DOF Group
Integrated Annual Report 2025
In our report
MANAGEMENT REVIEW
This is DOF 15
How DOF creates value for stakeholders 16
Our operating segments 17
Risk Management Framework 18
Identifying DOF’s key risks 19
Double Materiality Assessment (DMA) process 22
DOF’s approach to sustainability 23
Financial Summary 24
CORPORATE GOVERNANCE
The Board of Directors 27
The Management Team 29
Regional Management Team 29
2025 Corporate Governance Report 30
SUSTAINABILITY STATEMENTS
Sustainability Statements 2025 34
ESRS 2 35
DOF Governance Structure 38
Stakeholder engagement 42
Environment 57
E1 Climate Change 58
E2 Pollution 63
E5 Circular Economy 66
EU Taxonomy 69
Social 77
S1 Own Workforce 79
S1 Occupational Health and Safety 87
S1 Equal Treatment and Opportunities for All 90
S1 Other Work-Related Rights 95
S2 Workers in the Value Chain 98
Governance 102
G1 Business Conduct 103
Responsibility statement 109
IN REVIEW
In our report 2
Reflection from the CEO and CFO 3
Financial performance 5
Performance highlights 6
The DOF share 8
DOF’s strategy 9
DOF’s talented team 10
DOF’s Market and Operations 11
FINANCIAL STATEMENTS
Group consolidated financial accounts 110
Financial statements DOF Group 110
Financial statements DOF Group ASA 150
Confirmation from the Board 159
Independent auditor’s report 160
Appendix 164
1 2 3
BOARD OF DIRECTORS REPORT
2 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
Reflection from the CEO and CFO
Managing risk
DOF’s long-term strategy prioritises steady, low-risk, step-by-step development over short-
term gains. Our subsea business, built steadily since 2005, is an example of this growth
model. In 2025, we celebrated operational milestones of 25 years in Brazil and 20 years
in the Asia Pacific region. Today, major SURF and IMR contract awards show that leading
global operators increasingly view DOF as a preferred strategic subsea partner in our field.
As well as recording growth in all subsea regions, over the year
DOF reduced leverage and built financial resilience with
a stronger balance sheet. And, for the first time in its
history, the company began paying quarterly dividends
to shareholders. With backlog secured and indicators
that demand for our services will continue into
2026 and beyond, we are optimistic for DOF’s
future growth.
An outstanding year
The DOF Group delivered an outstanding performance in 2025. In a year defined by a record-high
order intake, efficient operational performance, and strong client satisfaction, we outpaced typical
seasonality, to finish the year with a good fourth quarter and a full year operational EBITDA of USD
781 million.
The main drivers were robust project completion in all subsea regions, high utilisation and a
positive development in the anchor-handling market. In addition, the DOF Denmark business-line,
established following the acquisition of 22 vessels in 2024, contributed a full year EBITDA USD
181 million to the Group. A particularly gratifying result, achieved through a demanding first-half
schedule to fully integrate and deploy the newly acquired fleet. The DOF Denmark figure includes
a USD 15 million gain-on-sale but excludes additional subsea regional earnings generated by the
expanded fleet capacity. A result that underlines the original acquisition rationale presented in
July 2024 and signals the successful completion of the integration programme. In 2026, now fully
integrated, it will no-longer be reported as separate business-line.
Building backlog
Our performance reflects more than a single year’s results. It is the outcome of
strategic decisions made over a decade ago, in combination with the resilience of
our business model and long-term planning. By consistently executing against
our strategic priorities, we have differentiated the company and built a
foundation for sustainable value for shareholders.
The Group’s business model uses a strong vessel management
organisation along with a complex subsea project organisation
to generate additional earnings from our own fleet and third-
party owned vessels, across a wide operational scope. Industry
cyclicality is addressed through a mix of firm, long-term
commitments for our assets and core services and the flexibility
to maximise shorter-term subsea contract commitments. In
addition, our global footprint enables us to serve clients where
demand is strongest and capture new business opportunities
globally. We can see the benefits of this approach in numbers; in
2025 we added almost USD 4 billion in new backlog, bringing the year-
end total backlog to USD 5.1 billion, this has risen to 5.2 billion in the
first quarter of 2026.
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
4 DOF INTEGRATED ANNUAL REPORT 2025
At our core, DOF’s success is secured by having the
best people in every location. The professionalism
of our team is the key to delivering safe,
responsible, and efficient operations. We see the
pride and care demonstrated by DOF’s seafarers
in maintaining vessels as if they were their own.
Together, our people’s competence, dedication, and
ownership mindset are what truly set us apart.
Safeguarding people
Our highest priority is the safety and well-being of
our people. Enhancing safety and environmental
performance across worksites worldwide is
achieved through continuous improvement and
constant focus.
As a result of the programmes implemented in
2025 to strengthen safety leadership, culture,
and capability, we see overall progress with our
safety performance reflected by a positive trend in
lagging and leading safety indicators. Nevertheless,
we cannot be complacent, and threat of a serious
incident remains a significant risk within our
organisation.
We aim to protect and empower employees and
contractors to stop unsafe or inappropriate actions,
to report any breach of law or any violation of the
DOF Group’s policies, or other legal or ethical
concerns, without fear of intimidation or reprisal.
DOF has reinforced our “Speak Up”, “Stop Work”and
“Dignity & Respect” culture with continued
campaigns focused on identifying, managing, and
reporting harassment in the workplace.
An engaged team
The 2025 employee survey results showed
DOF to have industry leading levels of employee
engagement and that individuals are proud of their
contribution to the company’s success. Having
increased the employee group by a third in 2025,
we are proud to have preserved the same high level
of engagement in the Group of 71 %, which is a
great reflection of the willingness of employees
to contribute to making DOF better. Internal
engagement, combined with strong client feedback,
helps to ensure we are in the best position to
deliver operational excellence.
ESG and Sustainability
Our report aligns with the EU Corporate
Sustainability Reporting Directive (CSRD),
reinforcing our commitment to transparency
and accountability in non-financial reporting. A
detailed overview of our progress is available in
the Sustainability Statement, which, together with
this report, forms an integral part of this year’s
Management Report.
We believe that maintaining and improving the
vessels we have is often the most responsible path
forward. By focusing on longevity, preventative
maintenance, and steady improvement, we extend
the life and performance of our fleet while reducing
unnecessary environmental impact. Progress on our
social commitments include reaching a milestone
aboard PLSV Skandi Vitoria, two women Captains
are now jointly leading the vessel. This achievement
represents a significant step forward for gender
equality in the offshore and maritime sectors and
is the result of DOF’s long-standing commitment to
our Gender Diversity programmes.
Looking ahead, strategic priorities for 2026
Maintaining a strong backlog remains our most
important strategic lever to mitigate the industry’s
primary external risk: fluctuations in oil prices
and demand. We secure this backlog, by doing
what DOF does best: maintaining our focus on
HSEQ, securing strong contracts, and delivering
consistent project execution.
The outlook is positive, with ongoing demand for
DOF’s services across various project scopes.
Based on a robust backlog coverage, uplift in rates
in several vessel segments, and continued high
subsea project and tendering activity, we initiate
our 2026 EBITDA guiding with a range of USD
830 - 880 million.
Middle East conflict, oil price and demand
At the time of preparing this letter, war has
engulfed the Middle East. DOF’s operations are
not deployed in the Middle East, and we have
not identified any direct exposure to assets or
operations in the region. In the short-term oil price
rise trend is likely to continue until production and
transport return to normal levels. The demand for
DOF’s services in not expected to be impacted.
However, in the medium to long term, the potential
indirect and direct effects on the industry remain
unclear, and we recognise that this level of
uncertainty introduces additional risk. As such, we
will continue to closely monitor the situation.
Thank you for your support
In closing we offer our sincere thanks to our clients
and partners, new and longstanding, for placing
their trust in us to support your operations around
the world.
Every employee and contractor contributes to
keeping us safe, delivering on our commitments,
and reinforcing our reputation as a preferred marine
and subsea services provider. We offer a heartfelt
thanks to the entire DOF team for their “perfect
performance” and for the pride and professionalism
that defined 2025.
Thank you.
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
All graphs and figures based on management reporting
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
2,250
2,000
1,750
1,500
1,250
1,000
750
500
250
0
USD million
2017 2019 20212018 2020 2022 2023 2024 2025
Operating revenue
EBITDA
Operating margin
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
2,250
2,000
1,750
1,500
1,250
1,000
750
500
250
0
0
2.000
1.500
1.000
500
Q1 Q2 Q4Q3
40.000
30.000
20.000
10.000
GBP
100
80
60
40
20
0
%
0
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
0
700
600
500
400
300
200
100
0
1,750
1,500
1,250
1,000
750
500
250
0%
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
USD million
0
18,000
15,000
12,000
9,000
6,000
3,000
NOK million
0
3,000
2,500
2,000
1,500
1,000
500
2017 2019 20212016 2018 2020
USD million
0 0
0
2020 2021
2020
2022 2023 2024
0
3,000
2,500
2,000
1,500
1,000
500
2017 2019 20212018 2020
USD million
2022 2023 2024 2025
2017 2019 20212018 2020 2022 2023 2024 2025 20242023 2025
Debt facility
replacements
Potential
sweep
Debt to be
refinanced
Long tenor
debt
USD million
2017 2019 20212018 2020 2022 2023 2024 2025
0
12,000
10,000
8,000
6,000
4,000
2,000
NOK million
202520252024 2027
2028
and there after
PSV North Sea Utilisation
Spot Rates 2008-2013
Spot rates PSV less than 750 m² deck
Spot rates PSV larger than 750 m² deck
Utilisation Total PSV
...and # of subsea tree awards rebounds
Subsea tree award
PSV North Sea Utilisation
Spot Rates 2008-2013
Spot rates PSV less than 750 m² deck
Spot rates PSV larger than 750 m² deck
Utilisation Total PSV
Operating revenue
EBITDA
Operating margin
Debt Norskan *
Debt DOFCON *
Debt DOF Rederi *
Debt to be refinanced
Debt DOFSUB *
Cash sweep flat EBITDA
Before any cash sweep
*
Operating margin
Debt Norskan
Debt DOFCON Debt DOF Rederi
DOF excl. DOFCON JV
DOFCON JV
Post-Q2 backlog expansion
IBD
Interest Bearing Debt
NIBD
Net Interest Bearing Debt
IBD
Interest Bearing Debt
NIBD
Net Interest Bearing Debt
Operating revenue
EBITDA
Operating margin
DOFCON JV 16%
Norskan 9%
DOF Subsea 18%
Shipowning 57%
Corp 2%
DOFCON JV 7%
Norskan 12%
DOF Subsea 45%
Shipowning 34%
Financial performance
An overview of our 2025 financial performance
Key figures DOF Group
AMOUNTS IN USD MILLION
Management reporting Financial reporting
From the Profit (Loss)
2025 2024 2025 2024
Operating income
2 014
1 513
1 871
1 385
Operating expenses
-1 218
-984
-1 153
-910
Operating profit (loss) before depreciation and impairment - EBITDA
796 529 718 475
Depreciation
-241
-205
-203
-160
Impairment (-) Reversal of impairment
7
134
7
98
Operating profit (loss) - EBIT
562 458 523 413
Net finance costs
-113
-103
-95
-84
Realised and unrealised currency gain (loss)
82
-160
77
-145
Net changes in gain/loss on derivatives
2
-
2
-
Net financial items
-29
-263
-16
-229
Profit (loss) before taxes
533 195 507 184
Tax income (expenses)
-67
-17
-40
-6
Profit (loss) for the year
467 178 467 178
Non-controlling interests
-
4
-
-
From the Balance sheet
Vessels and other non-current assets
3 292
3 045
3 079
2 803
Current assets
1 140
1 052
1 071
980
Total assets
4 432 4 097 4 150 3 783
Interest free debt
466
393
412
357
Net financing of the entity
3 967
3 704
3 737
3 426
Interest bearing debt
1 923
1 932
1 693
1 655
Equity
2 044
1 772
2 044
1 772
Key Figures
Backlog
5 100
3 254
4 700
2 803
Order intake
3 900
2 000
3 800
1 400
EBITDA before gain (loss) on sale of tangible assets
781
526
703
473
Operating margin
1)
39%
35%
38%
42%
Net interest bearing debt
2)
1 321
1 378
1 036
1 051
Leverage ratio
3)
17x
24x
15x
22x
Equity ratio
4)
46%
43%
49%
47%
CAPEX
5)
411
157
399
146
Earnings per share (USD)
6)
189
093
189
093
Diluted earnings per share (USD)
6)
189
093
189
093
Average number of shares
246 278 655
190 618 343
246 278 655
190 618 343
Diluted average number of shares
247 203 313
190 618 343
247 203 313
190 618 343
Operational development
1
Debt development
1
2025 Revenue per segment 2025 EBITDA per segment
1) EBITDA before gain (loss) on sale of tangible assets/Operating income
2) Interest bearing debt minus interest bearing receivables and cash. See note 23
3) Net interest bearing debt/EBITDA before gain (loss) on sale of tangible assets
4) Booked equity/Total assets
5) Note 13
6) Majority share of profit for the year/Average number of shares. See note 12
The management reporting is based on proportional consolidation of Joint Ventures (JV),
see the Group’s note 5 about the management reporting.
1
Based on the audited consolidated annual accounts
of the former DOF ASA for the period from
2017-2021 and DOF Group ASA for 2022-2025
5 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL PERFORMANCE
Performance highlights
Continued building
backlog
Adding almost USD 4bn
through 2025. Now
at above USD 5bn as
of year-end 2025.
Delivering on guidance
Delivered operational
EBITDA of USD
781m, upper end of
initial guidance. Good
performance from DOF
Denmark fleet with
USD 181m of EBITDA
(incl. gains on sales).
Started paying
dividends
USD 234m paid
during 2025
Refinancing
Comprehensive
refinancing completed
in March, with a USD
1,025m term facility.
0
1 200
1 000
800
600
400
200
0%
4.0
3.5
3.0
2.5
2.0
1.5
1.0
0.5
USD billion B2B
Q2’23 Q4’23 Q2’24Q1’23 Q3’23 Q1’24 Q3’24 Q4’24 Q1’25
Q2’25 Q3’25 Q4’25
1 537
Revenue
Order intake
B2B
BOOK TO BILL
Q ‘23 TO Q4 ‘25
SURF project
Energy company
Location: Africa
Duration: +450 vessel days
across 6 vessels
Value: USD 100 – 200m
Skandi Implementer
Client: 2x Int. oil companies
Location: Gulf of Mexico
Duration: 2 months total
Skandi Buzios
Client: Petrobras
Location: Brazil
Duration: 18 months extension to Q3 2026
Q1
Q2
Skandi Cutter
Location: Canada
Duration: 3-year extension
Value: USD 25 - 50m
Skandi Urca, Skandi Angra,
Skandi Iguaçu, Skandi
Logger and Skandi Paraty
Client: Petrobras
Location: Brazil
Duration: 4 years
BUILDING BACKLOG
Total order intake
of ~USD 4bn in
2025, representing
a book-to-bill ratio
of 2x for the year.
Skandi Achiever
Client: Petrobras
Location: Brazil
Duration: 4 years
DOF INTEGRATED ANNUAL REPORT 2025 6
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
Havila Phoenix
(third party vessel)
Client: BP
Location: North Sea
Duration: 3 years
Subsea services contract (IMR)
PIDF
Client: Petrobras
Location: Brazil
Duration: 3 years
Value: USD 390m
Geoholm, Skandi Carla, Skandi Olympia,
Skandi Chieftain and Skandi Commander
Client: Petrobras
Location: Brazil
Duration: 4 years
Skandi Fluminense & Skandi Lifter
Client: Petrobras
Location: Brazil
Duration: 4 years
Skandi Patagonia
Client: TotalEnergies
Location: Argentina
Duration: 3 + 2 years
Skandi Implementer
Client: Shell
Location: US Gulf
Duration: 75 – 120 days
Value: USD 25 – 50m
Skandi Inventor
Client: Int’l operator
Location: APAC
Duration: 1 year
Value: USD 25 – 50m
Cade Candies
(third party vessel)
Location: USA
Duration: 8 months
Skandi Açu, Skandi Niterói and Skandi Vitória
Client: Petrobras
Location: Brazil
Contract extensions
(all now firm until 2030)
Value: ~USD 100m of backlog
Q3
Q4
BUILDING BACKLOG
Project award
Location: Argentina
Duration: 250 vessel days
Value: USD 25 – 50m
86%
Fleet utilisation
in 2025
4bn
~USD
Total order intake
in 2025
DOF INTEGRATED ANNUAL REPORT 2025 7
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
The DOF share
DOF’s objective is to provide a competitive return on the shareholders’ invested capital through payment of a
dividend and appreciation of the share price. During 2025, the Board of Directors resolved the distribution of
dividends amounting to USD 0.95 per share (USD 234 million in total).
The DOF share was listed on the Oslo Stock Exchange under the ticker DOFG on 22 June 2023. There is one
class of shares, and all the shares carry voting rights and are freely transferable. As of year-end 2025, there
were 246,278,655 shares issued. The year-end closing price was NOK 95.25 per share, corresponding to a
total market value of the shares of NOK 23.5 billion. During 2025, the total trading volume in the DOF share was
130.6 million shares, corresponding to an average daily volume of 522,282 shares.
As of year-end 2025, DOF had 11,009 individual shareholders. Several sell-side analysts cover the DOF share.
The analysts that provide regular updates and estimates for DOF’s financial results and their consensus estimates
can be found at https://www.dof.com/shareholder-information/ analyst-coverage.
Top 20 shareholders as of 31 December, 2025
# Shareholder Shares as of 31 Dec 2025 Ownership %
1 A.P. Møller Holding A/S 61569664
250%
2 Geveran Trading Co. 29870269 121%
3 Folketrygdfondet 22178260 90%
4 ODIN 11213751 46%
5 DNB Asset Management AS 7564849 31%
6 Siem Industries Inc 6025374 24%
7 Nordea Funds 5389936 22%
8 Vanguard 5352395 22%
9 Møgster Offshore AS 3997173 16%
10 Magnus Roth 3172447 13%
11 MP Pensjon PK 2730473 11%
12 KLP Kapitalforvaltning AS 2655010 11%
13 BlackRock 2255777 09%
14 Storebrand Asset Management 2147693 09%
15 JPMorgan Asset Management 1784575 07%
16 Fidelity Investments (FMR) 1609231 07%
17 BNP Paribas Asset Management 1605784 07%
18 Arne Blystad 1568830 06%
19 Danske Invest 1354051 05%
20 Goldman Sachs Asset Management 1295306 05%
Sum top 20 175340848 712%
Sum outside top 20 70937807 288%
Total shares outstanding 246278655 1000%
The shareholder list represents identified underlying shareholders, including those behind nominee accounts. The shareholder analysis is provided by a third-party supplier.
While reasonable efforts have been made to verify the data, DOF can not guarantee that the analysis is complete.
0
500
1000
1500
2000
2500
3000
3500
4000
0
40
80
120
Jan 25
Feb 25
Mar 25 May 25Apr 25 Jun 25 Jul 25 Aug 25 Sep 25 Oct 25 Nov 25 Dec 25
Volume (thousand shares)
Share price (NOK)
Share price and volume in the DOF share in 2025
8 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
TALENTED
People
Safety TRIR*
2.03 / target 1.10
Employee Engagement (Enonva Score)
Response rate
71%
Satisfaction & Motivation
78%
Loyalty
88%
TAILORED
Market and operations
Average fleet utilisation
86%
Integration DOF Denmark Fleet
100%
Active clients
84
TRUSTED
Financial platform
All time high backlog in nominal terms
and coverage for coming years
(USD)
5bn
NIBD/LTM EBITDA target range
1.5–2.0x
EBITDA range for 2026
(USD)
830 – 880m
Three strategic pillars
DOF has a unique value proposition: operating owned and select third-party vessels, integrated subsea and marine services with in-house project management and engineering
capability. Our reputation for teamwork, professionalism, and high-quality assets, built over forty-five years, attracts repeat business, new clients and allows us to expand into new
segments. DOF’s rolling strategy is built on three pillars – our team, our market and operations, and maintaining a sustainable financial platform. Trusted, talented, tailored, we frame
our three year focus and turn strategy into action.
* Governance information page 30 and Financial Statements see page 110
* Quarterly dividend increased to USD 0.35 per share, paid 27 November 2025
DOF’S STRATEGY
1) The Annual Report and its Sustainability Disclosures should not be interpreted as promoting, requiring, or endorsing any form of preferential or
exclusionary treatment in hiring, promotion, leadership selections, or decisions of any kind based on any protected or personal characteristic.
2) The Annual Report is not and should not be interpreted as legal advice, legal opinion, or regulatory guidance, nor does it advocate, encourage, or
endorse coordinated or collective action among organisations to influence, restrict, or define labor, hiring, or any other practices in violation of US law.
*Total Recordable Incident Rate
9 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
STRATEGY: DOF’S TALENTED TEAM
Sharing knowledge, expertise and opportunities
DOF aims to create a workplace where people can apply skills, develop, and unlock their potential in an inspiring,
physically and psychologically safe environment. The key to DOF’s success remains unchanged – our people. Attracting,
developing, and retaining the right people is imperative in maintaining our competitive edge. The People and Organisation
strategy is designed to foster inclusion and equality, attract and retain talent, and ensure that both DOF and its people
possess the competencies required to meet the demands of emerging markets and evolving technologies.
Safety
DOF aims to provide a physically and psychologically safe working
environment by promoting a strong health and safety culture supported
by a robust safety management system, ensuring our people return home
safely and in good health.
Overall safety performance improved in 2025. We continue to focus
strongly on near-miss reporting and evaluation to strengthen prevention
and learning. Behaviour-based programmes constitute a core tool in
our safety culture, encouraging proactive and responsible actions at all
levels of the organisation.
DOF strengthened the Occupational Health, Safety and Environment
(OHSE) team, which supports workplace safety, environmental compliance,
and employee well-being. By increasing the number of specialist vessel-
based safety coaches, we aim to further embed safety awareness
onboard. Reinforcing psychosocial safety at DOF remains an important
priority on and offshore.
Employee engagement
All employees are invited to share their feedback through our recurring
employee survey. The survey is a key mechanism to integrate employee
insights into decision-making processes, policy development, targets,
and actions. The feedback gathered enables our teams to preserve
and strengthen engagement and performance across the organisation.
In 2025, our employee headcount increased significantly. Despite this
growth, we are proud to have maintained a high overall engagement level of
71% across the Group. The survey measures employee engagement across
eight core areas, providing insight into two key dimensions: Satisfaction
& Motivation and Loyalty. Results remain strong and stable year-on-year:
Satisfaction & Motivation: 78% (2025) compared to 79% (2024),
Loyalty: 88% (2025) compared to 89% (2024).
DOF outperformed both the industry benchmark and Ennova’s Top in
Class benchmark in a 2025 employee satisfaction survey, confirming the
strength of our culture and the continued commitment of our employees.
Career pathways and employee development
During this strategy period, we are strengthening alignment and synergies
across our marine and subsea functions by streamlining processes,
sharing best practices, and leveraging collective expertise. This supports
stronger collaboration, greater operational consistency, and a shared
culture across the organisation, while enhancing efficiency, innovation,
and value delivery to our clients.
DOF continues to improve how knowledge is shared, systems are aligned,
and ways of working are standardised across regions. In 2025, an
updated Human Resource Information System (HRIS) was evaluated to
help harmonise HR processes, increase flexibility, and support internal
mobility. Global resource sharing initiatives enable us to deploy skills
where demand is highest, improving our ability to manage seasonal and
other fluctuations.
10 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
STRATEGY: DOF’S MARKET AND OPERATIONS
25 years in Brazil
and 20 years in APAC
Our strategy builds on our core strengths
in long-term planning and capability
development, supported by our global
footprint. This approach has enabled us to
develop a highly skilled team and deliver
integrated marine and subsea services
across a wide range of offshore operations,
all backed by the DOF fleet.
In 2025, we celebrated operational milestones of 25 years in Brazil
and 20 years in the Asia Pacific region.
DOF Brazil’s 25 years of operations underscore our long-term commitment
to a region that has become a core market for the Group. Over the past
quarter century, we have built a strong local organisation, developed
long-standing client relationships and established a substantial fleet
presence supporting complex offshore developments.
Building on this strong foundation, contract awards across AHTS, RSV
and PIDF tenders added more than USD 2 billion to our backlog in
2025, significantly strengthening earnings visibility. The majority of
our local fleet is now contracted well through the end of the decade,
reflecting strong demand for our high-end vessels and offshore expertise.
DOF APAC launched in 2005 with a modest team and the ‘Geo’ blue
fleet, beginning with Geosea. Since then, the organisation has grown
to more than a 1000 strong workforce, recognised and respected for
its marine and subsea expertise, and supported by a fleet of nine high-
quality vessels capable of delivering across a wide range of operations.
The strength and competence of our growing workforce in Brazil and
other regions remain fundamental to consistent project delivery and
our sustained success in the market. Supported by continued high
tendering activity and robust client demand, we are confident that we
have established a solid platform for ongoing growth and long-term
value creation in the years ahead.
The DOF team has built a great reputation, is rightly recognised for
a ‘can-do’ attitude, of which we can all be proud.
11 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
STRATEGY: DOF’S MARKET AND OPERATIONS
6
Vessels
450+
Vessel days
600+
Personnel
Build on our core services
DOF’s strategy builds incrementally on what
we do best. It’s a success story of long-term
planning and capability building, resulting in an
expert team, complementary marine and subsea
services across a broad range of operations
conducted with the DOF fleet.
Maximise vessel versatility
A core principle of DOF’s business model
is to maximise vessel versatility, enabling
deployment across a wider range of activities.
This strategy supports higher utilisation
rates and enhances the earnings potential of
each vessel.
Large-scale SURF project
In the second half of 2025, six DOF vessels
were mobilised offshore Congo as part
of a major SURF project, marking one of
the year’s most significant operational
undertakings for the Group.
The project covered the full delivery scope, from engineering and
project management to installation of flexible flowlines, risers, cables
and associated subsea structures, in addition to installing a floating
production unit for the client. Planning and engineering activities were
coordinated across our offices in Aberdeen and Bergen, ensuring
tight integration between onshore and offshore teams and close
collaboration with the client.
The project comprised more than 450 vessel days and was completed
according to plan. We are proud to support the development of critical
production infrastructure and to see the continued confidence energy
companies place in DOF to plan, manage and execute large-scale
marine and subsea operations with disciplined and reliable delivery.
Optimised fleet composition
Flexible and interchangeable: fleet composition
is a key differentiator for DOF. Our fleet is
purpose-built and chartered-in to match
the needs of the offshore sector and for a
wide range of operations, water depths and
environmental conditions.
12
DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
Established expertise and
capabilities
With operational experience, capabilities, and
asset base well-suited for Offshore Wind (OW)
development, it is a natural extension into the
renewable energy sector. The Offshore Wind
market also presents strong demand for cable
laying and related services.
Networks and alliances
DOF has expanded its global offshore wind
presence by opening a business unit in
Korea. With a significant number of upcoming
projects located in the Ulsan region, the area is
emerging as a strategically important hub for
renewable energy activity.
STRATEGY: DOF’S MARKET AND OPERATIONS
Tailored and versatile,
emergency cable repair
When an emergency cable repair
requirement arose in Q2 2025, DOF was
awarded the contract and quickly mobilised
Skandi Inventor, successfully completing
the operation within 31 days.
In a record time of just over four weeks, full engineering and installation
analyses were completed, critical equipment was fabricated, and the
vessel was mobilised for offshore execution. Following mobilisation,
Skandi Inventor completed sea trials of its brand new Kystdesign
WROVs and calibration of crane AHC systems. The replacement of
220kV export cable was then loaded in Velsen, the Netherlands,
before successfully reconnecting more than 50 turbines to shore.
Despite challenging conditions, the team successfully recovered the
damaged cable, installed the new section to the required depth, and
executed the project according to schedule. The rapid mobilisation and
seamless coordination across teams demonstrates DOF’s operational
readiness and technical capabilities in time-critical situations.
Renewables-ready
DOF’s renewable energy organisation has the
structure, capability, and builds future assets
incrementally to meet increasing demand with
world-class project services.
Cross capable project delivery teams can work
on both conventional and renewable projects.
Maximising utilisation and building offshore wind
track record.
13 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
This is DOF
No matter where DOF operates in the world,
safety is held as the highest priority.
DOF is a leading provider of integrated subsea and marine
services to the global offshore energy market Established
in Austevoll in 1981, DOF has continued a proud tradition
of delivering safe and quality services to our customers
SEOUL
GEORGETOWN
“
We aspire to be a trusted and
leading partner delivering integrated
subsea and marine services globally
for a sustainable utilisation of offshore
energy and other subsea resources.”
11
22
1012
COPENHAGEN
45
years
operational history
6
operating
continents
Norway
headquartered
Vessel per region
1
Employees per region
All totals per 31.12.2025
2,207
2,076
11
701
30
USD
2,014
million
FY 2025 revenue
74
with 4 chartered-in
and 8 on management
6,000
people
3,800
people offshore
12
high end subsea
vessels
25
AHTS and AHTS with ROV/
crane + 5 on management
18
owned IMR CSV
+ 4 chartered-in
6
PSVs
+ 3 on management
1
CLV
vessel
¹ Includes owned vessels, chartered in
vessels, and vessels on management
ASIAPACIFIC REGION
BERGEN
AUSTEVOLL (HQ)
ABERDEEN
LUANDA
ST JOHN’S
HOUSTON
RIO DE JANEIRO
BUENOS AIRES
ATLANTIC REGION
SOUTH AMERICA REGION
NORTH AMERICA REGION
MACAÉ
PERTH
SINGAPORE
MANILA
MANAGEMENT REVIEW: GLOBAL FOOTPRINT
13
15 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
How DOF creates value for stakeholders
DEVELOPMENT
PRODUCTION
DECOMISSIONING
DISTRIBUTION + MARKETING END USE
UPSTREAM
DOWNSTREAM
EXPLORATION + INVESTIGATION
SITE INVESTIGATION + FABRICATION
Talented
Tailored
Trusted
A purpose-built fleet and knowledgeable,
dedicated core crews to support
safe operations
Regionally based vessels in a global fleet to provide
flexibility and capability across a wide-range of operations,
water depths and environmental conditions
End-to-end customised project delivery
A single point of access to all project resources including
design and engineering, vessels and marine management
Our operations rely on these business activities and other capital inputs
Investment and Development decisions
FabricationShipyards
Offshore
conventional energy
value chain*
Offshore renewable
energy value chain*
Natural
Resources
*How our activities relate to
ESRS sectors EEU and MOU
Expert Team
Strong
customer
relationships
Solid Financial Platform
Offices and
operational
yards
Market and
Operations
Technology
Reputation
MARINE
MANAGEMENT
SPECIALIST
FLEET
PROJECT
MANAGEMENT
We offer customers:
How our services are used, outcomes and benefits…
Circular
business
practices
INTEGRATED PROJECT DELIVERY TO MEET GLOBAL ENERGY DEMAND
Construction fleet
and subsea assets
AHTS and
PSV fleet
Ship building
and fabrication
Skilled and
dedicated
personnel
Survey and
Inspection
ROVs
Engineering
Diving
A safe, diverse
and inspiring,
inclusive
workplace
Lasting value for investors
and a long-term
competitive return
on the investment
Delivering our
partner
agreements
Practices to support
labour conditions
across the value chain
Contributing to the
energy mix required
by society
MANAGEMENT REVIEW: CREATING VALUE
DOF is structured around diversified strengths, offering both marine and offshore subsea services, a global footprint, and strong local networks
In 2025 the company worked with over 74 conventional energy operators and ten renewable energy developers
16 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
Our operating segments
DOF introduced a new segment reporting structure in 2025. The new segment reporting reflects the
corporate structure and financing structures. The Shipowning segment includes the vessels previously
reported under DOF Subsea, DOF Rederi, Iceman and DOF Denmark. The Subsea Regions segment represents
the value-added services performed by the subsea regions in addition to the vessel earnings. DOFCON JV is
now reported separately. The remaining segments, Corporate and Norskan, remain unchanged from previous
reporting structure.
