timeline.

Use of the risk model

Odfjell applies the TCFD risk model to categorize identified hazards within the framework. Impacts from these hazards, along with risks and opportunities, are incorporated into our double materiality assessment and corporate sustainability risk framework. This includes assessments of climate, nature, value chain, reputation, and litigation risks.

Corporate climate and nature risks are analyzed for probability and consequence under the three climate scenarios. Transition and direct risks identified via the TCFD framework are evaluated for near-term (0-5 years) and long-term (5-25 years) impacts. Mitigating actions for these risks are integrated into our action plans.

Climate and nature risk Odfjell

Climate-related physical risks and climate-related hazards

The analysis of hazards, derived from the aforementioned processes, informs our DMA and climate risk assessments. The following table outlines climate-related risks and areas of sensitivity for Odfjell:

Climate risk for Odfjell – Direct CN2

Climate-related transition risks and opportunities

The identification of transition risks follows the same methodology as direct risks, leveraging scenarios to pinpoint risks and opportunities across the value chain. Key considerations include regulations, market dynamics, and technological advancements. These findings are incorporated into the DMA and the ESRS E1-1 Transition plan.

The transition plan evaluates locked-in emission risks, EU Taxonomy alignment, and pathways to net-zero. While no industry-wide policy exists for achieving a 1.5°C target, frameworks such as the Science Based Targets initiative (SBTi) provide guidance. Odfjell has assessed SBTi requirements but has not yet aligned its targets with the initiative’s guidelines.

Our transition plan is built on an IMO Net-Zero scenario, focusing on actions to achieve net-zero by 2050. Given the regulatory environment of the shipping industry, these actions depend on advancements in technology, infrastructure, and long-term policy development. Transition risks and opportunities are summarized in the table below:

Climate risk for Odfjell – Transition CN1

Climate opportunities for Odfjell – ref. DMA (Part 1)

Climate opportunities for Odfjell – ref. DMA (Part 2)

IRO-1-E2 Description of the processes to identify and assess material pollution-related impacts, risks and opportunities

Pollution

Through a comprehensive assessment of our activities and value chain analysis, pollution to air and water has been identified as a material concern. Pollution to soil, however, is not considered material, as our maritime operations occur at sea, and our office activities do not constitute a significant source of pollution. Pollution, in this context, is defined as the direct or indirect introduction of pollutants into air and water resulting from our activities, which may harm human health and/or the environment or interfere with amenities and other legitimate uses of the environment. Pollutants are substances or other contaminants present in the air and sea that may adversely affect human health and/or the environment. For details on involvement of stakeholders please see policies related to pollution see link; E2-1.

The analysis indicates that actual pollution arises from greenhouse gas emissions (addressed under see link; ESRS E1), wash water from cleaning processes, and sulphur, nitrogen oxide and black carbon emissions from combustion engines. Potential pollution risks include cargo-related fuel or substance spills. Odfjell ensures full compliance with IMO MARPOL regulations as well as international and local pollution-related regulations. Waste and wastewater, which may have environmental impacts, are addressed under see link; IRO-1-E5 and are therefore excluded from IRO-1-E2.

Other forms of pollution, such as light and noise pollution, are deemed non-material. Underwater noise is addressed under see link; IRO-1-E4. Similarly, pollution from microplastics and marine debris is considered non-material based on findings from our LEAP analysis and DMA. Possible pollution from building and recycling of vessels is addressed under see link; IRO-1-E5, and in the company specific IRO on ship recycling.

LEAP process and findings

Odfjell has been one of the TNFD early adopters and previously reported on nature risk in line with the TNFD framework. Through this process, we have used the LEAP model in line with TNFD’s guidance on the identification and assessment of nature-related issues: the LEAP approach. We have used this approach to assess impact, risk, and opportunities related to pollution.

The table below describes the process and outcomes.

Identified transition risk related to pollution

Identified physical risk related to pollution

Opportunities related to pollution

Considerations of commission recommendation (EU) 2021/2279 on the use of the environmental footprint methods

Odfjell has considered the Environmental Footprint (EF) methods outlined in EU Recommendation 2021/2279 to measure and communicate the environmental performance of the fleet throughout the lifecycle. The EF methods provide a structured approach for evaluating and disclosing environmental impacts using life cycle assessment (LCA) principles.

The life cycle of a ship encompasses all stages, from design and construction through to operation and decommissioning or recycling. This life cycle has been used in the LEAP process and in the DMA to identify environmental, social and governance IROs, and the results of these assessments are presented in the relevant topical standards.

Odfjell initiated a study in 2023 to determine the emissions throughout the life cycle of vessels, focusing on GHG emissions and using ISO 14040/14044 standards, a recognized method for evaluating environmental impacts during a product's life cycle.

Below is an outline of the key phases:

IRO-1-E3 Description of the processes to identify and assess material water and marine resources-related impacts, risks and opportunities

Introduction

Water and marine resources are indispensable for biodiversity, human communities, and economic activities. These interconnected systems regulate the climate, provide fresh water, and sustain ecosystems, making them vital for global sustainability. This chapter outlines Odfjell’s considerations of our impacts, mitigation measures, and contributions to water-related global and regional sustainability ambitions.

Water and marine resources play key roles:

• Foundational for biodiversity: Supporting ecosystems and delivering critical services essential for life.
• Essential for human needs: Ensuring access to clean water for drinking, agriculture, and industries and supporting livelihoods through fishing and trade.
• Linked to climate resilience: Directly impacted by sea level rise, saline intrusion, and changing precipitation patterns caused by climate change.

Linkages to other ESRS topics

Water and marine resources are closely linked to:

• ESRS E1 Climate change: Addressing risks from sea level rise and ocean acidification.
• ESRS E2 Pollution: Managing emissions to water, including microplastics.
• ESRS E4 Biodiversity: Conserving aquatic ecosystems to sustain biodiversity.
• ESRS E5 Circular economy: Promoting wastewater recycling and reducing reliance on resource extraction.

Identification of material impacts, risks, and opportunities (IROs)

Odfjell conducted a comprehensive assessment to identify material IROs concerning water and marine resources in its operations and across its value chain. This included:

• Assessing water use, including consumption of water on board, surface and groundwater, withdrawals, and discharges.
• Evaluating marine resources to determine whether activities fall under extraction and associated economic activities.

Assessment process

1. LEAP Methodology: The LEAP process, as outlined under ESRS E2 Pollution, was used to screen sites and activities for water-related impacts, risks, and opportunities.
2. Value chain evaluation: Water-related topics and sub-topics were assessed for all activities in the value chain as part of the DMA.
3. Water scarcity analysis: Scenarios and climate risk assessments included evaluations of water scarcity.

Key findings

Own operations:

• Water consumption is limited to office use (non-material)
• Freshwater on board ships is produced from seawater using reverse osmosis systems.
• No material volume of water is discharged from Odfjell’s operations.
• The company uses seawater and freshwater produced onboard for tank cleaning. Discharges are diluted and handled in accordance with applicable MARPOL requirements.

Value chain:

• Water use includes cleaning and discharge activities at terminals, addressed under ESRS E2 Pollution.
• Water consumption at suppliers of products used in Odfjell has been assessed in the DMA, but not in interaction with the suppliers.

Community impacts:

• Odfjell’s operations do not significantly impact local communities with regard to water, so no consultations have been conducted with affected communities.

Marine resources:

• Activities involving the extraction and use of marine resources, as defined under ESRS E3 Water and marine resources, are not a part of Odfjell’s operations.

Results

Based on the LEAP methodology, DMA, and climate risk assessments, water and marine resources are not considered material topics for Odfjell. Given the limited material impacts identified, these topics are not reported in the topical standard. However, Odfjell remains committed to ongoing monitoring and will reassess if circumstances change.

IRO-1-E4 Description of the processes to identify and assess material biodiversity and ecosystems-related impacts, risks and opportunities

Introduction

Biodiversity and ecosystems are essential for sustaining life on Earth, providing critical services such as food, water, clean air, and climate regulation. These interconnected systems underpin the health of the planet and human well-being. This chapter outlines Odfjell’s approach to managing its impacts on biodiversity and ecosystems, mitigation actions, and alignment with global and regional sustainability ambitions.

Biodiversity and ecosystems are:

• Foundational for ecosystem services: Supporting essential functions like nutrient cycling, pollination, and climate regulation.
• Critical for human well-being: Providing food, medicine, and raw materials while maintaining cultural and recreational values.
• Linked to climate resilience: Biodiversity enhances ecosystem stability, aiding in adaptation to climate change and mitigating its effects.

Odfjell has assessed biodiversity and ecosystems (E4) as a material topic. In line with the TNFD LEAP approach, the assessment focuses on the following material sub-topics:

1. Direct drivers of biodiversity loss, and
2. Impacts on the state of species, in relation to Odfjell’s deep-sea chemical tanker operations.

The LEAP framework is applied as a screening and structuring tool to ensure systematic identification of impacts, dependencies, risks and opportunities across Odfjell’s operations and relevant value chain interfaces. The outcomes of this process inform the disclosures under ESRS E4-1 and ESRS E4-2.

The interrelation to other ESRS

Biodiversity and ecosystems are closely connected to other environmental matters. The main drivers of biodiversity and ecosystem degradation are climate change, pollution, land- freshwater- and sea- use change, direct exploitation of organisms and invasive alien species.

• ESRS E1 Climate change: Addressing greenhouse gas emissions and energy consumption, which impact habitats and species.
• ESRS E2 Pollution: Managing pollution to air, water, and soil, which directly affects biodiversity.
• ESRS E3 Water and marine resources: Highlighting water consumption and marine ecosystem impacts.
• ESRS E5 Circular economy: Promoting practices that reduce resource extraction and waste generation, supporting ecosystem preservation.

Identification and assessment of actual and potential impacts

Odfjell has through 2025 made an updated review of DMA and also updated the Nature risk assessment, following TNFDs new draft Sector Guidance for Marine transportation, and used this to improve the reporting under E4 in three ways:

1. Structuring and terminology (LEAP alignment)
   The disclosure is organised explicitly around the TNFD LEAP components (Locate, Evaluate, Assess, Prepare), consistent with TNFD's presentation of LEAP as an iterative approach that can be integrated into reporting cycles.
2. Sector-specific screening logic (routes, biomes, sensitive locations)
   The TNFD guidance was used to define:
   • Route and port-call basis for "Locate" using port-call data
   • Relevant marine and coastal biomes for deep-sea shipping exposure
   • Relevant sensitive-area categories and illustrative datasets/tools (e.g., MPAs/PSSAs/IMMAs and route overlays).
3. Risk and opportunity completeness and measurement direction
   The TNFD tables and examples were used to ensure that the ESRS risk/opportunity coverage includes:
   • Transition risks (policy/legal, technology, market, reputation) and physical/systemic risks relevant to the sector
   • Measurement and disclosure direction for marine transportation, including. It is a challenge to find relevant data, and to measure relevant data. This is an area under development.

This use of TNFD guidance supplements ESRS requirements by adding sector specificity, without replacing ESRS materiality criteria or ESRS disclosure structure.

LEAP assessment - Locate

• Sites in or near biodiversity-sensitive areas

Odfjell’s deep-sea shipping activities interface with nature across global trade lanes and port approaches. Consistent with TNFD sector guidance, Odfjell delineates shipping routes and port calls using AIS and port-call information to identify where operations occur and where exposure to biodiversity-sensitive areas may arise.

To identify interfaces with sensitive locations, Odfjell’s screening considers recognised marine sensitive-area types highlighted by TNFD, including:

• Marine Protected Areas (MPAs) (noting multiple MPA definitions),
• Particularly Sensitive Sea Areas (PSSAs),
• MARPOL Special Areas, and
• Important Marine Mammal Areas (IMMAs).

Odfjell’s operations are focused on deep-sea shipping. Vessels may operate in or near biodiversity-sensitive areas as defined above. Odfjell’s route and port-call screening is designed to identify and prioritise such exposures for further evaluation and assessment, with heightened attention to coastal approaches and ecologically sensitive waterways where biodiversity impacts may be amplified.

LEAP assessment - Evaluate

• Actual and potential impacts on biodiversity and ecosystems
• Dependencies on biodiversity and ecosystem services

TNFD identifies that marine transportation typically interfaces with multiple ocean and coastal biomes, and specifically lists biomes relevant to deep-sea shipping, including marine shelf, open ocean waters, deep sea floors, artificial marine systems, shoreline and coastal inlet biomes, and related coastal transition systems. Evaluated impact is listed in table below:

LEAP assessment – Assess

• Transition and physical risks and opportunities (based on impacts and dependencies)
• Consideration of systemic risks

Assessed transition risks and opportunities

Assessed physical (acute/chronic) and systemic risk

LEAP assessment - Prepare

• Biodiversity mitigating measures

The Prepare phase supports response planning and can provide the groundwork for a nature transition plan. Odfjell has not prepared a nature/biodiversity transition plan, but the prepared analysis includes analysis categorised using the SBTN AR3T framework (Avoid/Reduce; Restore/Regenerate; Transform). Odfjell is in the early stage of the prepare and mitigate process, and some of the actions are not yet implemented.

Consultations with affected communities

Odfjell’s deep-sea shipping does not involve long-term, site-specific extraction or comparable use of shared biological resources. Accordingly, biodiversity materiality assessment is primarily conducted through route/port interface screening, regulatory engagement and stakeholder inputs relevant to marine operations, together with the industry.

Where an activity or incident could negatively affect ecosystems and ecosystem services of relevance to affected communities (e.g., a significant pollution event near coastal communities or sensitive ecosystems), Odfjell engages through established mechanisms involving competent authorities, port authorities, and emergency response coordination. Avoidance of negative impacts is prioritised through prevention and operational controls; where impacts are unavoidable in acute incidents, response planning focuses on minimisation and mitigation consistent with legal and operational requirements.

IRO-1-E5 Description of the processes to identify and assess material resource use and circular economy-related impacts, risks and opportunities

Introduction

At Odfjell, we recognize the increasing importance of circular economy principles in advancing sustainable practices globally. Circular economy, as described under ESRS E5 AR 4, encompasses resource inflows, resource outflows, and waste management. As a provider of transportation services, Odfjell does not engage in activities that generate significant resource inflows or outflows in the conventional sense. Consequently, our operations produce limited waste, which is managed in compliance with all applicable regulations. Based on these considerations, we do not regard Circular Economy as a material topic for Odfjell.