Shipowning segment
The Shipowning segment represents DOF’s vessel ownership
outside of Brazil and forms the foundation of the Group’s integrated
offshore services model.
Shipowning owns 46 vessels as of year-end 2025. The vessels
are chartered on a time-charter basis, both internally to DOF’s
Subsea Regions and externally to third-party customers. Three
vessels were sold during 2025.
The segment’s earnings are driven by vessel utilisation, contract
duration and rate levels, and utilisation levels are influenced by
planned maintenance, vessel upgrades, mobilisations and transits
between regions. The Shipowning segment has historically delivered
high utilisation across the fleet, supported by long-term contracts
and strong demand for high-specification offshore vessels.
Through the Shipowning segment, DOF maintains strategic control
over critical marine assets, enabling efficient fleet allocation,
operational flexibility and seamless integration with the Group’s
subsea project execution capabilities. The segment plays a central
role in supporting DOF’s global project activity and value creation
across the offshore energy value chain.
Norskan Offshore
Norskan Offshore represents DOF’s Brazil-focused vessel ownership
and management segment. Norskan owns nine anchor handling
tug supply (AHTS) vessels, all of which are built in Brazil, with the
majority equipped with remotely operated vehicles (ROVs).
All owned vessels are employed on firm, long-term contracts
with Petrobras, providing stable utilisation and earnings visibility.
In addition to owning its fleet, Norskan acts as the vessel manager
for DOF’s entire fleet operating in Brazil, including vessels not owned
by Norskan. As part of this role, Norskan serves as the contractual
counterparty towards Petrobras and provides operational and
commercial management services for vessels deployed in the
Brazilian market.
Norskan’s earnings are primarily driven by the owned AHTS fleet,
while vessel management activities for third-party and Group-owned
vessels contribute additional revenue with limited EBITDA impact.
The segment has historically delivered high utilisation levels,
supported by long-term contracts and a strong operational track
record in Brazil.
Through Norskan, DOF maintains a strong local presence and
operational platform in Brazil, combining Brazilian-built vessels,
local competence, and long-standing customer relationships to
support safe and efficient offshore operations in one of the world’s
most active offshore energy markets.
Subsea regions
The Subsea Regions segment represents DOF’s regional subsea
operating companies, which deliver integrated project services in
support of offshore subsea construction activities. The segment
is organised into four geographic regions: Atlantic, Asia-Pacific
(APAC), North America, and Brazil.
Subsea Regions provide project execution capabilities and
value-adding services that complement DOF’s vessel fleet. These
services typically include project management, engineering,
planning, logistics, and operational support required to deliver
subsea projects across a wide range of scopes and water depths.
When executing a subsea project, the regional subsea organisations
normally charter vessels internally from the Shipowning segment,
and where required, may also charter vessels externally if suitable
capacity is not available within the Group. This structure allows DOF
to optimise fleet utilisation while maintaining operational flexibility
and competitive project delivery. Activity levels are supported
by tendering, contract awards, and backlog development across
all operating regions, contributing to DOF’s integrated offshore
services offering and global execution capability.
DOFCON JV
DOFCON is a 50/50 joint venture between DOF Group ASA and
TechnipFMC, established to own and operate a fleet of large
pipe-laying support vessels (PLSVs) in Brazil. The joint venture
represents a key pillar of DOF’s long-standing presence in the
Brazilian offshore market.
DOFCON owns six PLSVs, which are deployed exclusively in Brazil
and are employed on firm, long-term contracts with Petrobras.
These vessels are purpose-built for complex subsea construction
activities, including installation of flexible pipelines and associated
subsea infrastructure.
The DOFCON fleet has historically delivered high utilisation,
primarily due to multi-year contract coverage, and as a result, the
joint venture provides stable and predictable earnings to the Group.
Under the joint venture structure, DOF provides marine and
vessel-related services, while TechnipFMC delivers topside and
project-related services, reflecting the complementary competencies
of the two partners. This integrated operating model enables
efficient execution of complex subsea installation scopes in Brazil.
MARINE
MANAGEMENT
MARINE
MANAGEMENT
SPECIALIST
FLEET
SPECIALIST
FLEET
PROJECT
MANAGEMENT
MANAGEMENT REVIEW: CREATING VALUE
17 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
Risk management framework
Identifying DOF’s Key Risks
DOF’s Risk Management framework ensures that all Regions, Business
Units and Functions identify potential risks impacting their objectives and
operations. DOF’s Risk Management Framework is built upon a process where
risks and opportunities are escalated to the correct level of the organisation
to obtain a comprehensive view of the risks to DOF Groups objectives.
Risks and opportunities are shared through interviews and registers by risk
owners. The identified or escalated risks are categorised as Compliance,
Strategic, Occupational Health, Operational or Financial risks and assessed
and consolidated into an enterprise-wide risk landscape.
Governance, Risk and Compliance (GRC) Committee
Formed in 2025, the GRC Committee operates independently from risk
owners and provides over-sight of the DOF Group Risk Register. The
committee comprises individuals with a group-wide perspective and
expertise across Finance, ESG, Legal, Marine, Projects, Information
Technology, People, and Strategy.
Its role is to review and validate regional and functional risks and opportunities
submitted to the corporate risk register, perform quarterly control testing
and surveillance, and up-date executive management and risk owners on
critical controls, weaknesses, and improvements through the Chair. The
committee also monitors emerging risks based on avail-able information.
The GRC Committee reports to the Audit Committee via the Chief Financial
Officer, which in turn ensures that key risks are escalated to and discussed
by the Board of Directors.
RISK INFORMATION, COMMUNICATION AND REPORTING
Transparent reporting to maximise communication
of risk and opportunity to all stakeholders.
REVIEW AND REVISION MECHANISMS:
Audit Committee, Risk and Opportunity Review,
Double-Materiality Workshop, Financial / Scenario Planning
ENHANCED
PERFORMANCE
MISSION,
VISION AND
CORE VALUES
(CODE OF BUSINESS
CONDUCT & POLICIES)
ROLES AND
RESPONSIBILITIES
IN RISK AND
OPPORTUNITY
MANAGEMENT
Project Risk Registers
HAZID/HIRAs
Commercial/ Business
Acquisition Risk Reviews
BOARD OF DIRECTORS
AUDIT COMMITTEE
EXECUTIVE MANAGEMENT
REGIONAL AND BUSINESS
UNIT MANAGEMENT TEAMS
EXECUTION TEAMS
Risk and
Opportunity Register
Material Topics
GOVERNANCE STRUCTURE
Regional Risk
and
Opportunity Register
DOF RISK AND
OPPORTUNITY
REGISTER
Risks,opportunities and
impacts associated with
pillars; People, Planet,
Prosperity
and Principles
DOF
DOUBLE-MATERIALITY TOPICS
IMPACT
MATERIALITY
SCOPE: all sustainability matters affected by,
or that affect, DOF.
FINANCIAL
MATERIALITY
STRATEGIC RISK
associated with
executing strategy;
framing value creation
and annual improvement
programme.
OPERATIONAL RISK
associated with operations;
planning and executing marine
and subsea services.
BUSINESS RISK
associated with corporate
culture; adapting global model to
regional environments and
customs; local legal issues;
regional management.
MATERIAL FROM
BOTH PERSPECTIVES
E
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STRATEGY,
BUSINESS
OBJECTIVES
AND
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Enterprise Risk Management framework: COSO
Managing DOF’s Key Risks
Risk management in DOF relies on the concept that
all risks or opportunities should have a ‘risk owner’. It
is the risk owner that ensures appropriate controls
are in place and necessary plans are in place to
main risk levels within agreed risk appetite levels.
To maintain oversight, DOF uses key risk indicators
to monitor the effectiveness of controls and evaluate
the development of risk areas over time. Agreed risk
indicator metrics are measured against performance
criteria gauged against DOF’s Risk Appetite. In
conjunction with the GRC Committee those risks
that are emerging or tracking negatively against
key risk indicator metrics or DOF’s risk appetite
are subject to enhanced surveillance, testing and
management across the group.
Additionally, the Board of Directors and Audit
Committee hold deep dive sessions with executive
risk owners throughout the year to discuss selected
key risks.
MANAGEMENT REVIEW: RISK MANAGEMENT
18 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
Compliance
1
Breach of data security
3
Extended value chain compliance
Financial
6
Liquidity and currency volatility (combined)
H
E
A
L
T
H
a
n
d
S
A
F
E
T
Y
C
O
M
P
L
I
A
N
C
E
F
I
N
A
N
C
I
A
L
O
C
C
U
P
A
T
I
O
N
A
L
O
P
E
R
A
T
I
O
N
A
L
S
T
R
A
T
E
G
Y
1
3
2
8
5
9
4
7
Strategic
2
Fleet management and optimisation
5
Market Demand and Activity Levels
8
Technological innovation
Occupational Health and Safety
7
Serious Incidents
Operational
4
Resource availability and competency
9
Client Contract Management
MANAGEMENT REVIEW: RISK MANAGEMENT
Identifying DOF’s key risks
HIGH
MEDIUM
L
OW
6
HIGH
MEDIUM
L
OW
LOW
MEDIUM
H
IGH
LOW
MEDIUM
H
IGH
HIGH
MEDIUM
L
OW
HIGH
MEDIUM
L
OW
19 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
1
Breach of data security
2
Fleet management and optimisation
3
Extended value chain compliance
4
Resource availability and competency
5
Market demand and activity levels
Risk Owner: Head of IT
Risk Movement: Stable
Risk Category: Compliance
Risk Owner: EVP Marine & Asset Operations,
CEO
Risk Movement: Stable
Risk Category: Operational
Risk Owner: EVP Marine & Asset Operations
Risk Movement: Stable / Reduced
Risk Category: Compliance
Risk Owner: EVP Marine & Asset Operations,
EVP People and Organisation
Risk Movement: Stable
Risk Category: Operational
Risk Owner: CEO
Risk Movement: Reduced
Risk Category: Strategic
What is
the Risk
Breach of data security via external unlawful,
malicious or phishing threats, including breach of
data privacy or GDPR regulations.
Balancing asset longevity, while matching
evolving expectations in the offshore energy
market, may create both risks and opportunities
for targeted modernisation and renewal to
support future growth.
DOF’s broad geographical presence and varied
supply chain require ongoing oversight to ensure
consistent adherence to fundamental health
and safety standards, human rights principles,
recognised labour standards across all regions in
which we operate.
The professional contribution of DOF’s workforce and
extended value chain is a key success factor for the
organisation. The nature of our industry requires the
contribution of highly specialised individuals.
A smaller resource base combined with competing
operational requirements may lead to capacity
pressures and oversupply in certain areas.
Additionally, there is the need for targeted
competency strengthening in specific functions and
areas to support DOF’s global fleet and evolving
market expectations. This extends to key areas
within the supply chain.
Fluctuations in market conditions including
changes in energy prices, cyclical industry trends,
and variations in client investment activity may
influence overall demand for DOF’s services and
asset utilisation.
How we
manage it
Cybersecurity risks are managed through
a robust set of control measures. Existing
cybersecurity protocols establish the
foundational safeguards needed to protect
systems, data and operations. These controls
are reinforced by ongoing training for all
employees, ensuring the workforce remains
aware of evolving threats and equipped to
respond appropriately. DOF further strengthens
its systems through its partnership with the
NORMA Cyber Security Centre, providing
enhanced monitoring, threat intelligence and
specialist support.
Structured financial, operational and strategic
controls ensure optimum fleet management
and composition over time. Regular impairment
testing ensures assets continue to reflect their
recoverable value, while strong preventative
maintenance extends asset life and reduces
the risk of operational failures. Applying
Circular Economy principles enables reuse,
refurbishment and responsible end-of-life
management, supporting long-term asset
efficiency and responsibility.
Continuous monitoring of stakeholder
requirements ensures assets remain compliant
with evolving commercial, regulatory and
environmental expectations. Climate scenario
analysis provides insight into how future physical
and transition risks may affect asset suitability
and performance.
DOF’s diversified global asset base further reduces
concentration risk and supports resilience across
markets, clients and operating environments.
HR policies and labour standards set clear
expectations for responsible conduct across all
regions in which DOF operates. Vendor assessment
through the Fact Line process, supported by
supplier audits, strengthens visibility into working
conditions and labour-rights compliance within the
supply chain.
The Ethics Help Line provides a confidential
mechanism for employees, contractors and
suppliers to report concerns, enabling early
identification and resolution of potential breaches.
DOF’s robust Code of Business Conduct, reinforced
through mandatory training, establishes shared
expectations on ethical behaviour and respect
for human rights. These requirements extend
to business partners through the Supplier Code
of Conduct, ensuring consistent standards
irrespective of location.
Well established workforce-management controls
mitigate talent and capacity pressures. Regional
recruitment drives strengthen the pipeline
of specialised personnel needed to support
operational demands across both the local and
global fleet. Talent-retention initiatives, including
the Ambassador Program and other recognition
measures, help maintain engagement and reduce
turnover in critical roles. DOF also utilises
recruitment agencies to access specialist expertise
efficiently and address capability gaps within both
the internal workforce and key areas of the supply
chain.
Exposure to fluctuations in market conditions
is mitigated through commercial and strategic
controls designed to secure utilisation of its assets.
Firm commitments for DOF’s assets and services
provide predictable forward activity and reduce
sensitivity to short-term market movements.
Long-term relationships with key client’s further
support revenue continuity through shifting energy
cycles, while a strong contractual backlog improves
visibility and planning across the business. DOF’s
diverse market presence across regions, segments
and clients balance demand variations and reduces
dependence on any single market.
DOF’s high-end fleet composition strengthens
competitiveness and supports consistent utilisation
by aligning with client requirements for complex
operations and modern capabilities.
Risk Appetite No Appetite Limited Appetite No Appetite Limited Appetite Balanced Appetite
Consequence A delay in meeting the increasingly stringent
cyber-security requirements set by clients and
regulatory authorities may lead to the loss of future
business opportunities and could disrupt ongoing
projects and operational activities.
These factors may adversely affect project
execution timelines, costs, and client
relationships. Furthermore, if DOF is unable
to secure the future availability of assets and
operational services, it may be required to revise
its targets, which could in turn impact its business
outlook, reputation, and its financial position,
performance, and cash flow.
Failure to maintain consistent oversight across
DOF’s global operations and supply chain
could result in non-compliance with health,
safety, human rights, and labour standards,
leading to operational disruptions, legal and
regulatory consequences, reputational damage,
reduced client confidence, inconsistent supplier
performance, increased stakeholder scrutiny,
and financial impacts from penalties, remediation
costs, or interruptions to operations.
A constrained resource base, combined with
increasing operational demands, could create
capacity pressures, skills gaps, and imbalances
across critical functions. This may limit DOF’s ability
to secure and retain specialised expertise, affect
workforce and supplier performance, and hinder
DOF’s capability to support its global fleet and
evolving digital requirements, with potential impacts
on operational efficiency, service quality, and
long-term competitiveness.
Fluctuating market conditions, including shifts
in energy prices, industry cycles, and changes in
client investment activity, could reduce demand
for DOF’s services and lower asset utilisation. This
may lead to revenue volatility, reduced profitability,
operational inefficiencies, and potential challenges
in maintaining an optimal fleet deployment and
workforce capacity.
MANAGEMENT REVIEW: RISK MANAGEMENT
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6
Liquidity and currency volatility
7
Serious incidents
8
Technological innovation
9
Client contract management
Risk Owner: CFO
Risk Movement: Reduced
Risk Category: Financial
Risk Owner: Global HSE Lead, CEO
Risk Movement: Increased
Risk Category: Occupational Health and Safety
Risk Owner: CFO
Risk Movement: Stable
Risk Category: Strategic
Risk Owner: Regional EVP, Chartering Managers
Risk Movement: Stable
Risk Category: Operational
What is
the Risk
DOF operates in a market where incoming
payments may not align with outgoing cash flows,
margin erosion is an inherent risk, and exposure to
currency volatility can further affect the value and
timing of cash flows.
Unplanned high-impact safety or operational
events could influence workforce safety and result
in periods of reduced asset availability.
Failure to anticipate market needs, advance
technology, or deliver innovative, cost-effective
solutions for complex offshore challenges
could weaken its competitive position and limit
its ability to secure new work. Insufficient or
misaligned investment in energy-transition or other
technologies may hinder progress lower-carbon and
renewable markets, in addition to meeting evolving
client requirements.
Contractual obligations related to costs and
compensation arising from environmental
remediation, contractual penalties, pollution
incidents, damage to assets, subsea infrastructure
failures, third-party equipment downtime, and any
resulting financial losses.
How we
manage it
Cash-flow timing differences, margin pressure
and currency volatility are managed through
financial-risk controls. DOF applies a hedging
strategy that aligns cash inflows and outflows,
helping stabilise net exposure and reduce the
impact of currency fluctuations on operational
liquidity. Where appropriate, DOF also utilises
hedge accounting to ensure financial reporting
accurately reflects the economic effect of
hedging activities and reduces volatility in
reported earnings.
In addition, DOF maintains a disciplined
approach to liquidity management by monitoring
working-capital cycles including Days Sales
Outstanding (DSO), project-level billing milestones
and contractual payment terms to minimise
cash-flow gaps between project expenditure and
client receipts.
Treasury oversight ensures sufficient headroom
within the Group’s revolving credit facilities and
bilateral agreements, enabling DOF to respond
to short-term cash requirements and operational
surges without compromising liquidity resilience.
The risk of serious incidents is proactively and
continuously managed through comprehensive
health, safety, and operational controls. The
Health and Safety Management System (IMS)
and project documentation provide structured
procedures for safe operations across all
activities. Dedicated HSE personnel are assigned
to vessel and project operations to ensure
continuous oversight and adherence to safety
requirements. Competency Assurance processes
verify that personnel have the necessary skills and
training to perform safety-critical tasks.
Operational safeguards include the application of
DOF’s Life Saving Rules, a robust Permit-to-Work
(PTW) system, and the use of established
risk-management tools to identify, assess and
mitigate hazards.
Preventative maintenance programmes support
the reliability of safety-critical equipment and
reduce the likelihood of equipment-related
failures.
The DOF Workbook further reinforces safe
behaviours and consistent application of safety
standards across the organisation.
Focused investment, continuous market insight
and strengthened financial capacity ensure
DOF maintains pace with evolving market and
technology demands.
Targeted R&D programs support the digitalisation
and enhancement of existing assets, ensuring the
fleet remains competitive and capable of delivering
complex, modern offshore solutions.
Ongoing review and analysis of market trends
provide early visibility of emerging client needs,
energy-transition developments and technological
shifts, enabling timely strategic response.
DOF’s financial position, reinforced through
restructuring, supports continued investment
in innovation, new technologies and capability
development aligned with future market
requirements.
DOF manages exposure to contractual penalties,
environmental remediation costs, and damages
to assets or subsea infrastructure through strong
commercial, operational and governance controls.
Thorough tendering and contract reviews ensure that
commercial terms, risk allocations and liabilities are
clearly defined and aligned with DOF’s risk appetite
before project commitments are made. Rigorous
Project and Tender Management Reviews (PMRs)
support structured planning, early risk identification
and proactive mitigation throughout the project
lifecycle.
Project Management governing documentation
provides standardised break clauses and clear
operational requirements to minimise execution risk
and prevent incidents that could trigger contractual
or environmental liabilities. DOF also manages
potential exposure through capped liabilities,
ensuring that contractual risk remains controlled and
financially bounded.
Risk Appetite Limited Appetite No Appetite Balanced Appetite Limited Appetite
Consequence Together, these factors may create liquidity
pressures, including the potential inability to meet
payment obligations without incurring additional
costs, which could negatively impact the Group’s
financial performance.
Unplanned high-impact safety or operational
events could compromise workforce safety,
reduce asset availability, and disrupt ongoing
operations, leading to delays, increased costs,
and potential reputational and contractual
consequences for DOF.
Such shortcomings could result in reputational
damage, financial impacts, and reduced ability to
meet client expectations and long-term strategic
objectives.
Failure to effectively manage these contractual
obligations could result in significant financial
exposure through remediation costs, penalties, and
compensation claims. It may also lead to operational
disruptions, reduced asset availability, and delays
caused by subsea infrastructure failures or third-party
equipment downtime. In addition, such events could
damage client relationships, weaken DOF’s competitive
position, and negatively affect the Company’s
reputation and overall financial performance.
ESG Risks
ESG-related risks and opportunities,
including IRO’s are managed and
considered a risk management
methodology within the overall DOF
Risk Framework. ESG Impacts, Risks
and Opportunities are not treated
as a separate category but are
identified, assessed and escalated
through the same structures and
processes that apply to all other risk
types. Many financially material risks
are sourced and consolidated through
the corporate risk register, which
also captures ESG-linked exposures
where they have the potential to
influence financial performance or
resilience.
The DMA process is fully integrated
into this framework. It draws on
the same stakeholder engagement
mechanisms and governance
routines used across the broader risk
environment. Insights from the DMA
feed directly into the risk register and
vice versa, supporting the ongoing
identification and prioritisation of
ESG-related risks and opportunities.
As reflected in ESRS 2, this ensures
that topics such as HSE, resource
availability and other ESG-connected
issues appear within the existing
risk map and are addressed through
the organisation’s standard risk
management cycle.
Further information on the DMA
Process can be found in the
illustration below, with a more
qualitative description, including ESG
Impacts, Risks and Opportunities
within ESRS 2.
MANAGEMENT REVIEW: RISK MANAGEMENT
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Identify
IROs
Organisational Context Review
• Internal and external ESG drivers,
• Business and regulatory changes,
• Stakeholder mapping to primary
data sources.
Holistic Inputs Considered
• Business model & value chain
(upstream → downstream),
• Regulatory landscape,
• Risk register, governance, policies,
KPIs,
• Operational context & industry
benchmarks.
Excluded Topics (agreed by the
DMA teams.)
• No significant value-chain
interaction,
• Limited geographic or activity
exposure,
• Minor impact (scale, scope,
remediability),
• Low likelihood of financial effects.
Stakeholder
engagement
2024–2025 combined approach
ensures a robust, continuously
refined DMA aligned with CSRD.
Regional risks and opportunities
escalated through the DOF Risk
Framework.
Examine IROs across
the value chain
Existing IROs 2025 IROs
Upstream
↓
Marine Management
↓
Specialist Fleet
↓
Project Management
↓
Downstream
Sustainability IROs are integrated
into DOF’s Risk Management
Framework and treated as business
risks and opportunities.
Materiality
scoring approach
Scoring Elements
Impact Materiality
• Scale
• Scope
• Irreversibility
• Likelihood
• Threshold: High / Critical
Financial Materiality
• Likelihood and magnitude
• Nature of financial impact
• Threshold: >1% of 2025 revenue
• Aligned with financial accounting
principles
A topic is material if any associated
IRO exceeds impact or financial
thresholds.
Decision-making
and internal controls
Key Control Points
• Organisational context review
• Stakeholder identification
• IRO scoring validation
• ESRS-aligned methodology
• ERM-aligned thresholds &
timelines
• Full documentation of materiality
rationale
Governance Seal
Integration, monitoring
and review
Key Elements
• Ongoing Review
• Emerging IROs
• Regulatory developments
• Changing assumptions
Governance Enhancements (2025)
• GRC Committee
• Risk appetite statement
• Key risk indicators
2026 Forward Look
• ESG software implementation,
• Centralised IRO and ESG data,
• Improved monitoring, validation,
control & reporting.
Double Materiality Assessment (DMA) process:
Identifying and Assessing Impacts, Risks and Opportunities (IROs)
— aligned with ESRS 1 and CSRD requirements
Aligned with ESRS 1 | CSRD | DOF ERM Framework
External
Stakeholders
Key clients
Financial
stakeholders
Industry peers
and member
organisations
DMA
Validation
Internal
Stakeholders
Executive
Management
Senior
leadership
(post-
integration)
Regional and
support
functions
GRC,
Audit
Committee
MANAGEMENT REVIEW: RISK MANAGEMENT
Further information on DOF’s 2025 Double Materiality Process can be found in ESRS 2 see page 45
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DOF’s approach to sustainability
SDGs Environment
SDG 13
Social
SDGs 5, 4, 3, 8, 9
Governance
SDG 16
Main Challenges ahead
DOF faces a dynamic set of challenges across its environmental
landscape. In particular, the area of decarbonisation has become
complex because of rapidly evolving customer expectations and
shifts in the global energy market. As the industry transitions
toward low-carbon operations, DOF is focused on offering
commercially and technically feasible solutions that support
customers’ decarbonisation goals while navigating a volatile and
fragmented regulatory environment.
DOF sees 2026 as a year with a regulatory landscape as
complex and volatile as 2025. This will be characterised by
uncertainty, ambiguity and regional variances across DOF’s
geographical footprint.
Against this backdrop, DOF’s strategy centres on strengthening
decarbonisation efforts, enhancing energy management, and
ensuring we are renewable ready. Remaining committed to these
principles will allow DOF to navigate complexity while creating
long-term value in a rapidly changing energy landscape.
Occupational health, safety and security risks remain inherent across DOF’s global operations and
value chain, spanning occupational illness, credible security threats and the potential for major
incidents. Safeguarding people continues to be DOF’s highest priority and will remain central to
our approach in 2026. DOF’s overall Health and Safety performance improved in 2025. However,
with a total recordable incident rate of 2.03 and a rolling 12-month sick-leave rate of 3.3%, this
area continues to be DOF’s highest priority.
Meeting the demands of new markets, expanding assets and operational commitments will require
continued focus on attracting, developing and retaining the right talent. At the same time, the
sector faces tightening talent pipelines and an accelerating shift towards digital and low-carbon
capabilities, reinforcing the need for robust workforce development and broader diversity and
inclusion efforts.
Expectations for responsible business conduct across the value chain are increasing, particularly
regarding human-rights due diligence and supplier oversight. Ensuring safe working conditions,
secure employment and fair wages across DOF’s extensive supply chain remains a complex but
essential responsibility. DOF remains committed to upholding fundamental labour standards,
including those reflected in the ILO, MLC, UN Guiding Principles on Business and Human Rights,
Modern Slavery legislation and the Transparency Act.
Regulatory expectations on sustainability and corporate responsibility are
set to intensify in 2026, with evolving global and EU requirements placing
greater emphasis on transparent, consistent and decision-useful reporting. The
implementation of the Corporate Sustainability Reporting Directive (CSRD)
continues to advance, with further changes introduced through the EU’s
2025–2026 Omnibus amendments, which narrow scope yet reinforce the need
for robust governance, data integrity and strong disclosure controls. At the same
time, DOF’s diverse geographic footprint exposes the Group to complex and
often inconsistent legislative environments, including taxonomies, ESG-related
disclosures, industry-specific requirements and national labour legislation. All of
which demand strengthened oversight and adaptive compliance processes.
Cybersecurity risk also remains elevated, with 2025 threat-landscape
assessments highlighting increased ransomware, data-integrity and supply-chain
attacks, and expanding cybersecurity obligations across critical sectors such
as DOF’s. Navigating this regulatory and risk environment will require DOF to
further reinforce its governance structures, ensuring strong risk management,
rigorous internal controls and clear accountability as sustainability-related
expectations continue to evolve.
Strategic Pillar: DOF
3-year rolling strategy
Our market and operations
Maintaining our marine management excellence
Decarbonisation Efforts: DOF is committed to reducing its
environmental impact through vessel upgrades, operational
performance improvements, and alternative fuel initiatives.
Energy Management: The company focuses on enhanced monitoring
and reporting projects to drive progress on its vessel fuel efficiency.
Build on our core services
Renewable Energy: DOF is expanding its capabilities in the
renewable energy sector, particularly in Floating Offshore Wind
(FOW) and Fixed Offshore Wind markets.
Our team
Promote a culture where we are all SAFE
Safety and Well-being: The highest priority is the safety and well-being of employees, with
initiatives such as emergency management training, health and safety campaigns, and
psychological safety programs.
Engage employees, offer career pathways and develop the next generation
Employee Development: DOF promotes a culture where employees can develop their skills and
unlock their potential through various training programs, leadership development initiatives, and
global exchange programs.
A culture where we benefit from equity, diversity and inclusion across the
organisation
Diversity, Equity, and Inclusion (DEI): The company is committed to creating a diverse and
inclusive workplace, with initiatives such as unconscious bias training, gender diversity
programs, and the establishment of a global DEI committee.
Our financial platform
Safeguarding our organisation with good Governance
Corporate Governance: DOF follows the Norwegian Code of Practice for
Corporate Governance, ensuring robust governance structures and processes.
Managing Risk
Risk Management: The company has a comprehensive risk management
framework that integrates prioritised risks and opportunities into strategic
decision-making.
ESG: DOF’s commitment to transparency and accountability
in non-financial reporting
Transparency and Accountability: DOF is committed to transparency in
non-financial reporting, aligning with the Corporate Sustainability Reporting
Directive (CSRD) and other reporting frameworks.