However, we have assessed its relevance through our LEAP process and other rigorous methodologies to ensure alignment with sustainability reporting standards.

Assessment of life cycle impacts and ship recycling

A comprehensive lifecycle assessment of our vessels has been conducted, with regard to carbon emissions.

Ship recycling has been identified as a distinct topic but falls outside the scope of ESRS E5 since it does not involve direct resource inflows, outflows, or waste as defined by ESRS E5 AR 4. Ship recycling is defined as a company specific topic and addressed separately in ENT1 Ship recycling.

IRO-1-G1 Description of the processes to identify and assess material business conduct-related impacts, risks and opportunities

Introduction

The shipping industry operates in a dynamic, globally interconnected environment, engaging with diverse regulatory frameworks, cultures, and business practices. This complexity increases exposure to integrity-related risks, such as facilitation payments and corruption. Maintaining strong business conduct practices is crucial for ensuring compliance, fostering trust, and upholding ethical standards.

This chapter on ESRS G1 Business Conduct outlines Odfjell’s approach to business ethics, governance, and transparency. Through comprehensive disclosures, we provide insights into our strategy, policies, and performance, reinforcing our commitment to corporate integrity and responsible stakeholder engagement.

Key focus areas of this standard include:

• Business ethics and corporate culture: Policies and measures addressing anti-corruption, anti-bribery, and whistleblower protection.
• Supplier relationship management: Ensuring fair payment practices, particularly with small and medium-sized enterprises.
• Political influence and lobbying: Transparency in commitments and activities related to political engagement.

While human rights are integral to Odfjell’s business conduct assessments, they are covered separately under ESRS S1 Own workforce in this report.

To proactively manage integrity risks, Odfjell employs a structured approach, utilizing various methodologies and tools to assess and mitigate potential impacts, risks, and opportunities. By embedding ethical business conduct into our operations, we strengthen resilience, enhance stakeholder confidence, and contribute to a responsible and sustainable shipping industry.

Risk assessment framework

Odfjell’s integrity risk assessment draws on insights from various authoritative sources and tools, enabling a comprehensive understanding of the risks related to corruption, human rights, and business conduct matters. The following elements form the foundation of our approach:

1. Integrity risk assessment

• Conducted annually to map out potential risks and exposures across all operational areas and value chains.
• Uses data from key indexes such as Transparency International’s Corruption Perceptions Index (CPI), the Maritime Anti-Corruption Network (MACN), and various human rights indexes including the Global Rights Index and the Global Slavery Index.

2. Geographical exposure

• Risk assessments focus on countries with low CPI scores, high MACN incident rates, and identified human rights vulnerabilities.
• Examples include regions such as India, Egypt, and Bangladesh where facilitation payment requests have been reported. Ports frequently visited by Odfjell in high-risk countries are also prioritized in assessments.

3. Sector and activity analysis

• Specific activities, such as vessel operations and supply chain interactions, are assessed for integrity risks.
• The shipping sector’s exposure to practices such as facilitation payments during port calls and customs clearance is a focal point of our evaluations.

4. Inputs from established frameworks

• The Odfjell Anti-Corruption Framework aligns with the UK Bribery Act’s principles and the OECD’s Due Diligence Guidance for Responsible Business Conduct.
• Human Rights Due Diligence (HRDD) follows the OECD’s guidelines, ensuring a systematic approach to identifying and addressing potential human rights impacts. These are addressed under ESRS S1.

Criteria and methodologies for identifying IROs

To identify material IROs, Odfjell applies the following criteria:

1. Location-specific factors

• CPI scores and other risk indexes to gauge corruption
• Historical data on incidents and requests for facilitation payments in specific countries and ports.

2. Activity-specific factors

• Vessel operations and interactions at ports where integrity risks are historically prevalent.
• Supply chain activities, including procurement and relationships with suppliers.

3. Sectoral considerations

• Shipping industry-specific risks, such as customs clearance and interactions with government officials.
• Alignment with industry best practices as guided by MACN.

4. Engagement and monitoring

• Regular reporting and monitoring of integrity incidents through platforms such as the PortLog system.
• Continuous engagement with internal and external stakeholders, including whistleblower reports and industry collaborations.

Key tools and sources

Odfjell employs a range of tools and data sources to inform its integrity risk assessment process:

• Transparency International’s CPI: Provides country-specific corruption risk insights.
• MACN data: Offers detailed port-level integrity incident data.
• Human rights indexes: Includes the Global Rights Index, Global Slavery Index, and other metrics to assess human rights vulnerabilities.
• Internal monitoring tools: Dashboards and reports that track facilitation payment requests, whistleblower incidents, and compliance metrics.

Outcomes of the assessment

The outcomes of Odfjell’s integrity risk assessment have been incorporated into our broader sustainability and compliance strategies:

1. Proactive mitigation measures

• Strengthening policies and procedures to address identified risks.
• Enhancing employee training on anti-corruption and human rights principles.

2. Stakeholder collaboration

• Engaging with industry bodies such as MACN to share best practices and drive collective action.

3. Continuous improvement

• Regular reviews of the integrity risk framework to ensure relevance and alignment with emerging risks and regulatory changes.

Odfjell’s structured approach to assessing and mitigating risks related to corruption, human rights, and facilitation payments underscores our commitment to upholding the highest standards of integrity and ethical business conduct. By leveraging comprehensive methodologies and tools, we ensure that material impacts, risks, and opportunities are identified and managed effectively, fostering trust and sustainability across our global operations.

IRO-2 Disclosure Requirements in ESRS covered by the business’s sustainability statement

ESRS content index list

A list with all disclosure requirements in ESRS covered by the undertaking’s sustainability statement (Disclosure Requirement ESRS 2 IRO-2 paragraph AR 19 & ESRS 2 Appendix C) can be found at the beginning of the Sustainability Statement, see link; content index.

List of datapoints in cross-cutting and topical standards

A list of data points in cross-cutting and topical standards that derive from other EU legislation (Disclosure Requirement ESRS 2 IRO-2 paragraph 56 & ESRS 2 Appendix B) can be found in Appendix A, see link; Appendix A.

Explanation of how material information to be disclosed in relation to material impacts, risks and opportunities has been determined

Odfjell has employed a structured process to determine the material information to be disclosed in relation to the IROs assessed as material. This approach is in line with the criteria outlined in ESRS 1, section 3.2, on Material Matters and Materiality of Information. Below is a detailed explanation of our methodology:

• Materiality determination process: The material topics were identified through a double materiality assessment process. The material topics are described in detail under IRO-1 and SBM-3 of this report. This process enabled us to identify topics deemed material to Odfjell's business, stakeholders, and the environment.
• Mapping and assessment: Using the EFRAG Guidance Following the identification of material topics, we used the EFRAG Guide ID 177 – Links between AR16 and Disclosure Requirement (July and Nov. 2024). This guidance was instrumental in mapping the link between the sustainability matters listed in AR 16 and the disclosure requirements in the topical standards. Each topic, sub-topic, and sub-sub-topic identified as material was assessed for its corresponding data points.
• Categorization and disclosure of data points: We categorized data points based on their status as mandatory, conditional, if applicable, or phase-in:
  • Mandatory: Fully addressed in our disclosures.
  • Conditional and If Applicable: Addressed where relevant to our operations.
  • Phase-in: Not addressed in this reporting period, as these data points are not yet applicable.

• If policies, actions, or targets were unavailable, this has been explicitly mentioned in our comments, ensuring transparency in our reporting. Additionally, for all required metrics, estimates have been provided where actual figures were unavailable.
• Use of thresholds and judgement: No fixed quantitative thresholds were applied during the materiality assessment. Instead, professional judgement was exercised to determine applicability and materiality, ensuring a tailored and context-specific approach to each data point.

Environmental information

EU taxonomy

Executive summary

This report provides disclosures on Odfjell’s economic activities and their eligibility and alignment with the EU Taxonomy Regulation, in accordance with the requirements applicable for the reporting year 2025.

The EU Taxonomy is a classification system established by the European Union to determine which economic activities can be considered environmentally sustainable. The framework is set out in Regulation (EU) 2020/852 and has been incorporated into Norwegian law through the EEA Agreement. The Taxonomy entered into force in Norway on 1 January 2023, following its adoption under the EEA framework on 15 December 2022.

Odfjell has reported in accordance with the EU Taxonomy since the 2022 reporting year. The company’s reporting focuses on its core activities within seaborne transportation and storage of bulk liquids, with particular relevance to the environmental objectives of climate change mitigation and climate change adaptation.

On 8 January 2026, amendments to the EU Taxonomy Regulation and the associated disclosure requirements were published in the Official Journal of the European Union. These amendments form part of the EU Commission’s Omnibus simplification package, adopted in February 2025, and introduce simplified disclosure requirements and updated reporting templates. The amendments apply to 2025 reporting periods, with an option for undertakings to defer application until the 2026 reporting year.

Odfjell has elected to apply the amended EU Taxonomy Regulation and the new simplified disclosure templates for the 2025 reporting period, in line with the Omnibus simplification package.

Odfjell remains in scope for EU Taxonomy reporting, as the company is subject to the Corporate Sustainability Reporting Directive (CSRD). While the Omnibus package will result in changes to the scope of the EU Taxonomy over time, the Taxonomy currently applies to all undertakings within the scope of CSRD.

All of Odfjell’s identified activities are Taxonomy-eligible. However, the company does not currently meet all the technical screening criteria required for full Taxonomy alignment, primarily due to the applicable emissions thresholds for maritime transport activities.

The report describes Odfjell’s methodology, governance arrangements, and data collection processes for EU Taxonomy reporting. It identifies sea and coastal freight transport and retrofitting of vessels as eligible activities under the Taxonomy. While alignment criteria are not yet fully met, Odfjell has initiated significant investments in fleet renewal and energy-efficiency measures, including wind-assisted propulsion technologies, which are expected to contribute to emissions reductions and support future Taxonomy alignment.

Background and perspective on the EU taxonomy

Background

The EU Taxonomy is a classification system developed by the European Union to establish a common framework for identifying environmentally sustainable economic activities. It was introduced as a core element of the European Green Deal, with the objective of directing capital flows towards activities that support the transition to a low-carbon, climate-resilient and resource-efficient economy.

The framework is established by Regulation (EU) 2020/852 (the Taxonomy Regulation), supplemented by a series of delegated acts specifying technical screening criteria and disclosure requirements. These delegated acts have progressively expanded the scope of the taxonomy and clarified the conditions for Taxonomy eligibility and alignment across sectors.

The incorporation of the EU Taxonomy into Norwegian law was approved by the Storting in December 2021. Implementation was completed following the entry into force of the Taxonomy Regulation (taksonomiforordningen) and the Disclosure Regulation (offentliggjøringsforordningen) under the EEA Agreement on 15 December 2022. The Norwegian legislation entered into force on 1 January 2023, through the law entitled: “Lov om offentliggjøring av bærekraftsinformasjon i finanssektoren og et rammeverk for bærekraftige investeringer.”

This law incorporates the EU Taxonomy Regulation and related disclosure requirements as they are amended over time.

On 8 January 2026, amendments to the EU Taxonomy framework were published in the Official Journal of the EU (2026/73). These amendments are part of the Omnibus simplification package, adopted by the European Commission on 26 February 2025, which aims to reduce reporting complexity, streamline disclosures and improve usability of the Taxonomy framework. The amendments apply to 2025 reporting periods, with an option for undertakings to defer application until the 2026 reporting year.

Odfjell has chosen to apply the amended regulation and updated templates from the 2025 reporting year, reflecting an early-adoption approach to regulatory simplification and consistency with CSRD reporting.

Basis for preparation and regulatory framework

This EU Taxonomy report has been prepared as part of Odfjell’s sustainability statement in accordance with the applicable EU sustainability reporting framework and Norwegian implementing legislation.

The report is based on Regulation (EU) 2020/852 (the EU Taxonomy Regulation), including Article 8, which sets out the requirements for disclosure of turnover, CapEx and OpEx related to Taxonomy-eligible and Taxonomy-aligned economic activities.

The structure, methodology and presentation of disclosures follow Commission Delegated Regulation (EU) 2021/2178 (the Disclosures Delegated Act), as amended. Amendments adopted as part of the EU Commission’s Omnibus simplification package, published in the Official Journal of the European Union on 8 January 2026 and applicable to the 2025 reporting period (with an option to defer to 2026), introduce simplified disclosure requirements and updated reporting templates. Odfjell has elected to apply the amended regulation and updated templates for the 2025 reporting period.

The assessment of Taxonomy eligibility, substantial contribution and Do No Significant Harm (DNSH) is based on the technical screening criteria set out in Commission Delegated Regulation (EU) 2021/2139, as amended by Delegated Regulations (EU) 2022/1214, 2023/2485 and 2024/3215.

As Odfjell is in scope of the Corporate Sustainability Reporting Directive (CSRD) (Directive (EU) 2022/2464), the company remains subject to EU Taxonomy reporting requirements. The Taxonomy disclosures are integrated into the sustainability statement prepared in accordance with the Accounting Directive (Directive 2013/34/EU, Articles 19a and 29a) and the European Sustainability Reporting Standards (ESRS).

Odfjell’s EU taxonomy reporting

Odfjell has reported on the EU Taxonomy since 2022, demonstrating its commitment to sustainable maritime operations and compliance with evolving European sustainability regulation.

This report sets out Odfjell’s approach to EU Taxonomy reporting, including:

• Identification of taxonomy-eligible activities
• Assessment of substantial contribution, Do No Significant Harm (DNSH) and minimum safeguards
• Disclosure of financial KPIs (turnover, CapEx and OpEx)
• Integration of taxonomy reporting into Odfjell’s CSRD sustainability statement, in line with the European Sustainability Reporting Standards (ESRS)

The application of the Omnibus simplification package is reflected in the structure, level of detail and templates used in this report.

Relevance

The EU Taxonomy currently applies to undertakings that are within the scope of the Corporate Sustainability Reporting Directive (CSRD). While the Omnibus package will introduce changes to the scope of the EU Taxonomy over time, all CSRD-in-scope undertakings remain subject to EU Taxonomy reporting for the 2025 reporting year.

Odfjell SE is listed on the Oslo Stock Exchange and headquartered in Norway. The company meets the CSRD scope criteria and is therefore required to report in accordance with the EU Taxonomy Regulation.