Responses
in ESRS Link
E1 Climate Change
E2 Pollution
E5 Circular Economy
S1 Own Workforce
S2 Workers in the Value Chain
G1 Business Conduct
This universal approach to sustainability is applied across all the geographic regions in which we operate Our strategy covers the services we provide to our Conventional
Energy and Offshore Wind industries. It is informed by our relationships with our customers and designed to meet their sustainable management requirements and build
awareness of our services sustainable attributes Our stakeholder engagement strategy fosters awareness and understanding of our approach
APPLIED IN ALL THE REGIONS WE OPERATE, ACROSS ALL OUR SERVICES, IN PARTNERSHIP WITH OUR CONVENTIONAL ENERGY AND GAS AND OFFSHORE WIND CUSTOMERS
MANAGEMENT REVIEW: ESG AND SUSTAINABILITY
23 DOF INTEGRATED ANNUAL REPORT 2025
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Financial summary
MANAGEMENT REVIEW: FINANCE
The Group revenue in 2025 was USD 1,871
million (USD 1,385 million) and the operating
profit before depreciation and impairment
(EBITDA) was USD 718 million (USD 475
million) including gain on sale of vessels of
USD 15 million (USD 2 million). The year 2025
is stronger than previous year in terms of
revenue and EBITDA due to increased activity,
improved rate levels and the full inclusion of
DOF Denmark.
The operating profit (EBIT) amounted to USD
523 million (USD 413 million) of which USD
-203 million (USD -160 million) represents
depreciation, USD 1 million represents
impairment and USD 9 million (USD 98
million) reversal of impairment. The reversal of
impairment is related to two AHTS vessels in
Brazil with improved earnings.
Net financial items amounted to USD -16
million (USD -229 million) of which net financial
cost represents USD -96 million (USD -84
million). The net currency gain/loss amounted
to USD 78 million (USD -145 million), mainly
represents unrealised currency gain (loss) on
the USD loan facility in Norskan, where BRL is
the functional currency.
The tax costs mainly comprise of withholding
tax on activity in certain regions, corporate tax
and deferred taxes assets not recognised in the
previous year.
The Group’s net result in 2025 was USD 467
million (USD 178 million) and adjusted for other
comprehensive income the net result was USD
505 million (USD 181 million).
The consolidated balance sheet at year end
2025 was USD 4,150 million (USD 3,783
million). The non-current assets consist of
vessels, subsea equipment and ROU at a
book value of USD 2,427 million (USD 2,238
million) and investment in joint ventures at a
value of USD 311 million (USD 311 million).
The recognition of deferred tax assets from
previous years has increased in 2025 due to
improved earnings and amounts to USD 147
million (USD 113 million). Other non-current
assets represent contract costs, goodwill
and receivable relate to shareholders loan to
DOFCON JV and sub-leases.
Current assets represent currents receivable
of USD 575 million (USD 486 million) and total
cash of USD 496 million (USD 495 million).
Total equity was USD 2,044 million (USD
1,772 million) representing a equity of 49%
(47%).
The net interest bearing debt was USD 1,035
million (USD 1,051 million) at year end 2025.
The current debt totals USD 591 million (USD
490 million) of which USD 203 million (USD
165 million) represents interest bearing debt.
The cash flow from operating activities was
USD 661 million (USD 479 million) and net
operating cash flow after net finance cost
and tax paid was USD 528 million (USD 374
million). The operating cash flow has been
impacted by working capital increase due to
high activity.
The net cash flow from investing activity was
USD -229 million (USD -442 million) mainly
related to periodical maintenance on the fleet,
new ROV and operating equipment and the
newbuild Skandi Norseman. In addition to cash
income related to sold vessels and amortisation
receivable sub-leases.
The net cash flow from financing activity
was USD -308 million (USD 307 million) of
which USD -75 million (USD 234 million)
represent net cash impact from proceeds and
amortisation of debt to financial institutions
and leases, and USD -234 million represent
dividend payment to shareholders.
The parent company financial statement for
2025 shows an operating profit of USD -4
million (USD -8 million). Net financial items are
USD 958 million (USD 111 million) and are
impacted by dividend from subsidiaries and
reversal of accruals for guarantees. Net result
was USD 945 million (USD 102 million). Total
balance sheet per 31 December 2025 totals
USD 2,661 (USD 1,512 million) of which equity
was USD 2,088 million (USD 1,376 million).
Financing and capital structure
The Group’s total interest-bearing debt at the
end of the year is USD 1,693 million (USD
1,655 million) of which USD 1,435 million (USD
1,553 million) represent secured debt to credit
institutions, USD 148 million (USD 53 million) is
a bond debt and USD 110 million is lease debt
(related to right-of-use assets and sub-leases).
On 27 March 2025, the Group successfully
refinanced a significant portion of its debt with
a new USD 1,025 million term facility. The
facility has a five-year term and a seven-year
repayment profile. The refinancing replaced
several existing debt facilities, and this new
facility provides greater financial flexibility,
supports the Group’s long-term capital
structure, and allowed quarterly dividend
payments from second quarter 2025. The
amortisation profile of the term facility was
amended after year end 2025, resulting in
a 40% reduction of the annual installments
effective from March 2026.
The newbuild, Skandi Norseman, has been
financed in a ringfenced structure with a US
private placement of USD 140 million, of
which, USD 100 million has been drawn down
and included in non-current debt to credit
institutions. The facility is amortising over a
fifteen-year term from delivery of the vessel in
2027 until its final due date in 2042.
In Norskan, a balloon payment was made in
September and at year end 2025 the BNDES
facility represents all secured debt in Norskan.
The BNDES loan matures in the period from
2030-2033 and includes fixed interest rates in
the range of 3.9-4.9% for the entire duration
of the loans. Reduced amortisation was agreed
until end of 2025 for the BNDES facilities.
In addition, an unsecured five-year bond
of USD 150 million was issued on the 2
September 2025.
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MANAGEMENT REVIEW: FINANCE
Financial risk
The Group is exposed to various types of
financial risk relating to its ongoing business
operation, including market risk (including
foreign exchange risk, interest rate risk and
price risk), credit and liquidity risk. The Group’s
overall risk management seeks to minimise
potential adverse effects of the Group’s financial
performance.
The Group operates globally and is exposed
to foreign exchange risk arising from various
currency exposures. Foreign exchange risk
arises when future commercial transactions,
contractual obligations (assets), liabilities and
investments are in other currencies than the
functional currencies for each company in the
Group. The Group aims to achieve a natural
hedge between cash inflows and cash outflows
to secure the debt funding in equivalent currency
as the committed earnings from the charter
contracts, and further to manage the remaining
foreign exchange risk arising from commercial
transactions, through forward contracts and
similar instruments as appropriate.
The Group is exposed to changes in interest
rates as parts of the Group’s liabilities have
a floating rate of interest. All vessels with
financing via BNDES in Brazil are secured at a
fixed rate of interest throughout the duration of
the loan.
The Group is exposed to price risk at two main
levels:
►
The demand for the Group’s vessels is
sensitive to changes in the oil industry, for
example oil price movements, exploration
and general activity level within the
offshore energy industry. This may affect
both the pricing and the utilisation of the
Group’s assets.
►
The costs of construction of new assets,
replacement and maintenance of assets
are sensitive to changes in market prices.
The Group has a framework for the management
of short, medium and long-term funding and
liquidity management requirements. The Group
continually monitors forecast and actual cash
flows and matches the maturity profiles of
financial assets and liabilities.
The Group’s counterparties’ credit risk has
historically been low as the Group’s customers
traditionally have had good financial capability
to meet their obligations and have high credit
ratings. Historically, the portion of receivables
not being collectable has been low.
For further discussion of the Group’s financial
risk management, please refer to Note 3 to the
Financial statements.
The Company has signed D&O insurance on
behalf of the board members and executive
management to protect against claims which
may arise from the decisions and actions taken
within the scope of their regular duties The
insurance policy is signed with international
reputable companies.
Profit allocation
The parent company financial statements
have a profit of USD 945 million. The Board
of Directors proposes to allocate this figure to
retained earnings in the equity.
The consolidated financial statements have a
profit of USD 467 million, and total compre-
hensive income of USD 505 million.
Going concern
The financial statements of the Parent
Company’s and the Group’s consolidated
financial statement are prepared on the
assumption of going concern.
The markets have continued to be strong and
based on the high backlog and the budget; the
Board is of the opinion that the Company and the
Group are going concerns.
Events after balance sheet date
Vessels
The Group has entered into an agreement to
purchase the very high-end AHTS vessels Aurora
Saltfjord and Aurora Sandefjord (“the Vessels”).
The vessels are 2011-built anchor handling tug
supply (AHTS) vessels featuring a bollard pull of
almost 400 meter tones, making them among
the most powerful AHTS vessels globally.
As a step to high-grade the AHTS fleet aligned
with the company’s strategy, DOF has agreed
to sell the AHTS vessel Skandi Laser (2010
built, 252mt bollard pull) subject to final
documentation.
The net investment from the transactions
is approximately USD 100 million, of which
approximately USD 30 million is expected to be
cash and the rest to be financed with available
debt funding. The divestment of Skandi Laser
is expected to result in a sales gain of approx-
imately USD 12 million to be recorded in Q2
2026.
Contracts
The Group has awarded multiple contracts after
balance date.
See further details in note 35 to the Financial
Statements, page 149.
Outlook
The global market environment remains
supportive, although potential shifts in market
sentiment stemming from the conflict in the
Middle East require continued vigilance. This is
an area DOF is actively monitoring ensuring that
geopolitical developments are assessed system-
atically and integrated into our decision-making
processes.
Our substantial order backlog provides strong
revenue visibility and helps mitigate potential
short-term volatility. Sustained high levels of
tendering activity reflect a healthy pipeline of
future opportunities. We remain confident in
our ability to secure new contracts and deliver
on existing commitments, supported by our
diversified geographic footprint, disciplined risk
oversight, and proven execution capabilities.
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The Board of Directors
Svein Harald Øygard
Chair
Svein Harald Øygard, holds a degree in Economics
(Cand.Oecon) from the University of Oslo. He is a
business owner and independent advisor. Svein
Harald has worked within the Norwegian Ministry of
Finance, including as Deputy Minister. He has held
multiple senior roles at McKinsey, including senior
partner, leader of Oil & Gas in Latin America, global
knowledge Leader Oil and Gas, and has held the title
of senior partner Corporate Finance in Sparebank1
Markets. In 2009, Svein Harald served as Central
Bank Governor of Iceland, also leading the Executive
Committee of the Icelandic bank restructuring. He is
the co-founder of DBO Energy. Svein Harald is Chair
of Gold Road and Akershus University Hospital and
sits on the boards of TGS-NOPEC. He served on the
board of Seadrill through the last phase of its
restructuring process and on the board of Norwegian
Air Shuttle as it was reestablished in 2021.
YEAR OF BIRTH
1960
CITIZENSHIP & RESIDENCY
Norwegian citizen and resides in Norway
SHARES IN DOF GROUP ASA
760,000 (held through close associate)
BOARD APPOINTMENT
April 2023
BOARD MEETING PARTICIPATION IN
10 meetings
INDEPENDENT
Yes
Erik Bergöö
Vice Chair
Erik Bergöö, appointed Vice Chair of the Board of
Directors at the extraordinary general meeting of
the Company on 26 July 2024, acceded his position
on 1 November 2024 in connection with closing of
the Transaction. Erik holds a Master of Science (M.
Sc.) in Industrial Engineering and Management.
Currently the Head of Shipping and Offshore
Portfolio at A.P. Møller Holding A/S, since July
2023, he joined A.P. Møller Holding A/S in 2016 as
Head of financial investments. Prior to which Erik
gained extensive experience in various roles within
global financial markets across Scandinavia, the UK,
and Singapore. In addition to his current role at the
Company, he serves as a director of Maersk
Product Tankers A/S, A.P. Møller Maritime ApS,
Ammonia Carriers A/S, and APMH Invest V ApS.
Further, he serves as manager of APMH Invest XVI
ApS and A.P. Møller Maritime ApS.
YEAR OF BIRTH
1978
CITIZENSHIP & RESIDENCY
Swedish citizen and is based in Sweden
SHARES IN DOF GROUP ASA
None
BOARD APPOINTMENT
November 2024
BOARD MEETING PARTICIPATION IN
9 meetings
Harald Thorstein
Board Member
Harald Thorstein holds a MSc in Industrial
Economics and Technology Management from
Norwegian University of Science and Technology
(NTNU), with specialisation in Finance and
Optimalisation. He is the founder and owner of the
London-based advisory company Arkwright London
Ltd. and has previously held positions in Seatankers
Management and DNB Markets. Harald is currently
Chair of the Board of Jacktel AS and Director of
Odfjell Drilling Ltd, Odfjell Technology Ltd and Yara
ASA. Further board experience includes B2 Impact
ASA, Altus Intervention, Aquaship AS, Aktiv Kapital,
Axactor, SFL Corp, Seadrill, Frontline 2012, Golden
Ocean, Deep Sea Supply and Solstad Offshore.
YEAR OF BIRTH
1979
CITIZENSHIP & RESIDENCY
Norwegian citizen living in Great Britain
SHARES IN DOF GROUP ASA
228,261
BOARD APPOINTMENT
April 2023
BOARD MEETING PARTICIPATION IN
10 meetings
INDEPENDENT
Yes
Christine J. Morris
Board Member
Christine J. Morris holds a BS in Mathematics, an
MS in Actuarial Sciences from the Catholic
University of Louvain (UCL) in Belgium, and an MBA
for the Graduate School of Business at Stanford
University, CA, USA. Christine has over 30 years of
experience across all aspects of the finance
function, from foundational accounting and controls
to capital raising, investors relations, strategy and
M&A. In addition Christine serves on the board and
chairs the audit committee of Svitzer A/S. She has
spent most her career in the U.S. and has extensive
experience in the Oilfield Services sector, including
positions at Halliburton, BJ Services and Maersk
Drilling. Christine has prior experience as CFO and
senior finance roles for public and private US
companies in the telecommunication and technology
space, including US West, MediaOne, Covad
Communications, Adelphia and DataLogix and most
recently as CFO of BT Business.
YEAR OF BIRTH
1966
CITIZENSHIP & RESIDENCY
Belgian and American citizen living in the US
SHARES IN DOF GROUP ASA
90,000
BOARD APPOINTMENT
April 2023
BOARD MEETING PARTICIPATION IN
10 meetings
INDEPENDENT
Yes
27 DOF INTEGRATED ANNUAL REPORT 2025
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Daniela Davila
Board Member
Daniela Davila is a Brazilian lawyer and holds a
bachelor’s degree in law from Pontificia Universidade
Católica – PUC, Rio de Janeiro, Brazil, with LLM in
Corporate Law (FGV) and MBA in Petroleum Business
(COPPE/UFRJ). Daniela is a senior partner and
member of the board of directors of the Brazilian law
firm Vieira Rezende Advogados, where she leads the
O&G and Offshore practice. She acts as special
counsel to ABESPETRO (Brazilian Association of
Suppliers to the Petroleum Industry) and is a member
of AIEN (Association for International Energy
Negotiators) Latin American Executive Committee.
Previously, she served as an advisor to the Brazilian
Ministry of Mines and Energy and worked as special
counsel to PETROBRAS’s financial department for
over 10 years. Daniela held positions as director of
Sipetrol Brasil (ENAP group) and Höegh LNG Brasil
(HÖEGH LNG group).
YEAR OF BIRTH
1970
CITIZENSHIP & RESIDENCY
Brazilian and Portuguese citizen living in Brazil
SHARES IN DOF GROUP ASA
None
BOARD APPOINTMENT
April 2023
BOARD MEETING PARTICIPATION IN
10 meetings
INDEPENDENT
Yes
Adrian Geelmuyden
Board Member
Adrian Geelmuyden holds a BSc in economics from
the Norwegian School of Economics and Business
Administration. He is employed as an Investment
Director with Seatankers Management, and has
previously held positions in Solstad Offshore, Deep
Sea Supply and RS Platou. Adrian is currently also
a Director of Edda Wind.
YEAR OF BIRTH
1985
CITIZENSHIP & RESIDENCY
Norwegian citizen living in the United Kingdom
SHARES IN DOF GROUP ASA
16,000
BOARD APPOINTMENT
May 2024
BOARD MEETING PARTICIPATION IN
10 meetings
Kristin H. Holth
Board Member
Kristin H. Holth, appointed to the Board of Directors
at the extraordinary general meeting of
the Company on 26 July 2024 and acceded her
position on 1 November 2024 in connection with
closing of the Transaction. Kristin holds a bachelor’s
degree in economics and business administration.
With extensive high-level business experience, she
has previously held several Executive Vice President
(EVP) positions at DNB Bank ASA, most recently
serving as EVP and Global Head of Ocean
Industries. In addition to her role at the Company,
Kristin serves as director of Noble Corp Plc.,
HitecVision, Kongsberg Martime, Safe Bulkers Inc,
Econnect Energy and is also a member of the BI
Social Impact Advisory Board and Faculty Team at
the CBS (Copenhagen Business School) Blue Board
Leadership Program.
YEAR OF BIRTH
1956
CITIZENSHIP & RESIDENCY
Norwegian citizen and based in Norway
SHARES IN DOF GROUP ASA
2,500 (held through close associate)
BOARD APPOINTMENT
November 2024
BOARD MEETING PARTICIPATION IN
9 meetings
INDEPENDENT
Yes
28 DOF INTEGRATED ANNUAL REPORT 2025
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The Management Team Regional Management Team
Mons S. Aase
CEO
Mons S. Aase, CEO of the DOF Group since
2005 and part of the management team since
1998, holds a MSc from the Norwegian Institute
of Technology (NTNU), and a Cand. Merc. from
the Norwegian School of Economics (NHH in
Bergen). His previous career experience was
gained in the finance and shipbroking industries
and he has more than 25 years’ experience
within the offshore energy industry. He chairs
and serves on numerous Boards of Directors of
several companies.
Martin Lundberg
CFO
Martin Lundberg has more than 15 years’
experience within the offshore energy industry. He
has previously held various roles within the DOF
Group, including Group Head of Treasury, Acting
Chief Financial Officer, and SVP Finance and
Investor Relations, and has been the CFO since
2025. Martin holds a Business Administration
master’s degree from Norwegian School of
Economics and is a graduate of the AFF Solstrand
Leadership Program. He chairs and serves on
numerous Boards of Directors of several companies
within the DOF Group and serves on the board of
directors of Bergen Shipowning Association.
During the reporting year, the Management Team included the role of Group General Counsel, which was held by
Petter Ove Pharo. However, Mr. Pharo stepped down in November ‘25 and the role has since been closed down.
Marianne Møgster
EVP Marine & Asset Operations
Marianne Møgster joined the DOF Group in
2008 and has held several leadership positions
in the Group including most recently EVP
Sustainability. Marianne has more than 20 years’
experience in the offshore energy industry,
including finance roles in DOF, StatoilHydro, and
Norsk Hydro. She is currently serving on several
Board of Directors in Norway, including
Norwegian Shipowners Association and
Norwegian Hull Club.
Toril Træen
EVP People & Organisation
Toril Træen joined the DOF Group in 2013 and
has held several leadership positions in the
Group. Toril has more than 25 years’ experience
with international HR and Organisational
management in the offshore energy industry,
including leading subsea companies. She is
currently serving as deputy board member for
Underwater Entrepreneurs, Norwegian
Shipowners Association and as board member in
AFF, Norway’s largest leadership and
organisational development consultancy.
Jan-Kristian Haukeland
EVP Renewables
Jan-Kristian Haukeland joined the DOF Group in
2011 and has held several leadership positions
in the Group. Jan-Kristian has more than 30
years’ experience in the subsea and shipping
business. His career includes significant subsea
project experience. He has served on numerous
Board of Directors in Norway and currently
serves on, among others, North Wind and Group
for Underwater Entrepreneurs.
Michael Rosich
EVP Asia-Pacific
Michael Rosich joined the DOF Group in 2006
and has held several leadership positions in the
Group. He has specialised in the global offshore
energy discipline for more than 35 years and
gained broad engineering and project
management experience in various roles in Brown
& Root, Subsea 7 (including Rockwater and
Halliburton Subsea) and CSL, operating in the
Asia Pacific and Atlantic regions.
Marco Sclocchi
EVP North America
Marco Sclocchi joined DOF in 2009 as President
of DOF Subsea USA, which became the fourth
DOF region in 2013. He has 30 years in the
Offshore and Subsea Construction Market
holding various executive leadership and
management roles including Saipem America
Commercial Manager and Sonsub Vice President
of Business Development.
Mario Fuzetti
EVP Brazil
Mario Fuzetti joined DOF in 2014 from Saipem
USA where he held positions of Project &
Operations Director, Commercial and Business
Development Director. He has over 45 years’
experience including Leadership, Area
Management, Project Management, EPCI
contracts, engineering, fabrication and
installation of offshore facilities, pipelines, and
SURF - subsea systems in deep and shallow
water, worldwide.
Dag Raymond Rasch
EVP Atlantic
Day Raymond Rasch joined the DOF Group in
2017 and has held several commercial
leadership positions in the Group. He has more
than 20 years’ experience which includes
operational and leadership roles across project
execution and commercial functions in both
conventional and renewable energy globally.
29 DOF INTEGRATED ANNUAL REPORT 2025
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2025 Corporate Governance Report
As a Norwegian public limited liability company listed on the Oslo Stock Exchange, DOF Group ASA (“DOF”
or the “Company”) is subject to a number of corporate governance regulations contained in the Norwegian
legislation. DOF’s board of directors firmly believes that robust corporate governance is fundamental to
driving sustainable value creation and achieving the Company’s core objectives, and essential for aligning
the interests of shareholders, management, employees, and other stakeholders.
1 STATEMENT ON CORPORATE GOVERNANCE IN DOF
DOF has adopted a set of corporate governance documents. These apply to all consolidated entities
within the DOF group of companies (the “DOF Group” or the “Group”) and are available on the
Company’s website.
DOF’s current corporate governance principles were adopted by the board of directors on 16 May 2025
and are based on the Norwegian Code of Practice for Corporate Governance (the “Code”) as revised in
2021. A new revision of the Code was published 28 August 2025, with effect for the financial year 2025.
The revisions have no material impact on the Company’s compliance with the Code.
In accordance with the Code and other legislation, DOF reports annually on its compliance with corporate
governance requirements and recommendations. This corporate governance report follows the system used
in the Code. Deviations from the Code are addressed under each section.
2 BUSINESS PURPOSE
The business purpose of DOF is set out in section 2 of the Company’s articles of association which reads:
The object of the company is to engage in trading and shipping business and other offshore related activity,
including participation in other companies with the same or similar objects.
The articles of association are available at the Company’s website.
The board of directors has defined clear objectives, strategies and risk profiles for the Company’s business
activities. The Company has established comprehensive guidelines for integrating considerations related
to its surroundings and stakeholders into its value creation process. In this endeavour, the board of
directors takes into account financial, social, and environmental factors. These objectives, strategies, and
risk profiles are evaluated annually by the board to ensure alignment with the Company’s goals. DOF’s
compliance with these objectives, the strategy, and risk profile, as well as the possible need for adjustments
of them, are monitored by the board of directors throughout the year.
3 EQUITY AND DIVIDENDS
DOF and subsidiaries had USD 2,044 million in book equity as of 31 December 2025, corresponding
to an equity ratio of 49 per cent. The parent company’s book equity amounted to USD 2,088 million,
corresponding to an equity ratio of 78 per cent. The board of directors regularly monitors that the capital
structure is appropriate to the Group’s objective, strategy and risk profile, and that the capital requirements
set forth in applicable laws and regulations are met.
The Company’s dividend policy is established by the board of directors and forms the basis for the board’s
proposals to the Company’s general meeting on mandates to pay dividend and dividend payments. The main
principles for the Company’s dividend policy are available on the Company’s website and include statements
that DOF aims to create long-term shareholder value through increased share value and dividend payments
whilst simultaneously focusing on managing the Group’s leverage at a level that is resilient through cycles.
DOF’s board of directors obtained a mandate to approve the distribution of dividend in the 2025 annual
general meeting. The background for the proposal was explained in the notice of the 2025 annual general
meeting.
DOF’s board of directors further obtained mandates in the annual general meeting in May 2025 to increase
the Company’s share capital by up to NOK 61,569,662.50 to facilitate further growth and to increase the
share capital by up to NOK 3,750,000 to be used in connection with the Company’s option programme for
senior executives. The board also obtained a mandate in the 2025 annual general meeting to acquire own
shares with a total nominal value equivalent to approximately 10% of the share capital at the time.
The board’s proposals for board authorisations comply with the relevant recommendation in the Code. All
authorisation granted to the board were assessed and resolved as separate agenda items at the general
meetings. The authorisations were limited to defined purposes and remain valid until the next annual
general meeting, however not beyond end of June the following year.
4 EQUAL TREATMENT OF SHAREHOLDERS
DOF has one share class, each share carries one vote, and all shares carry equal rights, including the right
to participate in general meetings and the right to dividends.
Existing shareholders have pre-emptive rights to subscribe for shares in the event of share capital
increases. The general meeting may resolve by a qualified majority to set aside the pre-emptive rights of
existing shareholders. The proposals from the board of directors to the general meeting in May 2025 to
deviate from the pre-emptive right of existing shareholders in connection with mandates to increase in
share capital were justified in the notice of the general meeting. The mandates obtained in the annual
general meeting in May 2025 to increase the Company’s share capital were not used in 2025.
Transactions in own shares will be carried out in a manner that ensures equal treatment of all shareholders.
No transactions in own shares were undertaken in 2025.
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5 FREELY NEGOTIABLE SHARES
The shares of DOF are listed on the Oslo Stock Exchange. The articles of association have no restrictions
on owning, trading or voting for shares.
The shares subscribed for by certain members of the board of directors and executive management on 8
June 2023, in connection with the Company’s initial public offering in June 2023, are subject to lock-up
undertakings with the Company. The undertakings are effective until and including the date falling 36
months from the first day of trading of the shares on the Oslo Stock Exchange for 2/3 of the subscribed
shares and 24 months for 1/3 of the subscribed shares. The undertaking can be waived by the Company.
6 GENERAL MEETINGS
The board of directors sets the agenda for the general meetings and oversees that the meetings are
prepared and conducted in a manner that enables all shareholders to participate and vote in the general
meetings.
The notice of the general meetings is given in writing no later than 21 days prior to the meeting. The
deadline for shareholders to give notice of their intention to attend the meeting is set no earlier than two
business days before the date of the general meeting.
All relevant documents, including proposals for resolutions to be considered by the general meeting and
recommendations by the nomination committee, are available at the Company’s website from the same
date. The documents are sufficiently detailed, comprehensive and specific to allow shareholders to form a
view on all matters to be considered at the meeting.
Shareholders may vote on each of the proposals to be considered at the general meeting, including voting
for individuals in elections. Shareholders may exercise their rights by proxy attendance and electronic
attendance. A person who can act as proxy is appointed and forms for granting proxies, which allows for
voting on each individual matter, are attached to the notice of the general meetings.
The minutes of the general meeting are made available on the Company’s website promptly after the
meeting in closed.
Deviations from the Code:
DOF has chosen not to follow the Code’s recommendation to facilitate the election of an independent
chair of the general meeting. Based on the company’s organisation and shareholder structure, it is deemed
appropriate that the chair of the board be proposed as the chair of the general meeting.
The chair of the board has been the only member of the board present in the general meeting in 2025. The
nature of the matters to be adopted has not necessitated the presence of the entire board or the chair of
the nomination committee.
7 NOMINATION COMMITTEE
The nomination committee of DOF is established pursuant to DOF’s articles of association section 6.
The general meeting has adopted instructions for the nomination committee governing the duties of the
nomination committee. The instructions are available on the Company’s website. The nomination committee
recommends candidates for the chair and members of the board, candidates for the chair and members of
the nomination committee, and remuneration for the members of these bodies to the general meeting. The
nomination committee have contact with shareholders, the board of directors and the company’s executive
personnel as part of its work on proposing candidates for election. The recommendations from the
nomination committee contain justifications for the proposals made by the committee. The general meeting
elects the chair and members of the nomination committee and determines the committee’s remuneration.
The members of the nomination committee are Martin Larsen (chair), Kristian Falnes and Jan Erik Klepsland.
None of the members of the nomination committee are employed by or hold board positions in the
Company. A majority of the members of the nomination committee is considered independent of the board
and executive management of the Company.
Information concerning the nomination committee, including membership of the committee and deadlines
for making suggestions or proposing candidates, as well as information on how shareholders can propose
candidates, is available on DOF’s website.
8 COMPOSITION AND INDEPENDENCE OF THE BOARD
Pursuant to DOF’s articles of association section 5 the Company’s board of directors shall consist of four to
seven members. The current board consist of seven shareholder-elected members, whereof five, including
the chair, were elected at the annual general meeting in May 2025 for a period of one year, and two were
elected at the extraordinary general meeting in July 2024 for a period of two years effective from the
closing of the Maersk Supply Service transaction on 1 November 2024.
The composition of the board aims to ensure that the interests of all shareholders are attended to, that
the board can function effectively as a collegiate body, and meets the Company’s need for competence,
capacity and diversity.
A majority of the members of the board are independent of the executive management and have no
material business connections of the Company. At least two board members are independent of the main
shareholder (shareholders holding more than 10%), and the gender representation requirements set out in
section 6-11a of the Norwegian Public Limited Liability Companies Act are complied with. The executive
management of the Company does not hold board positions.
Members of the board are encouraged to own shares in the Company.
Further information about the board members, including competence, considerations on independence,
record of attendance at board meetings and shareholding is available in the integrated annual report.
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9 THE WORK OF THE BOARD
General
The board has implemented instructions for the board and the executive management. The instructions
focus on determining internal allocation of responsibilities and duties.
The board of directors hold board meetings whenever needed, normally six ordinary meetings annually, as
well as a number of extraordinary meetings due to matters requiring the board’s urgent deliberation and
approval. The annual report includes information on attendance at board meetings held throughout the year.
Conflict of interests and disqualification
Members of the board and executive management cannot consider matters in which they have a special and
prominent personal or financial interest. To ensure unbiased and impartial considerations and resolutions,
the instructions for the board of directors stipulates that each board member shall inform the board and
executive management of any material interests that they may have in matters to be considered by the
board of directors.
Agreements with related parties
Transactions between the Company and its shareholders, a shareholder’s parent company, members
of the board, executive management or closely associated parties to any such party which are
deemed material under the Norwegian Public Limited Liability Companies Act, are subject to approval
by the general meeting. Furthermore, the board is required to arrange for an independent auditor
valuation of the transaction.
Further, the instructions for the board of directors state that an independent third party valuation is
to be procured also for (i) transactions with shareholders and other closely associated persons that
are deemed non-immaterial to either party involved (i.e. transactions that are below the materiality
threshold set out in the Norwegian Public Limited Liability Companies Act, but still not deemed
immaterial), and (ii) transactions between companies within the Group if any of the companies involved
have minority shareholders. All such agreements are presented in the Company’s annual report.