Odfjell meets at least two of the following size thresholds:

* Excluding JV where we do not have operational control iaw CSRD

Methodology and eligibility

Activities and consolidation

Odfjell’s core business includes the seaborne transportation of bulk liquids and their storage through our joint venture terminals. These activities are relevant under the EU Taxonomy framework, particularly in relation to climate change mitigation and adaptation objectives.

However, our EU Taxonomy reporting does not include Odfjell’s investments in terminals and its associated activities. This is because Odfjell does not consolidate revenues from its joint venture terminals, nor does it have operational control over these entities. While ESRS follows assets on the balance sheet plus operational control, the EU Taxonomy solely follows how revenue, CapEx, and OpEx are recorded in consolidated financial statements.

For reporting revenue from eligible and aligned activities, the Taxonomy's definition of the turnover KPI refers to IAS 1 82(a), which means that sales revenue from consolidated entities is included, while revenue from investments in associates and joint ventures (JVs) is excluded. Based on this, Odfjell’s terminals were not included in 2024 Taxonomy reporting, and hence not in 2025.

This change was adopted in 2024, as a part of the CSRD reporting

Governance and ownership structure of terminals

Odfjell is an integrated shipping company with ownership stakes in terminals located in the United States, Belgium, and South Korea.

The United States and South Korea terminals are structured as joint ventures, where Odfjell holds a 50% ownership stake. The Belgium terminal is an associated company.

In our financial reporting, Odfjell Terminals (Terminals) are accounted for using the equity method rather than full consolidation. Although these terminals support chemical storage and transportation, they are independently operated as public terminals and not specifically integrated into Odfjell’s shipping activities. Governance of these terminals is managed through shareholder agreements, which allocate equal control among shareholders and establish a board with equal representation from each shareholder. As such, Odfjell does not have operational control over these terminals and is not a controlling owner.

Due to the lack of operational control, terminals are not consolidated in Odfjell’s financial statements nor included in our sustainability reporting and taxonomy reporting. Instead, these terminals are considered part of the upstream value chain for Odfjell’s activities and are accounted for as such.

Our sustainability statement includes material topics identified through the double materiality assessment, covering upstream, core operations, and downstream activities. A value chain analysis (VCA) has been developed to evaluate sustainability topics across the entire value chain (Ref. ESRS 1). This analysis has also played a key role in disclosing scope 3 carbon emissions, assessing human rights impacts, and managing supplier relationships.

The sustainability statement consolidates all controlled entities in the Odfjell Group, using the same methodology as our financial reporting.

Data collection

The EU Taxonomy has six environmental objectives; however, well-defined criteria have only been developed for two objectives relevant to Odfjell's activities: climate change mitigation and adaptation.

The data used in the taxonomy assessment consists primarily of qualitative evaluations under the substantial contribution criteria, the Do No Significant Harm (DNSH) principle, and Minimum Safeguards (MS). No quantitative data has been employed, and Odfjell does not meet the alignment criteria.

This report further details the calculations of OpEx, CapEx, and revenue. The data aligns with ESRS reporting and is consistent with Odfjell’s financial statement, and is subject to limited assurance. Emissions data play a crucial role in sustainability reporting and in evaluating compliance with the taxonomy criteria. These emissions data undergo external review and verification by DNV, ensuring their accuracy and reliability.

Eligibility and compliance

Eligibility and transitional activity

The EU Taxonomy establishes criteria to determine whether an economic activity qualifies as environmentally sustainable. To be considered Taxonomy-eligible, an activity must fall under the environmental objectives defined in the Taxonomy and meet the substantial contribution criteria outlined in Regulation (EU) 2020/852.

Odfjell’s possible Taxonomy-eligible activities include:

• Sea and coastal freight water transport (6.10)
• Retrofitting of sea and coastal freight and passenger water transport (6.12)

These activities align with the delegated acts adopted under Article 10(3), Article 11(3), Article 12(2), Article 13(2), Article 14(2), and Article 15(2) of Regulation (EU) 2020/852, which specify the technical screening criteria for substantial contribution to climate change mitigation and adaptation.

The activity is a transitional activity as referred to in Article 10(2) of Regulation (EU) 2020/852, provided it complies with the remaining technical screening criteria.

Odfjell has not had activity under 6.12 that meets the eligibility criteria in 2025. The investments in sails can in good conditions meet the requirements of a 15% reduction in fuel consumption, but we decide to take a strict interpretation, as this cannot be achieved when it is no wind. CapEx and OpEx related to WAPS do not meet the material threshold of 10% under the regulation Delegated Regulation 2026/73 of 4 July 2025, and not assessed as a separate activity under 6.12, but investments are included in 6.10

Assessment of compliance with article 3 criteria

To qualify as Taxonomy-aligned, an activity must:

• Contribute substantially to at least one environmental objective and meet the technical screening criteria established in the delegated acts
• Do no significant harm (DNSH) to other environmental objectives
• Comply with minimum social safeguards

Odfjell assessed its activities using these compliance criteria and found that while its operations are Taxonomy-eligible, they do not currently meet all requirements for full Taxonomy alignment. Odfjell meets the criteria for minimum safeguards (MS) and DNSH, but as Odfjell is not in alignment with the substantial contribution criteria, we have limited the explanation of MS and DNSH, and refer to other relevant ESRSs.

Interpretation of alignment

As described in this report, Odfjell’s Taxonomy-eligible activities have been assessed against the technical screening criteria for Climate Change Mitigation set out in Commission Delegated Regulation (EU) 2021/2139, as amended.

Based on this assessment, Odfjell’s eligible maritime transport activities do not meet the applicable emission intensity thresholds required to qualify as making a substantial contribution to the Climate Change Mitigation objective. Consequently, no turnover associated with these activities qualifies as Taxonomy-aligned under Environmental Objective 1.

In addition, Odfjell has assessed whether any of its economic activities may qualify as making a substantial contribution to Climate Change Adaptation (Environmental Objective 2) in accordance with Regulation (EU) 2020/852 and the related technical screening criteria.

The criteria for substantial contribution to Climate Change Adaptation require that an activity:

• has identified the material physical climate risks relevant to the activity through a climate risk and vulnerability assessment; and
• has implemented physical and/or non-physical adaptation solutions that substantially reduce the most significant identified climate risks; and
• qualifies either as a Taxonomy-aligned activity in its own right or as an enabling activity within the meaning of Article 16 of Regulation (EU) 2020/852.

Odfjell has considered whether operational measures such as weather routing systems could qualify as adaptation solutions. While such measures contribute to operational resilience and risk management, they do not constitute a standalone Taxonomy activity, nor do they qualify as an enabling activity as defined under the Regulation. Accordingly, they cannot be considered Taxonomy-aligned turnover.

The potential inclusion of related CapEx or OpEx has also been evaluated in accordance with Commission Delegated Regulation (EU) 2021/2178, which sets out the methodology and templates for Article 8 disclosures. Any expenditures associated with such measures are limited in scale and fall below the applicable materiality threshold for separate disclosure.

On this basis, Odfjell concludes that it does not have economic activities that meet the criteria for substantial contribution to the Climate Change Adaptation objective, and therefore reports no Taxonomy-aligned turnover, CapEx or OpEx under Environmental Objective 2.

Accounting principles

Accounting policy

Odfjell’s accounting principles are presented in note 2 of the Group’s financial statement. The Odfjell Group prepares its consolidated financial statements in accordance with International Financial Reporting® (IFRS) as adopted by the EU.

For 2023 reporting, Odfjell included its share of joint ventures (JVs) in the taxonomy calculations. However, from 2024 reporting, terminal activities in joint ventures have been excluded as previously described. Storage is not a screened activity under the EU Taxonomy and, therefore, is not an eligible economic activity.

Changes in reporting from 2024 to 2025

Odfjell has adopted the new guidance and new templates in line with the delegated act of 8. January 2026.

The new guidance provides changes in the way KPI is calculated. For Odfjell, this will not be any changes, as denominator is zero both in 2024 with the old KPI, and in 2025with the new.

Odfjell do not report on Nuclear and Gas, in line with the new guidance.

Compared to 2024 reporting, we have reduced the reporting related to Do no Significant Harm (DNSH) and Minimum Safeguards (MS) to only report for one objective, as the economic activity is not aligned. Information related to DNSH and MS is fully described in other parts of the ESRS reporting.

Material changes in CapEx plan

Odfjell remains committed to investing in sustainable technologies, with a particular focus on retrofitting vessels for fuel efficiency and initiating investments in wind-assisted propulsion. While Odfjell has not yet developed a dedicated CapEx plan to ensure future EU Taxonomy alignment, ongoing investments in retrofits and fleet renewal may support alignment in the future. As of 2025, no material CapEx investments have been reclassified as Taxonomy-aligned, but this may change in future reporting cycles. Adopting the 10% threshold, it is unlikely that retrofit activities under 6.12 will be material

Odfjell has initiated investments in retrofit activities, specifically for wind-assisted propulsion. While these investments may qualify under a separate economic activity (Retrofits), they will not contribute to the alignment of activity 6.10 (Sea and Coastal Freight Water Transport) under the EU Taxonomy.

Odfjell will continue to evaluate investment strategies to enhance sustainability while monitoring regulatory developments for future Taxonomy alignment opportunities.

KPI contextual information

Contextual information about turnover KPI

Odfjell’s turnover is determined by gross revenue from sea transport (Ref Financial Statement, note 4).

Odfjell does not have amounts related to Taxonomy-aligned activities pursued for internal consumption.

Odfjell has sustainability-linked loans as well as transition finance loans. Activities under these frameworks are the same activities as the defined eligible activity. Future activities under the Transition Finance Framework may be aligned when they meet CapEx criteria or retrofit activity criteria.

Contextual information about taxonomy CapEx KPI

Contextual information about OpEx KPI

The denominator has, since 2023, been adjusted to exclude operational expenses at JV terminals.

Taxonomy criteria and alignment of environmental objectives

For the 2025 reporting period, Odfjell has assessed its activities against the technical screening criteria for Climate Change Mitigation (Environmental Objective 1) as set out in Regulation (EU) 2020/852 (the EU Taxonomy Regulation) and the related delegated acts.

The assessment is based on:

• Commission Delegated Regulation (EU) 2021/2139 (Climate Delegated Act), establishing the technical screening criteria for climate change mitigation and adaptation, as amended;
• Commission Delegated Regulation (EU) 2023/2485, which introduced amendments to the technical screening criteria for climate objectives;
• Commission Delegated Regulation (EU) 2021/2178 (Disclosures Delegated Act), specifying the reporting methodology, templates and key performance indicators, as amended.

Amendments adopted under the EU Commission’s Omnibus simplification package, published in the Official Journal of the European Union on 8 January 2026 and applicable to the 2025 reporting period, have introduced streamlined reporting requirements. In line with these amendments, Odfjell reports solely on the Climate Change Mitigation objective for 2025.

Furthermore, following the Omnibus amendments, Odfjell is not required to disclose information relating to activities covered by Commission Delegated Regulation (EU) 2022/1214 (gas and nuclear activities) for the 2025 reporting period.

In accordance with the updated regulatory framework, Odfjell has not reproduced the full legal text of the technical screening criteria in this report. Instead, a concise description of the applicable criteria is provided for clarity. For the complete and authoritative wording of the requirements, reference is made to Regulation (EU) 2020/852 and the relevant delegated acts, as amended.

Substantial contribution to objective 1 - climate change mitigation

Odfjell only meets one of two criteria.

Do no significant harm criteria for climate change mitigation

(Annex 1 refers to Annex in EU 2021/2139 amended by 2022/1214, 2023/2485 and 2024/3215)

Governance and minimum safeguards

Minimum safeguards

Minimum safeguards platform on sustainable finance criteria

The Platform on Sustainable Finance delivered its final report on minimum safeguards in October 2022, advising on the application of minimum safeguards (MS) in relation to the Taxonomy Regulation Articles 3 and 18. It does so by a) embedding MS in existing EU regulation, b) identifying substantive topics relating to the standards and norms referenced in Article 18 of the Taxonomy regulation and c) presenting advice on compliance with MS. The report highlights following indicators of non-compliance with MS.

Odfjell does not meet any of the criteria for non-compliance and therefore meets the criteria for minimum safeguards.

Double counting

All Odfjell’s activities are regarded as eligible and related to one activity and so avoiding the risk of double counting.

EU taxonomy templates

E1 Climate change

Introduction to climate change

This chapter of the Sustainability Statement addresses the reporting requirements of ESRS E1. Odfjell has developed a transition plan for climate mitigation, which is closely linked to climate risk and impact, risk, and opportunity (IRO) disclosures in the General Disclosures section, as well as other aspects of the topical standard in E1.

The transition plan also incorporates considerations for a just and equitable transition, which are relevant to the S1 and S2 disclosures. Due to the disclosure requirements of the ESRS, there is a risk of overlapping topics related to climate change.

ESRS 2 SBM-3-E1 Material climate change-related impacts, risks, and opportunities and their interaction with strategy and business model

The double materiality assessment outlined in ESRS IRO-1 (see link, IRO-1) identified the following material impacts, risks and opportunities: climate change mitigation, climate change adaptation and energy consumption, as described in the table below.

At Odfjell SE, our strategic ambition regarding climate change is rooted in a profound commitment to sustainability and long-term value creation. Recognizing the critical importance of mitigating climate risks, we have integrated comprehensive climate strategies into our core business operations. Our approach is guided by the principles of transparency, accountability, and continuous improvement, ensuring that we not only meet, but exceed regulatory requirements and stakeholder expectations. Odfjell’s climate targets you can find in our climate change transition plan, see link E1-1 Climate targets.

Our actual negative impact on climate change occurs in our own operations and across our whole value chain in the short, medium and long term. Our biggest environmental impact is our emission of GHG from our operated fleet globally on all oceans and coastal waters. The main source of GHG emissions is carbon dioxide (CO₂) from the combustion engines on our vessels (scope 1). The most significant factors for emitted CO₂ are:

• Fleet size (number of operated ships)
• Efficiency of the ships (technology, fuel efficiency)
• Operation of the ships (speed, routing, port time)

These factors will vary from year to year. The most important factor for absolute emissions is the size of the fleet. The Odfjell fleet consists of the Odfjell controlled fleet (Owned, Bareboat) and the Odfjell operated fleet (Owned, Bareboat, Time Chartered to Odfjell and Pool), see link; ESRS 2 BP-1.