Board committees
The board has established an audit committee and a remuneration committee to yield efficiency in the
board work. The board committees are preparatory bodies, and no decision-making responsibility is
delegated to any of the board committees.
The audit committee is comprised of Christine J. Morris (chair), Kristin H. Holth and Svein Harald Øygard.
The composition and duties of the audit committee comply with the statutory requirements. The committee
is a working committee for the board, preparing matters and acting in an advisory capacity. The committee
performs a review of the quarterly reports and the annual integrated (financial and ESG/sustainability)
report of the company and supports the board of directors in safeguarding that the company has sound risk
management and internal controls over external reporting. All members have either formal qualifications
within accounting or auditing, or relevant experience and skills within the same, and have the competence
required to fulfil their duties based on the organisation and operations of the Company. All members are
independent of the Company. The board have issued instructions for the work of the audit committee.
The remuneration committee is comprised of Harald L. Thorstein (chair), Daniela Ribeiro de Fernandez-
Davila, Erik Bergöö and Svein Harald Øygard. The remuneration committee serves as a preparatory and
advisory sub-committee of the board in questions relating to the Company’s compensation of its executive
management, enabling a thorough and independent preparation of matters relating to this. All members are
independent of the Company’s executive management. The Board have issued instructions for the work of
the remuneration committee.
Annual evaluations
The board of directors has conducted a self-evaluation of its performance for the preceding year, including
an assessment of its composition, competence and work methods.
10 RISK MANAGEMENT AND INTERNAL CONTROL
General
Effective and proper internal control and risk management are key for building and maintaining trust,
achieving the Company’s objectives, and ultimately creating value. Robust internal control systems and
risk management practices can prevent the Company from encountering situations that could harm its
reputation or financial standing.
DOF’s Code of Business Conduct, available on www.dof.com, adopted by the board, describes the main
principles for compliance and how the compliance function is organised. The Company also has a compre-
hensive set of governing documents which provide detailed descriptions of procedures covering all aspects
of the management of the Company’s operational business.
Annual review and risk management in the annual report
The board oversees the implementation of appropriate internal control systems and systems for risk
management, and that these are proportionate to and reflect the extent and nature of the Company’s
activities. A review of the most critical areas of risk exposure and the internal control arrangements for
such areas is performed annually.
The Annual Report describes the main features of the Company’s internal control and risk management
systems as they are connected to the Company’s financial reporting. This covers the control environment
in the Company, risk assessment, control activities and information, communication and follow-up. The
Company’s management focus on frequent and relevant reporting of both operational and financial matters to
the board, to ensure that the board has sufficient information for decision-making and can respond quickly to
changing conditions. Board meetings are held frequently, and management reports are provided to the board
on a monthly basis. Financial performance is reported on a quarterly basis.
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11 REMUNERATION OF THE BOARD OF DIRECTORS
The remuneration of the board of directors is determined by the Company’s annual general meeting, based
on the proposal from the nomination committee.
The annual executive remuneration report and the annual report provide details of all elements of the
remuneration and benefits of each member of the board, including, to the extent applicable, any consider-
ation paid by the Company to members of the board in addition to the board remuneration.
DOF believes that the board’s remuneration accurately reflects the responsibility, expertise, and complexity
of the Company and its business, as well as the time and level of activity dedicated by board members and
any committees they participate in.
12 SALARY AND OTHER REMUNERATION FOR EXECUTIVE PERSONNEL
The general meeting of DOF has adopted guidelines for determining remuneration to the CEO and other
members of the executive management. The guidelines include the main principles for the Company’s
remuneration policy, including measures to ensure alignment of the interests of the shareholders and the
executive management. DOF considers that the guidelines contribute to meeting the Company’s strategic
goals, long-term interests, and financial sustainability.
In accordance with relevant legislation, DOF prepares an annual executive remuneration report with details
of all elements of the remuneration and benefits of each member of the executive management of DOF. The
report is presented to the annual general meeting for advisory vote.
Deviations from the Code:
The Company’s arrangements for performance-related remuneration of the executive personnel for 2025
deviate to some extent from the recommendations of the Code in respect of absolute limits and clear,
measurable criteria. While the arrangements have been considered to be in the long term interest of the
Company, are now replaced with a KPI based variable pay scheme with absolute limits.
13 INFORMATION AND COMMUNICATIONS
DOF has established guidelines for reporting financial and other information based on transparency and the
requirement of equal treatment in the securities market, including separate instructions for handling inside
information.
Financial and other information is disclosed with due regard to the requirement of equal treatment of all
participants in the securities market, in compliance with the rules of the Public Limited Liability Companies
Act, the rules applicable to companies listed on the Oslo Stock Exchange and otherwise as deemed
appropriate and required at any given time. The information is published through Oslo Stock Exchange’s
information system and at the Company’s website.
Communications with the shareholders outside of the general meeting are done in compliance with the
provisions of applicable laws and regulations and in accordance with the principle of equal treatment of the
Company’s shareholders.
All information distributed to the Company’s shareholders are published on the Company’s website at the
same time as it is sent to shareholders.
14 TAKE-OVERS
The board of directors has established the main principles for its actions in the event of a takeover offer.
The principles refer to and incorporate the principles for takeover situations of the Code. In the event of
a take-over bid the board of directors will act in the best interest of the shareholders and in compliance
with all rules and regulations applicable for such an event as well as practices recommended in the Code,
including to help ensure openness and equal treatment of all shareholders, and that the Company’s business
activities are not disrupted unnecessarily.
15 AUDITOR
The Company’s auditor annually submits the main elements of the plan for the audit of the Company
to the audit committee, as well as an annual written confirmation of its independence, information on
services other than statutory audit provided to the Company, information about threats to the auditor’s
independence, and measures implemented to combat such threats.
The auditor is invited to the audit committee meeting and board meeting that deal with the annual accounts
and sustainability reporting. The auditor accounts for key matters of the audit, and comments, to the
extent applicable, on material changes in the Company’s accounting policies, the assessment of material
accounting estimates or material matters related to the sustainability reporting, as well as all material
matters on which there may have been disagreement between the auditor and the executive management
of the Company.
The audit committee reviews the Company’s systems for internal control, including risk management related
to financial and sustainability reporting with the auditor annually, addressing weaknesses the auditor
has identified and suggestions for improvements. The auditor further participates in all audit committee
meetings.
The audit committee has established guidelines addressing the executive management’s use of the auditor
for other purposes than auditing.
The auditor is invited to attend the annual general meeting and will attend if the matters to be dealt with are
of such nature that the auditor’s presence is deemed necessary.
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34 DOF INTEGRATED ANNUAL REPORT 2025 34 DOF INTEGRATED ANNUAL REPORT 2025
PHOTO: Captains Débora Ferreira and
Daniela Borborema jointly
lead PLSV Skandi Vitória.
DOF Group
Sustainability
Statements 2025
DOF
MANAGEMENT
REVIEW
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GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
SUSTAINABILITY STATEMENTS - ESRS 2
35 DOF INTEGRATED ANNUAL REPORT 2025 35 DOF INTEGRATED ANNUAL REPORT 2025
ESRS 2
Basis for Preparation 1
General information
DOF has reported to the Global Reporting Index (GRI) standard since 2014 and has published material economic,
environmental, and social metrics and performance in Annual Integrated Reports. DOF first reported using ESRS
and CSRD requirements in 2024. This year’s Sustainability Statement follows a similar structure and the same
CSRD framework allowing comparability.
In this Statement, ESRS General and Topical standard disclosures are presented in detail for our business operations
and include our upstream and downstream value chain to give a full account of our sustainability performance.
DOF has adopted the ESRS approach to our double materiality assessment (DMA) process, which includes impacts,
risks and opportunities, in addition to outlining associated policies, actions, metrics and targets (For a detailed
description of the scope, methodology and assumptions of our DMA process, see ESRS 2 IRO-1 on page 45).
The Sustainability Statement follows the categorisation of short, medium and long-term time horizons as defined
in ESRS 1.
The Sustainability Statements are placed within the Management Report and presented in four sections:
1 General information,
2 Environmental information,
3 Social information,
4 Governance information
External assurance
Limited level of assurance of ESRS reporting, which has been conducted by an independent third party,
PricewaterhouseCoopers AS. For the auditors’ report, (see page 160).
Our Sustainability Statement has been prepared on a consolidated basis, aligning with the scope of the financial
report for 2025. The Group’s Financial statements reflect the IFRS® Accounting Standards as adopted by the
EU The Group’s consolidation principles are as follows:
• Subsidiaries are all entities over which the Group has control. The Group controls an entity when the Group
is exposed to, or has rights to, variable returns from its involvement with the entity and can affect those
returns through its power over the entity.
• Subsidiaries are fully consolidated from the date on which control is transferred to the Group. They are
deconsolidated from the date that control ceases.
• GHG emissions from vessels in the DOF / TechnipFMC Joint Venture in Brazil, DOFCON, are accounted for
under Scope 3 Investment category as outlined in E1-6.
No information corresponding to intellectual property, know-how or the results of innovation has been omitted
from the sustainability statement.
Validation of Metrics
Unless otherwise specified for a particular metric, DOF’s sustainability metrics have not been validated by an
external body other than the independent assurance provider.
Basis for Preparation 2
Value chain estimation, sources of estimation and outcome uncertainty
There are some metrics in the upstream value chain related to Scope 3 emissions in E1-6 that are based on
estimates. This relates to Scope 3 categories 1 (purchased goods and services), 2 (capital goods) and partially
4 (upstream transportation and distribution) Please refer to E1-6 for further details regarding the methodology.
This has a medium degree of uncertainty.
The data on waste management practices and waste composition is based on direct measurements, including tank
soundings and waste transfer records from contracted waste collectors. While the Garbage Record Book records
waste volumes in cubic meters, DOF also converts these volumes into weight. This is done through a combination
of direct weighing, precise measurement, and, when required, the use of established volume to weight conversion
factors specific to different waste types. These conversion factors are primarily based on international standards;
where such standards do not exist, the best available information sourced from reputable online references is
applied. DOF utilises volume to weight conversion factors for garbage record logs that are missing weight inputs.
This has been implemented as a more standardised approach than estimating conversions offshore. The adoption
of a standardised volume to weight conversion method represents a change from the approach used in 2024
and significantly increases data quality by providing greater consistency compared to relying on crew expertise.
DOF introduced a standardised method for converting volume to weight in 2025, replacing the previous reliance
on crew judgement. This change improves data quality by ensuring more consistent and reliable conversions.
In 2025, DOF has incorporated short-term leases into the OPEX denominator in accordance with the Article 8
requirements. The comparable figures in this year’s report have been updated to reflect the inclusion of short-term
leases, correcting an error in prior-period reporting. This adjustment enhances the completeness and consistency
of the OPEX definition in line with the EU Taxonomy Delegated Act.
Readers should note changes and limitations of scope that result from adapting our sustainability reporting to
align with the CSRD and the ESRS. For 2025, this includes ESRS Phase in Requirement exemptions (ESRS 2
BP-2 17a) have been used this year. The specific phase in requirement exceptions and disclosures incorporated
by reference are on page 52.
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GOV-1 The role of the administrative, management and supervisory bodies
Good corporate governance is essential for sustainable value creation and underpins the Company’s strategic
and ESG performance. Our corporate governance principles are based on the Norwegian Code of Practice for
Corporate Governance (the Code). Any deviation from the recently revised code is disclosed by DOF. Overall, the
Corporate Governance structure and processes define Accountability, Actions, Assurance and Advice to align the
organisation’s strategic ESG objectives and activities with prioritised stakeholder interests.
The Board of Directors, Audit Committee and Executive Management interface is responsible for oversight, control
and management of identified material Impacts, Risks and Opportunities (IROs) and DOF’s Risk Management
Framework is a key mechanism in the process.
During the year, DOF conducted a comprehensive review of its Group Risk Management processes to enhance
effectiveness and ensure consistent application across all functional areas and regions. A key outcome of this
review was the establishment of a Governance, Risk and Compliance (GRC) Committee, as well as the introduction
of a new Group Risk Appetite Statement and associated Key Risk Indicators.
The Group’s Risk Framework is based on the Committee of Sponsoring Organizations of the Treadway Commission
(COSO) model. This framework guides the identification, assessment, and management of risk factors that could
impact organisational performance across the domains of Strategic, Operational, Compliance, Financial and
Occupational Health and Safety Risks. Risks and opportunities are managed throughout the organisation, ensuring
each risk is owned by the responsible party at the appropriate stage of the business cycle. All risks are managed in
line with the risk appetite set by the Board of Directors and are subject to effective and verifiable control measures
implemented by teams with relevant expertise. Key Risk Indicators are used as a tool to understand when risk
performance is outside of tolerable risk acceptance levels.
DOF’s Risk Management Framework is closely aligned with its Double Materiality Assessment (DMA) processes.
Corporate risks and opportunities form the basis for financial materiality within the DMA and are reviewed regularly
by the Board, Audit Committee, and Executive Management. These bodies follow a structured schedule to review
enterprise risks and material topics, including Impacts, Risks, and Opportunities (IROs).
Within the Risk Management Framework, DOF has clearly defined a structure of responsibility and accountability
for corporate risk management. Executive Management teams retain responsibility for managing risks and
opportunities to a level that is consistent with DOF’s risk appetite levels in addition to ensuring that emerging
risks or opportunities are identified and escalated where necessary. The Board and Audit Committee oversee the
risk management framework but ensure risks responsibilities are retained by risk owners. Information from the
GRC Committee is used by the executive management team to take appropriate actions to mitigate and prevent
risks. The Chief Financial Officer chairs the GRC Committee and is responsible for the day-to-day management
of identified IROs, ensuring dedicated oversight and effective management (see Risk Management Framework
see page 18).
In terms of ESG matters, employee representation in the development and management of IROs is conducted
across multiple formal channels which are described in the Stakeholder Engagement table (see page 42). As all
employees are invited to engage in at least one of the channels, the gender breakdown of representation reflects
the company-wide breakdown. Established Risk Management routines ensure risk and opportunity, including
IROs, are managed throughout the organisation and suitably qualified employees play a significant role in ESG
risk management.
The governance structure includes regular meeting schedules, where IROs are assessed to manage risk, capture
opportunities, and monitor material topics, many of which are included in the Global Improvement Programme.
The Global Improvement Program is DOF’s structured, group wide framework for turning strategy into action by
aligning global and regional improvement activities with the company’s long term vision and ESG commitments.
Each annual programme outlines priority initiatives, connecting them directly to DOF’s strategic pillars. It ensures
consistent progress by defining KPIs, assigning responsibilities, and integrating improvement activities into tools for
monitoring and follow up. Executive and Regional Management Teams conduct an annual review of the Global and
Regional Improvement Programmes, to agree on priorities for the next period and set targets related to material IROs.
The Board of Directors
The Board is the highest governing body and is responsible for governance, strategy and sustainable development
to create lasting value and align with the prioritised interests of stakeholders. The Board strengthens its oversight of
ESG performance with the input of the Audit Committee. Additionally, the Board delegates roles and responsibilities
and provides resources to Executive Management to achieve the organisation’s ESG objectives and maintains
oversight of legal, regulatory and ethical compliance.
The Board comprises seven non-executive directors, with a 43% female and 57% male membership composition.
72% of Board members are independent as defined by the Norwegian Corporate Governance Board’s recommendation
for independence of the Board. A single board member is associated with the main shareholder.
There are ten members of the Executive Management Team (EMT) of comprising 20% female and 80% male, none
of whom hold Board positions in the parent company of the Group.
Board members draw on diverse professional disciplines and hold the skills and experience relevant to the conventional
and emerging offshore energy sector in varied geographic locations and, our core services, to give well-rounded
insights into our operations. An overview of the experience includes resources, offshore energy, sustainability,
finance, technology, global market dynamics, and the public sector (see BoD on page 38).
The Board’s performance, expertise and composition is evaluated annually to ensure it has the competencies to
support our strategic aspirations. Board members enhance their understanding of current ESG matters though their
work on other related industry Boards, as well as the seminars and conferences they attend. In 2025 the Audit
Committee received several CSRD briefing sessions in addition to an overview of IROs. The skills and competencies
required to deliver the strategic direction and operations, including new and evolving disciplines, are identified and
managed in the Corporate People and Organisation strategy and reported to the Board.
The Audit Committee
The Audit Committee supports the Board in the administration and exercise of its oversight responsibility in accordance
with, inter alia, the Norwegian Public Limited Liability Companies Act, the Norwegian securities legislation, the
Norwegian Auditors Act, Regulation (EU) No 596/2014 of the European Parliament and of the Council of 16 April
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2014 on market abuse (commonly referred to as Markedsmisbruksforordningen or MAR), applicable listing rules
of Oslo Børs, including Oslo Rule Book II - Issuer Rules regarding non-harmonised rules for issuers listed on Oslo
Børs, the Norwegian Code of Practice for Corporate Governance, as applicable and other recommendations or
requirements applicable to a stock listed company.
Responsibilities of the Audit Committee are outlined in Instructions for the Audit Committee incorporated in the
Corporate Governance Principles and reflected in the Instructions to the Board of Directors. The Audit Committee
has a broad focus to ensure it has sufficient understanding of:
• Governance, controls and mechanisms,
• ESG risk and opportunity management,
• Material topics,
• Financial and sustainability accounting and reporting principles and processes, including risk management
and internal control,
• Policy reviews and advice,
• Auditor independence
The Audit Committee equips the Board to review implications for DOF’s ESG strategy, operational capacity and
business conduct, as well as understand market dynamic developments and international policy responses. The
Risk Management process, which includes our DMA process and material topics, gives the Audit Committee an
ongoing review of organisational risk as well as our IROs. Additionally, the Board delegates responsibility for all
company policy development and review to the Audit Committee which is tasked with assessing the implications and
efficacy of policies and governing documents and providing advice to ensure DOF meets its professional obligations.
The members of the Audit Committee are elected by and amongst the members of the Board for a term of up to
two years and have the Risk Management, Energy Sector and Financial competence required to fulfill duties based
on the organisation and operations of the DOF Group.
The CEO and Executive Management Team
The Board has overall responsibility for the management of the company, however, as sustainable development is
integrated into business strategy it falls within the CEO’s day-to-day management responsibility. In this capacity,
the CEO provides leadership for the Global Improvement Programme, where strategic and key ESG initiatives are
organised and managed.
In addition to the day-to-day management responsibilities, the CEO is accountable to the Board for ensuring that
all policies related to business conduct are implemented DOF’s policies and business management system, and
the process by which they are managed, are a core element of internal control for business conduct compliance
in all areas of our operations.
As the Chair of the GRC Committee, day-to-day management of Corporate Risks, Opportunities and IRO’s are
delegated to the Chief Financial Officer in dialogue with the Board, Audit Committee and Executive Management.
The CFO is supported by the ESG function and GRC Committee who are subject matter experts across CSRD,
Regional, Functional and Operational areas. Combined, this structure ensures adequate resources and expertise
are assigned to CSRD compliance and across each material IRO.
GOV-2 Information provided to, and sustainability matters addressed by the business’s
administrative, management and supervisory bodies.
In 2025, the Audit Committee met five times. During these meetings risk management and DOF risk management
framework was an agenda item. This involved various discussions including reviews of IROs, improvements to the
risk management framework and emerging risks that require further investigation or control. Significant updates
to IROs or emerging risk discussions are provided to the Board on a quarterly basis by both the Audit Committee
Chair and the CFO, ensuring continuous oversight throughout the year.
The Audit Committee’s agenda covers the evaluation of due diligence implementation, the effectiveness of policies,
and the outcomes of actions, metrics, and targets. While reviews are conducted annually, special sessions are
convened if significant changes or new risks arise. All material impacts, risks, and opportunities addressed by
the Board and Executive Management are defined through the Double Materiality Assessment (DMA) process,
presented at Audit Committee meetings, and detailed in the SBM 3 IRO Table (see page 44)
Throughout the year, IROs are consistently monitored, and key performance targets are addressed at Board
meetings. The Board of Directors also receive updates on ESG Reporting activities, including but not limited
to CSRD compliance, CDP Reporting and Ethics Helpline cases. Health and safety risks are a routine topic of
discussion (see Occupational Health and Safety).
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DOF Governance Structure
CEO
Executive Management Team
Sustainability is integrated into business strategy
which falls within the CEO’s day-to-day
management responsibility Leading the executive
management team the CEO oversees:
Strategy Development and Implementation |
Business Risk and Opportunity Management |
HSEQ | Operations | Global Improvement
Programme | Finance | People and Organisation |
Legal and Ethical Business
Governance, Risk
and Compliance (GRC) Committee
As the Chair of the GRC Committee, day-to-day management
of Corporate Risks, Opportunities and IRO’s are delegated to
the Chief Financial Officer in dialogue with the Board, Audit
Committee and Executive Management.
Risk Appetite Statement and associated Key Risk Indicators.
DOF’s Risk Management Framework is closely aligned with its
Double Materiality Assessment (DMA) processes.
Responsible for the day-to-day management of identified IROs,
ensuring dedicated oversight and effective management.
Board of Directors
The highest governing body - responsible for making strategic decisions in the best interests of the Group, enterprise risk management,
Managing material topics so as to create lasting value for stakeholders
Audit Committee
The Board strengthens its oversight of Sustainability with the input
of the Audit Committee, established in line with the Norwegian public
limited liability companies act. The committee is a working committee
for the Board, preparing matters and acting in an advisory capacity
The Audit Committee has a broad focus to ensure it has sufficient
understanding of:
Management and control of the operations, risks, material topics |
Financial and sustainability accounting and reporting principles and
processes | Risk management and internal control | External auditor
and its independence
Within the Enterprise Risk Management (ERM) process, the Board
and Audit Committee actively monitor the development of top and
emerging risks. They use information from the GRC Committee to
take appropriate actions to mitigate and prevent these risks.
Remuneration Committee
Functions as a preparatory and advisory sub-committee of
the Board in questions relating to the Company’s strategy for
the compensation of its executive management - ensures
thorough and independent preparation of matters relating to
compensation of the Company’s executive management
Nomination Committee
Recommend candidates for the election of members and
chair of the Board, and is independent of the Company’s
Board
Monthly Board Reporting
Strategy Other Committees
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GOV-3 Integration of sustainability-related performance in incentive schemes
DOF does not integrate sustainability-related performance in our incentive schemes.
GOV-4 Statement on due diligence
See Core elements of due diligence on page 55
GOV-5 Risk management and internal controls over sustainability reporting
The core ESG team brings together specialists from Environmental, Health and Safety, Human Resources, Supply
Chain Management, Communications and Governance. While the CFO holds overall responsibility for Group ESG
Reporting, operational responsibility is delegated to the Head of ESG Reporting, who leads the consolidated DMA,
climate-risk evaluation, and the Group’s sustainability data collection and conversion processes.
Sustainability reporting is a continuous, Group-wide effort. Key challenges include human error, data misalignment
across regions, and ongoing system integration following the DOF Denmark acquisition.
To ensure a robust internal control environment, DOF applies a structured governance framework for sustainability
reporting that is integrated with DOF’s broader risk management framework. Internal controls are embedded
across the reporting lifecycle and include:
• Defined roles and responsibilities within the ESG function, ensuring data owners are clearly accountable for
providing complete, timely and accurate information.
• Formal data collection protocols, including standardised reporting templates, documented assumptions,
and version-controlled methodologies to ensure reliability and consistency across all regions and business
segments.
• System-based controls within the unified ESG data framework, such as validation rules, access permissions,
and revision logs that help reduce manual error and strengthen data integrity.
• Periodic quality reviews led by the ESG team, which include cross-checks against operational metrics and
historical trends.
• Risk-based prioritisation, where sustainability topics and data points with the highest potential for
misstatement are subject to enhanced scrutiny, additional supporting evidence, and secondary validation by
subject matter experts.
SBM-1 Strategy, business model and value chain
DOF operates as an international contractor to offshore energy producers, subsea engineering companies and
offshore windfarm developers. Our primary value generating activities are integrated subsea and marine services
where access to a fleet of vessels and subsea assets are an essential component of the business model, and the
fleet is the source of the Group’s largest GHG emissions.
Present in six operating continents, DOF employs more than 6,000 people across 26 offices and in 2025 had 84
clients. There is a trend in our client base, who in meeting their own commitments, expect contractors to reduce
GHG emissions and continuously improve other areas of ESG performance. Evolving stakeholder demands in
relation to our core activities’ climate impacts and the changes in the energy market are key strategic drivers for
our organisation’s future value creation (see page 16).
Employees per Country
Region Country Employees as of (3112. 2025)
Asia Pacific
Australia
749
Asia Pacific Philippines 72
Asia Pacific
Singapore
188
Asia Pacific Indonesia 3
Atlantic
Denmark
524
Atlantic UK 200
Atlantic Angola 87
Atlantic
Norway
982
Atlantic Ghana 2
North America Canada 324
North America
Mexico
9
North America USA 149
South America Brazil 2 164
South America
Argentina
34
DOF’s value creation model and value chain
Our value creation model and value chain are described here (How DOF creates value for stakeholders, page 16).
We rely on upstream inputs from our main suppliers and depend on various forms of ‘capital’ to deliver integrated
subsea and marine services. We use the IFRS framework understanding of value creation model where ‘capitals’
are defined as stocks of value that are increased, decreased or transformed through the activities and outputs
of the organisation.
Core components of the business model are the provision of a specialist fleet, the associated marine management
activities and combinations of specialist subsea services to enable integrated project delivery in a mix of subsea
project contracts and time charter contracts. We have developed long-term relationships with reputable shipyards
in each of our operating regions to ensure our maintenance, class renewal and other drydocking schedules, and
bunkering services are undertaken in a commercial manner. Offshore project delivery relies on third-party fabrication
services and port facilities for every day but essential activities such as project mobilisation and demobilisation.
These and other supply chain relationships are built over-time, operated under contract and compliance parameters
applied through vendor management processes.
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Capital inputs we rely on:
Our expert team: including employees and contractors. Our team’s experience, know-how and commitment are a
competitive advantage in service delivery to customers. Recognised as an important stakeholder group, employee
engagement helps us provide meaningful work, equitable treatment and compensation, inclusivity, and ample
development prospects. The Corporate People and Organisation strategy builds the capability necessary to
prioritise the future potential of assets in the fleet and to enter new markets.
Key initiatives include:
• Future skill development: competency project and annual performance appraisal compliance.
• DOF Ambassadors programme: next generation leader development, a year-long, professional development
programme.
• Continuity management: strategic succession planning to anticipate and proactively address planned and
unplanned vacancies in the executive management team.
• The Employee Brand refresh project and improved recruitment and retainment processes.
• Remuneration review programme and increase in-line with market rates.
Strong customer relationships and partnerships: we aim to offer services and technologies to match and support
our customer’s evolving requirements. Feedback through customer engagement allows us to anticipate and
deliver a vessel fleet and subsea services that prioritise responsible practices, meet operational requirements
and complement supply chains from an ESG perspective.
Key features include:
• The energy transition to cleaner energy production and renewable sources is a feature of our industry sector
new and evolving demands from our stakeholders and the changes in the energy market are key drivers for
the organisation’s future value creation potential.
• DOF is positioning its assets and competencies to address new markets to be ready to expand into
the renewables market, specifically Offshore Wind (OW) field development and maintenance activities.
Although OW activities utilise the transferable skills of the existing team, the renewable organisation has
been developed, focusing on managing personnel continuity, and key individuals that are critical to organic
diversification into emerging market areas.
Offices and operational yards: offering vessels, asset and services located close to regional customers, in the same
time zone but supported by a global team, is a commercial imperative in our business model. To do this DOF has
regional teams, vessels and assets accommodated in over 26 strategically located offices, operational yards and
logistics bases. These facilities may change from time-to-time but are always managed under contract parameters,
compliance vetted through Vendor Fact-lines assessment and subject to audits. All locations have clear controls
and safety and security protocols.
Natural resources: we consume natural resources to operate. This includes fossil fuels for propulsion and energy,
seawater for ballasting and other metals or minerals as part of consumables or components. Natural resource
inputs are managed through the Environmental Impact Policy as well as regional supply chains and interfaces.
A robust financial platform: Our business is capital intensive, we operate in an industry that may be cyclical, and
working capital is subject to the timing of contract cash flows where the timing of receipts from clients and the
payments of suppliers may not align. A sustainable financial platform is essential to underpin and enable ongoing
operational performance. Through investor engagement channels, transparent reporting and presentations we
provide creditors and shareholders with accurate earnings estimates, enabling stakeholders to make well-informed
decisions. DOF has a robust well-established controls and mechanism to manage the financial performance . (See
Financial statements DOF Group on page 110.)
Key objectives include:
• Securing firm commitment for DOF’s assets and services to build visible backlog and sustainable capital
returns.
• Securing long term relationship with the clients.
• Hedging strategy focusing on the cash inflow vs outflow.
• Hedging accounting when appropriate.
Technology: a high-quality fleet and assets that meet stakeholder expectations is essential in our value proposition.
DOF has initiatives in place to digitalise our operations, optimise energy efficiency and reduce energy consumption.
DOF leverages its capability in fleet and asset management by:
• Continuing to implement programmes to digitalise existing assets where it can provide a competitive
advantage, including vessel batteries, autonomy and remote operations, maintenance monitoring, fuel
efficiency, cloud-based solutions, and high-speed, offshore internet.
• Ongoing review and analysis of market trends.
• Contracting high-quality vessels into the fleet.
Our reputation: for quality, reliability, and trusted offshore project delivery. Built over decades, our reputation starts
with our corporate values and our governance systems and controls to support safe, legal and ethical operations
wherever we do business. We plan and deliver comprehensive solutions for conventional and renewables offshore
operations, ensuring projects run safely, smoothly and to schedule, and clients can rely on us to do so .
All the contracts DOF undertakes are in the development, operational and decommissioning phases of the value
chain that first rely on front-end investment and development decisions made by International Operators and
Governments. Our business does extend to the early investment, investigation or development phase of either Oil
and Gas or Renewables value chains.
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Most of our offshore operations assists in the production of energy for clients and other agencies ‘own’ the on-sales
or distribution channels. Ultimately, our business sits in a value chain that contributes to the energy mix required
by society, but interfaces with a relatively small client base.
DOF has specific strategic priorities for ESG performance to build on business opportunities in new segments
and technical and digital solutions to reduce GHG emissions in line with stakeholder expectations and energy
market transitions.
Incorporation by reference
Some elements of Strategy, business model and value chain (SBM-1) disclosure requirement are covered on pages
15,16 and 23 References to the relevant paragraphs can be found in the IRO-2. Disclosure requirements
in ESRS covered by the undertaking’s sustainability statement on page 52 SBM-1 §40 (Business Activities
and sector exposure).
Business activities and sector exposure
In 2025, the majority of DOF’s business was providing key support activities for oil and gas operations, and as
such considered in the fossil fuel (coal, oil and gas) sector as defined by ESRS. This includes services such as
anchor handling and towing, mooring, and subsea inspection, maintenance and repair.
DOF also performed other activities not considered key support activities for oil and gas operations. Within this
we also consider services related to decommissioning of oil and gas installations.
In preparing the EU Taxonomy, these are the activities with turnover considered in this “other” category:
• Transmission and distribution of electricity.
• Demolition and wrecking of buildings and other structures.
Sector Revenue (million USD)
Fossil fuel
1 80463
Other 6648
Further breakdown of the figures and details above regarding the “other” activities can be found in EU Taxonomy
(see page 69).
SBM-2 Interests and views of stakeholders
Engaging with stakeholders is central to our ESG strategy, shaping our understanding of material issues and forming
the basis for improvement initiatives in the Global Improvement Program. This engagement drives the development
of solutions and initiatives that underpin our ESG commitments and Global Improvement Plan.
DOF’s stakeholder engagement program is an ongoing process designed to capture input from both internal and
external stakeholders. Stakeholder perspectives are a core element of our double materiality assessment (DMA).
In 2025, we expanded on previous years’ efforts by engaging critical internal and external stakeholders, including
new senior management teams (as part of integration and organisational restructuring), key clients with significant
backlog revenue, external financial stakeholders, industry peers, member groups, and Executive Management
teams. We also ensured regional representation by identifying, escalating, and incorporating the most critical
Regional Risks and Opportunities within the DOF Risk Framework.
The table below outlines some of DOF’s most significant stakeholders, methods of engagement, and the objectives
and application of these interactions. Stakeholder perspectives are essential features of our materiality assessment
and due diligence efforts. Key stakeholder group perspectives inform our strategy and business model in the
following ways:
• Key stakeholder expectations are considered through the DOF Risk Management process which captures
risk and opportunity in a coordinated, ongoing process to preserve and enhance value. The insights and
perceptions gained through various stakeholder engagement channels are used in our review and revision
cycles. This mechanism, in combination with other processes, results in prioritised risks, opportunities, and
material topics inclusion in strategy and ESG objectives. To complete the loop, ESG and other strategic
initiatives are organised and managed within the Global Improvement Programme.
• Regular engagement with employees drives key parts of our people and organisation strategy.
Understanding and meeting workforce expectations is critical to building a collaborative approach and
the ongoing management of operational priorities such as safety, security, health, inclusion, bullying,
harassment and wellbeing.
• Employee engagement shaped the ‘Dignity and Respect at Work’ programme to address bullying,
harassment, sexual harassment and workplace violence behaviour risks identified in our industry. The annual
employee engagement survey is an important instrument for employee feedback in 2025, the engagement
survey achieved a 71% out of a hundred response rate. Notably, the survey included specific questions to
measure psychological safety, harassment and sexual harassment and to build upon baseline data gathered
in 2024.
• Overall, the employee survey measures employee engagement using two main KPIs, Satisfaction &
Motivation and Employee Loyalty where DOF scored 78 of a hundred and 88 of a hundred respectively. DOF
outperformed the industry benchmark and gained Ennova’s own top-in-class ranking. The survey results are
integrated into our People and Organisation improvement plans and support workforce planning decision-
making.
• The perspective of value chain workers gained through our supplier relationships inform our approach to
sustainable procurement. Through the governance system, due diligence and involvement with industry
bodies DOF promotes responsible business practices and Human Rights compliance across the industry’s
value chain.
• Customer engagement is imperative as it allows DOF to anticipate and deliver a vessel fleet and subsea
services that prioritise responsible practices, meet operational requirements and complement supply chains
from an ESG perspective.
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Stakeholder engagement
Stakeholder Group Our Channels Key Topics 2025 Measures and Initiatives
OUR OWN WORKFORCE
• Employees
• Contractors
Stakeholder expectations
Meaningful work, equitable treatment and compensation, inclusivity,
and ample development prospects for everyone
• Annual Employee satisfaction surveys
• Regular Townhall meetings
• Organisational development workshops
• DOF Code of Business Conduct
• HR Policy, & training programmes
• Performance Appraisals
• Intranet / DOF portal
• Ethics Helpline
• Employment relations and occupational health and safety representatives
• Safety, security, health and wellbeing
• Business model resilience and emissions management
• Sustainable Financial Platform
• Business ethics and compliance
• Employee wellbeing, experience and engagement
• Equality and diversity
• Training and development
• Employee engagement survey
• HR Employee Survey improvement plans
• Diversity and inclusion committee and plan
• Workplace safety environment focus
• Offshore Leader’s Conference
• Dignity and respect in the workplace guide (see page 90)
• Ethics Helpline
VALUE CHAIN WORKERS
Stakeholder expectations
Responsible business practices, and partnership on strategic issues
to uphold adequate working conditions, secure employment, and fair
wages through our supply chain
• Union negotiations
• Via other worker representatives
• Surveys and feedback sessions
• Training and capacity-building programmes
• Supplier Code of Conduct
• Safety, Health, Security and wellbeing
• Code of business Conduct
• Due diligence
• Governance practices to safeguard labour conditions across the value chain
• Human Rights due diligence and compliance audits
CUSTOMERS
Stakeholder expectations
DOF to anticipate and deliver a vessel fleet and subsea services that
prioritise responsible practices, meet operational requirements and
complement supply chains from an ESG perspective
• Contract review meetings
• Customer- and Client feedback process
• Regular operational meetings
• Day-to-day communication
• Risk assessments
• Industry seminars
• Safety, Health, Security and wellbeing
• GHG emissions. Energy management
• Waste and hazardous materials management
• Ecological impact / Biodiversity
• Human rights
• Data security
• Employee diversity, engagement & inclusion
• Business model resilience
• Sustainable finance
• Product design and life cycle management. Supply chain management
• Physical impact of climate change
• Business ethics
• Management of legal & regulatory environment
• Critical incident risk management
• Understand customers’ expectations
• Governance and ethical business practices
• Customer supply chain emissions reduction
• Human Rights due diligence and compliance audits
• Quality services
SUPPLIERS
Stakeholder expectations
DOF to promote responsible business practices and offer partnership
on strategic issues
• Regular communication
• Annual workshop
• Code of Business Conduct within contract terms
• Oversight of performance and contractual issues
• Audits
• Safety, Health, Security and wellbeing
• Human rights and Labour practices
• Waste and hazardous materials management
• Supplier Code of Conduct
• Governance and ethical business practices
• Human Rights due diligence and compliance audits
• Fair procurement strategy
• Supply Chain Managers Forum
FINANCIAL INVESTORS STAKEHOLDERS
Stakeholder expectations
DOF is expected to implement strategies, plans, and actions aimed at
mitigating short- and long-term risks to the business model. They seek
proactive measures to safeguard against potential threats and ensure
sustained financial stability
• Quarterly and Monthly reports and investor presentations forums
• Budgeting process
• Fleet key performance indicators
• Continuous dialogue, engagement and consulting
• Management agreements
• GHG emissions reductions and Energy management
• Human rights and Labour practices
• Employee health, safety and security
• Employee diversity, engagement & inclusion
• Business model resilience
• Physical impact of climate change
• Business ethics
• Critical incident risk management
• Legislative compliance
• ESG ratings
• Compliant financial and sustainability data reporting
• Secure finance
• Investor Relations website and function
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SBM-3 Material impacts, risks and opportunities (IROs) and their interaction with strategy and
business model
DOF’s DMA process was revised to comply with ESRS requirements in 2024. The DMA process involves direct
engagement with multiple internal stakeholder groups and assesses the interests of key external stakeholders.
This includes, but is not limited to key clients, financial institutions, Industry working groups, suppliers, and the
wider society.
To ensure an accurate representation of stakeholders’ interests, information from a variety of engagement channels
was utilised. This includes desktop research and interviews of key internal stakeholders. The selection and engagement
of stakeholders in 2025 for the DMA review, is based upon review of DOF’s Organisational Context 2025.
The resulting Material IROs (See SBM 3 IRO Table on see page 44) are integrated into the Board and Executive
Management’s discussions on strategy and major transactions as DOF’s risk management process encompasses
the IROs. From this process, agreed strategic and key ESG initiatives are organised and managed in the Global
Improvement Programme. Regular review schedules and well-practiced routines manage risk, capture opportunities,
assess material topics and measure progress to enhance and preserve value generation.
DOF’s strategy and business model are designed to address material IROs while capitalising on opportunities
for sustainable growth. The organisational structure and leadership team support business and services lines to
meet demand and growth in an evolving market. ESG performance reporting and transparency has increased in
our value chain. DOF has publicly reported and managed material topics since 2014. Many ESG improvement
initiatives span years and are tracked and managed accordingly. The Global Improvement Programme reviews are
conducted annually, and regular meetings cover matters relating to evaluation of implementation of due diligence,
effectiveness of policies, and the outcomes of actions, metrics, and targets adopted.
Changes in the energy market in recent years are key drivers for our organisation’s future value creation and DOF’s
business model has adapted to utilise the organisation’s assets and competencies in new markets. The Renewable
energy market, like Offshore Wind are a good fit for DOF’s transferable skills, existing team and assets, and
represents a significant organic diversification opportunity. Risk analysis is conducted using short-term (1 year),
medium-term (2-5 years), and long-term (5+ years) horizons within its Corporate Risk and Opportunity register, in
addition to assessing potential climate-related risks and opportunities. This analysis included scenario modelling
for various IPCC global warming models.
Comparability and changes from prior year
Compared to the prior reporting period, there were minor changes in the prioritization and scope of sustainability
related impacts, risks and opportunities reflecting DOF’s business context. This includes the addition of two new
material IRO’s and some changes in trajectory of existing IRO’s from previous reporting period. No IRO’s from last
year have been removed. The additional IROs and changes in prioritization and scope are outlined in SBM 3 IRO
Table. It is noted that these changes did not result in a significant risk of a material adjustment to the carrying
amounts of assets and liabilities has been identified within the next annual reporting period, based on management’s
assessment of the assumptions, estimates and judgments applied in preparing the related financial statements. This
assessment considered the potential financial effects arising from sustainability-related impacts, risks and opportunities.
The material impacts, risks and opportunities (IROs) identified through the materiality assessment described below
are presented by topical standard, and disclosed in conjunction with the relevant ESRS requirements, including ESRS
E1 Climate Change, ESRS E2 Pollution, ESRS E5 Circular Economy and Resource Use, ESRS S1 Own Workforce,
ESRS S2 Workers in the Supply Chain, and ESRS G1 Business Conduct, within DOF’s Sustainability Statements.
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Key
IRO type
Impact materiality Financial materiality
PI
Potential impact
AI
Actual impact
!
Potential risk
!
Actual risk
O
Opportunity
Stakeholder priority increasing unchanged decreasing
Time horizon
Short-term Short-to medium-term Medium-to long-term Long-term
SBM 3 IRO Table
ENVIRONMENTAL
MATERIAL IMPACTS,
RISKS AND OPPORTUNITIES
IRO
TYPE
VALUE
CHAIN
AREA
STAKE
HOLDER
PRIORITY
TIME
HORIZON
E1 Climate Change
Emissions from fossil fuels
Vessel fleet relies on fossil fuels, thus GHG emissions are linked
to the level of operational activity
AI
Direct
Perpetuation of fossil fuel use
DOF’s participation in conventional offshore
energy markets may contribute to the continued
reliance on the use of fossil fuels which negatively
impacts the environment
PI
Downstream
Indirect emission profile
DOF’s extended value chain is a significant
component of the overall emission profile
AI
Upstream
Physical Climate Change
Changes to weather patterns as a result of climate
change may cause increased fuel consumption
!
Direct
Client Decarbonisation Focus
Clients are more focused on decarbonisation, but current
contracts and client appetite do not enable recovery of
capital costs for decarbonisation investments
!
Downstream
E2 Pollution
Financial exposure in offshore spills
A significant offshore spill event may expose
DOF to financial liabilities
PI
Direct
E5 Circular Economy
and Resource Use
Generation of Waste
DOF generates significant quantities of waste as
part of day-to-day activities and as part of vessel
overhauls and maintenance
AI
Across whole
value chain
SOCIAL
MATERIAL IMPACTS,
RISKS AND OPPORTUNITIES
IRO
TYPE
VALUE
CHAIN
AREA
STAKE
HOLDER
PRIORITY
TIME
HORIZON
S1 Own Workforce
Wage and compensation
Compensation expectations may negatively affect DOF’s ability to
attract and retain the required competence
AI
Direct
Occupational Health and Safety
High consequence low probability incidents can have fatal or
serious consequences for workers
PI
Direct
Security risk
Increased operational activity in areas with high security risk may
negatively affect health, safety and wellbeing of DOF workforce
PI
Direct
Security risk management
Increased operational activity in areas with high security risk
requires additional security risk management measures and
resources
!
Direct
Major accident event
DOF may have a major accident event involving multiple personnel
!
Direct
Inclusion and equality
There are perceived or actual barriers to inclusion and equality
in a male dominated industry which can have a negative effect
within DOF
AI
Direct
Global availability of resources
The availability of resources and key competencies are becoming
limited because of a smaller resource pool
!
Direct
Personnel continuity
Inability to meet competency demands within emerging markets,
new technologies and stakeholder expectations
!
Direct
Data security
Exposure to data breaches, cyber attacks and unauthorised access
to employee data
PI
Direct
Data privacy compliance
Breach of data privacy legislation may result in significant fines for
the organisation
!
Direct
MATERIAL IMPACTS,
RISKS AND OPPORTUNITIES
IRO
TYPE
VALUE
CHAIN
AREA
STAKE
HOLDER
PRIORITY
TIME
HORIZON
S2 Workers in the Value Chain
Child and forced labour within extended value chain
DOF is exposed to the use of child and forced labour as a result of
business relationships with shipyards, manning agencies and the
use of some manufactured products
PI
Upstream
Labour conditions
DOF is not always able to assure the labour conditions of its
extended value chain, exposing it to non-compliance to UN
Global Compact
PI
Upstream
Occupational Health and Safety
High consequence low probability incidents can have fatal or
serious personnel consequences for workers
PI
Upstream
Occupational Health and Safety at shipyards
Maintaining adequate health and safety standards within shipyards
is a significant challenge as tasks are performed using third-party
management systems
PI
Direct
Global availability of resources
The availability of resources and key competencies are becoming
limited because of a smaller resource pool
!
Upstream
Personnel continuity
Inability to meet competency demands within emerging markets,
new technologies and stakeholder expectations
!
Upstream
GOVERNANCE
MATERIAL IMPACTS,
RISKS AND OPPORTUNITIES
IRO
TYPE
VALUE
CHAIN
AREA
STAKE
HOLDER
PRIORITY
TIME
HORIZON
G1 Business Conduct
Exposure to differing cultural norms
DOF’s global footprint exposes operations to different cultural
norms that may result in breaches of our core values
PI
Direct
Compliance to anti-corruption and bribery legislation
DOF may encounter corruption and bribery within the high-risk
areas we work
PI
Direct
Supplier exposure to corruption and bribery
Through its operational footprint DOF may work with suppliers
that do not comply with UN Global Compact conditions
!
Upstream
Lifecycle management of end-of-life assets
DOF needs to ensure adequate levels of due diligence in the
process of divestment of assets to avoid severe reputational
and financial damage because of non-compliance
PI
Downstream
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IRO-1 Description of the process to identify and assess material impacts, risks and opportunities
During 2025, DOF conducted a materiality assessment based on ESRS 1 requirements. The assessment involved identifying and objectively assessing impacts, risks and opportunities (IROs) and resulted in a completed
double-materiality assessment (DMA). The impacts, risks and opportunities identified in the DMA are described under the relevant topical ESRS in this report.
Identify IROs Stakeholder Engagement Examine IROs Related to Value Chain Materiality Scoring Approach Decision-Making and Internal Controls Future Steps: Integration, Monitoring,
and Review
DOF began the 2025 Double Materiality
Assessment (DMA) process with a
comprehensive review of the organisational
context. This review served as the
foundation for the DMA by identifying both
internal and external changes that influence
ESG matters, and by mapping these
changes to relevant stakeholders or primary
data sources for further insight.
The organizational context review
encompassed a broad range of factors,
including DOF’s business model, value
chain, regulatory landscape, stakeholder
expectations, impacts and risks from the
corporate risk register, organizational
and governance structure, policies, KPIs,
operational context, and industry benchmarks.
This holistic approach ensured that all relevant
elements were considered from the outset.
And incorporated upstream, direct and
downstream areas of the value chain.
Sustainability topics and sub-topics that did
not align with DOF’s value chain were excluded
from the analysis. Justification for the
exclusions include:
• Our value chain had no significant
interaction with the sustainability topics.
• The activities or geographies where the
IROs are not material.
• The impact materiality was determined to be
minor in scale, scope or remediability.
• The likelihood of financial effects from the
topic was low based on DOF’s business
model, operations and exposure.
• The teams involved in the DMA process
agreed the excluded material topics.
In 2025, DOF applied an expanded
stakeholder engagement approach to verify
and build upon the 2024 double materiality
assessment. Engaging with stakeholders
remains central to our ESG strategy and
informs the development of our Global
Improvement Plan. This year’s assessment
combined insights from internal and
external stakeholders, including new senior
management teams following organisational
integration, key clients with significant
backlog exposure, external financial
stakeholders, industry peers, member
organisations, and Executive Management.
Regional representation was ensured by
identifying and escalating critical Regional
Risks and Opportunities within the DOF
Risk Framework.
This process builds on the 2024 DMA
methodology, where internal stakeholders
from support functions and Regions
participated through global workshops to
identify and validate impacts, risks, and
opportunities (IROs) to the sub-topic level.
External perspectives were supplemented
through client feedback, peer and association
interactions, and targeted desktop research.
Financial risks and opportunities were
assessed using the most recent Corporate
Risk and Opportunity Register and validated
by the GRC Committee, Audit Committee,
Executive teams and relevant internal
stakeholders. The combined 2024–2025
approach ensures a robust and continuously
refined methodology for identifying,
validating, and prioritising sustainability-
related impacts, risks, and opportunities in
line with CSRD requirements.
DOF re-reviewed its organizational context to
identify any significant changes to business
activities, capital inputs and dependencies
across our upstream activities, Marine
Management, Specialist Fleet, Project
Management and Downstream Operations.
Understanding the organizational context
was important when considering the DOF’s
relationship with IROs.
IROs were then examined across specific
activities within the direct areas of our
control in addition to extended business
relationships. Specific focus was made
towards verifying existing IROs and
evaluating exposure to new IRO’s because of
changes to business context in 2025.
Sustainability-related risks and opportunities
are integrated into the Risk Management
framework along with other types of business
risks. This ensures internal stakeholders have
a holistic view of sustainability considerations
and these are as business risks. Sustainability
IROs are therefore a fundamental component
of DOF’s overall view of organisational risks
and opportunities.
Examination of climate-related IROs was
integral to the DMA for sustainability issues
related to climate change mitigation and
adaptation. DOF reviewed its climate-
related scenario analysis considering
the organizational context review to aid
the DMA process and identification and
assessment of physical and transitional
risks and opportunities across prescribed
climate scenarios.
The materiality assessment’s scoring method
and criteria followed ESRS 1 requirements
and focused on:
• Impact materiality: considered the scale,
scope, irreversibility, and likelihood of
impacts being positive/negative and actual/
potential Impact materiality threshold was
set at high or critical levels, determined by
impact materiality criteria.
• Financial materiality: assessed the financial
significance of risks or opportunities, their
likelihood, the nature of financial impacts and
whether they exceed DOF’s threshold of 1%
of 2024 revenue. The financial materiality
threshold within DMA is consistent with our
financial accounting.
The scoring criteria incorporated time
frames and thresholds from DOF’s ERM
system, aligning sustainability-related risks
and opportunities with other enterprise risks
and opportunities.
A sustainability topic was classified as
material if any associated IRO surpassed
the set threshold, indicating either impact
materiality, financial materiality, or both.
Not Material issues were those falling below
these thresholds.
The outcome of the materiality approach and
list of material topics were validated by the
Audit Committee and Board of Directors in
Q4 2025.
• Critical decisions in the process included:
• Review of Organisational Context.
• Identify key internal stakeholder
representatives.
• Validate IRO scoring with identified
stakeholders.
• Present sustainability matters in the Q4
Board meeting.
• Scoring methodology adhered to ESRS
guidelines.
• Aligned with DOF’s ERM system to set
thresholds and timeline.
• Each IRO was documented to justify its
materiality.
DOF views the DMA process as one that
is iterative, requiring ongoing review and
update to reflect emerging IROs, evolving
trends, regulatory changes and underlying
assumptions.
DOF intends to strengthen the links between
its Risk Management Framework and the
DMA process. The formation of the GRC
Committee, risk appetite statement and
key risk indicators in 2025 allow improved
levels of governance into key IROs that are
important to the organization. This has a net
positive effect on overall management of
IROs in the business.
In 2026, DOF will finalise the selection of
new ESG software. Implementing this ESG
platform will enable DOF to organise IROs
and consolidate ESG data, providing deeper
insights for the business. This platform
will support more effective validation,
monitoring, communication, control, and
review of key ESG metrics.
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E1 IRO-1 Description of process to identify and assess climate-related IROs
As described in ESRS SBM-3, DOF updated its DMA in 2024. The assessment objectively scored IROs as a basis to determine whether sustainability matters were material or not. In 2023, DOF assessed its climate-related IROs,
which were revisited in 2024 and filtered into the updated DMA, as well as conducting a climate-related scenario analysis.
Climate Scenarios Workshops DMA Process Outcomes
The climate scenario analysis DOF used incorporated three climate risk scenarios (SSP1-19,
SSP2-45, and SSP5-85), from the Intergovernmental Panel on Climate Change (IPCC) 6th
Assessment Report (Intergovernmental Panel on Climate Change, 2021).
The scenarios provide a comprehensive evaluation of transitional and physical climate risks,
approximately corresponding to the Representative Concentration Pathways (RCPs) 26, 45, and
85, respectively.
Shared Socioeconomic Pathways (SSPs) are scenarios that explore different possible futures for
society and the environment SSP1-19 represents a sustainable future with rapid technological
development and low emissions, SSP2-45 is a middle-of-the-road scenario with moderate
economic growth and emissions, and SSP5-85 is a high-emissions future with high economic
growth and continued reliance on fossil fuels. Using the mentioned SSPs, our climate-related
scenario analysis identifies key forces shaping the conventional subsea and renewable markets.
Policy assumptions range from stringent emissions reduction and carbon pricing in SSP1-19,
driving growth in offshore renewables, to moderate climate policies in SSP2-45, and limited
action in SSP5-85, sustaining high demand for oil and gas.
Macroeconomic trends under SSP1-1.9 emphasise a green economy, reducing fossil fuel
infrastructure needs, while SSP5-85 reflects robust economic growth fueled by traditional
energy, and SSP2-45 balances both. Energy usage and mix see rapid renewable adoption in
SSP1-19, gradual transition in SSP2-45, and sustained fossil fuel reliance in SSP5-85, directly
influencing the market. Technological advancements are most pronounced in SSP1-19, fostering
offshore wind and subsea robotics, while SSP5-85 drives innovations in fossil-fuel extraction.
These forces highlight transition risks in renewable-driven pathways, physical risks from extreme
weather across all scenarios, and opportunities for growth in both renewable and traditional
subsea infrastructure depending on the pathway. The scenario analysis did not use geospatial
data, however, did consider our global operational footprint and is deemed consistent with
assumptions made in the financial statement.
Time Frames
The time frame used in the scenarios defined short, medium and long-term as 0 -1, 2 -5 and 5
years or more respectively. When evaluating climate impacts to assets, the time frames were also
assessed in relation to the expected lifespan of vessels and across strategic planning horizons
within the Group.
Our activities were screened and actual and potential future GHG emission sources identified,
including operational emissions and value chain impacts, focusing on fossil fuel-based operations,
supply chain, and changes associated with project development.
Within this process we sought to evaluate the sensitivity of market segments, including extreme
weather events and rising sea levels, by evaluating the likelihood, magnitude, and duration
of these hazards. As much as possible analysis considered the vulnerability of critical supply
chain nodes and operational sites based on their locations and climate risk profiles to ensure
comprehensive risk evaluation.
DOF utilised workshop outcomes from 2024, as the basis for the 2025 study. As a starting
point, the 2024 climate scenario analysis was reviewed against changes identified from the
organisational context review 2025. As there were no material changes to the activities, areas of
work, client base or value chain it was assumed that most of the 2024 Climate Scenario Analysis
outcome remain valid for the year.
In 2024, workshops with relevant leaders across the company lead the process Identifying climate
related risks and opportunities involved a top-down approach, as well as an ‘outside-in’ analysis of
risks and opportunities specific to conventional oil and gas and renewable segments.
Risks
Transition risks were assessed by identifying asset types and business activities with significant
locked-in GHG emissions and evaluating their alignment with the EU Taxonomy.
The analysis includes vessels and their emission profiles across the full operational lifespan,
feasibility with regulatory shifts, technological advancements, and market changes that may
impact their viability and compliance with climate transition goals.
Resilience analysis assumes the transition to a lower-carbon economy will drive increased demand
for renewable energy infrastructure, offshore wind expansion, and advanced subsea technologies,
while acknowledging uncertainties such as policy shifts and market adoption rates.
Assets most at risk, particularly those tied to fossil fuel exploration, are integrated into our
strategy and investment decisions, with mitigation efforts including service diversification, R&D in
low-carbon technologies, and workforce training for sustainable operations.
Reliance on Fossil Fuels and GHG Emissions
Emissions from our fleet have a material impact on climate change. Additionally, a significant
portion of total emissions fall under Scope 3 (downstream leased assets), as clients retain
operational control Failure to adapt to market and regulatory change poses transition risks,
with potential financial impacts.
Without the introduction of commercially and technically viable renewable energy sources, this
remains a short, medium, and long-term negative impact, directly linked to our operations.
Supporting Conventional Subsea Markets and Fossil Fuel Dependence
Primary revenue streams are closely tied to conventional subsea markets, which reinforce
societal reliance on fossil fuels. This contributes to climate change by driving continued fossil
fuel consumption, creating an actual negative impact on the downstream value chain.
This impact is expected to persist over the medium to long term, as fossil fuel use continues to
drive long-term shifts in temperature and weather patterns.
Fossil Fuel Dependence in the Supply Chain & Scope 3 Emissions
Our supply chain relies on fossil fuels, leading to high Scope 3 emissions. As operational
activities increase, emissions from upstream suppliers (providing products and services) also
rise. The procurement, manufacturing, and transportation of these products are carbon-
intensive, resulting in a significant Scope 3 emission profile and an actual negative climate
impact. This impact remains relevant across short, medium, and long-term time horizons, as
long as our operations are linked to upstream fossil fuel use.
Inability to pass on costs of decarbonisation and compliance towards upstream value chain
A new market and transition risk has been identified, reflecting the current sentiment in the
marine contracting industry regarding the costs of decarbonisation. At present, industry
commercial structures do not allow for the capital expenditure required for decarbonisation
to be passed up the value chain to clients, despite strong client interest in decarbonising their
own operations. This challenge is compounded by a lack of suitable market incentives, existing
contract structures, limited client willingness to pay, inconsistent availability of subsidies, and
varying legislative frameworks across DOF’s geographical footprint.
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E2 IRO-1 Description of process to identify and assess pollution-related IROs
The materiality assessment considered impacts, risks and opportunities related to the topics, sub-topics, and sub-sub-topics in line with the ESRS 1 General Requirements, including topics and sub-topics related to pollution.
Through this process, the upstream, downstream, and direct areas of our value chain was evaluated to understand what is material across our scope of operations, globally.
Screening Methodologies & Assumptions Consultations & Community Engagement Assessment of Risks and Opportunities DMA Process Outcomes
To identify actual and potential pollution-related impacts, a
comprehensive screening process across site locations and business
activities across our operations was undertaken to assess the
interface with nature.
This involved an evaluation of emissions from our direct assets,
upstream, and downstream activities using historic data from
environmental incidents and past risk assessments. The screening
methodologies included detailed data collection on pollutant
emissions, their severity, and likelihood of impacts on the
environment and human health.
External parties or communities were not consulted as part of
this process.
To guide our assessment and identification of risks and impacts, we
evaluated several sources of existing risk documentation. This included
the review of:
• Hazard Identification Risk Assessments (HIRAs) performed for projects,
• Evaluating client Environmental Plans for offshore operations, and,
• Applicable legislation.
Feedback from Regional Executives via stakeholder interviews also
confirmed this as an area of heightened risk, especially in regards to
liabilities towards remediation of pollution incidents in certain regions via
contract clauses. Regional risk registers were also reviewed to assess
vulnerabilities related to pollution.
The assessment helps us understand and address our pollution-related
impacts but also ensures our commitment to responsible environmental
stewardship, risk management, and sustainable operations across our
value chain.
Pollution of Water
Unplanned discharges of hazardous materials as a material impact on
the environment have been identified. These impacts arise from the loss
of secondary containment, leading to potential pollution incidents.
Key sources include:
• Release of antifouling chemicals,
• Spills during bunkering operations,
• Subsea operations resulting in inadvertent hydraulic fluid release,
• Loss of containment on the main deck,
• Discharge of hydrocarbons during project activities ,
• The incidents present short- medium, and long-term environmental risks,
with potential financial consequences,
• An uncontrolled spill or loss of secondary containment could result in
financially material impacts, including regulatory penalties, reputational
damage, and increased operational costs,
• No opportunities were identified in relation to pollution.
E3 IRO-1 Description of the processes to identify and assess material water and marine resources-related IROs
As part of our DMA process, DOF has implemented processes to identify and assess material impacts, risks, and opportunities related to water and marine resources in our operations and value chain.
Screening Methodologies & Assumptions Consultations & Community Engagement Assessment of Risks and Opportunities DMA Process Outcomes
To evaluate water and marine resource related IROs site locations and
business activities were screened to identify potential impacts.
Past risk assessments, incidents, compliance/non-conformities and
client environmental plans were evaluated. DOF has also reviewed
client environmental plans to evaluate geographical locations of
operations and environmental sensitivities.
Benchmarking: DOF applied industry benchmarks and peer
comparisons to assess performance in relation to others in our
industry. This was done through industry forum events and desktop
analysis of 2024 Annual Reports.
External parties or communities were not consulted as part of
this process.