Odfjell mitigates its material climate change impacts by focusing on reducing scope 1 emissions from our operations, improving energy efficiency in our offices, and engaging with upstream value chain partners to address and minimize scope 3 emissions.

This actual reduction of a negative impact occurs in our own operations over the short, medium and long term by reducing GHG emissions through optimized route planning and improved energy efficiency through retrofits. See our fleet transition plan E1-1 for further descriptions, see link; E1-1.

Our analysis has identified an inherent risk that ships may not be able to meet emissions and energy-efficiency requirements. For more details, see link; E1-1. However, the same analysis indicates that, due to Odfjell’s initiatives to reduce emissions across our existing fleet and the estimated lifespan of our vessels, we do not consider the risk of stranded assets to be significant. Reference, see link; ESRS 2 IRO-1-E1 and notes on financial risk in Financial Statement. Despite these risks, Odfjell’s commitment to sustainability position Odfjell as a preferred provider, offering lower costs for customers when CO₂ is taxed and scope 3 emissions are reported.

In our climate risk assessment, we have identified relevant climate physical and transitional risks, using the TCFD framework. We have presented an analysis of the most significant risks with a potential financial impact related to climate risk. For results, see link; ESRS 2 IRO-1-E1.

Climate change adaptation is considered a material issue due to its potential impact on our employees and workers across the value chain. Extreme weather events—such as heatwaves and severe cold—pose risks to infrastructure, health and safety, and operational continuity, increasing the likelihood of marine casualties. In addition, stricter international and regional regulations on emissions (e.g., tighter sulphur limits and black carbon restrictions) may require significant operational and technological adjustments.

Although adaptation needs are challenging to assess, short-term measures will focus on managing increased heat and more volatile weather conditions. Building resilience into our operations is essential to ensure continuity and reduce vulnerability to climate-related disruptions.

Adaptation measures will also have broader societal implications. For example, transitioning to alternative fuels such as e-fuels will demand substantial inputs of renewable energy. This creates challenges, as higher demand for green energy in shipping could reduce its availability for other sectors, potentially leading to indirect or replacement emissions.

Energy consumption across our value chain includes:

Scope 3: Energy embedded in the production of purchased goods and assets.

Scope 2: Indirect emissions from electricity and heating in our offices globally

Scope 1: Fuel consumption on our own vessels, externally operated ships, and transshipment activities.

Transitioning to sustainable energy sources is a key enabler for decarbonization and cost efficiency, reducing environmental impact while supporting long-term resilience.

Resilience of our strategy and business model related to climate change related impacts.

Odfjell has assessed the resilience of its strategy and business model through comprehensive climate and nature risk assessments, as well as a double materiality assessment. These analyses incorporate climate scenario assessments to evaluate potential future risks and opportunities associated with climate change. Our approach ensures a holistic understanding of how climate-related factors may impact our operations, financial stability, and long-term strategic positioning.

The resilience of Odfjell’s business model is further supported by the flexibility of our fleet and the diversification of our customer base. Our vessels are equipped with stainless steel tanks, enabling them to carry a wide range of liquid cargoes and adapt to changes in product demand and regulatory requirements. Odfjell serves a broad and diversified customer portfolio across geographies and industries, and is not dependent on a limited number of customers or products. This flexibility reduces exposure to transition risks linked to shifts in specific value chains or markets, supports continued fleet utilisation under different climate transition scenarios, and strengthens the long-term resilience of our strategy and business model.

The resilience analysis has been conducted as part of our ongoing risk management and strategic planning efforts. We have systematically assessed transition risks, direct physical risks, and financial implications using climate scenario analysis aligned with the requirements set out in ESRS 2 IRO-1. These assessments consider multiple time horizons to evaluate both short- and long-term risks to our fleet, business operations, and financial performance.

Our risk assessments include evaluating the financial impact of transition risks, such as regulatory changes, carbon pricing mechanisms, and evolving market expectations. The analysis also considers direct risks posed by physical climate hazards, including extreme weather events and long-term shifts in environmental conditions. The findings from these assessments are integrated into our broader corporate strategy and sustainability roadmap.

The results of our resilience analysis indicate that Odfjell’s business model is currently robust when considering the impacts of climate change and transition risks as they are presently understood. Our strategic initiatives to reduce emissions across our existing fleet, coupled with the estimated lifetime of our vessels, ensure that we do not face a risk of stranded assets. Additionally, our approach to fleet renewal and energy-efficiency improvements mitigates the risk of locked-in emissions, supporting our long-term decarbonization strategy.

We have developed a clear pathway to align with industry standards and achieve net-zero emissions. This includes investments in energy-efficient technologies, operational efficiencies, and ongoing engagement with regulatory and industry bodies to remain ahead of evolving requirements. While our current analysis supports the resilience of our business model, we acknowledge that the regulatory landscape is continuously evolving. New regulations could pose additional challenges, particularly if they impose restrictions that limit our ability to trade ships. As part of our commitment to proactive risk management, we will continue to monitor and adapt our strategy to ensure ongoing compliance and alignment with global climate objectives.

Additionally, we actively engage with stakeholders to incorporate their insights into our risk management and strategic planning processes, ensuring our business model remains adaptable and forward-looking. Please also see link; ESRS 2 SBM-3 Resilience of strategy and business model.

The financial effects of our material risks and opportunities on our financial position, financial performance and cash flows were evaluated in the financial materiality assessment in the DMA process and follow our corporate risk level definitions for consequences. Please also see link, ESRS 2 SBM-3 Financial effects of material risks and opportunities and ESRS 2 IRO-1 Methodologies and assumptions applied.

Resilience analysis: assumptions and methodology

Odfjell has assessed the resilience of its strategy and business model in relation to climate change through scenario analysis and risk assessments, as described under ESRS 2 SBM-3. Climate-related risks and opportunities are integrated into the company’s strategy and enterprise risk management processes, and the Board of Directors oversees the assessment of climate risks and the implementation of the company’s transition plan. The resilience analysis evaluates how the transition to a lower-carbon economy and the physical impacts of climate change may affect Odfjell’s operations, markets and long-term strategic positioning.

The analysis is based on several key assumptions regarding macroeconomic developments, energy markets and technology deployment. It assumes continued global demand for seaborne transportation of chemicals and sustained international trade, while recognising that the sector will operate under increasingly stringent climate-related regulation and carbon pricing mechanisms. The analysis further assumes that the costs associated with the energy transition will increase over time and that customers will gradually share a greater portion of these costs across the maritime value chain.

With regard to energy use and fuel availability, the analysis assumes a gradual transition from conventional marine fuels towards fuels with lower lifecycle emissions. Sustainable biofuels are expected to play an important role in the medium term due to their compatibility with existing vessel technology, while the availability of scalable zero- or near-zero-emission fuels is expected to increase over the longer term as technologies mature and supporting infrastructure develops.

The analysis also assumes continued improvements in vessel energy efficiency through fleet renewal, retrofit measures and operational optimisation, as described under ESRS E1-3. Emerging technologies are expected to be adopted gradually as they become commercially viable. Certain technologies, such as onboard carbon capture, are currently not considered part of Odfjell’s transition pathway, while others, including nuclear propulsion, are considered technically possible but unlikely to become commercially relevant in the near term due to long development timelines and high costs. Shore power is expected to develop gradually but is not considered a primary decarbonisation lever for the company’s deep-sea operations. The analysis further recognises dependencies related to the availability of sustainable fuels, regulatory developments, access to capital, shipyard capacity and the pace of technological development.

The resilience analysis considers short-, medium- and long-term time horizons, reflecting the typical asset lifetime of vessels in the chemical tanker segment, which may extend up to 30 years. Short-term assessments focus on the coming five years and primarily consider regulatory developments and operational improvements. Medium-term assessments extend to approximately 2030–2040 and focus on fleet renewal, scaling of lower-carbon fuels and implementation of new technologies. Long-term assessments extend towards 2050 and are aligned with Odfjell’s net-zero target disclosed under ESRS E1-4.

For physical risk analysis, Odfjell has primarily assessed IPCC scenarios representing higher levels of warming, as these are expected to have the most significant operational implications for maritime transport. A separate physical risk analysis based on a 1.5°C scenario was not conducted, as it was not expected to materially change the company’s physical risk profile. In addition, transition pathways such as the IEA Net Zero Emissions scenario were considered as reference points for assessing long-term transition dynamics.

The resilience analysis assumes implementation of the mitigation actions and transition measures described under ESRS E1-3 and the transition plan under ESRS E1-1, including fleet renewal, operational efficiency improvements and the gradual adoption of lower-carbon fuels. Climate-related considerations are integrated into strategic investment decisions, including fleet renewal, which is a key element of maintaining competitiveness and regulatory compliance in a lower-carbon economy.

While the potential financial implications of climate-related risks and the transition are considered qualitatively as part of the resilience assessment, long-term financial impacts remain subject to significant uncertainty due to factors such as fuel availability, technology development, regulatory changes and market conditions. The resilience analysis therefore focuses on assessing the robustness of Odfjell’s strategy and transition pathway under a range of plausible climate scenarios rather than producing precise long-term financial projections.

E1-1 Transition plan for climate change mitigation

Introduction

In line with the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS), Odfjell presents its Transition Plan for Climate Change Mitigation. The plan outlines our strategic approach to reducing greenhouse gas (GHG) emissions and preparing the Company for a low-carbon future, while maintaining safe, reliable and commercially resilient operations.

The primary objective of the transition plan is to reduce emissions across our operations and contribute to global climate goals, including those set out in the Paris Agreement. The plan describes how Odfjell manages climate-related risks and opportunities, integrates decarbonisation into strategic decision-making, and aligns climate targets with operational measures, capital allocation and long-term fleet planning.

Decarbonisation is embedded across our business through the integration of climate considerations into capital expenditure (CapEx), operating expenditure (OpEx) and revenue generation. Investments focus on energy-efficient newbuildings, fleet upgrades and retrofits, operational improvements, and the use of lower-emission fuels. Together, these measures support near-term carbon-intensity reductions while preserving long-term optionality as technologies and fuel pathways evolve.

Operational efficiency, stakeholder engagement and continuous monitoring are central to achieving our climate objectives. Odfjell seeks to balance regulatory compliance, technological development and financial discipline to ensure resilience in a regulatory and market environment that remains subject to uncertainty and change.

While sector-wide decarbonisation pathways for shipping are still evolving, Odfjell has developed a robust and pragmatic transition plan designed to deliver sustained emissions reductions over time. Although explicit alignment with a 1.5°C trajectory cannot currently be confirmed, the plan sets out concrete actions to reduce carbon intensity in the short and medium term and supports the broader decarbonisation of the maritime sector.

This transition plan serves as a high-level framework. Further disclosures are provided in Odfjell’s Sustainability Statement. Due to strategic and competitive considerations, detailed fleet-specific transition plans are not publicly disclosed.

Regulatory developments and continuity of the transition plan 2025

In April 2025, the International Maritime Organization (IMO) took an initial vote on the Net Zero Framework (NZF) at the Marine Environment Protection Committee (MEPC). In response, Odfjell assessed the potential implications of the proposed framework and updated internal fleet transition planning to ensure readiness for the expected regulatory direction.

However, following the Extraordinary MEPC session in October 2025, the adoption of the Net Zero Framework was postponed. As a result, no new binding international climate regulations for shipping entered into force during the year. Consequently, Odfjell has reverted to the transition plan framework originally presented in the Annual Report for 2025.

The transition plan included in the 2025 Annual Report is therefore largely unchanged. Climate targets remain the same, and no material regulatory assumptions have been revised. This reflects the purpose of a transition plan: to provide a stable, long-term strategic framework that is resilient to regulatory timing uncertainty while remaining adaptable as new requirements are adopted.

Despite the postponement of the IMO Net Zero Framework, Odfjell remains fully committed to acting in line with its climate targets. We continue to implement operational, technical and fuel-related measures to reduce emissions and prepare the fleet for future regulatory developments, ensuring that the Company is positioned to deliver on its climate ambitions irrespective of short-term regulatory delays.

Other changes for 2025 reporting

The transition plan related to capital expenditures is updated to reflect the most recent commitments.

Just and equitable transition

At Odfjell, a just and equitable transition means ensuring that the shift to low-carbon shipping is inclusive and beneficial for all stakeholders, including workers, communities, consumers, and the broader maritime industry. This approach recognizes that addressing climate change is not solely about reducing emissions but also about ensuring fairness and equity throughout the transformation process.

Double materiality and social matters

Our double materiality assessment identifies impact, risk, and opportunities, highlighting the importance of integrating social considerations into our transition strategies. Social matters, identified as material to Odfjell, play a pivotal role in shaping our transition plan. As we work to mitigate climate change, we are committed to addressing the social implications of our actions, ensuring that they are fair and inclusive for all.

Just transition and climate disclosures

The concept of a just transition is particularly relevant to Odfjell’s plan for climate change mitigation. A just transition requires careful consideration of the social impacts of moving towards a climate-neutral and more sustainable economy. It is widely recognized that this shift has significant implications for workers, communities, and consumers across various sectors, including energy, transport, and financial services.

Supporting workers and communities

For the shipping industry, a just transition involves supporting seafarers and other workers as we adopt new technologies and fuels. Odfjell actively participates in initiatives like the IMO Maritime Just Transition Task Force, which focuses on preparing the workforce for the future by prioritizing safety, education, and skills development. Ensuring that our workforce is adequately trained and supported during this transformation is a priority.

We are also committed to minimizing disruptions for workers and communities affected by the transition from fossil fuels. This includes engaging with stakeholders, sourcing responsibly, and upholding human rights across our supply chain. By addressing these challenges directly, Odfjell aims to reduce potential inequities and strive for the benefits of decarbonization are distributed fairly.

Avoiding unintended consequences

A just transition means recognizing and addressing the broader social and economic impacts of decarbonization. It is essential to ensure that the decarbonization of the shipping industry does not inadvertently increase emissions in other sectors or transfer the challenges to other parties. Odfjell remains committed to a holistic approach that prioritizes fairness and equity across the value chain, including our partnerships with suppliers and customers.

Leadership in sustainable shipping

By embedding the principles of a just and equitable transition into our business practices, Odfjell aims to lead the creation of a sustainable shipping industry. This involves not only addressing the urgent need for climate action but also supporting people and communities throughout the transition. Our commitment to fairness, equity, and inclusivity ensures that our journey toward a low-carbon future is one that leaves no one behind.

Climate targets

Greenhouse gas emissions

According to the GHG Protocol, emissions are categorized into three scopes to help organizations identify and manage their greenhouse gas emissions comprehensively:

Scope 1: Direct emissions from sources owned or controlled by the company. For Odfjell, these primarily include emissions from the combustion of fuel in the company’s operated vessels. Scope 1 emissions constitute approximately 58.8% of Odfjell's total emissions.

Scope 2: Indirect emissions from the generation of purchased electricity, steam, heating, or cooling consumed by the company. For Odfjell, scope 2 emissions represent less than 0.1% of total emissions, reflecting the relatively minor role of electricity consumption in the company’s operations.

Scope 3: All other indirect emissions that occur in the value chain of the company, including both upstream and downstream activities. For Odfjell, scope 3 emissions, such as those from shipbuilding, supply chain activities, fuel production and end-of-life disposal, account for approximately 41.2% of total emissions. 37.4% of scope 3 is related to fuel activities (Scope 3 cat. 3).

Climate targets

Odfjell has set the following climate targets (Ref to other parts of ESRS E1-4):

1. Odfjell will cut greenhouse gas emissions by more than 57% by 2030 compared to 2008.
2. Odfjell is dedicated to pursuing a zero-emission strategy and will only order new net zero-capable vessels.
3. Odfjell will be a net-zero company by 2050.
4. Odfjell will support initiatives to develop technology for decarbonization, energy efficiency, and net zero emissions, promoting a fair and equitable transition.
5. Odfjell will actively collaborate with our suppliers and customers to improve energy efficiency and reduce total emissions from our activities.

Absolute emissions

Odfjell is committed to transparency and leadership in the maritime industry's journey toward decarbonization. As part of our climate change mitigation strategy, we recognize the importance of distinguishing between absolute emissions and emissions intensity—two key metrics that offer distinct perspectives on our environmental performance.

Absolute emissions represent the total volume of GHGs emitted, regardless of activity levels or fleet size. This metric aligns with global climate goals such as the Paris Agreement, which targets absolute reductions in emissions.

Emissions intensity, on the other hand, measures emissions per unit of transport work, such as per ton-mile. This provides a normalized benchmark for operational efficiency, reflecting how effectively we are reducing emissions relative to our business activities.

Odfjell reports emissions from both its controlled fleet (owned vessels) and operated fleet (chartered vessels and pool vessels). Including time charter (TC) vessels and pool vessels in our absolute emissions ensures comprehensive transparency. However, this approach presents a dilemma: while we strive to decarbonize, we do not have direct control over the long-term trajectories of vessels we do not own.

Odfjell's absolute emissions may increase if our fleet grows, either organically or through a larger operated fleet. This growth does not imply higher emissions globally, as other owners might operate these vessels less efficiently. By integrating these vessels into Odfjell's operations, we often achieve greater efficiency and lower emissions on a holistic scale. Nonetheless, this limits our ability to design a clear trajectory for absolute emission reductions since our fleet size, vessel mix, and access to decarbonization technologies are dynamic and partly outside our control.

Navigating toward net zero

Odfjell has set an ambitious target of achieving net-zero absolute emissions by 2050. However, this pathway is complex due to factors such as:

The reliance on external developments, including the availability and adoption of new low- and zero-carbon fuels.

The timeline for phasing out older vessels and replacing them with ships equipped with advanced technologies.

Uncertainties in fuel pricing, infrastructure readiness, and the pace of global regulatory developments.

We anticipate that the most significant reductions in absolute emissions will occur closer to 2050 as the adoption of alternative fuels matures and well-to-wake emissions decrease. Older, less efficient vessels will be retired, and state-of-the-art technologies will dominate the fleet. In the meantime, intensity-based targets provide an actionable metric for driving operational efficiency and ensuring year-on-year improvements. The historic absolute emissions in tCO₂eq and prediction pathways in the figure below illustrate this.

About the targets

The targets encompass relevant greenhouse gas emissions in accordance with the Kyoto Protocol, specifically covering carbon dioxide (CO₂), methane (CH₄), and nitrous oxide (N₂O). Other gases listed under the protocol are not applicable to Odfjell’s operations.

The Odfjell fleet’s emission reduction target for 2030 (Target 1) is an intensity-based target, for our controlled fleet measured using the Annual Efficiency Ratio (AER), and benchmarked against the International Maritime Organization (IMO) standards, using 2008 as the baseline. AER calculations are conducted in accordance with IMO regulations, specifically MARPOL Annex VI, Regulation 2.49, and the guidelines outlined in documents MEPC.336(76), MEPC.337(76), MEPC.338(76), and MEPC.339(76). This is used for the IMO Carbon Intensity Indicator (CII).

Emission calculations are based on the applicable carbon factors as stipulated in Regulation (EU) 2023/957, which amends Regulation (EU) 2015/757, including Annexes I and II.

EU ESRS requires a reference baseline. The baseline for the AER target is a linear trajectory that can be calculated from the 2008 reference and the 40% reduction in 2030. Odfjell will therefore use a reference value based on the IMO industry standard of AER of 11.45 in 2021. Targets cover our controlled fleet, consisting of owned, bareboat and financial lease vessels, but exclude time charter and pool vessels.

Net zero emissions for Odfjell means reducing greenhouse gas emissions across the value chain to as close to zero as possible, with any remaining emissions neutralised through permanent removals. This is accomplished by reducing emissions through efficiency improvements and sustainable fuels, carbon capture or shore power, and offsetting any remaining emissions via verified carbon reduction projects. The goal is to ensure that all emissions are addressed on a full well-to-wake lifecycle basis, targeting net zero by 2050 in line with the IMO’s GHG reduction strategy.

Net zero capable is defined as a vessel that is technically adaptable and prepared for the retrofit of machinery and fuel systems that can accommodate alternative fuels or emission reduction technologies, including emission capture systems. This readiness is contingent on the commercial, environmental, and practical feasibility of such technologies at the time of implementation. A net zero capable vessel must be equipped for the use of alternative fuels, such as biofuels, bio-LNG, e-ammonia, and e-methanol, as and when these become viable. Additionally, it should be prepared for carbon capture and storage (CCS) systems, if applicable, and optimized for energy efficiency through measures like shore power integration and wind-assisted propulsion.

The net-zero emission target for 2050 reflects Odfjell’s long-term ambition to contribute to global climate goals. However, achieving this target is subject to various uncertainties and factors beyond Odfjell’s direct control, including but not limited to the availability, scalability, and affordability of alternative fuels and technologies, evolving regulatory frameworks, and broader market and economic conditions. While Odfjell is committed to taking reasonable measures to pursue this target, there is no guarantee that all necessary conditions will be met.

Compatibility with limiting global warming to 1.5 degrees

The Paris Agreement on climate change was agreed in 2015 by Parties to the United Nations Framework Convention on Climate Change (UNFCCC) and entered into force in 2016. The Paris Agreement’s central aim is to strengthen the global response to the threat of climate change by keeping a global temperature rise this century well below 2 degrees Celsius above pre-industrial levels, and to pursue efforts to limit the temperature increase even further to 1.5 degrees Celsius. The agreement binds states to implement actions and report on their National Determined Contributions (NDCs). The Paris Agreement does not include international shipping, but the IMO, as the regulatory body for the industry, is committed to reducing greenhouse gas emissions from international shipping. Odfjell is regulated by the IMO, and complies with the regulations and strategy to reduce greenhouse gas emissions to be net zero by 2050.

In July 2023, the IMO adopted the 2023 IMO Strategy on Reduction of GHG Emissions from Ships. The strategy falls within a broader context that includes the Paris Agreement. The IMO Strategy aims to enhance the IMO's contribution to global efforts by addressing GHG emissions from international shipping. International efforts to address GHG emissions include the Paris Agreement and its goals.

IMO GHG Strategy

The IMO has set out four levels of ambition and indicative checkpoints, to reach net-zero GHG emissions from international shipping. These targets were adopted by the Maritime Environmental Protection Committee (MEPC) 80 7 July 2023 in resolution 377(80) - 2023 IMO Strategy on reduction of GHG emissions from ships. The strategy is available on IMO’s website and not repeated here. The pathway is illustrated below.

Carbon intensity

A critical metric in the pursuit of net-zero emissions is carbon intensity, which quantifies the amount of CO₂ emissions per unit of transport work. The IMO has set forth a benchmark known as the Annual Efficiency Ratio (AER), which serves as a reference value to measure and regulate carbon intensity in line with global decarbonization efforts. While the IMO’s targets provide a framework for carbon intensity reduction, Odfjell’s approach surpasses these industry standards.

Odfjell has implemented a comprehensive and ongoing strategy focused on emission reduction, placing carbon intensity at the core of our sustainability agenda. Through continuous innovation and operational efficiency improvements, Odfjell has consistently maintained carbon intensity levels well below the benchmarks and trajectories established by the IMO. This proactive approach has enabled us to operate with significantly lower emissions since 2008, the IMO’s initial reference year, resulting in a performance surplus relative to the IMO calculated baseline in tCO₂/dwt-mile.

Fuel initiatives

FuelEU Maritime regulations (FEM) were implemented in 2025 and target a reduction in the carbon intensity of maritime fuels used within EU waters. The regulation mandates that ships reduce their carbon intensity by 2%, escalating to 50% by 2050 for voyages within the scope of the EU regulation. The regulation incentivises the use of low-carbon and renewable fuels such as biofuels, hydrogen, and ammonia while discouraging reliance on conventional fossil fuels through financial penalties for non-compliance.

FuelEU Maritime will work alongside the EU Emissions Trading System (ETS), placing a price on carbon emissions from ships, further encouraging the uptake of green fuels and energy efficiency measures.

At a global level, the IMO’s Global Fuel Intensity standard (GFI) will complement the EU’s efforts, focusing on reducing the carbon intensity of international shipping. The GFI will be a goal-based¹ marine fuel standard regulating the phased reduction of the marine fuel's GHG intensity as a part of the basket of measures that will be implemented by the IMO.

¹ Goal-based standards (GBS) in the IMO are high-level standards and procedures that are to be met through regulations, rules and standards for ships.

The IMO has also developed a Net-Zero Framework that combines economic and technical elements. The IMO voted to postpone the implementation of this framework until October 2025, leaving some uncertainty going forward regarding GFI and an economic element.

IMO strategy and alignment with climate goals: a critical perspective

The IMO strategy outlines the global ambition and framework for decarbonizing shipping. These targets are designed for the entire shipping industry and cannot be directly applied to individual ships or fleets. To achieve the goals of the Paris Agreement, the IMO intends to follow up this strategy with updated regulations that will establish a trajectory toward net-zero emissions.

Odfjell’s GHG reduction targets are aligned with the IMO’s net-zero strategy and, in some cases, exceed the IMO’s intensity targets for 2030. However, despite the IMO adopting the Paris Agreement’s objectives, there is no scientific evidence to suggest that the 50% reduction target by 2050 is sufficient to align with the 1.5°C pathway, which requires net-zero emissions across all sectors by mid-century.

Limitations of the current IMO strategy

The IMO’s strategy does not mandate immediate or aggressive enough measures to address emissions in the short term. This delay risks slowing the adoption of decarbonization technologies and practices that are urgently needed. The Intergovernmental Panel on Climate Change (IPCC) has provided clear guidance on what is required to meet the 1.5°C target:

Global emissions must decline by approximately 45% by 2030, relative to 2010 levels, and reach net-zero by 2050

For the shipping sector, this necessitates near-complete decarbonization by mid-century, with substantial reductions achieved by 2030.

However, under the current IMO strategy, projections indicate that absolute emissions from international shipping will not peak until the 2030s, let alone achieve the sharp reductions required this decade. The strategy’s reliance on efficiency improvements, while valuable, cannot deliver the absolute reductions necessary to meet the 1.5°C pathway.

Alignment with 1.5 degrees

There are multiple standards and initiatives for setting science-based targets in line with climate science. However, Odfjell has not yet verified its targets under any specific framework or standard. Public policies for the shipping sector have not defined clear sectoral pathways, making it challenging to confirm whether Odfjell’s targets are fully compatible with the 1.5°C goal. Consequently, Odfjell does not claim that its targets are aligned with the 1.5°C pathway. This position complies with the disclosure requirements under see link, E1-4.

While the IMO strategy provides a critical foundation for global shipping's decarbonization, it falls short of the scientific benchmarks needed to meet the 1.5°C target. Odfjell remains committed to ambitious emissions reduction targets and continues to advocate for more aggressive action to address climate change. As the sector evolves and public policies provide clearer frameworks, Odfjell will continue to refine its strategy and align with best practices to ensure meaningful progress toward a sustainable future.

Decarbonization levers and key actions

Odfjell has identified several key decarbonization levers to achieve its emission reduction targets:

Fleet transition plan

Odfjell has a specific fleet transition plan that includes new ships, changes to existing ships, and recycling plans for our managed fleet. This plan aims to meet the company’s strategic ambitions and targets, as well as compliance with IMO and EU regulations, lifetime considerations, and capacity for renewal. The plan is company confidential.

Transition activities

Odfjell has introduced a Transition Finance Framework (TFF), aimed to support funding our transition. The framework offers a holistic approach to transition investments, capturing both small and large decarbonization projects in which Odfjell intends to invest. The framework can be used for bonds and loans and adhere to the latest industry guidelines for use-of-proceeds and transition financing. The framework encompasses a wide range of energy-efficiency initiatives that will support Odfjell’s journey towards a climate-neutral fleet in 2050. The participating financial institutions will benefit from our commitment to transparency and see their funds being directed towards a wide range of initiatives aimed at emission reduction. The plan has the following six transition categories:

• Ship retrofit projects
• Energy-efficient solutions
• Research and development and transition strategy
• Infrastructure
• Vessel lifetime extensions
• Low-carbon and zero emissions newbuildings

For more information about our transition finance framework and sustainable finance, see our website www.odfjell.com.

Decarbonization initiatives and possible effects

Since 2007, Odfjell has implemented and tested various technologies and initiatives to reduce emissions and improve efficiency. While significant progress has been made, additional initiatives remain under consideration. These measures are categorized in the graph below, with potential improvement effects estimated by DNV.