Our materiality assessment covered:
• Water use: consumption of surface and groundwater, including
withdrawals and discharges,
• Marine resources: our use of marine resources and the impact on
ecosystem health.
The rationale behind the process is to first identify potential worksites
and/or business activities that have the potential to impact water and
marine resources.
Regional risk registers were reviewed to assess vulnerabilities related
to water and marine related IROs.
The indirect impacts to marine resource availability and quality because
of value chain operations identified were not considered material.
No opportunities were identified within this process.
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E4 IRO-1 Description of the processes to identify and assess biodiversity related IROs
As part of our DMA process, DOF has implemented processes to identify and assess material impacts, risks, and opportunities related to biodiversity in our operations and value chain.
Screening Methodologies & Assumptions Consultations & Community Engagement Assessment of Risks and Opportunities DMA Process Outcomes
To identify biodiversity and ecosystem-related IROs,
we screened site locations and business activities
to assess potential impacts. This process included
reviewing past risk assessments, incidents, complaints
and non-conformities, as well as evaluating client
Environmental Plans for locations where our vessels
have operated.
Benchmarking: DOF applied industry benchmarks
and peer comparisons to assess performance in
relation to others in our industry. This was done
through industry forum events and desktop analysis
of 2024 Annual Reports.
External parties or communities were not consulted as part of
this process.
In alignment with AR 4 and AR 6 of the ESRS E4 guidelines, our materiality assessment considered on
the following aspects:
Contribution to Direct Impact Drivers on Biodiversity Loss.
• Climate Change: evaluation of greenhouse gas emissions and their contribution to climate change, which
is a significant driver of biodiversity loss.
• Sea-Use Change: our operations’ impact on water resources and marine habitats, including seabed
disturbance and disturbance to marine fauna or flora.
• Direct Exploitation and Pollution: the effects of resource extraction and pollution from our operations
were examined, particularly regarding their impact on local species and ecosystems.
• Invasive Species: the potential for our activities to introduce or spread invasive alien species via hull
fouling or ballast water management.
Impacts on Species and Ecosystems.
• Species Population and Extinction Risk: we analysed our operations’ impact on marine fauna and flora
populations and their global extinction risk, focusing on endangered species.
• Ecosystem Condition and Services: the extent and condition of ecosystems in proximity to our
operations were evaluated, including the impact on essential ecosystem services such as water
purification, pollination, and climate regulation.
• Regional risk registers were reviewed to assess vulnerabilities related to biodiversity IROs.
Potential impacts associated with the introduction of
invasive marine species, disruption to marine habitats
during subsea intervention campaigns and disruption
to marine fauna were identified and not considered
material.
E5 IRO-1 Description of the processes to identify and assess material resource use and circular economy-related IROs
DOF’s materiality assessment considered its impacts, risks, and opportunities related to the topics, subtopics, and sub-subtopics in the ESRS 1 General Requirements, including topics and subtopics related to Circular Economy and
resource use. Through this process, DOF evaluated the upstream, downstream, and direct areas of its value chain to gain a deep understanding of what material is across our scope of operations globally.
Screening Methodologies & Assumptions Consultations & Community Engagement Assessment of Risks and Opportunities DMA Process Outcomes
Environmental aspect registers, Integrated
Management System documentation and the Corporate
Risk and Opportunity Register were evaluated to
identify risks and impacts.
In addition, we used information gathered during the
EU Taxonomy process to determine eligibility and
alignment, providing qualitative and quantitative
insights into risks and opportunities related to resource
use and circular economy.
Benchmarking: DOF applied industry benchmarks and
peer comparisons to assess performance in relation
to others in our industry. This was done through
industry forum events and desktop analysis of 2024
Annual Reports.
External parties or communities were not consulted as part of
this process.
The assessment enables an understanding of raw material dependencies
and outputs to ensure our commitment to responsible environmental
stewardship, risk management, and sustainable operations across our
value chain.
Regional risk registers were reviewed to assess vulnerabilities related to
resource use and circular economy.
Generation of Waste
Waste Management has been identified as a material topic under Resource Use and
Circular Economy, with actual and potential impacts arising from:
• Vessel overhauls,
• Disposal of end-of-life components,
• Waste generated from day-to-day operations.
These impacts are present in direct operations, as well as upstream and downstream areas
of the value chain. Given its significance, Waste Management remains material across
short, medium, and long-term time horizons.
The inflow of resources for vessel newbuilding and major vessel conversions has been
identified as a potential material impact. However, as DOF’s newbuild program remains are
relatively small component of the entire value chain this is not considered a material topic
within the reporting period.
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S1 Description of the process to identify and assess material workforce-related IROs
A detailed materiality assessment was conducted in alignment with the ESRS 1 General Requirements, specifically addressing the topics, sub-topics, and sub-sub-topics related to workforce impacts under ESRS S1: Own Workforce.
This process included evaluating our direct operations and value chain to understand material issues related to workforce matters across our global scope of operations.
Screening Methodologies & Assumptions Consultations & Community Engagement Assessment of Risks and Opportunities DMA Process Outcomes
To identify actual and potential workforce-related impacts, risks,
and opportunities, a comprehensive screening process was
conducted across all regions of operation. The screening process
included an analysis of employee-related data, labour metrics,
Health and Safety records, and training hours. Historical trends,
including incidents of work-related injuries or labour disputes,
were also analysed to assess the scale, scope, and likelihood of
workforce-related risks.
Employee engagement surveys: internal surveys and employee
feedback were analysed to identify issues such as workplace
satisfaction, inclusion, and well-being.
Health and Safety assessments: historical data on Lost Time
Injury Frequency (LTIF) and Total Recordable Injury Rates (TRIR)
were reviewed to evaluate health and safety performance across
global operations.
Benchmarking: DOF applied industry benchmarks and peer
comparisons to assess performance in areas such as gender
pay gaps, living wage, training investments, and collective
bargaining coverage.
As part of the process, internal stakeholders were consulted,
including regional People and Organisation teams, HSE
departments, and Executive Vice Presidents.
Throughout the year there has been continuous engagement
with NGO’s and union representatives to gather industry and
work group perspectives.
To guide the identification of risks and opportunities, internal and
external documentation was reviewed, including:
• Workforce Health and Safety policies were analysed to ensure
alignment with international labour standards and regulatory
requirements.
• Training and development plans, skills development and future
workforce capability needs were assessed to identify strategic
opportunities.
• Regional risk registers were reviewed to assess vulnerabilities
related to workforce conditions, legal compliance, and operational
disruptions caused by workforce-related issues.
Working Conditions (Wage & Compensation)
Our capacity to attract and retain skilled employees is under pressure due to
rising wage and compensation expectations driven by inflation, a constrained
talent pool, and intensified competition for talent. Additionally, labour market
constraints are increasing recruitment costs, including advertising, interviewing,
and onboarding expenses. These factors directly impact workforce planning and
recruitment processes. Given its significance, this risk is considered material
across short-, medium-, and long-term horizons.
Health and Safety
Workforce health and safety is at risk, with both actual and potential impacts.
Potential risks include occupational hazards that could lead to low-probability,
high-consequence incidents such as serious or fatal injuries, increased operations
in high-risk areas negatively affecting workforce health, safety, and well-being,
and the occurrence of a major accident involving multiple personnel. An actual
risk is the need for enhanced security measures and resources for operations
in high-security risk areas. These impacts, risks, and opportunities (IROs) are
present in our direct operations. Given its significance, this risk remains material
across short, medium, and long-term time horizons.
Inclusion, Equality, and Workforce Continuity
Workforce composition and continuity pose a risk, with both actual and potential
impacts. The male-dominated nature of the oil and energy industry presents an
actual negative impact as it creates barriers to diversity and inclusion, affecting
workplace culture and employee retention. An actual risk is the shrinking talent
pool, which limits access to key competencies and challenges workforce planning
and recruitment. A potential risk involves difficulties in meeting competency
demands in emerging markets, new technologies, and evolving stakeholder
expectations due to industry requirements, regulatory restrictions, and reputational
risks. These impacts, risks, and opportunities (IROs) are present in DOF’s human
resources practices and operational capabilities. Given its significance, this risk
remains material across the medium- to long-term time horizons.
Other Work-Related Rights (Data Security and Privacy)
Employee data security and privacy are at risk, with potential impacts arising
from exposure to data breaches, cyber-attacks, and unauthorised access to
employee data, posing a potential negative impact. Additionally, a potential risk
includes fines resulting from non-compliance with data privacy legislation. These
impacts are present in DOF’s IT systems and data management practices, making
this risk material.
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S2 Description of the process to identify and assess material IROs related to workers in the value chain
Screening Methodologies & Assumptions Consultations & Community Engagement Assessment of Risks and Opportunities DMA Process Outcomes
To identify material impacts and risks associated with workers in the
value chain, a systematic screening process was undertaken.
Mapping the value chain included the identification of key suppliers,
subcontractors, and business partners globally, with emphasis on high-
risk geographies and sectors.
Supply chain audits and assessments informed the analysis of supplier
practices related to human rights, labour standards, and health and
safety, including compliance with international frameworks such as
the UN Guiding Principles on Business and Human Rights and the ILO
Core Conventions.
Historical data was reviewed and past incidents, such as breaches of
supplier codes of conduct or labour violations reviewed, to determine
the likelihood and severity of future risks.
Risk Segmentation: classification of suppliers based on risk factors,
including geographic location, industry type, and reliance on vulnerable
worker populations (e.g., migrant labour or contract workers).
As part of this process, internal and external stakeholder
were consulted, including:
• Internal stakeholders: supply chain management and
procurement teams, regional executives, and operational
managers were consulted to identify specific worker-
related challenges and risks within the supply chain.
• External stakeholders: supplier engagement and audits
provided additional perspectives on worker conditions,
employment practices, and alignment with the Business
and Supplier Code of Conduct.
Our systematic assessment of IROs related to workers in the value
chain, took the following steps:
• Collaboration with procurement and supply chain management to
assess supplier compliance with the Supplier Code of Conduct and
areas of exposure.
• Internal and third-party audit findings to validate supplier performance
on labour and human rights issues.
• Supplier engagement with key suppliers and subcontractors.
• Third-party experts undertook risk segmentation of areas of exposure
across our value chain.
Our diverse geographical footprint and supply chains create potential fundamental
industry labour standards compliance risks. Potential impacts and risks sources
include inadequate wages and poor working conditions for supply chain workers.
Potential impacts could mean poverty and a poor quality of life, unacceptable health
and safety standards and excessive working hours for these stakeholders. These
issues are particularly relevant to our business relationships with shipyards and
external manning agencies especially in geographical regions that have precedence to
systematic breaches of worker rights.
The potential risk arises from varying cultural norms and standards in different
regions and DOF is exposed to non-compliance with UN Global Compact standards.
These impacts are present in DOF’s downstream value chain and the risk material
across short, medium, and long-term time horizons.
Equal Treatment and Opportunities for All
Our extended value chain faces significant resource constraints and competency
gaps, creating risks to safe and efficient strategy execution in traditional subsea and
renewable markets. Actual and potential impacts and risks arise from inadequate
training and skills development in the value chain that could impact DOF’s short-term
business model.
Medium and long-term prospects face potential risk due to inadequate training and
skills development because of the industry’s ability to attract, retain, and develop new
generations of the workforce. These impacts are present across DOF’s value chain and
the risk material across short, medium, and long-term time horizons.
Other Work-Related Rights
DOF operates in regions designated as having “no guarantee of rights” by the ITUC
raising the associated risk of forced labour and child labour in its downstream value
chain. Potential impacts and risks arise from the use of forced labour and child labour
in the downstream value chain, particularly within shipbuilding and manning services.
This risk is associated with operations and business relationships in the Middle East
and North Africa, Asia-Pacific, and Africa.
The potential negative impact relates to reputational damage to DOF in the short,
medium, and long term due to exposure to child labour. These impacts are present in
DOF’s operations in specific regions. Given its significance, this risk remains material
across short, medium, and long-term time horizons.
Occupational Health and Safety
DOF’s value chain is vulnerable to occupational health and safety risks, especially
high-consequence, low-probability incidents. The potential risks arise from
occupational health and safety risks, particularly in shipyard activities where DOF has
limited control and the increased risk due to varying and systematically low safety
standards in different geographic locations of DOF’s operations.
These risks can have immediate and long-term impacts and are directly connected to
DOF’s core business model Given its significance; this risk remains material across
short, medium, and long-term time horizons.
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G1 IRO-1 Description of the processes to identify and assess material business conduct-related IROs
The identification of material impacts and risks related to business conduct involved mapping geographic areas in which DOF or its extended value chain operates with elevated potential impacts or risks associated with corruption
bribery, and human rights violations. DOF then identified risks and impacts based on business activities associated with conventional energy and renewable market segments including historic exposure to business conduct IROs.
Screening Methodologies & Assumptions Consultations & Community Engagement Assessment of Risks and Opportunities DMA Process Outcomes
The identification of IROs in relation to business conduct
matters involved mapping geographic areas in which
DOF or its extended value chain operates with elevated
potential impacts or risks associated with corruption
bribery, and human rights violations.
As part of the process, internal stakeholders
were consulted including supply chain
management and procurement teams, regional
executives and operational managers to identify
specific worker related challenges.
Risks and impacts were identified based on business
activities associated with conventional energy
and renewable market segments including historic
exposure to business conduct IROs.
The materiality assessment identified the following impacts and risks relating to business conduct as material to DOF:
Corporate Culture
Failure to build a corporate culture fostering awareness and the discipline to follow the CoBC and comply with the
business management system has a potential negative impact arising from non-compliance with the CoBC and
management systems, impacting direct operations and upstream activities.
Risk of Bribery and Corruption in Certain Operations
DOF faces a heightened risk of corruption and bribery in some operations. Bribery and corruption incidents are a
potential risk, leading to fines, penalties, and reputational damage. This could undermine business relationships with
customers and suppliers.
The risk exists in our own operations and is considered systemic to the industry and certain countries. It occurs in the
short, medium, and long term and is considered material.
Management of Relationships with Suppliers (Including Payments)
Our core services rely on suppliers for timely, high-quality materials which presents potential challenges related
to supplier relationships. A potential negative impact arise from long payment terms, while managing costs
and minimising operational delays, may strain suppliers’ cash flow, potentially leading to challenges with paying
subcontractors or employees.
The potential negative impact is concentrated in the upstream value chain, occurs in the short, medium, and long term,
and affects SME suppliers most acutely. This risk is considered material.
Lifecycle Management of end-of-life assets
To maintain a fleet that meets evolving market needs, DOF must manage both newbuild projects and the responsible
handling of end-of-life assets. The sale of vessels demands rigorous due diligence to minimise the risk of significant
compliance breaches. If third-party buyers of end-of-life assets are not properly vetted and aligned with regulatory
requirements, DOF could face substantial reputational and financial harm. This risk is especially relevant in upstream
areas of the value chain and is considered to have a plausible short- to medium-term impact on the DOF Group.
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IRO-2 Disclosure requirements in ESRS covered by the undertaking’s sustainability statement
ESRS 2
Disclosure
Description
Phase-in
Page
BP-1
General basis for preparation of the sustainability statement
N/A
35
BP-2
Disclosures in relation to specific circumstances
N/A
35
GOV-1
The role of the administrative management and supervisory
N/A
36
GOV-2
Information provided to and sustainability matters addressed by the business’s
administrative, management and supervisory bodies
N/A
37
GOV-3
Integration of sustainability-related performance in incentive schemes
N/A
37
GOV-4
Statement on due diligence
N/A
37
GOV-5
Risk management and internal controls over sustainability reporting
N/A
39
SBM-1
Strategy, business model and value chain
N/A
39
SBM-2
Interests and views of stakeholders
N/A
41
SBM-3
Material impacts, risks and opportunities and their interaction with strategy and
business model
Anticipated financial effects omitted per phase
in allowance
43
IRO-1
Description of the processes to identify and assess material impacts, risks and
opportunities
N/A
45
IRO-2
Disclosure Requirements in ESRS covered by the business’s sustainability statement
N/A
52
MDR-P
Policies adopted to manage material and sustainability matters
N/A
MDR-A
Actions and resources in relation to material sustainability matters
N/A
MDR-M
Metrics in relation to material sustainability matters
N/A
MDR-T
Tracking effectiveness of policies and actions through target
N/A
Disclosure Description Phase-in
Page
ENVIRONMENT E1 CLIMATE CHANGE
E1-1
Transition plan for climate change mitigation
N/A
58
E1-2
Policies related to climate change mitigation and adaptation
N/A
58
E1-3
Actions and resources in relation to climate change policies
N/A
58
E1-4
Targets related to climate change mitigation and adaptation
N/A
59
E1-5
Energy consumption and mix
N/A
60
E1-6
Gross Scopes 1, 2, 3 and Total GHG emissions
N/A
60
E1-7
GHG removals and GHG mitigation projects financed through carbon credits
N/A
62
E1-8
Internal carbon pricing
N/A
62
E1-9
Anticipated financial effects from material physical and transition risks and potential
climate-related opportunities
Disclosure omitted per phase in allowance
62
ENVIRONMENT E2 POLLUTION
E2-1
Policies related to pollution
N/A
63
E2-2
Actions and resources related to pollution
N/A
64
E2-3
Targets related to pollution
N/A
65
E2-4
Pollution of air, water and soil
N/A
65
E2-5
Substances of concern and substances of very high concern
N/A
65
E2-6
Anticipated financial effects from pollution-related risks and opportunities
N/A
65
ENVIRONMENT E5 RESOURCES AND CIRCULAR ECONOMY
E5-1
Policies related to resource use and circular economy
NA
66
E5-2
Actions and resources related to resource use and circular economy
NA
67
E5-3
Targets related to resource use and circular economy
NA
66
E5-4
Resource inflows
NA
67
E5-5
Resource outflows
NA
67
E5-6
Anticipated financial effects
Disclosure omitted per year one phase-in
allowance
68
SOCIAL S1 OWN WORKFORCE
S1-1
Policies governing own workforce
N/A
78
S1-2
Process for engaging with own workforce and workers’ representatives about impacts
N/A
81
S1-3
Processes to remediate negative impacts and channels for own workforce to raise
concerns
N/A
82
S1-4
Taking action on material impacts on own workforce, and approaches to managing
material risks and pursuing material opportunities related to own workforce, and
effectiveness of those actions
N/A
83
Disclosure Description Phase-in
Page
S1-5
Targets related to managing material negative impacts, advancing positive impacts,
and managing material risks and opportunities
N/A
84
S1-6
Characteristics of the undertaking’s employees
N/A
84
S1-7
Characteristics of non-employees in the undertaking’s own workforce
N/A
85
S1-8
Collective bargaining coverage and social dialogue
N/A
85
S1-9
Diversity metrics
N/A
94
S1-10
Adequate wages
N/A
85
S1-11
Social protection
N/A
85
S1-12
Persons with disabilities
N/A
-
S1-13
Training and skills development metrics
Disclosure omitted per phase in allowance
-
S1-14
Health and safety metrics
Disclosure partly omitted per phase-in allowance
Omitted information: cases of work-related
ill-health and on number of days lost to injuries,
accidents, fatalities and work-related ill health
89
S1-15
Work-life balance metrics
N/A
-
S1-16
Remuneration metrics (pay gap and total remuneration)
N/A
94
S1-17
Incidents, complaints and severe human rights impacts
N/A
86
SOCIAL S2 WORKERS IN THE VALUE CHAIN
S2-1
Policies related to value chain workers
N/A
98
S2-2
Processes for engaging with value chain workers about impacts
N/A
100
S2-3
Processes to remediate negative impacts and channels for value chain workers to
raise concerns
N/A
100
S2-4
Taking action on material impacts on value chain workers, and approaches to
managing material risks and pursuing material opportunities related to value chain
workers, and effectiveness of those action
N/A
101
S2-5
Targets related to managing material negative impacts, advancing positive impacts,
and managing material risks and opportunities
N/A
101
GOVERNANCE G1 BUSINESS CONDUCT
G1-1
Business conduct policies and corporate culture
N/A
103
G1-2
Management of relationships with suppliers
N/A
106
G1-3
Prevention and detection of corruption and bribery
N/A
106
G1-4
Incidents of corruption or bribery
N/A
108
G1-5
Political influence and lobbying activities
N/A
G1-6
Payment practices
N/A
108
DISCLOSURES INCORPORATED BY REFERENCE
ESRS 2 Description Section
GOV-1
The role of the administrative management and supervisory - Profiles of
Board of Directors and profiles of Executive Management Team
Board of Director’s Report
• The Board of Directors
• The Management Team
27
29
GOV-2
Information provided to and sustainability matters addressed by the
business’s administrative, management and supervisory bodies - Board of
Directors and Executive Management Team focus areas and expertise
Board of Director’s Report
• The Board of Directors
• Management Team
27
29
SBM-1
Strategy, business model and value chain - Market position, strategy,
business model and value chain
This is DOF
How DOF creates value for stakeholders
Our operating segments,
DOF’s approach to sustainability
15
16
17
23
STANDARDS NOT CONSIDERED MATERIAL
Topic
Description Materiality assessment
E3
Water and Marine Resources
DOF identified indirect impacts to marine resource availability and quality because of value chain operations
Nevertheless, these were not deemed material to DOF No opportunities were identified within this process
E4
Biodiversity and Ecosystems
DOF identified potential impacts associated with the introduction of invasive marine species, disruption to marine
habitats during subsea intervention. These were not deemed material to DOF. No opportunities were identified within
this process.
S3
Affected Communities
DOF’s material impact on communities is through our environmental impact, and as such the relevant information is
presented in the Environmental chapter
S4
Consumers and End-Users
DOF is a business-to-business service provider company and does not produce products for consumers and end-users
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List of data points in cross-cutting and topical standards that derive from other EU Legislation
Disclosure Requirement and related data point SFDR reference Pillar 3 reference Benchmark Regulation reference EU Climate Law reference
Material /
Not material
Page & (para)
reference
ESRS 2 GOV-1 Board’s gender diversity paragraph 21 (d)
Indicator number 13 of Table #1 of Annex 1
Commission Delegated Regulation (EU) 2020/1816,
Annex II
Material
36
ESRS GOV-1 Percentage of board members who are
independent paragraph 21 (e)
Delegated Regulation (EU) 2020/1816, Annex II
Material
36
ESRS 2 GOV-4 Statement on due diligence paragraph 30
Indicator number 10 Table #3 of Annex 1
Material
55
ESRS 2 SBM-1 Involvement in activities related to fossil fuel
activities paragraph 40 (d) i
Indicators number 4 Table #1 of Annex 1
Article 449a Regulation (EU) No 575/2013: Commission
Implementing Regulation (EU) 2022/2453 Table 1: Qualitative
information on Environmental risk and Table 2: Qualitative
information on social risk
Delegated Regulation (EU) 2020/1816, Annex II
Material
41
ESRS 2 SBM-1 Involvement in activities related to chemical
production paragraph 40 (d) ii
Indicator number 9 Table #2 of Annex 1
Delegated Regulation (EU) 2020/1816, Annex II
Not Material
N/A
ESRS 2 SBM-1 Involvement in activities related to
controversial weapons paragraph 40 (d) iii
Indicator number 14 Table #1 of Annex 1
Delegated Regulation (EU) 2020/1818, Article 12(1)
Delegated Regulation (EU) 2020/1816, Annex II
Not Material
N/A
ESRS 2 SBM-1 Involvement in activities related to
cultivation and production of tobacco paragraph 40 (d) iv
Delegated Regulation (EU) 2020/1818, Article 12(1)
Delegated Regulation (EU) 2020/1816, Annex II
Not Material
N/A
ESRS E1-1 Transition plan to reach climate neutrality by
2050 paragraph 14
Regulation (EU) 2021/1119, Article 2(1)
Material
58
ESRS E1-1 Undertakings excluded from Paris-aligned
Benchmarks paragraph 16 (g)
Article 449a Regulation (EU) No 575/2013; Commission
Implementing Regulation (EU) 2022/2453 Template 1: Banking
book Climate Change transition risk: Credit quality of exposures
by sector, emissions and residual maturity
Delegated Regulation (EU) 2020/1818, Article 121
(d) to (g), and Article 122
Material
N/A
ESRS E1-4 GHG emission reduction targets paragraph 34
Indicator number 4 Table #2 of Annex 1
Article 449a Regulation (EU) No 575/2013; Commission
Implementing Regulation (EU) 2022/2453 Template 3: Banking
book - Climate change transition risk: alignment metrics
Delegated Regulation (EU) 2020/1818, Article 6
Material
59
ESRS E1-5 Energy consumption from fossil sources
disaggregated by sources (only high climate impact sectors)
paragraph 38
Indicator number 5 Table #1 and Indicator n 5 Table #2
of Annex 1
Material
60
ESRS E1-5 Energy consumption and mix paragraph 37
Indicator number 5 Table #1 of Annex 1
Material
60
ESRS E1-5 Energy intensity associated with activities in
high climate impact sectors paragraphs 40 to 43
Indicator number 6 Table #1 of Annex 1
Material
60
ESRS E1-6 Gross Scope 1, 2, 3 and Total GHG emissions
paragraph 44
Indicators number 1 and 2 Table #1 of Annex 1
Article 449a; Regulation (EU) No 575/2013; Commission
Implementing Regulation (EU) 2022/2453 Template 1: Banking
book - Climate change transition risk: Credit quality of exposures
by sector, emissions and residual maturity
Delegated Regulation (EU) 2020/1818, Article 5(1),
6 and 8(1)
Material
60
ESRS E1-6 Gross GHG emissions intensity paragraphs 53
to 55
Indicators number 3 Table #1 of Annex 1
Article 449a Regulation (EU) No 575/2013; Commission
Implementing Regulation (EU) 2022/2453 Template 3: Banking
book - Climate change transition risk: alignment metrics
Delegated Regulation (EU) 2020/1818, Article 8(1)
Material
60
61(1)
ESRS E1-7 GHG removals and carbon credits paragraph 56
Regulation (EU) 2021/1119, Article 2(1)
Not Material
62
ESRS E1-9 Exposure of the benchmark portfolio to climate-
related physical risks paragraph 66
Delegated Regulation (EU) 2020/1818, Annex II
Delegated Regulation (EU) 2020/1816, Annex II
Not Material
62
ESRS E1-9 Disaggregation of monetary amounts by acute
and chronic physical risk paragraph 66 (a) ESRS E1-9
Location of significant assets at material physical risk
paragraph 66 (c)
Article 449a Regulation (EU) No 575/2013; Commission
Implementing Regulation (EU) 2022/2453 paragraphs 46 and
47; Template 5: Banking book - Climate change physical risk:
Exposures subject to physical risk
Not Material
62
ESRS E1-9 Breakdown of the carrying value of its real
estate assets by energy-efficiency classes paragraph 67 (c)
Article 449a Regulation (EU) No 575/2013; Commission
Implementing Regulation (EU) 2022/2453 paragraph 34;
Template 2: Banking book -Climate change transition risk: Loans
collateralised by immovable property - Energy efficiency of the
collateral
Not Material
62
ESRS E1-9 Degree of exposure of the portfolio to climate-
related opportunities paragraph 69
Delegated Regulation (EU) 2020/1818, Annex II
Not Material
62
ESRS E2-4 Amount of each pollutant listed in Annex II of the
E-PRTR Regulation (European Pollutant Release and Transfer
Register) emitted to air, water and soil, paragraph 28
Indicator number 8 Table #1 of Annex 1 Indicator
number 2 Table #2 of Annex 1 Indicator number 1 Table
#2 of Annex 1 Indicator number 3 Table #2 of Annex 1
Not Material
65
ESRS E3-1 Water and marine resources paragraph 9
Indicator number 7 Table #2 of Annex 1
Not Material
N/A
ESRS E3-1 Dedicated policy paragraph 13
Indicator number 8 Table 2 of Annex 1
Not Material
N/A
ESRS E3-1 Sustainable oceans and seas paragraph 14
Indicator number 12 Table #2 of Annex 1
Not Material
N/A
ESRS E3-4 Total water recycled and reused paragraph 28 (c)
Indicator number 62 Table #2 of Annex 1
Not Material
N/A
ESRS E3-4 Total water consumption in m^3 per net revenue
on own operations paragraph 29
Indicator number 61 Table #2 of Annex 1
Not Material
N/A
ESRS 2- SBM-3 - E4 paragraph 16 (a) i
Indicator number 7 Table #1 of Annex 1
Not Material
48
ESRS 2- SBM-3 - E4 paragraph 16 (b)
Indicator number 10 Table #2 of Annex 1
Not Material
48
ESRS 2- SBM-3 - E4 paragraph 16 (c)
Indicator number 14 Table #2 of Annex 1
Not Material
48
ESRS E4-2 Sustainable land / agriculture practices or
policies paragraph 24 (b)
Indicator number 11 Table #2 of Annex 1
Not Material
N/A
ESRS E4-2 Sustainable oceans / seas practices or policies
paragraph 24 (c)
Indicator number 12 Table #2 of Annex 1
Not Material
N/A
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ESRS E4-2 Policies to address deforestation paragraph
24 (d) Indicator number 15 Table #2 of Annex 1 Not Material N/A
ESRS E5-5 Non-recycled waste paragraph 37 (d)
Indicator number 13 Table #2 of Annex 1
Material
68
ESRS E5-5 Hazardous waste and radioactive waste
paragraph 39 Indicator number 9 Table #1 of Annex 1 Material 68
ESRS 2- SBM3 - S1 Risk of incidents of forced labour
paragraph 14 (f) Indicator number 13 Table #3 of Annex I Material 99
ESRS 2- SBM3 - S1 Risk of incidents of child labour
paragraph 14 (g) Indicator number 12 Table #3 of Annex I Material 98
ESRS S1-1 Human rights policy commitments paragraph 20
Indicator number 9 Table #3 and Indicator number 11
Table #1 of Annex I Material 80
ESRS S1-1 Due diligence policies on issues addressed
by the fundamental International Labor Organisation
Conventions 1 to 8, paragraph 21 Delegated Regulation (EU) 2020/1816, Annex II Material 87
ESRS S1-1 processes and measures for preventing
trafficking in human beings’ paragraph 22 Indicator number 11 Table #3 of Annex I Material 87
ESRS S1-1 workplace accident prevention policy or
management system paragraph 23 Indicator number 1 Table #3 of Annex I Material 87
ESRS S1-3 grievance/complaints handling mechanisms
paragraph 32 (c) Indicator number 5 Table #3 of Annex I Material 82
ESRS S1-14 Number of fatalities and number and rate of
work-related accidents paragraph 88 (b) and (c) Indicator number 2 Table #3 of Annex I Delegated Regulation (EU) 2020/1816, Annex II Material 89
ESRS S1-14 Number of days lost to injuries, accidents,
fatalities or illness paragraph 88 (e) Indicator number 3 Table #3 of Annex I Material 89
ESRS S1-16 Unadjusted gender pay gap paragraph 97 (a)
Indicator number 12 Table #1 of Annex I
Delegated Regulation (EU) 2020/1816, Annex II
Material
94
ESRS S1-16 Excessive CEO pay ratio paragraph 97 (b) Indicator number 8 Table #3 of Annex I Material 94
ESRS S1-17 Incidents of discrimination paragraph 103 (a)
Indicator number 7 Table #3 of Annex I
Material
86
ESRS S1-17 Nonrespect of UNGPs on Business and Human
Rights and OECD Guidelines paragraph 104 (a)
Indicator number 10 Table #1 and Indicator n 14 Table
#3 of Annex I
Delegated Regulation (EU) 2020/1816, Annex II
Delegated Regulation (EU) 2020/1818 Art 12 (1) Material 86
ESRS 2- SBM3 - S2 Significant risk of child labour or forced
labour in the value chain paragraph 11 (b) Indicators number 12 and n 13 Table #3 of Annex I Material 50
ESRS S2-1 Human rights policy commitments paragraph 17
Indicator number 9 Table #3 and Indicator n 11 Table #1
of Annex 1 Material 99
ESRS S2-1 Policies related to value chain workers paragraph
18 Indicator number 11 and n 4 Table #3 of Annex 1 Material 99
ESRS S2-1 Nonrespect of UNGPs on Business and Human
Rights principles and OECD guidelines paragraph 19 Indicator number 10 Table #1 of Annex 1
Delegated Regulation (EU) 2020/1816, Annex II
Delegated Regulation (EU) 2020/1818, Art 12 (1) Material 99
ESRS S2-1 Due diligence policies on issues addressed
by the fundamental International Labor Organisation
Conventions 1 to 8, paragraph 19 Delegated Regulation (EU) 2020/1816, Annex II Material 55
ESRS S2-4 Human rights issues and incidents connected to
its upstream and downstream value chain paragraph 36 Indicator number 14 Table #3 of Annex 1 Material 101
ESRS S3-1 Human rights policy commitments paragraph 16
Indicator number 9 Table #3 of Annex 1 and Indicator
number 11 Table #1 of Annex 1 Not Material N/A
ESRS S3-1 non-respect of UNGPs on Business and Human
Rights, ILO principles or OECD guidelines paragraph 17 Indicator number 10 Table #1 Annex 1
Delegated Regulation (EU) 2020/1816, Annex II
Delegated Regulation (EU) 2020/1818, Art 12 (1) Not Material N/A
ESRS S3-4 Human rights issues and incidents paragraph 36 Indicator number 14 Table #3 of Annex 1 Not Material N/A
ESRS S4-1 Policies related to consumers and end-users’
paragraph 16
Indicator number 9 Table #3 and Indicator number 11
Table #1 of Annex 1 Not Material N/A
ESRS S4-1 Non-respect of UNGPs on Business and Human
Rights and OECD guidelines paragraph 17 Indicator number 10 Table #1 of Annex 1
Delegated Regulation (EU) 2020/1816, Annex II
Delegated Regulation (EU) 2020/1818, Art 12 (1) Not Material N/A
ESRS S4-4 Human rights issues and incidents paragraph 35
Indicator number 14 Table #3 of Annex 1
Not Material
N/A
ESRS G1-1 United Nations Convention against Corruption
paragraph 10 (b) Indicator number 15 Table #3 of Annex 1 Not Material 103
ESRS G1-1 Protection of whistle-blowers paragraph 10 (d)
Indicator number 6 Table #3 of Annex 1
Material
105
ESRS G1-4 Fines for violation of anti-corruption and anti-
bribery laws paragraph 24 (a) Indicator number 17 Table #3 of Annex 1 Delegated Regulation (EU) 2020/1816, Annex II) Material 108
ESRS G1-4 Standards of anti-corruption and anti- bribery
paragraph 24 (b) Indicator number 16 Table #3 of Annex 1 Material 108
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Core elements of due diligence
Core elements of due diligence Paragraphs or pages in the Sustainability Statement Does the disclosure relate to Society and/or the Environment?