It is important to note that not all tested or evaluated activities have been or will be implemented. The decision to proceed with any initiative is contingent upon its demonstrated ability to impact emission reductions and operational efficiency positively, and in an economically sustainable manner.

The figure below illustrates various potential levers and actions for emission reductions, as identified by the DNV Maritime Forecast. Additional technologies and operational measures will be incorporated as they become available. The figure also highlights initiatives that Odfjell has already implemented or tested.

Operational efficiency

In addition to fleet transition, we are working on improving the operational efficiency of our fleet in terms of optimal speed, weather routing, hull cleaning, port efficiency, and utilization. This is done in combination with improving information and digitalization for better decision support.

Indirect and value chain emissions

Odfjell is dedicated to achieving net-zero emissions across all scopes, including scope 3, as part of our long-term sustainability ambitions and targets. To advance these goals, we are actively collaborating with suppliers to improve scope 3 reporting accuracy by transitioning from a spend-based to an activity-based reporting approach. More than 80% of our scope 3 emissions are attributed to fuel production. These emissions are closely linked to our scope 1 reduction efforts, as our net-zero targets address "well-to-wake" emissions, encompassing emissions during production, transportation, and consumption of fuel.

At present, we have not set a formal target for scope 3 emissions. Our focus remains on enhancing data quality by collecting detailed activity-based data to replace our initial spend-based estimates.

Additionally, Odfjell is committed to reducing scope 2 emissions by implementing energy-saving measures and increasing the use of renewable energy across our office locations, despite scope 2 emissions representing less than 1% of our overall footprint.

Beyond fuel-related emissions, we are working closely with our broader supplier base to enhance reporting transparency and reduce the environmental impact of the products we source. These initiatives are integral to our ongoing commitment to minimizing our environmental footprint and fostering sustainable practices throughout our value chain.

Furthermore, Odfjell is engaging with the owners of our time chartered vessels to enhance efficiency and reduce emissions. Although we do not have direct control over these ships, they are part of our operated fleet and contribute to our scope 1 emissions. This collaboration includes knowledge sharing, as well as the implementation of technical and operational measures to drive improvements.

Complementing these initiatives, Odfjell actively supports the development of the infrastructure and technologies necessary to achieve a net zero-emission shipping industry. By doing so, we contribute to the decarbonization of the maritime value chain and the broader transition towards net-zero and sustainable shipping.

Lifetime extension

An integral aspect of reducing total emissions, including those within the value chain, is evaluating the potential for extending the lifespan of existing vessels. Shipbuilding is a significant source of emissions that are categorized under scope 3. Extending the operational life of a vessel, however, necessitates additional maintenance and upgrades, which also contribute to scope 3 emissions.

To better understand these dynamics, Odfjell conducted a Life Cycle Assessment (LCA) for a specific ship class. The assessment sought to evaluate the requirements for lifetime extension, the feasibility of obtaining certification and approval for operation beyond the design life, and the total emissions throughout the ship's life cycle. The findings revealed that scope 1 emissions generated during the operational phase of a ship significantly exceed the scope 3 emissions associated with its construction. This indicates that, over an extended period, a life extension does not substantially impact the total emissions across a ship's life cycle. These considerations will be an integral part of the transition planning.

The implementation roadmap for the transition

Investments and funding

Capital expenditures

Capital expenditure and sustainable financing

Odfjell is making significant investments in its transition plan, with a strong focus on fleet renewal and technological innovation. These investment plans are carefully aligned with the company's fleet transition strategy, ensuring that we have the capacity to execute the necessary actions related to new vessel acquisitions, time charter commitments, energy-saving devices, adoption of alternative fuels, and measures to enhance operational efficiency.

To support our sustainability ambitions, Odfjell has established two sustainable finance frameworks. The first is the Sustainability-Linked Financing (SLF) framework, which is designed for general-purpose financing. Through this framework, Odfjell can issue bonds and secure loans linked to our sustainability targets. The SLF framework has garnered significant interest from both investors and financial institutions, leading to strong demand for bonds and loans issued under this structure.

In 2024, Odfjell introduced a Transition Finance Framework (TFF), a use-of-proceeds framework that enables the issuance of bonds and loans specifically linked to activities supporting our transition to net-zero. Both the SLF and TFF frameworks are externally verified by a third-party organization and are fully aligned with the principles and guidelines set forth by the International Capital Market Association (ICMA) and the Loan Market Association (LMA).

Capital expenditure and fleet renewal

Odfjell recognises that the long-term renewal of its owned and controlled fleet, including the replacement of large stainless steel chemical tankers (“super-segregators”), is a critical enabler of the transition to a low-carbon future. These vessels, characterised by multiple segregations and stainless-steel cargo tanks, are designed to serve a wide range of trades and will incorporate state-of-the-art energy-efficiency measures and fuel-ready technologies to support future decarbonisation pathways.

Odfjell has a long track record of investing in energy-saving devices and technical upgrades across its fleet. These investments have delivered both emissions reductions and strong financial performance, with historical payback periods typically ranging from one to seven years, depending on operating profile, fuel prices, regulatory developments and trade patterns. This experience underpins our disciplined approach to capital allocation in support of the transition plan.

The Company continues to proactively test new technologies and energy-efficiency solutions with the objective of scaling those that demonstrate satisfactory technical performance and commercially reasonable payback. In 2025, Odfjell tested wind-assisted propulsion using suction sail technology on Bow Olympus, achieving positive operational and emissions-reduction results. Subject to final investment decisions, this forms the basis for potential scaling and retrofitting of additional vessels.

While specific CapEx amounts related to individual transition measures are not publicly disclosed, Odfjell expects future capital allocation to be increasingly aligned with the EU Taxonomy for sustainable activities. It is noted that deep-sea chemical tankers are not currently taxonomy-eligible until they achieve zero tailpipe emissions. In line with Odfjell’s sustainability objectives, all newbuildings will be net-zero capable and are expected to be taxonomy-aligned when operating on net-zero well-to-wake fuels, as defined in Commission Delegated Regulation (EU) 2021/2178.

Odfjell operates a diversified fleet of chemical tankers, classified as medium, large and super-segregators. Although vessels are technically designed for operational lifetimes of 30–40 years, commercial trading constraints typically limit market acceptance to approximately 20–30 years. Maintaining a competitive and efficient fleet therefore requires continuous renewal, complemented by the divestment of older tonnage for responsible and sustainable recycling.

Fleet renewal decisions are driven by technology readiness, vessel size suitability and capital efficiency. To mitigate technology and capital risk, Odfjell has adopted a flexible fleet renewal strategy that leverages long-standing partnerships with Japanese shipyards and vessel owners. This approach includes long-term time charters with purchase options, reducing exposure to large, single-cycle newbuilding programs while preserving strategic optionality in addition to two vessels that is built for Odfjell's ownership at Japanese yards.

Through these partnerships, Odfjell has secured access to modern, energy-efficient vessels on long-term charters, alongside selective ownership. The delivery schedule includes nine vessels in 2026, eleven vessels in 2027 and a planned three vessels in 2028, ranging from approximately 25,000 to 40,000 DWT. These vessels incorporate advanced energy-efficiency technologies and are a central component of Odfjell’s pathway to achieving its climate targets. Investments in wind-assisted propulsion systems and advanced rudder technologies have also been made on selected chartered vessels to further enhance efficiency and reduce fuel consumption.

Under IFRS 16, the bareboat charter components of these arrangements are capitalized over the lease term and classified as (Right-of-use) Assets. The estimated capitalized assets are approximately USD 600 million over the next three to four years.

In addition, Odfjell has established a joint venture with Nissen Kaiun to operate a combined fleet of stainless-steel chemical tankers. Odfjell Hakata Maritime AS will initially comprise ten vessels, equally contributed by Odfjell and Nissen Kaiun, further strengthening access to modern and efficient tonnage.

Collectively, these initiatives will materially increase the proportion of commercial trading days operated by modern, energy-efficient vessels, enhancing emissions performance, operational resilience and the long-term robustness of Odfjell’s transition plan.

Operational expenses

For the purpose of this ESRS E1 transition plan, Operational Expenditures (OpEx) comprise all recurring and non-capitalized expenditures required to operate the fleet and implement Odfjell’s decarbonization pathway. This definition differs from OpEx as defined under the EU Taxonomy Regulation and from OpEx as presented in Odfjell’s financial statements. In this context, OpEx reflects the total operational cost required to execute the transition plan, including voyage-related expenses, fuel, regulatory compliance costs, non-capitalized technical measures, research and development, and relevant general and administrative expenses directly supporting the green transition.

Fuel represents the most material operational expenditure in the transition plan. As low- and zero-carbon fuels become commercially available, Odfjell expects a gradual shift from conventional fuels toward biofuels and, over time, e-fuels. During the transition period, operational flexibility remains essential, and both fossil and alternative fuels will be used in parallel. Biofuels are expected to carry a price premium compared to conventional very low sulfur fuel oil, and future availability and pricing remain uncertain. The financial impact of the EU Emissions Trading System (EU ETS) further increases fuel-related operating costs. To safeguard economic viability, Odfjell applies bunker adjustment clauses and specific EU ETS clauses in its contracts, enabling cost pass-through to customers. The company also monitors and, where appropriate, adopts emerging standardized clauses developed by industry bodies such as BIMCO to ensure transparent allocation of regulatory compliance costs, including those related to FuelEU Maritime and IMO carbon intensity requirements.

In the longer term, deep decarbonization could require the adoption of e-fuels. However, current availability is limited, and prices are multiple times higher than conventional marine fuels. Material fleet-wide adoption is therefore expected to take time and will depend on market maturation, infrastructure development and regulatory clarity. Odfjell continuously monitors technological and commercial developments to assess timing and scale of implementation.

Beyond fuel, the transition plan includes operational measures that are not capitalized but contribute to emission reductions and compliance. These include minor technical upgrades below capitalization thresholds, operational efficiency initiatives, digital performance optimization tools, pilot testing of alternative fuels, and related data and analytics activities. Although individually limited in scale compared to fleet renewal investments, these measures collectively support incremental performance improvements and regulatory alignment.

The execution of the transition plan also requires sustained general and administrative expenditures related to sustainability strategy, regulatory compliance management, emissions monitoring and reporting systems, research and development, industry collaboration, and internal competence building. These costs are integral to governance and implementation and form part of the total operational expenditure required to achieve Odfjell’s climate objectives.

Operational expenditure projections are subject to uncertainty, particularly regarding future fuel price differentials, carbon pricing trajectories and the development of global regulatory frameworks. Odfjell manages this exposure through contractual mechanisms, fuel flexibility, active regulatory monitoring and industry engagement. Together with the capital investments described in the preceding section, these operational expenditures constitute the financial framework necessary to execute Odfjell’s transition plan in alignment with ESRS E1 Climate change.

Locked-in GHG emissions and transition risk

Odfjell is fully committed to achieving net-zero emissions and ensuring that our operations align with global climate goals. A critical part of this effort is the assessment of potential locked-in greenhouse gas emissions from our assets and products, particularly our fleet. Based on a thorough evaluation of our current operations, we conclude that Odfjell does not have any significant locked-in emissions that would jeopardize our GHG reduction targets.

Our fleet currently operates on fossil fuels, including VLSFO and Marine Gas Oil (MGO). While these fuels are associated with GHG emissions, it is essential to highlight that our existing vessels are technically capable of operating on sustainable, net-zero fuels such as biofuels or e-fuels without requiring considerable engine retrofits. This capability significantly mitigates the risk of locked-in emissions over the lifetime of the fleet.

Moreover, Odfjell has committed to only ordering new vessels that are net-zero capable, which further underscores our forward-looking approach to eliminating locked-in emissions. Therefore, the emission profile of our current and future fleet is fully aligned with our long-term sustainability targets.

The transition to a low-carbon future presents challenges for the entire maritime industry, including the cost and availability of sustainable fuels. However, Odfjell has developed a comprehensive fleet transition plan that balances cost efficiency with the need to meet regulatory requirements, including compliance with the IMO Global Fuel Standard and FuelEU Maritime regulations.

By integrating biofuels and other renewable energy sources into our operations, Odfjell has the flexibility to achieve net-zero emissions without the need for costly retrofits. This approach ensures that our fleet remains both competitive and environmentally responsible, minimizing transition risk.

Importantly, Odfjell’s reporting includes both owned and time chartered vessels. While an increase in the fleet size may lead to higher absolute emissions, this does not reflect an overall increase in emissions at the global level. In fact, Odfjell has demonstrated its ability to run ships more efficiently than others, meaning that by managing additional vessels, we can reduce carbon intensity across the board.

As vessels reach the end of their economic life—estimated at 25-32.5 years—they will be responsibly recycled. The recycling process will contribute to a net positive effect on GHG emissions, as recycled materials, such as steel, reduce the need for new resources, thereby lowering life-cycle emissions.

Odfjell’s strategy to manage its existing fleet, adopt sustainable fuels, and responsibly recycle vessels ensures that locked-in emissions are not a significant risk. Our climate targets remain within reach, and our ongoing fleet transition plan will continue to align Odfjell with global sustainability goals, minimizing both transition risk and environmental impact.

Alignment with EU taxonomy regulation

In an era where sustainable practices are increasingly vital for operational resilience and competitiveness, Odfjell remains focused on embedding sustainability into our operations in line with the EU Taxonomy Regulation and the Commission Delegated Regulation (EU) 2021/2139. As we implement our strategy, our economic activities—including CapEx, OpEx, and revenue-generating activities—will, over time, reflect a greater alignment with taxonomy criteria for climate mitigation and adaptation.

It is important to note that alignment with the EU Taxonomy is not the goal but rather a result of our efforts to deliver on our sustainability strategy. By prioritizing our strategy, we ensure that the progression toward taxonomy alignment is a natural outcome of focused and meaningful action. This approach allows us to support our long-term vision and the industry’s transition toward a low-carbon economy without viewing regulatory alignment as an endpoint.

Through this strategic focus, we position ourselves to advance sustainable practices that meet the evolving standards and reinforce our commitment to resilient and responsible maritime operations.