a) Embedding due diligence in governance, strategy and
business model
ESRS 2 GOV-2 - see page 37
Social and Environment
ESRS 2 GOV-3, see page 39 Social and Environment
ESRS 2 SBM-3 - see page 43, ESRS 2 SBM-3 E1 - see page 46, ESRS 2 SBM-3 E2 - see page 47, ESRS 2 SBM-3-E5- see page 48 Environment
ESRS 2 SBM-3, see page 43, ESRS 2 SBM-3-S1, see page 49, ESRS 2 SBM-3-S2, see page 50
Social
ESRS 2 SBM-3, see page 43, ESRS 2 SBM-3-G1, see page 51 Social and Environment
b) Engaging with affected stakeholders in all key steps of the
due diligence
ESRS 2 GOV-2, see page 37, ESRS 2 SBM-2, see page 41, ESRS 2 IRO-1, see page 45 Social and Environment
ESRS 2 MDR- P:
E1-2, see page 58, E2-1, see page 63, E5-1, see page 66 Environment
ESRS 2 MDR-P:
S1-1, see page 79, S2-1, see page 99 Social
Topical ESRS:
G1-1, see page 104 Social and Environment
Topical ESRS:
S1-2, see page 81, S2-2, see page 100 Social
c) Identifying and assessing adverse impacts
ESRS 2 IRO-1, see page 45 Social and Environment
ESRS 2 SBM-3, see page 43
ESRS 2 SBM-3-E1 - see page 43, ESRS 2 SBM-3-E2 - see page 46, ESRS 2 SBM-3-E5 see page 48 Environment
ESRS 2 SBM-3, see page 43
ESRS 2 SBM-3-S1, see page 49, ESRS 2 SBM-3-S2, see page 50 Social
ESRS 2 SBM-3, see page 43,
ESRS 2 SBM-3-G1, see page 51 Social and Environment
d) Taking actions to address those adverse impacts
ESRS 2 MDR-A:
E1-3, see page 59, E2-2, see page 64, E5-2 Environment
ESRS 2 MDR-A:
S1-4, see page 83, S2-4, see page 101 Social
Topical ESRS:
E1-1, see page 58 Environment
Topical ESRS:
G1-1, see page 103, G1-2, see page 106, G1-3, see page 107 Social and Environment
e) Tracking the effectiveness of these efforts and
communicating
ESRS 2 MDR-M:
E1-5, see page 60, E1-6, see page 60, E2-5, see page 65, E5-4, see page 67, E5-5, see page 67 Environment
ESRS 2 MDR-M:
S1-8, see page 85, S1-9, see page 94, S1-10, see page 85, S1-14, see page 89, S1-16, see page 94, S1-17, see page 86 Social
ESRS 2 MDR-M:
G1-4, see page 108, G1-5, G1-6, see page 108
Social and Environment
ESRS 2 MDR-T:
E1-4, see page 59, E2-3, see page 63, E5-3, see page 66 Environment
ESRS 2 MDR-T:
S1-5, see page 94, S2-5, see page 101 Social
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SUSTAINABILITY STATEMENTS ESRS ENVIRONMENT
Environment
DOF is a global player in the maritime industry. Working within the marine industry segment of offshore contracting,
DOF seeks to proactively manage the environment in which our value chain relies. Fundamental to our value chain
is the global fleet of vessels and subsea assets we own and operate. These assets are both our value proposition
as an organization and the source of our most notable environmental interactions and resource use.
2025 has presented a particularly challenging market environment for DOF in addressing material issues related
the environmental management and decarbonisation. The regulatory landscape across the International Maritime
Organisation, Europe and other jurisdictions has become highly polarised and volatile. Environmental regulations
in marine contracting and the wider marine industry are now increasingly fragmented, politicised and subject to
frequent changes and regional inconsistencies.
For a Global shipowner like DOF, who operates an international fleet the lack of regional harmonisation creates
significant uncertainty and complexity. The constant shifting and conflicting requirements make it difficult to plan
and implement long-term strategic initiatives related to environmental management.
Despite these external challenges, DOF remains committed to reducing emissions and minimising environmental
impacts wherever it is technically and commercially feasible. Addressing these challenges and opportunities, we
are committed to implementing a structured approach to environmental management. This includes:
• Understanding and managing environmental impacts: continuously assessing our environmental impacts,
risks and opportunities across our operations and value chain,
• Integrated management of IROs: Embedding an appreciation of Environmental Impacts, Risks and
Opportunities into our decision-making processes, ensuring that our strategy aligns with both regulatory
developments and industry best practices,
• Strategic focus to enhance energy efficiency, adopt cleaner technologies, and transition toward more
sustainable operational practices.
Identifying IROS 2025
In 2025, DOF strengthened its double-materiality assessment by expanding stakeholder input and validating prior
assumptions, resulting in a clearer understanding of material impacts, risks, and opportunities across environmental
topics. Climate Change, Pollution, and Circular Economy/Resource Use remain the Group’s top environmental
IROs, all of which are now fully integrated into the Corporate Risk Register and managed as core business risks.
IROS
ENVIRONMENTAL
MATERIAL IMPACTS,
RISKS AND OPPORTUNITIES
IRO
TYPE
VALUE
CHAIN
AREA
STAKE
HOLDER
PRIORITY TIME HORIZON
E1 Climate Change
Emissions from fossil fuels
Vessel fleet relies on fossil fuels, thus GHG emissions are linked to the level of
operational activity
AI
Direct
Perpetuation of fossil fuel use
DOF’s participation in conventional offshore
energy markets may contribute to the continued
reliance on the use of fossil fuels which negatively
impacts the environment
PI
Downstream
Indirect emission profile
DOF’s extended value chain is a significant
component of the overall emission profile
AI
Upstream
Physical Climate Change
Changes to weather patterns as a result of climate
change may cause increased fuel consumption
!
Direct
Client Decarbonisation Focus
Clients are more focused on decarbonisation, but current contracts and client appetite
do not enable recovery of capital costs for decarbonisation investments
!
Downstream
E2 Pollution
Financial exposure in offshore spills
A significant offshore spill event may expose
DOF to financial liabilities
PI
Direct
E5 Circular Economy
and Resource Use
Generation of Waste
DOF generates significant quantities of waste as
part of day-to-day activities and as part of vessel
overhauls and maintenance
AI
Across whole
value chain
Key
IRO type Impact materiality Financial materiality
PI
Potential impact
AI
Actual impact
!
Potential risk
!
Actual risk
O
Opportunity
Stakeholder priority increasing unchanged decreasing
Time horizon
Short-term Short-to medium-term Medium-to long-term Long-term
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SUSTAINABILITY STATEMENTS E1 CLIMATE CHANGE
E1 Climate Change
DOF assesses and controls the environmental impact of its operations, benchmarking fuel efficiency performance
and monitoring GHG emissions across its value chain. We apply pollution prevention measures, focusing emissions,
such as air pollution known to be detrimental to the environment.
Our strategic approach takes three avenues to address the main challenges and focuses on:
• Reducing our own emissions,
• Support upstream and downstream value chain decarbonisation targets,
• Develop our offshore renewable energy services.
E1-1 Transition plan for climate change mitigation
DOF currently has no formal decarbonisation roadmap or transition plan as defined under ESRS E1. Our approach to
managing greenhouse-gas emissions is focused on ensuring compliance with applicable decarbonisation regulations
and meeting client and stakeholder expectations. While we continue to monitor regulatory developments and
strengthen the accuracy of our emissions data, particularly following the significant fleet expansion in late 2024,
we have not set absolute emission-reduction targets or developed a transition plan that includes decarbonisation
levers or resource requirements.
E1-2 Policies related to climate change mitigation and adaptation
Environment Impact Policy: Covers all emissions, including air emissions.
Purpose
The Environmental Impact Policy supports the management of climate-related
impacts by committing DOF to minimise environmental impact, promote efficient
use of natural resources, prevent pollution and drive continuous improvement
in environmental performance. Environmental considerations are required to be
integrated into operations, projects and newbuilds, which supports reductions in
fuel use and associated greenhouse gas emissions. The policy’s requirement to set,
review and monitor environmental objectives and targets provides a framework for
governing and improving climate-related performance.
Covers
All onshore and offshore worksites and all individuals present on our sites
Supports IROs
All Environmental IRO’s
Accountable
CEO
Available
Integrated Management System, SEEMP, Website, All DOF Worksites
Works with Policy
Documents
CoBC, Garbage Management Plan
Certification
ISO 14001
In line with ISO 14001 compliance, we understand climate change as a significant environmental aspect
and a risk that must be managed through the business management system. Climate change adaptation
and mitigation considerations are integrated into operational planning and risk assessment, ensuring fuel
consumption and emissions are continuously monitored and optimised, even under challenging operational
conditions such as harsh weather and longer voyages. Our Environmental Impact policy also commits to
actively monitoring and communicating performance to the industry and community. To do this, we assess
and control the environmental impact of our operations, benchmark fuel efficiency performance and
monitor GHG emissions across the value chain. Pollution prevention measures focus on emissions, such
as air pollution known to be detrimental to the environment. Our performance in this area is transparent
and openly communicated within annual reporting mechanisms.
Compliance with GHG-related regulations and industry best practices extends to Scope 3 emissions.
Environmental performance is continuously monitored and reviewed, ensuring alignment with evolving
climate regulations, industry benchmarks and stakeholder requirements. Consideration for environmental
improvements is prioritised in new-build projects, supporting the adoption of lower-emission technologies
and alternative fuels. While not explicitly stated in the policy, active engagement with industry stakeholders
and suppliers, explores clean energy alternatives and enhance transparency in environmental reporting.
IROS
MATERIAL IMPACTS,
RISKS AND OPPORTUNITIES
IRO
TYPE
VALUE
CHAIN
AREA
STAKE
HOLDER
PRIORITY TIME HORIZON
E1 Climate Change
Emissions from fossil fuels
Vessel fleet relies on fossil fuels, thus GHG emissions are linked to the level of
operational activity
AI
Direct
Perpetuation of fossil fuel use
DOF’s participation in conventional offshore
energy markets may contribute to the continued
reliance on the use of fossil fuels which negatively
impacts the environment
PI
Downstream
Indirect emission profile
DOF’s extended value chain is a significant
component of the overall emission profile
AI
Upstream
Physical Climate Change
Changes to weather patterns as a result of climate
change may cause increased fuel consumption
!
Direct
Client Decarbonisation Focus
Clients are more focused on decarbonisation, but current contracts and client appetite
do not enable recovery of capital costs for decarbonisation investments
!
Downstream
Key
IRO type Impact materiality Financial materiality
PI
Potential impact
AI
Actual impact
!
Potential risk
!
Actual risk
O
Opportunity
Stakeholder priority increasing unchanged decreasing
Time horizon
Short-term Short-to medium-term Medium-to long-term Long-term
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SUSTAINABILITY STATEMENTS E1 CLIMATE CHANGE
E1-4 Targets related to climate change mitigation and adaptation
DOF does not currently have climate change mitigation and adaptation targets that can be presented in a transition
plan using absolute emission reduction in line with the Paris Agreement.
E1-3 Actions and resources in relation to climate change
DOF’s five main decarbonisation focus areas (“measures”) are not “one-size-fits-all”. Each measure needs to be
separately evaluated per vessel, as the effectiveness of the measure depends on factors such as type of vessel,
type of operations, and operational area.
KEY ACTION
Optimizing operations with digital fleet and client
support
Focus on speed management and logistics, reducing non-ECO speed
transit. 41 vessels fully connected (automated readings and analysis)
at the end of 2025 and 29 partially connected (import and analysis of
manually entered data). OPEX for 2025: USD 75377. The goal for
2026 is to have all owned vessels fully connected by end of the year.
SCOPE OF ACTION
Fleet-wide operational optimisation
CORRESPONDING POLICY
Environmental Impact Policy:
• Ensure environmental management is given equal consideration
throughout all operational planning and undertaking.
• Assess and control the aspects and impacts of our operations upon
the environment;
• Monitor our environmental performance and address deficiencies
where identified;
• Consider environmental improvement areas as high priorities during
projects and new buildings.
PROGRESS
Ongoing - estimated 25% emission reduction potential compared to
operating without having or acting on these insights
TIME HORIZON FOR COMPLETION*
Medium Term
KEY ACTION
Biofouling management: antifouling products and
robotic cleaning
Invest in better antifouling products and robotic cleaning to reduce
drag and fuel use Short-term implementation for hull cleaning;
medium- to long-term for advanced technologies No specific OPEX/
CAPEX outside dry-docking programmes.
SCOPE OF ACTION
Fleet-wide hull maintenance and efficiency
CORRESPONDING POLICY
Environmental Impact Policy:
• Assess and control the aspects and impacts of our operations upon
the environment,
• Ensure environmental management is given equal consideration
throughout all operational planning and undertaking.
PROGRESS
Ongoing - estimated 25% emission reduction potential compared to
vessel baseline (pre-implementation state).
TIME HORIZON FOR COMPLETION*
Medium Term
KEY ACTION
Battery and hybrid system integration
Focus on dynamic positioning (DP) vessels .These systems are
expected to reduce fuel consumption and emissions by optimizing
engine loads and allowing less engines to be used during operations
Subsea and construction vessels, which spend substantial time in DP
mode, should be prioritised for battery system implementation 15
priority vessels identified, with no committed projects yet Long-term
investment; medium-term implementation after approval No current
OPEX/CAPEX allocated.
SCOPE OF ACTION
Selected vessels within the fleet
CORRESPONDING POLICY
Environmental Impact Policy:
• Assess and control the aspects and impacts of our operations upon
the environment,
• Ensure environmental management is given equal consideration
throughout all operational planning and undertaking.
PROGRESS
Identified 15 priority vessels - estimated 11-13% fuel/emission
reduction potential compared to not having such system installed.
TIME HORIZON FOR COMPLETION*
Long-term
KEY ACTION
Enhanced ship energy efficiency management
programme (SEEMP)
A long list of operational and technical improvement measures have
been identified by the operational teams and the vessels, of which
most are low-cost items. These should be followed up as part of
the vessels mandatory SEEMP, with enhanced focus. An important
component of the decarbonisation strategy will be the introduction
of dedicated. OPEX funds allocated to cover the cost of such energy
efficiency measures. This ensures that vessels energy efficiency
measures are adequately funded and tracked without compromising
other critical budget areas. This has a medium-term horizon as it
will be part of the vessels’ annual budgets and OPEX, however it is
currently not a significant part of the vessels’ total OPEX. Pending
finalisation of emission reduction targets and climate transition plan.
SCOPE OF ACTION
Fleet-wide energy efficiency improvements
CORRESPONDING POLICY
Environmental Impact Policy:
DOF applies five recognised decarbonisation levers (“measures”) to
guide vessel-level evaluations of emissions-related improvements.
These measures are not “one size fits all”; their applicability
and impact vary significantly by vessel type, operational profile
and geographical area. As a result, each lever is assessed
on a vessel-specific basis to ensure that any efficiency or
emissions-related action aligns with regulatory requirements, client
expectations and operational realities.
• Ensure environmental management is given equal consideration
throughout all operational planning and undertaking,
• Assess and control the aspects and impacts of our operations upon
the environment,
• Monitor our environmental performance and address deficiencies
where identified,
• Consider environmental improvement areas as high priorities during
projects and new buildings.
PROGRESS
Ongoing - estimated 15% emission reduction potential compared to
vessel baseline (pre-implementation state)
TIME HORIZON FOR COMPLETION*
Medium Term
KEY ACTION
Biofuel adoption
Medium- to long-term solution Some vessels capable of running on
HVO. Evaluated case-by-case No current OPEX/CAPEX allocated.
SCOPE OF ACTION
Selected vessels within fleet To be determined based on commercial
and technical feasibility
CORRESPONDING POLICY
Environmental Impact Policy:
• Assess and control the aspects and impacts of our operations upon the
environment,
• Ensure environmental management is given equal consideration
throughout all operational planning and undertaking.
PROGRESS
Under evaluation - estimated 5-10% reduction (up to 90% with full
HVO use)
TIME HORIZON FOR COMPLETION*
Long-term
*Short-term (1 year), medium-term (2-5 years), and long-term (5+ years) horizons
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SUSTAINABILITY STATEMENTS E1 CLIMATE CHANGE
E1-5 Energy consumption and mix
Energy consumption and mix 2024 2025
1 Fuel consumption from coal and coal products (MWh) 0 0
2 Fuel consumption from crude oil and petroleum products (MWh) 1 959 996 2742 880
3 Fuel consumption from natural gas (MWh) 0 0
4 Fuel consumption from other fossil sources (MWh) 0 0
5 Consumption of purchased or acquired electricity, heat, steam and cooling from fossil sources (MWh) 6 690 6 423
6 Total fossil energy consumption (MWh) (calculated as the sum of lines 1 to 5) 1 966 686 2749 303
Share of fossil sources in total energy consumption (%) 0 0
7 Consumption from nuclear sources (MWh) 0 0
Share of consumption from nuclear sources in total energy consumption (MWh) 0 0
8 Fuel consumption for renewable sources, including biomass (also comprising industrial and municipal waste of
biologic origin, biogas, renewable hydrogen etc) (MWh) 0 0
9 Consumption of purchased or acquired electricity, heat steam and cooling from renewable sources (MWh) 0 0
10 The consumption of self-generated non-fuel renewable energy (MWh) 0 0
11. Total renewable energy consumption (MWh) (calculated as the sum of lines 8 to 10) 0 0
Share of renewable sources in total energy consumption (%) 0 0
Total energy consumption (MWh) (calculated as the sum of lines 6 and 11) 1 966 686 2749 303
The primary source of energy consumption is marine gas oil (MGO) on board our vessels and is allocated in
row 2, “Fuel consumption from crude oil and petroleum products”. The conversion factor used is DEFRA for the
respective years 2024, 2025. The remaining is consumption of purchased or acquired electricity, heat, steam
and cooling. As DOF has not purchased any Renewable Energy Certificates (RECs), this consumption is allocated
within category 5; “Consumption of purchased or acquired electricity, heat, steam and cooling from fossil sources”.
DOF has seen an increase in total energy consumption (MWh) from 2024 to 2025 as a result of an increase in
fleet size with the integration of DOF Denmark vessel fleet from the Q4 2024.
The activities performed by DOF have been evaluated to be related to NACE sections B (Mining and Quarrying),
F (construction) and section H (transportation and storage). These sections are high climate impact sectors Thus,
the energy intensity is based on the Group’s total energy consumption and total operating revenue.
DOF measures GHG intensity relative to operating revenue. Under ESRS terminology, this corresponds to
‘net revenue’.
Energy intensity based on net revenue
Energy intensity per net revenue
2024
2025
% 2025 / 2024
Total energy consumption from activities in high climate impact
sectors per net revenue from activities in high climate impact
sectors (MWh/Monetary unit) 1 420 MWh/million USD 1469 MWh/million USD 3 %
E1-6 Gross scopes 1, 2, 3 and total GHG emissions
Scope 1 emissions originate from combustion of Marine Gas Oil (MGO) on board vessels where DOF has operational
and/or financial control.
Scope 2 emissions originate from purchased electricity, heating and cooling for offices / workshops, and vessel
shore power.
Scope 3 category information is further detailed in the table “Scope 3 calculation methodology and boundaries”.
The following Scope 3 categories have been determined not material:
Scope 3 category Evaluation of materiality
7 Employee commuting The majority of DOF’s workforce are offshore and the travel emissions are included in category 6
8 Upstream leased assets Third-party vessels leased by DOF are reported in Scope 1 due to DOF’s operational control of the vessel
9 Downstream transportation Any transportation performed by DOF’s vessels is included in Scope 1 emissions
10 Processing of sold products DOF does not sell products
11 Use of sold products DOF does not sell products
12 End-of-life treatment of sold products DOF does not sell products
13 Downstream leased assets Due to the ownership of vessels that DOF lease out, they are reported in Scope 1
14 Franchises DOF does not have franchises
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SUSTAINABILITY STATEMENTS E1 CLIMATE CHANGE
Retrospective Milestones and target years
Base Year
(N/A)
Comparative
2024 2025
% 2025/
2024 2025 2030 (2050)
Annual %
target /
Base year
Scope 1 GHG emissions
Gross Scope 1 GHG emission (tCO2eq) N/A 537 909 752 767 40 % N/A N/A N/A N/A
% of Scope 1 GHG emissions from regulated emissions
trading schemes N/A 0 0 0 N/A N/A N/A N/A
Scope 2 GHG emissions
Gross location-based Scope 2 GHG emission (tCO2eq) N/A 542 566 4 % N/A N/A N/A N/A
Gross market-based Scope 2 GHG emissions (tCO2eq) N/A 3 374 2 865 -15 % N/A N/A N/A N/A
Significant Scope 3 GHG emissions
Total Gross indirect (Scope 3) GHG emissions (tCO2eq) N/A 307 940 377 755 23 % N/A N/A N/A N/A
1 Purchased goods and services N/A 78 422 81 079 3 % N/A N/A N/A N/A
2 Capital goods N/A 20 630 30 461 48 % N/A N/A N/A N/A
3 Fuel and energy-related Activities (not included in
Scope 1 or 2) N/A 123 454 172 716 40 % N/A N/A N/A N/A
4 Upstream transportation and distribution N/A 7 172 5 917 -4 % N/A N/A N/A N/A
5 Waste generated in operations N/A 250 168 -33 % N/A N/A N/A N/A
6 Business travel N/A 19 574 22 889 17 % N/A N/A N/A N/A
15 Investments N/A 58 437 64 526 10 % N/A N/A N/A N/A
Total GHG emissions
Total GHG emissions (location-based) (tCO2eq) N/A 846 391 1 131 088 34 % N/A N/A N/A N/A
Total GHG emissions (market-based) (tCO2eq) N/A 849 223 1 133 387 34 % N/A N/A N/A N/A
GHG intensity based on net revenue
DOF measures GHG intensity relative to operating revenue. Under ESRS terminology, this corresponds to ‘net
revenue’. Operating Revenue can be found in the Management Reporting section of the account.
GHG intensity per net revenue 2024 2025 % 2025 /2024
Total GHG emissions (location-based) per net
revenue (tCO2eq/Monetary unit) 611 tCO2eq / million USD 605 tCO2eq / million USD -1 %
Total GHG emissions (market-based) per net
revenue (tCO2eq/Monetary unit) 613 tCO2eq / million USD
606 tCO2eq / million USD
-1 %
Calculation methodologies
Scope 1 emissions are calculated by multiplying fuel consumption from vessels with an internationally recognised
emission factor (ref emission factors table). The emissions have not been validated by an external body other than
the assurance provider.
Scope 2 emissions are calculated by multiplying consumption of purchased electricity, district heating/cooling, or
heat natural gas, by internationally recognised emission factors (ref emission factors table). The emissions have not
been validated by an external body other than the assurance provider.
Scope 3 emissions are calculated using different methodology based on availability of data, as shown in the
following table. The emissions have not been validated by an external body other than the assurance provider.
Item Methodology Reporting boundary
1 Purchased goods and services Spend-based
Purchased goods and services by companies in the
consolidated financial statements
2 Capital goods Spend-based
Capital goods purchased by companies in the
consolidated financial statements
3 Fuel and energy-related Activities (not
included in Scope 1 or 2)
Activity-based
Consumption x emission factor
Based on fuel consumption on own and managed vessels,
and 3
rd
party vessels where DOF is in operational control
Upstream electricity emissions
4 Upstream transportation and distribution
Partial activity-based (9 %) provided by
supplier, partial spend-based (91 %)
Transportation and distribution services purchased by
companies in the consolidated financial statements
5 Waste generated in operations
Activity-based
Amount x emission factor
Waste incinerated on own and managed vessels
Waste incinerated on 3
rd
party vessels where DOF has
operational control
6 Business travel
Activity-based, all emissions provided by
supplier Business travel of own workforce
15 Investments
Activity-based
Consumption x emission factor
Emissions from fuel consumption for vessels owned by
Joint Venture (direct fuel emissions and WTT emissions).
For 2025, this includes six vessels owned by DOFCON
Brasil AS (DOF Group ownership share 50%).
Some Scope 3 categories in our carbon accounting were calculated using spend-based methods, facilitated by Ignite
Procurement’s carbon accounting module, which utilises Climatiq database (global carbon emission datasets) for
emission factor data. All transactional data for 2025 was matched to EXIOBASE 3 emission factors and adjusted
for inflation and currency fluctuations by Climatiq through this module and categorised accordingly. This methodology
was applied to Categories 1 (purchased goods and services), 2 (capital goods), and, in part, Category 4 (upstream
transportation and distribution).
To enhance accuracy, taxes, trade margins, and freight costs were excluded from expenditure calculations to
align with EXIOBASE’s basic price model. Furthermore, expenditures were adjusted for inflation and currency
fluctuations to ensure consistency with the emission factor year. Transactions were mapped to EXIOBASE 3
product categories using supplier industry, account information, and text descriptions, while supplier country and
currency were used for regional classification.
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Scope Item Source
2 Electricity Guyana
1) IEA (2025)
2) No residual mix EF available, location-based EF (1) applied in market-based calculation
3) IEA (2025), Energy Statistics Data Browser
2 District heating NO/Bergen Fjernkontrollen (2025)
2 District cooling NO/Bergen Based on Fjernkontrollen (2024) and Norsk Energi (2020)
2 Heat Natural gas DEFRA (2025)
3 Residual waste, incinerated
Calculated by CEMAsys based on Ecoinvent 312
3 Marine gas oil (MGO) (WTT) DEFRA (2025)
3 Marine gas oil (MGO) DEFRA (2025)
3 Electricity Canada (upstream) IEA (2025)
3 Electricity UK (upstream) IEA (2025)
3 Electricity Denmark (upstream) IEA (2025)
3 Electricity Norway (upstream) IEA (2025)
3
Electricity Singapore
(upstream) IEA (2025)
3 Electricity USA (upstream) IEA (2025)
3 Electricity Brazil (upstream) IEA (2025)
3 Electricity Australia (upstream) IEA (2025)
3
Electricity Philippines
(upstream) IEA (2025)
3 Electricity Indonesia (upstream) IEA (2025)
3 Electricity Argentina (upstream) IEA (2025)
3 Electricity Guyana (uptream) IEA (2025)
3 Electricity Angola (upstream) IEA (2025)
3 Electricity Mexico (upstream) IEA (2025)
E1-7 GHG removals and GHG mitigation projects financed through carbon credits
In 2025, DOF has not participated in GHG removals and GHG mitigation projects financed through carbon credits.
E1-8 Internal carbon pricing
DOF does not currently have an internal carbon pricing scheme.