Odfjell operates in two primary sectors:

• Transport
• Storage/Terminals

Within the transport sector, we have identified two economic activities that fall under the scope of transitional activities, as defined in the Delegated Act for Climate Change Mitigation. These activities are deemed "taxonomy eligible" under the EU Taxonomy, as they are included in the current regulations:

Sea and coastal freight water transport, vessels for port operations and auxiliary activities (6.10)

Retrofitting of sea and coastal freight and passenger water transport (6.12)

While Odfjell’s activities in these areas are eligible under the taxonomy, they are not yet fully aligned with the criteria established for zero direct emissions. Our current fleet operations, which rely on fossil fuels such as VLSFO and MGO, do not meet the stringent requirements for zero direct emissions under the Delegated Regulation for 6.10, and Odfjell has not had activities that meet the criteria for 6.12 in 2025, and in line with the materiality requirement in the EU taxonomy from 2025.

Odfjell has developed a comprehensive fleet transition plan that outlines our path to net-zero, and that will align with the EU Taxonomy, by focusing on the following key areas:

CapEx

Investments in new vessels that are net-zero capable are central to our CapEx strategy. These vessels, which can operate with significantly reduced GHG emissions, are expected to meet the criteria for taxonomy alignment. This includes compliance with the relevant emissions thresholds established under the Delegated Regulation for activity 6.10. There are technical exemptions that are valid until December 2025, but Odfjell has not planned for any new economic activity that will meet these criteria in 2025.

Additionally, retrofitting existing vessels to improve fuel efficiency and reduce emissions will contribute to alignment. Under activity 6.12, retrofitting projects that result in a reduction of fuel consumption by more than 10% meet the taxonomy criteria. For instance, the planned installation of e-sails across our fleet is projected to achieve fuel reductions exceeding this threshold, thus qualifying as a taxonomy-aligned investment.

OpEx

Once new vessels begin operations and achieve net-zero emissions, the ongoing OpEx associated with these vessels will also align with the taxonomy criteria.

Similarly, the OpEx related to retrofitted vessels, provided they meet the 10% fuel efficiency improvement criteria, will be considered taxonomy aligned.

Revenue

As Odfjell’s fleet transitions to net-zero emissions, the revenues generated from these operations will be classified as taxonomy-aligned under activity 6.10. This shift is anticipated to occur as new vessels enter service, eligible ships operating on a significant level of biofuel ratio and retrofitted vessels begin operating at reduced emissions levels.

Our retrofit strategy is a critical component of aligning with the EU Taxonomy. The installation of technologies such as e-sails and other fuel efficiency measures are expected to deliver substantial reductions in GHG emissions and fuel consumption. These retrofitting measures not only reduce Odfjell’s carbon footprint but also contribute directly to meeting the criteria under activity 6.12.

In addition to retrofits, our newbuildings program will ensure that all future vessels are net-zero capable. This proactive approach to fleet renewal ensures that Odfjell will remain at the forefront of sustainability in the maritime industry, contributing to climate mitigation goals while remaining compliant with the evolving regulatory landscape.

Odfjell’s approach to taxonomy alignment is centered on the transition to a net-zero emissions fleet and ongoing investments in retrofitting technologies. While our current operations are eligible but not yet fully aligned with the EU Taxonomy, the plans in place will support possible taxonomy alignment later.

Policy for offsetting

Odfjell is committed to prioritizing direct emissions reductions across our operations as the most effective path toward achieving sustainability and aligning with climate objectives. Our primary focus remains on the decarbonization of our fleet and shore-based activities through innovation, advanced technologies, and optimized operational efficiencies. We believe that tangible emissions reductions at the source should take precedence over external compensatory measures.

While we prioritize reducing emissions directly, we acknowledge that residual emissions may remain due to technological or operational limitations. In these instances, we consider the use of offsetting mechanisms to address such residual emissions. However, in compliance with the European Financial Reporting Advisory Group (EFRAG) guidance, we must clarify that any purchased or planned carbon credits will not be counted toward Odfjell's gross GHG emissions reduction targets. Instead, we transparently will report these credits as separate mitigation efforts.

Our approach to offsetting will ensure alignment with ESRS E1-7, which requires transparency on the financing and intentions behind any carbon credits used. For projects outside our value chain that generate GHG removals, we will disclose the scope, nature, and extent of any financed carbon credits in our sustainability reporting, including those supporting climate mitigation projects that achieve verified GHG removals.

In line with the ESRS definitions, we distinguish between credits for GHG removals (suitable for achieving net-zero objectives) and carbon credits related to emissions avoidance or reduction, which can only serve as compensatory measures, not for achieving net-zero emissions. Any claims or public statements Odfjell makes regarding GHG neutrality will detail how residual emissions are intended to be neutralized by GHG removals and how these actions complement, rather than replace, direct emissions reduction efforts. The integrity and credibility of the carbon credits we choose will meet the highest standards, ensuring that they do not impede or detract from Odfjell’s commitment to achieving gross GHG reduction targets.

Odfjell remains dedicated to transparency and accountability in all offsetting activities. Our disclosures will align with the ESRS, fully informing stakeholders—including investors, regulators, and the public—of the scope, purpose, and impact of our offsetting initiatives.

Customers and value chain

At Odfjell, we recognize that achieving our net-zero ambition requires collaboration across the entire value chain. As part of our energy transition strategy, we work closely with our customers to ensure a smooth, efficient, and sustainable transformation. The journey towards net-zero emissions is a shared responsibility that requires a collective effort across industries. Odfjell believes that the costs and risks associated with the energy transition should not be borne by one party alone. Instead, these should be distributed across the value chain, from our operations, to our customers, and ultimately, to the end consumers.

We aim to work closely with our customers to share the financial and operational risks of this transition. This includes:

• Collaborating on innovative solutions to reduce emissions and improve energy efficiency.
• Cargo consolidation and port efficiency
• Co-financing initiatives that promote decarbonization, such as the adoption of low-carbon fuels and technologies.
• Joint ventures or partnerships that spread the risk of new investments.

By working together, we can accelerate the transition while ensuring the financial burden is equitably shared.

The costs of the energy transition are an inevitable part of achieving a net-zero future. These costs, including investments in new technologies, compliance with emissions trading systems (ETS), operational changes, and increased price on energy/fuel, must be passed through the value chain. We believe that:

Customers should understand that the shift to more sustainable practices will be reflected in transportation costs due to higher fuel price, emission tax, and cost of upgrades to ensure compliance.

End consumers will also play a role in bearing these costs, as the need for sustainable solutions becomes the market norm.

This transparent approach ensures that the true cost of sustainability is accounted for across the entire supply chain.

While the energy transition comes with challenges, it also offers significant opportunities. Odfjell views this as an opportunity to create value for our customers through:

Reduced ETS costs: An efficient transition will lower our customers’ exposure to ETS-related expenses as emissions are reduced, and compliance becomes easier.

Scope 3 Emissions Reduction: By working with Odfjell, customers can benefit from our low carbon intensity in the segment, which may help lower customers Scope 3 emissions and support their sustainability ambitions.

The transition to net-zero emissions is not just a compliance necessity; it also represents an opportunity for Odfjell and our customers to improve operational efficiency, reduce long-term costs, and enhance our collective sustainability performance.

Disclosure of CapEx related to fossil fuels

Odfjell is dependent on fossil fuel for the fleet, but does not have any investments in coal, oil and gas-related economic activities per relevant NACE codes.

Exclusions

Odfjell’s activities are not excluded from the EU Paris-aligned benchmarks, consistent with the requirements in Commission Delegated Regulation (EU) 2020/1818 (Climate Benchmark Regulation), Articles 12.1 (d) to (g) and 12.2.²

² eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32020R1818

Transition governance

Alignment of the transition plan

At Odfjell, sustainability and energy transition are deeply rooted in our core business strategy and financial planning. Odfjell has set six long-term goals and medium-term targets. Goals and targets are aligned with the transition plan.

Every year, Odfjell's board of directors and management conduct a comprehensive climate and nature risk assessment following the guidelines set by the Task Force on Climate-related Financial Disclosures (TCFD) and the Task Force on Nature-related Financial Disclosures (TNFD). This annual review identifies both risks and opportunities related to climate change and environmental challenges, offering critical inputs into our strategic planning. The climate transition risk assessment is a central driver of our broader climate change mitigation and fleet transition strategy, ensuring that we proactively address regulatory and operational challenges associated with decarbonization.

Our financial planning is linked to the fleet transition plan, enabling Odfjell to allocate the necessary resources to execute our sustainability and fleet renewal ambitions. By aligning capital investments with the long-term needs of our fleet transition, we ensure that the company has the financial strength to adopt greener technologies and new fuels without compromising operational stability.

Additionally, Odfjell carries out a board-aligned double materiality assessment. This assessment helps us identify the financial and environmental impacts of our operations, ensuring that our sustainability actions are financially sound and aligned with broader societal goals. The results of the DMA are used to regularly update our sustainability targets and action plans, ensuring that our strategies remain dynamic and relevant to the evolving external environment. The transition plan will be subject to annual review by management and the board of directors.

Sustainability is a fundamental part of our overall business strategy and a critical goal for Odfjell. This is reflected in how we align actions to drive the energy transition and decarbonization efforts with our long-term incentive plan for management and short-term incentive plan for all shore-based employees. By embedding sustainability into our performance-based incentives, we ensure that our entire organization drives the transition progress towards net-zero.

Approval of the transition plan

The transition plan has been approved by Odfjell’s management and board of directors, ensuring that it is a central component of the company’s strategic direction. The governance structure supports the implementation of the plan, with oversight from the chief sustainability officer and regular reporting to the board of directors.

Progress

Odfjell has made significant progress in implementing its transition strategy. As of 2025, the company has achieved a 55% reduction in carbon intensity compared to the 2008 baseline. Odfjell reports progress on carbon intensity and significant energy efficiency projects in quarterly reporting. We report the GHG emission reduction progress in tCO₂/dwt-mile annually, measured against EU benchmarks.

In 2024, Odfjell set new ambitious climate targets to continue the transition towards net-zero and ensure compliance with existing and upcoming regulations to achieve the goals of the Paris Agreement. Continuous investment in fleet renewal, energy efficiency, and new technologies are essential parts of the transition.

E1-2 Policies related to climate change mitigation and adaptation

Odfjell’s environmental policy is part of a comprehensive framework designed to manage material IROs related to climate change mitigation and adaptation. The policy’s general objectives include reducing greenhouse gas emissions, enhancing energy efficiency, and supporting the transition to renewable energy sources. It addresses key material issues such as operational emissions, regulatory compliance, and technological advancements. The environmental policy sets Odfjell’s climate targets. The process for monitoring involves regular assessments and reporting to ensure continuous improvement and adherence to environmental standards.

The scope of Odfjell’s environmental policy encompasses all company activities, including upstream and downstream value chains, across all geographies where the company operates. It includes stakeholders such as employees, customers, suppliers, and regulatory bodies. The policy excludes no significant activities or geographies, ensuring a holistic approach to environmental management. As part of our governance structure, the board of directors and executive management hold ultimate responsibility for overseeing the company’s environmental strategy and ensuring adherence to this policy. The chief sustainability officer (CSO), operational and ship management teams are tasked with implementing environmental initiatives and regularly updating the board on progress.

Odfjell’s environmental policy aligns with third-party standards and initiatives, such as the International Maritime Organization (IMO) regulations and the Paris Agreement ambitions. In setting the policy, Odfjell considers the interests of key stakeholders, including customers and regulatory authorities, to ensure it meets their expectations and requirements. The policy is made available to all potentially affected stakeholders through the company’s website and internal communication channels, ensuring transparency and accessibility.

The policy addresses climate change mitigation by investing in low and zero-carbon capable ships, net-zero fuels, and optimizing route planning to reduce emissions. For climate change adaptation, Odfjell supports the development of zero-emission technologies and infrastructure to enhance resilience. Energy efficiency is a core focus, with continuous improvements in operational practices and technological upgrades. Additionally, the policy promotes the deployment of renewable energy sources to further reduce the company’s environmental footprint.

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

Odfjell implements a set of climate change mitigation actions to achieve the climate targets and transition plan described in ESRS E1-1. The company’s decarbonisation strategy combines improvements in energy efficiency with a gradual transition to fuels with lower lifecycle carbon intensity.

Climate change mitigation actions

Odfjell’s decarbonisation pathway is structured around three main levers: fleet renewal and technical improvements, operational efficiency measures, and the gradual transition to lower-carbon fuels.

Fleet renewal and technical improvements are a central element of Odfjell’s transition plan. The company is gradually increasing the share of modern and energy-efficient vessels through its fleet renewal programme. New vessels incorporate improved hull design, energy-efficient equipment and other technical improvements that contribute to reduced fuel consumption and emissions.

In parallel, Odfjell implements a retrofit programme aimed at improving the efficiency of the existing fleet through technical upgrades and the installation of energy-saving devices.

In 2025, Odfjell tested wind-assisted propulsion technology through the installation of suction sails on Bow Olympus. The installation demonstrated fuel and emissions reductions of approximately 15–20% under normal operating conditions, with higher reductions under favourable wind conditions. During the year, Bow Olympus also completed a transatlantic demonstration voyage combining wind-assisted propulsion with 100% certified sustainable biofuel, achieving an estimated 85% reduction in carbon intensity compared with conventional operations. Odfjell continues to evaluate the potential for wider deployment of wind-assisted propulsion technologies as part of its technical decarbonisation measures.

Operational efficiency improvements represent a continuous component of Odfjell’s emission reduction efforts. These measures include voyage optimisation, speed management, weather routing, improved vessel utilisation, hull and propeller maintenance, and digital decision-support tools. These initiatives contribute to incremental improvements in fuel efficiency and emissions performance across the fleet.

Fuel transition and value chain engagement constitute a third key lever. Odfjell expects a gradual shift from conventional marine fuels towards fuels with lower lifecycle emissions, including certified sustainable biofuels and, over time, other low-carbon or zero-emission fuels as they become commercially available. Fuel transition is closely linked to regulatory developments such as the EU Emissions Trading System (EU ETS) and FuelEU Maritime.

In 2025, Odfjell launched the world’s first operational deep-sea green corridor between Brazil and Europe using certified sustainable biofuel. The initiative demonstrates the operational feasibility of low-carbon fuels and contributes to developing scalable supply chains.

Odfjell recognises that achieving net-zero emissions requires collaboration across the maritime value chain. The company therefore works with customers and other stakeholders to distribute the costs and risks associated with the energy transition and to support the uptake of lower-carbon solutions.

Outcomes of climate actions

The actions implemented in 2025 contributed to further improvements in the energy efficiency of Odfjell’s fleet. The company achieved a new record-low carbon intensity and maintained full compliance with the Carbon Intensity Indicator (CII) framework, ensuring that all vessels achieved at least a C-rating.

The suction sail installation on Bow Olympus demonstrated fuel and emissions reductions of approximately 15–20% under normal operating conditions, with higher reductions under favourable wind conditions. The transatlantic demonstration voyage combining wind-assisted propulsion and certified sustainable biofuel achieved an estimated 85% reduction in carbon intensity.

The combined effect of fleet renewal, retrofit activities, operational efficiency measures and fuel transition contributes to Odfjell’s climate ambition of reducing fleet carbon intensity (AER) by 57% by 2030 compared with the IMO 2008 reference level, and ultimately achieving a climate-neutral fleet by 2050.

Due to commercial sensitivity related to fleet transition planning and technology deployment, Odfjell does not disclose detailed emission reduction contributions for individual decarbonisation levers. However, all actions form part of the company’s integrated pathway towards achieving its climate targets.

Resources allocated to climate actions

The implementation of Odfjell’s climate transition plan requires both capital expenditures (CapEx) and operational expenditures (OpEx).

The most significant capital expenditures relate to fleet renewal, including the introduction of new energy-efficient vessels through long-term charter arrangements and ownership structures. These arrangements are capitalised as right-of-use assets under IFRS. The capitalised value of these fleet renewal commitments is estimated at approximately USD 600 million over the next three to four years.

Odfjell also invests in retrofit programmes and energy-saving technologies for the existing fleet, including installations of energy-saving devices and pilot projects related to wind-assisted propulsion. In the medium term, such retrofits may represent additional investments; however, individual installations are currently not material relative to vessel asset values. Investments in retrofit activities during the reporting year are disclosed in the notes to the financial statements.

The fuel transition primarily affects operational expenditure rather than capital expenditure. The gradual adoption of lower-carbon fuels and the introduction of carbon pricing mechanisms such as the EU ETS are expected to increase operating costs over time. Under certain scenarios, the combined cost of low-carbon fuels and carbon pricing may increase fuel-related operating expenses to approximately two to three times the cost of conventional very low sulphur fuel oil.

Odfjell manages transition-related cost impacts through contractual mechanisms with customers and through collaboration across the value chain to distribute the costs and risks associated with decarbonisation.

Relationship to EU Taxonomy disclosures

The relationship between Odfjell’s climate actions and the EU Taxonomy Regulation is described in the EU Taxonomy section of this Sustainability Statement. While certain retrofit activities may potentially fall within the scope of Taxonomy activity 6.12 (retrofit of sea and coastal freight water transport), current retrofit projects do not meet all criteria for permanent efficiency improvements required for Taxonomy alignment.

Future investments are therefore not classified as Taxonomy-aligned at this stage. The EU Taxonomy disclosures and related CapEx and OpEx key performance indicators are presented in the relevant section of this report.

The implementation of Odfjell’s climate actions depends on continued access to capital, the development of commercially viable low-carbon fuels, and the evolution of regulatory frameworks and supporting infrastructure. Odfjell therefore applies a phased approach to the transition, combining operational improvements with gradual adoption of new technologies and fuels.

E1-4 Targets related to climate change mitigation and adaptation

Odfjell has established climate-related targets that support the company’s long-term decarbonisation strategy and transition plan described in ESRS E1-1. The targets focus on reducing greenhouse gas emissions from shipping operations through improvements in energy efficiency and the gradual transition to lower-carbon fuels.

Carbon intensity target for 2030

Odfjell has adopted a target to reduce fleet carbon intensity (AER) by 57% by 2030 compared with the IMO 2008 reference benchmark. The target applies to Scope 1 emissions from the controlled fleet, including owned vessels and vessels under bareboat charter or financial lease arrangements. Vessels operating under time charter or in pools are not included in the boundary of this target.

The target is measured using the Annual Efficiency Ratio (AER), which is aligned with the methodology used under the IMO Carbon Intensity Indicator (CII) regulatory framework.

The IMO 2008 benchmark is used as the underlying baseline because it represents the reference year adopted in the IMO greenhouse gas strategy and in the development of the CII regulatory framework. The year 2008 is widely used in the shipping industry as the starting point for measuring decarbonisation progress.

To comply with ESRS requirements for a recent reference point, Odfjell also discloses a reference value for 2021, which reflects the company’s AER performance of 8.1. This reference point allows progress towards the 2030 target to be monitored using a more recent operational baseline while maintaining alignment with the IMO benchmark trajectory.

In addition to Odfjell’s own target trajectory, the IMO regulatory framework requires ships to achieve a 40% reduction in carbon intensity by 2030 compared with 2008 levels. Odfjell uses this regulatory trajectory as a compliance baseline against which its own decarbonisation trajectory can be assessed.

Odfjell has not established a separate absolute emissions target for 2030. Absolute emissions in shipping depend primarily on fleet size and transport demand. The company therefore uses an intensity-based target to measure decarbonisation performance. Further explanation of the decarbonisation pathway and assumptions underlying the target is provided in the transition plan under ESRS E1-1.

The target does not include Scope 2 emissions, although Odfjell has an ambition to achieve net-zero Scope 2 emissions by 2040 through procurement of renewable electricity and other measures.

Net-zero target for 2050

Odfjell has adopted a board-approved target to achieve net-zero greenhouse gas emissions by 2050 across Scope 1, Scope 2 and Scope 3 emissions.

The target covers emissions across the company’s value chain and reflects the ambition to transition the company’s operations and supply chain towards climate neutrality over the long term. Achieving this target will require significant technological developments, the availability of scalable low-carbon fuels and supporting infrastructure.

The target is aligned with the direction of the IMO 2023 greenhouse gas strategy, which aims for net-zero emissions from international shipping by or around 2050.

As a net-zero target, residual emissions that cannot be eliminated through operational improvements, technology deployment or fuel transition may be balanced through carbon removal or verified carbon reduction projects. The company’s approach to such mechanisms is described in the transition plan under ESRS E1-1.

Alignment with climate scenarios and transition pathway

Odfjell’s decarbonisation pathway is described in the transition plan under ESRS E1-1 and the actions supporting the targets are described in ESRS E1-3.

The company’s climate strategy has been assessed against several climate scenarios. For physical risk analysis, Odfjell has primarily assessed higher-warming IPCC scenarios that are expected to have a more significant impact on maritime operations. A 1.5°C physical scenario was not separately analysed, as it was not expected to materially change the current risk picture for the company.

For transition analysis, Odfjell has also considered the IEA Net Zero Emissions (NZE) scenario, which represents a pathway consistent with limiting global warming to approximately 1.5°C. Odfjell does not currently claim that its targets are fully aligned with a science-based 1.5°C pathway. Further discussion of the scenario analysis and transition assumptions is provided in ESRS E1-1.

External verification

Odfjell’s climate targets were reviewed by the external auditor as part of the assurance of the Sustainability Statement. In addition, DNV verified that Odfjell achieved its previous target of 50% reduction in carbon intensity by 2023, which formed the basis for the company’s decision to adopt a new target for 2030.

Climate adaptation targets

Odfjell has not established quantified climate adaptation targets. However, the company maintains safety and operational resilience objectives aimed at protecting seafarers, vessels and terminal operations from physical climate impacts. Climate-related risks and resilience measures are described in the relevant sections of this Sustainability Statement.

E1-5 Energy consumption and mix

Transportation is a high climate impact sector according to NACE Sections A to H and Section L (as defined in Commission Delegated Regulation (EU) 2022/1288). The energy values are calculated per quantity of fuel type with the energy consumption calculator tool by the Sustainable Energy Authority of Ireland (SEAI) since 2011. All conversion factors in this tool are based on net calorific values. For 2025 we based the calculation of the energy from fuel consumption from crude oil and petroleum products on the specific fuel type via our own GHG emissions Power BI dashboard. Please find energy consumption and mix in the following table.

Note: all numbers, excluding Terminals JV, not comparable with earlier reported numbers in previous annual reports

Note: all numbers, excluding Terminals JV, not comparable with earlier reported numbers in previous annual reports. Net revenue from activities in high climate impact sectors (Tankers) and total net revenue from annual report 2024, Note 4 Segment information and disaggregation of revenues

E1-6 Gross scopes 1, 2, 3 and total GHG emissions

About scope 1 emissions

The direct emissions from our vessels (scope 1) are the biggest source of emissions for Odfjell. This is the factor that has biggest impact on the environment. The absolute emissions do not tell the full story, as it is so dependent on fleet size. That is why Odfjell also reports on the carbon intensity for the controlled fleet. The scope 1 GHG emissions in this reporting (see table below) contain CO₂, N₂O and CH₄ Tank to Wake emissions of our vessels. These emissions are calculated based on fuel consumption per fuel type with the applicable emission factors according to EU regulation 2023/1805. For fleet categorization, please see link; Emission reporting and fleet categorization in BP-2.

About scope 2 emissions

Scope 2 covers the indirect emissions created by the production of energy we buy (i.e power for offices). We calculate location- and market-based scope 2 emissions for our offices in Norway, The Philippines, Singapore and Brazil. From 2025 we also included GHG emissions reporting from our smaller offices in USA, South Korea, South Africa, Dubai and China. The national electricity generation emission factors and/or the national electricity residual mix factors by Carbon Footprint Ltd. from the Carbon Data Intelligence (CaDI) database were used. Since 2023, the Bergen office in Norway has a 100% renewable energy certificate of origin. Houston office (USA) and Sao Paulo office (Brazil) have an energy mix with electricity from renewable sources. Electricity from renewable sources accounts for 12.8% of the total location-based scope 2 emissions. Other scope 2 emissions, other than the consumption of electricity, came from the consumption of biofuel in the Bergen office and consumption of natural gas for cooling in the Houston (USA) office. The emissions factor for biofuel by the Norwegian Environmental Department (Miljødirektoratet) was used. Scope 2 emissions account only for less than 0.1% of Odfjell’s total emissions and are therefore regarded as not material.

About scope 3 emissions

Scope 3 covers our upstream and downstream value chain emissions. Scope 3 is divided into 15 different categories, where eight are relevant for Odfjell. See BP-2 Value chain estimation - emissions in scope 3 for more information related to Scope-3.

Purchased goods and services (category 1) and Fuel and energy-related activities (category 3) of scope 3 emissions were included from 2022 on. The values for the 2021 baseline year were extrapolated for this report from the years 2022-2023. Odfjell has been supported by ReFlow, a carbon footprint consultation and software solution company (https://re-flow.io/). For more details, please see link; Value Chain Estimation – emissions in scope 3. Scope 3 Category 1 emissions were estimated using a spend-based EEIO approach with EXIOBASE v3.9.4 emission factors adjusted to 2025 price levels including Ship management procurement costs, provisions – garrets, port costs, IT costs and corporate services costs (non-IT) e.g. office rent and consulting.

For Fuel and energy-related activities (category 3), the methodology follows IPCC 2021 GWP100 factors, which provide internationally recognized data on well-to-tank (WTT) emissions. Data was sourced from Odfjell’s Bunker Purchase List, which details the quantity of each fuel type used in the company’s shipping operations. The corresponding IPCC 2021 GWP100 emission factors were applied to each fuel type to calculate WTT emissions.

Changes in calculation of emissions from Capital Goods (category 2) are described in ESRS2 BP-2 Value chain estimation – emissions in scope 3.

Emission calculation from Upstream transportation and distribution not included in scope 1 or scope 2 (category 4) is based on a combination of spend based calculation from transport services, and activity-based calculations related to transport of fuel, related to the direct emissions of fuel barges used in bunkering operations.

Waste generated in operations (category 5) includes waste from the main offices in Bergen, Manila, Singapore and Sao Paulo as well as smaller the offices in USA, South Korea, South Africa, Dubai and China. Waste emissions calculation is based on the average-data method using primary data by the garbage disposal service providers. The emission factors for different waste types from the US EPA GHG emission factors Hub were used. Waste amount from ships was not measured for 2025. The first measurements from ships will be available in 2026.

Business travel (category 6) includes travel by plane and car by the crew on Odfjell managed ships and the employees of the offices in Bergen, Manila, Singapore and Sao Paulo as well as smaller the offices in USA, South Korea, South Africa, Dubai and China. It is calculated on the distance-based method using primary data by the travel agencies.

Employee commuting (category 7) is calculated on the distance-based method, based on average kilometer commute by car or public transport per employee for the offices in Bergen, Manila, Singapore and Sao Paulo as well as smaller the offices in USA, South Korea, South Africa, Dubai and China. The emission factors for different commuting types from the US EPA GHG emission factors Hub were used.

Investments (category 15) includes scope 1 and scope 2 emissions from JV terminals in USA and South Korea. In 2025 the scope 1 and 2 emissions are based on reported numbers from the terminals. In 2024, these numbers were based on estimates from reported data in 2023. The reported numbers for 2024 have been corrected in 2025.

The following scope 3 categories are not relevant to Odfjell:

• Upstream leased assets (category 8) – Odfjell has no leased assets.
• Downstream transportation and distribution (category 9) – Odfjell does not have downstream transportation or distribution processes of sold products (including retail and storage).
• Processing of sold products (category 10) - Odfjell does not sell products or have processing of sold intermediate products by third parties.
• Use of sold products (category 11) – Odfjell provides only transport and storage services for products owned by others. We report our scope 1 emissions for these services to our customers, but we do not sell or have any responsibility for the products that are stored or transported.
• End-of-life treatment of sold products (category 12) - Odfjell does not sell products.
• Downstream leased assets (category 13) - Odfjell has no leased assets.
• Franchises (category 14) - Odfjell does not have any franchises.

Scope 3 emissions account for 41.2% of Odfjell’s total location-based GHG emissions. 0.75% of scope 3 emissions were calculated using primary data for category 5 and 6.

GHG emissions

In 2025, the total GHG emissions reduction was 19.4%, compared to the 2021 emissions base year. The reduction in scope 1 emissions for 2025 was 19.3%, compared to the 2021 emissions base year. The reduction in scope 3 emissions for 2025 was 19.4%, compared with the 2021 emissions base year.