E1-9 Anticipated financial effects from material physical and transition risks and potential
climate-related opportunities
DOF has opted to exercise the phase-in allowance to omit the financial effects from material physical and transition
risks and potential climate-related opportunities required in E1-9.
SUSTAINABILITY STATEMENTS E1 CLIMATE CHANGE
For further details on the methodology and emission factors applied, please refer to the documentation available
online: https://www.igniteno/carbon-accounting-methodology.
We see increasing availability of data directly from suppliers, and aim to move from spend-based to activity-based
primary data from suppliers as it becomes available. This will be a gradual process where an increasing percentage
of Scope 3 emissions are based on primary data and less on spend-based estimates.
Emission factors used
The below list references the sources of conversion factors to calculate emissions and/or energy in the CEMAsys
climate accounting tool:
Scope
Item
Source
1 Marine gas oil (MGO)
DEFRA (2025)
(includes gases CO
2
, CH
4
, N
2
O)
2 Electricity Norway
1) IEA (2025)
2) AIB (2025)
3) IEA (2025), Energy Statistics Data Browser
2 Electricity Singapore
1) IEA (2025)
2) No residual mix EF available, location-based EF (1) applied in market-based calculation
3) IEA (2025), Energy Statistics Data Browser
2 Electricity USA
1) IEA (2025)
2) Green-e (2024), unweighted average for all 27 eGrid subregions, calculated by CEMAsys
3) IEA (2025), Energy Statistics Data Browser
2 Electricity UK
1) IEA (2025)
2) AIB (2025)
3) IEA (2025), Energy Statistics Data Browser
2 Electricity Brazil
1) IEA (2025)
2) No residual mix EF available, location-based EF (1) applied in market-based calculation
3) IEA (2025), Energy Statistics Data Browser
2 Electricity Canada
1) IEA (2025)
2) No residual mix EF available, location-based EF (1) applied in market-based calculation
3) IEA (2025), Energy Statistics Data Browser
2 Electricity Mexico
1) IEA (2025)
2) No residual mix EF available, location-based EF (1) applied in market-based calculation
3) IEA (2025), Energy Statistics Data Browser
2 Electricity Australia
1) IEA (2025)
2) DCCEEW (2025), market-based
3) IEA (2025), Energy Statistics Data Browser
2 Electricity Philippines
1) IEA (2025)
2) No residual mix EF available, location-based EF (1) applied in market-based calculation
3) IEA (2025), Energy Statistics Data Browser
2 Electricity Argentina
1) IEA (2025)
2) No residual mix EF available, location-based EF (1) applied in market-based calculation
3) IEA (2025), Energy Statistics Data Browser
2 Electricity Indonesia
1) IEA (2025)
2) No residual mix EF available, location-based EF (1) applied in market-based calculation
3) IEA (2025), Energy Statistics Data Browser
2 Electricity Denmark IEA
1) IEA (2025)
2) AIB (2025)
3) IEA (2025), Energy Statistics Data Browser
2 Electricity Angola
1) IEA (2025)
2) No residual mix EF available, location-based EF (1) applied in market-based calculation
3) IEA (2025), Energy Statistics Data Browser
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E2 Pollution
Prevention and mitigation of pollution is a material concern for both DOF and the wider marine industry. Our industry
faces an array of pollution challenges including major spill events, prevention of marine plastic pollution, protection
of biodiversity, air pollution, ship recycling and underwater noise. The most pertinent and material pollution topic
for DOF is the liability towards costs associated with large-scale pollution spill events, including remediation and
contractual obligations towards third parties. DOF is exposed to this potential material risk through the combination
of both stringent contractual agreements towards clients and operations spanning multiple jurisdictions and
sometimes sensitive marine habitats. When evaluating peers within the industry and external stakeholders such
as clients, there is commonality in this being a material issue.
DOF’s strategic approach focuses on:
• Cooperation with strategic partners, development and application of industry,
best practice standards and pollution prevention methodologies,
• Open stakeholder communication,
• Proactive risk management,
• Crew training and preparedness,
• Reducing liability through contract management,
• Supply Chain Management.
E2-3 Targets
DOF seeks to minimise offshore spill pollution events to a level as low as reasonably practicable.
DOF considers any loss of secondary containment over fifty Liters to be a significant spill. We have an ambition
of reaching zero significant spills through implementing robust preventative and mitigation measures offshore.
DOF uses its integrated management system to record the nature of spill events, including the total volume of spill
as an absolute metric and emission loads. Information is gathered via the Integrated Management System and
incident reports to collate information on spill events, including volumes, locations and the level of containment
Pollution events are reported according to the Global Standard - Non-Conformity and Incident Management In
addition, all spill incidents are reported directly from the vessel through our event flash application to relevant
stakeholders in the business If the nature of a pollution event is significant, an incident investigation is conducted
and reported to the respective geographic region regulators.
As a relative metric, DOF records the number of significant spills to the environment per million manhours. This remains
an important performance indicator as it ensures we can decouple the number of significant spills from the level of
vessel activity. Whilst our ambition is to have no significant spills to the environment, our global improvement program
sets a target of less than four significant spills per million manhours. This metric has been tracked and agreed upon
by the Executive Management team over several years. This metric of recording spills to water is seen as voluntarily
within DOF, in addition to mandatory reporting and investigation obligations we have across the various jurisdictions
DOF works. Both the target of significant spills and monitoring of total spill volume encompasses DOF’s direct value
chain, including chartered vessels. Targets are not based on conclusive scientific evidence.
By tracking spill volume and frequency, trends can be identified, benchmarks set, the effectiveness of prevention
and corrective measures understood and demonstrate compliance with environmental regulations such as MARPOL.
This contributes to pollution prevention and control in the offshore environment and ensures we meet the intent
of its Environmental Impact Policy.
E2-1 Policies related to pollution prevention
Environment Impact Policy: Covers all pollutants and substances
Purpose
The policy directly addresses pollution-related impacts through
commitments to pollution prevention, assessment and control of
environmental aspects and impacts, and compliance with applicable
environmental laws and industry best practice. It treats all environmental
incidents as preventable and sets an ambition of zero spills to the external
environment, while also committing to reduce and restrict environmentally
harmful waste. Ongoing monitoring of environmental performance and
corrective action ensures pollution risks are systematically managed.
Covers
All onshore and offshore worksites and all individuals present on our sites
Accountable
CEO
Available
Integrated Management System, SEEMP, Website, All DOF Worksites
Works with Policy
Documents
CoBC, Planet Manual, Environmental Compliance Standard
Certification
ISO 14001
The Environmental Impact Policy governs pollution prevention, environmental impact minimisation and
covers the IRO of “major pollution events because of spills”. The Policy and adherence to ISO 14001
provides a structured approach to identify, address and monitor environmental risks such as offshore spill
pollution events.
IROS
MATERIAL IMPACTS,
RISKS AND OPPORTUNITIES
IRO
TYPE
VALUE
CHAIN
AREA
STAKE
HOLDER
PRIORITY
TIME
HORIZON
E2 Pollution
Financial exposure in offshore spills
A significant offshore spill event may expose
DOF to financial liabilities
PI
Direct
Key
IRO type Impact materiality Financial materiality
PI
Potential impact
AI
Actual impact
!
Potential risk
!
Actual risk
O
Opportunity
Stakeholder priority increasing unchanged decreasing
Time horizon
Short-term Short-to medium-term Medium-to long-term Long-term
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E2-2 Actions and resources in relation to pollution
KEY ACTION
Proactive Risk Management:
Prevention of pollution events is prioritised by implementing rigorous
risk management practices as outlined in the Integrated Management
System. This includes comprehensive planning and risk assessments
throughout project and marine operations. Additionally, we maintain a
robust emergency response framework, including vessel emergency
response procedures, SOPEP, Project Emergency Response Plans,
emergency preparedness drill and contract management standards, to
effectively manage pollution incidents.
SCOPE OF ACTION
Fleet and project-wide pollution risk management
CORRESPONDING POLICY
Environmental Impact Policy:
• Ensure environmental management is given equal consideration
throughout all operational planning and undertaking,
• Consider all environmental incidents to be preventable and make all
efforts to meet the target of zero spill to the external environment.
PROGRESS
Continuous, as part of Integrated Management System
TIME HORIZON FOR COMPLETION*
Not applicable, continuous program of improvement
KEY ACTION
Crew Training and Preparedness
Crew members undergo regular training in shipboard pollution
emergency plans (SOPEP/SMPEP), including periodic drills and
simulations. To enable a state of readiness, SOPEP/SMPEP are used
as required by the vessel Drill Matrix, ensuring that our crew is always
prepared and able respond to potential pollution incidents. All vessels
have SOPEP drills scheduled on a quarterly basis.
SCOPE OF ACTION
Fleet-wide crew training and emergency preparedness
CORRESPONDING POLICY
Environmental Impact Policy:
• Ensure environmental management is given equal consideration
throughout all operational planning and undertaking,
• Consider all environmental incidents to be preventable and make all
efforts to meet the target of zero spill to the external environment,
• Apply applicable laws and regulations and where deficient apply
company and industry best practice.
PROGRESS
Continuously monitored as part of vessel assurance processes
TIME HORIZON FOR COMPLETION*
Not applicable, continuous program of improvement
KEY ACTION
Reducing Liability
DOF’s insurance policy is designed to limit liability for pollution
events by focusing on specific areas of responsibility. Pollution
is treated as a break clause within contracts; whereby positive
confirmation of compliance is required or authorised sign-off of
deviation away from standard terms.
The company only accepts liability for pollution caused by its own
equipment and vessels, explicitly excluding liability for pollution from
underground reservoirs, permanent installations, or uninsurable risks.
Additionally, DOF’s contracting standard also dictates we cannot
accept liability for unlimited pollution indemnity.
To manage this risk within the extended value chain, pollution
liabilities are passed down to vendors on a knock-for-knock basis,
ensuring that DOF is not left with uninsured risks if a vendor fails to
insure for pollution. Additionally, any indemnity for pollution must be
carefully reviewed against the relevant insurance policy to ensure
it provides adequate coverage. This thorough approach helps DOF
manage potential pollution risks and claims effectively, safeguarding
the company from significant financial exposure.
SCOPE OF ACTION
Across Group, unless otherwise authorised according to authority
matrix
CORRESPONDING POLICY
Environmental Impact Policy:
• Apply applicable laws and regulations and where deficient apply
company and industry best practice,
• Assess and control the aspects and impacts of our operations upon
the environment.
PROGRESS
Continuous, as part of Integrated Management System
TIME HORIZON FOR COMPLETION*
Not applicable, continuous program of improvement
KEY ACTION
Supply Chain Management
Mechanisms in pre-qualification and tendering processes ensure
upstream areas of our value chain following the same preventative
and mitigation measures for pollution control. This includes
desktop reviews of pre-qualification documentation, audits,
onsite inspections, and monitoring based on the criticality of
subcontracted work scopes. During execution phases of work,
monitoring and follow-up of subcontractors is based upon the
scope of work being performed and criticality.
SCOPE OF ACTION
Upstream value chain compliance with pollution controls
CORRESPONDING POLICY
Environmental Impact Policy:
• Apply applicable laws and regulations and where deficient apply
company and industry best practice,
• Ensure environmental management is given equal consideration
throughout all operational planning and undertaking,
• Assess and control the aspects and impacts of our operations upon
the environment.
PROGRESS
Continuous, as part of Integrated Management System See ERSR S2
TIME HORIZON FOR COMPLETION*
Not applicable, continuous program of improvement
*Short-term (1 year), medium-term (2-5 years), and long-term (5+ years) horizons
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E2-4 Pollution of air, water and soil
DOF evaluated its direct value chain to determine its environmental impact. It concluded it does not emit pollutants
exceeding the threshold values specified in Annex II of Regulation EC No 166/2006 as part of planned or foreseeable
discharges. This assessment accounts for emissions and pollutants emanating from all facilities under our direct
operational control.
While DOF does emit GHG pollutants from the combustion of marine diesel oil, these emissions are reported in
detail within the ESRS E1 sustainability statement.
To ensure compliance with MARPOL Annexes II and III, DOF reviewed relevant compliance documents and evaluated
all spill events that resulted in a breach of secondary containment. The company has determined that no Annex II
pollutants were emitted in these incidents. The following tables outline our performance in relation to significant
spills, significant spills per million manhours and total volume of spills.
Number of significant spills (over 50 litres)
2023 2024 2025
0 spills 0 spill 3
Number of significant spills (over 50 litres) per million man-hours
2023 2024 2025
0 0
021
Spill performance volume per year (loss of secondary containment in litres)
2023 2024 2025
105 114 516
Analysis of yearly trend
There has been an upward trend in the volume of spill pollution incidents. Skandi Acergy and Skandi Nomad had
unplanned releases of hydraulic oil because of equipment failure events, at a combined quantity of 180 Liters. Both
incidents were investigated with accompanying corrective and preventative measures. Analysis of both hydraulic
spill incidents indicate ‘defective equipment, machinery or tools’ as being the direct cause of the incident occurring.
The third significant spill occurred on the Skandi Niteroi, resulting in 155 Liters of diesel being unintentionally
discharged to the environment. Immediate causes of this incident were related to a failed bilge pipe and improper
operation of bilge valves. Given the seriousness of the event, multiple corrective and preventative actions have
been assigned and agreed upon by the client. Neither incident resulted in fines or legal action, and corrective
measures were agreed upon by the title holder and client.
Although microplastics generated by our value chain are not specifically measured, operations were assessed and
concluded there are no significant sources of this pollutant.
All discharges to the sea, whether planned or unplanned, are strictly regulated and monitored. The company uses
a combination of vessel or asset flow meters, sensors, alarm systems, and CCTV systems to identify and estimate
discharges. Additionally, compliance documents such as the Inventory of Hazardous Materials and Documents
of Compliance for the Carriage of Goods provide DOF with detailed information about the substances carried on
board its vessels, their storage requirements, and maximum quantities. Compliance against requirements within
these documents is verified periodically by Class Society and through internal project and ISM audits.
E2-5 Substances of concern and substances of very high concern
The value chain was evaluated and there were no substances of concern or substances of very high concern that
are generated, procured, or used across our facilities.
E2-6 Anticipated financial effects from material pollution related risks and opportunities
DOF exercises the right to utilise the phase-in option.
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E5-1 Policies related to circular economy
Environment Impact Policy:
Purpose
The policy supports resource efficiency and circular economy principles by
committing DOF to minimise environmental impact through efficient use of
natural resources, waste reduction and recycling. It includes commitments
to reduce environmentally harmful waste and to consider environmental
improvements in projects and newbuilds, supporting more resource-
efficient asset design and operations. The setting, review and monitoring of
environmental objectives and targets provides a structure for continuous
improvement in resource use and waste performance.
Covers
All onshore and offshore worksites and downstream suppliers
Accountable
CEO
Available
IMS, Garbage Management Plan, Website, All DOF Worksites
Works with Policy Documents
CoBC, Planet Manual
Certification
ISO 14001
E5 Circular Economy
DOF’s most material concern in relation to Circular Economy is the actual impacts associated with the generation
of waste materials as part of day-to-day operations. The philosophy of ‘circular thinking’ is also strategically
important to DOF’s value creation model whereby it is essential that the use-full life of our assets is preserved for
as long as possible to protect asset integrity, avoid unnecessary resource outflows and ensure our vessels see
out their budgeted lifespan.
DOF’s circular economy measures focus on waste hierarchy, and efficient use of natural resources to avoid the
unnecessary wastage.
Our strategic approach uses two levers to address the main challenges and focuses on:
• Utilizing industry best practice standards and methodologies to meet and extended asset useful life,
• Environmental improvement during projects and new buildings.
E5-3 Targets related to resource use and circular economy
DOF has not established measurable targets in relation to resource use and circular economy. A key challenge
for DOF regarding reducing waste is that it is difficult to decouple the rate in which waste is generated from the
level of activity.
As resource in-flows and outflows are not considered material, DOF has not adopted absolute or relative targets.
Additional targets will be assessed when shipbuilding or asset decommissioning activities substantially increase.
Despite this, we employ various processes to track the effectiveness of policies related to the circular economy
and actions related to controlling circular economy impacts, risks, and opportunities.
Waste management
To ensure the effectiveness of our IMO-approved garbage management plan, DOF tracks its application within
operations. This involves regular waste generation monitoring and record of disposal records via UNISEA, in
addition to internal and external audits of onboard waste management practices, and analysis of operational data
to identify areas for improvement.
DOF tracks the effectiveness of these measures by reviewing the number of incidents related to non-compliance
with the garbage management plan. DOF can also gauge the effectiveness of these policies through the safety
observation card system and audit processes.
During the reporting period, one non-conformity was recorded related to disposal of garbage and subsequent
record keeping. In this instance, the generation of incinerator ash was not recorded under the correct category of
the Garbage record book. The clerical error has now been addressed.
The Environmental Impact Policy states the ambition in this area, we seek to adhere to the waste hierarchy, avoid
the inefficient use of natural resources, and comply with relevant legislation.
IROS
MATERIAL IMPACTS,
RISKS AND OPPORTUNITIES
IRO
TYPE
VALUE
CHAIN
AREA
STAKE
HOLDER
PRIORITY
TIME
HORIZON
E5 Circular Economy
and Resource Use
Generation of Waste
DOF generates significant quantities of waste as
part of day-to-day activities and as part of vessel
overhauls and maintenance
AI
Across whole
value chain
Key
IRO type Impact materiality Financial materiality
PI
Potential impact
AI
Actual impact
!
Potential risk
!
Actual risk
O
Opportunity
Stakeholder priority increasing unchanged decreasing
Time horizon
Short-term Short-to medium-term Medium-to long-term Long-term
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E5-2 Actions in relation to resource use and circular economy
KEY ACTION
Garbage and Waste Management Plans
All vessels in the fleet have a garbage management plan that
prioritises waste reduction, recycling, and responsible disposal.
The plan minimises waste generation, seeks to reuse materials
where possible, and segregates waste streams to maximise
proper processing when waste is transferred from the vessel.
Project documentation such as Health, Safety and
Environmental Management Plans assists DOF with the
management of project-specific wastes or managing waste
streams in remote or sensitive environments.
SCOPE OF ACTION
Fleet-wide application of Garbage Management Plan
Project HSE Management Plans established on an ad-hoc basis
related to the nature and level of Project
CORRESPONDING POLICY
Environmental Impact Policy:
• Ensure environmental management is given equal consideration
throughout all operational planning and undertaking.
• Assess and control the aspects and impacts of our operations upon
the environment.
• Apply applicable laws and regulations and where deficient apply
company and industry best practice.
• Reduce and restrict the production of waste products known to be
detrimental to the environment.
• Minimise our impact on the environment through pollution
prevention, efficient use of natural resources and the reduction and
recycling of waste.
PROGRESS
Ongoing, as part of Business Management System
TIME HORIZON FOR COMPLETION*
*Short-term (1 year), medium-term (2-5 years), and long-term (5+ years) horizons
E5-4 Resource in-flows
Our value chain, especially in engineering, vessel design, procurement, and supply chain management, can influence
the quantity, origin, recyclability, and source of raw materials. DOF has identified virgin steel as a critical raw
material input, in the areas of new-build and major vessel conversions. DOF has an active new-build program, with
one new-build vessel currently being built. The nature of DOF’s 2025 newbuild program was not deemed extensive
enough to consider resource in-flows as a material topic in the context of our value chain.
Other process materials, semi-manufactured goods, and assets such as heavy machinery, transport vehicles, and
IT equipment are used; however, their use is sporadic, localised, and no single resource input is fundamental to
the marine contracting services DOF provide.
A core consideration of DOF’s new build program is circular design. New build vessels incorporate considerations
for preventative maintenance and meeting the markets’ long-term needs in terms of vessel specification and
capabilities. These core elements are central to ensure that the vessel fulfills its budgeted lifespan.
E5-5 Resource out-flows
DOF integrates circular economy principles throughout its value chain by responsibly managing resource outflows
and applying circular design to projects, materials, and product lifecycles. This approach is especially important in
decommissioning, where the focus is on maximizing recovery efficiency, promoting material recirculation, minimizing
waste, and ensuring proper segregation for future recycling and recovery. Following our materiality assessment, no
material impacts, risks, or opportunities related to resource outflows from products and services were identified.
Products and materials
Resource outflows and circular design:
No major vessel conversions or asset decommissioning activities occurred during the reporting period and therefore
no substantial by-products associated with manufacturing or production processes have been identified.
As part of our day-to-day operations, waste is generated from end-of-life machinery components, consumables,
sea-fastening grillage, installation aids, and IT equipment. These by-products are not considered substantial
resource outflows, as they are produced irregularly, in varying quantities and with characteristics unique to each
vessel or project, rather than being fundamental to the direct value chain.
DOF is involved in the value chain of offshore decommissioning. DOF acts on behalf of its clients to recover,
segregate and deliver end-of-life subsea products to onshore waste disposal facilities. DOF deploys engineering
design principles to maximise the quantity of product recovered, in addition to ensuring that it is adequately
segregated for intended waste streams and high-value reuse. This includes, but is not limited to, prioritization of
modular breakdown, use of ROV cutting to preserve component integrity, refurbishment of components where
feasible and use of chain of custody-tracking to avoid waste leakage.
Waste reduction and management strategy
Our waste reduction strategy is aligned with circular economy principles, aiming to recirculate materials and minimise
waste generation. Vessel-specific Garbage Management Plans provide the framework for optimal waste sorting,
enabling the appropriate treatment of waste streams once disembarked. Waste transfer notes are maintained
to document the handover of disposal responsibilities to third-party carriers, which may be directly contracted
or managed through clients or agents. All waste discharges, whether planned or unplanned, are recorded in the
Garbage Record Book, detailing the date, vessel position, quantity and type of waste, and its point of discharge,
whether a ship, port, or reception facility.
Total waste generation:
During 2025, our operations generated approximately 79,295 metric tonnes of waste, consisting of hazardous
and non-hazardous waste streams, delivered ashore, discharged at sea, or incinerated in compliance with MARPOL
Regulations. Of this, 35,040 metric tonnes were classified as hazardous waste and 44,254 metric tonnes as
non-hazardous waste, as defined by the Waste Framework Directive (Directive 2008/98/EC). A total of 40,896
metric tonnes of waste was discharged at sea under MARPOL Annex V requirements, while 821 metric tonnes
were incinerated using MARPOL Annex VI-compliant incinerators on board our assets. Although DOF does not
have full oversight of the ultimate disposal of waste once discharged from vessels, 2,620 metric tonnes of vessel
waste was discharged from the vessel in waste streams intended for recycling or recovery.
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**Contextual information and data transparency:
The data on waste management practices and waste composition is based on direct measurements, including tank
soundings and waste transfer records from contracted waste collectors. While the Garbage Record Book records
waste volumes in cubic meters, DOF also converts these volumes into weight. This is done through a combination
of direct weighing, precise measurement, and, when required, the use of established volume to weight conversion
factors specific to different waste types. These conversion factors are primarily based on international standards;
where such standards do not exist, the best available information sourced from reputable online references is
applied. DOF utilises volume to weight conversion factors for garbage record logs that are missing weight inputs.
This has been implemented as a more standardised approach than estimating conversions offshore. The adoption
of a standardised volume to weight conversion method represents a change from the approach used in 2024
and significantly increases data quality by providing greater consistency compared to relying on crew expertise.
While the use of a conversion rate for missing metric-based garbage records has improved data quality, some
uncertainty remains because certain figures are estimated by crew. The extent of these estimations is unknown,
as the methodology for determining waste metrics is neither visible onshore nor documented within the garbage
record logs.
To enhance transparency, DOF acknowledges that the level of uncertainty varies by waste stream and geography,
with higher uncertainty where contractor provided data cannot be independently verified. While the use of
standardised conversion factors improves consistency, the resulting weight estimates may still carry an inherent
estimation tolerance. To mitigate these uncertainties, DOF engages only licensed waste management providers
and uses information provided within vessel logs, transfer notes, and carrier documentation where available,
increasing confidence in point of generation measurements.
The destination and method of disposal are influenced by external factors such as local regulatory requirements,
waste management infrastructure, and varying levels of waste recovery mandated by environmental standards. Due
to the complexity of disposal arrangements across the value chain including multiple discharge locations, waste
carriers, contract structures, and chains of custody DOF does not have full oversight of ultimate disposal methods
and quantities. As a result, the categorisation of waste across ESRS E5 5 reporting types (reuse, recycling, recovery,
incineration, and landfill) reflects DOF’s best estimate classification based on the waste stream at discharge rather
than verified downstream outcomes. Uncertainty is greatest in regions with fragmented waste infrastructure or
multiple subcontractors, and in such cases actual downstream processes may differ from assumed classifications.
Waste logs managed under the Garbage Management Plan are recorded in accordance with MARPOL Annex V, and
classifications have been cross referenced with the EU Waste Framework Directive to ensure ESRS alignment.
E5-6 Anticipated financial effects from pollution-related impacts, risks and opportunities
DOF exercises the right to utilise the phase-in option.
ESRS Requirement Waste Category
Total Waste
2024(Metric Tonnes)
Total Waste
(Metric Tonnes) Breakdown
E5-5 37(a) Total waste generated 120 400 79 295
Includes hazardous, non-hazardous, sea
discharges, and incinerated waste
E5-5 37(b)(ii) Waste recycled 10 590 2 620 Discharged in recyclable waste streams**
Waste recycled
(hazardous) 9 770 0 Discharged in recyclable waste streams**
Waste recycled (non-
Hazardous) 819 2 620 Discharged in recyclable waste streams**
E5-5 37(c)(i)
Waste incinerated (non-
hazardous) 529 821
Incinerated onboard vessels using MARPOL
Annex VI-compliant incinerators
E5-5 37(c)(iii) Other disposal operations 106 398 40 896
Includes sea discharges under MARPOL Annex
V requirements
Other disposal operations
(hazardous) 3 350 1 077
Includes sea discharges under MARPOL Annex
V requirements
Other disposal operations
(non-Hazardous) 103 048 39 819
Includes sea discharges under MARPOL Annex
V requirements
E5-5 37(d) Non-recycled waste 109281 76 674
Includes MARPOL-compliant discharges,
incinerated waste, ‘other disposal operations’;
and waste without feasible recycling options
Non-recycled waste
(hazardous) 5566 35 040
Includes MARPOL-compliant discharges,
incinerated ashes, and waste without feasible
recycling options
Non-recycled waste (non-
Hazardous) 103 701 41 633
Includes MARPOL-compliant discharges, other
disposal operations, and waste without feasible
recycling options
Waste composition and hazardous waste:
DOF saw a reduction is total waste in 2025. This can be attributed largely to a significant reduction in treated
sewage discharges as a result of operating locations, project requirements and varying personnel levels compared
to the previous year. A review of garbage record logs confirms no anomalies with waste reporting practices. The
composition of waste is largely driven by the operational nature of our industry. DOF’s primary waste stream is
non-recyclable waste which is made up of both wastes disposed ashore or to other vessels and discharged to sea.
A significant proportion of non-recyclable waste include food waste, grey water, and sewage, which are treated
and discharged at sea within the limits and exceptions outlined by MARPOL. These discharges represent almost
half of our waste output in terms of volume.
Approximately 44% of our waste can be classified as hazardous waste, with the majority of this waste consisting
of oily water arising from engine room operations, bilge water, fuel oil purification, tank cleaning, maintenance, and
ballast water management activities. 97% of the waste volume generated by DOF is categorised as non-recyclable,
principally because of the large quantities of oily water waste streams in addition to seawater discharges that are
treated and discharged under MARPOL requirements (52% of total waste volume).
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Summary KPI’s 2025
The EU Taxonomy is a classification system that defines which
economic activities can be considered environmentally sustainable.
As the regulation evolves, DOF’s reporting and accounting practices
continue to develop to ensure as maximal alignment relative to
eligible activities. For 2025, DOF has utilised the original EU
Taxonomy rules that were applicable prior to the 2025 Omnibus
simplification and materiality thresholds. DOF’s 2026 reporting
cycle will adopt the Omnibus simplification package. For 2025,
DOF assessed all economic activities executed during the reporting
period for Taxonomy eligibility and alignment. Eligible activities were
evaluated against the Technical Screening Criteria (TSC), Do No
Significant Harm (DNSH) requirements, and Minimum Safeguards.
DOF has also enhanced its ability to identify eligible activities
through tagging of opportunities by operational teams as they
arise within the CRM system and continues track their evolution
into executed contracts ensuring necessary documentation or
information is collected proactively. These updates improve the
accuracy and consistency of classifications but do not represent
fundamental changes our accounting policy.
For 2025, our Taxonomy aligned revenue amounts to TUSD
49,624 compared with TUSD 15,897 in 2024. The increase
reflects a higher value of activities falling within eligible Taxonomy
categories, supported by improved traceability of project scopes
and more robust internal and external evidence collection for
DNSH assessments.
EU Taxonomy
Turnover
16% Taxonomy
eligible, but NOT aligned activities
81% Taxonomy
NON-eligible activities
3% Taxonomy
aligned activites
Aligned
3%
CAPEX
5% Taxonomy
eligible, but NOT aligned activities
95% Taxonomy
NON-eligible activities
0% Taxonomy
aligned activites
CapEx
Aligned
0%
OPEX
CapEx
Aligned
1%
21% Taxonomy
eligible, but NOT aligned activities
78% Taxonomy
NON-eligible activities
1% Taxonomy
aligned activites
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Our Taxonomy aligned CAPEX for the year remains zero for 2025 reporting periods, which is the same as 2024. The
increase in eligible CAPEX reported in 2024 was due to the accounting treatment of the DOF Denmark acquisition,
where the recognised asset additions were attributed to eligible operational activities. As this acquisition was
fully recognised in the 2024 reporting period, no comparable eligible additions occurred in 2025, resulting in a
significantly lower CAPEX numerator.
Taxonomy-related OPEX remains broadly consistent between 2024 and 2025. Under the Article 8 definition,
OPEX includes research and development, short-term leases, and maintenance, repair and day-to-day servicing
of vessels, ROVs and equipment, while major running costs such as fuel fall outside the scope. Following the cor-
rection of a prior-period error, the 2024 OPEX taxonomy figure has been updated to include short-term leases,
resulting in an adjusted eligible/not-aligned share of 28%. The corresponding 2025 figure is 20%. The amount of
eligible-aligned OPEX remains unchanged, as the correction affects only the denominator. In 2025, a small portion
of eligible OPEX related to remediation activities in the APAC region was considered aligned.
Eligible-aligned activities 2025 included in DOF’s EU Taxonomy Reporting
The table below outlines DOF’s EU Taxonomy-eligible and Taxonomy-aligned activities for 2025. It is intended to
clarify the types of work performed by DOF that fall within the scope of the EU Taxonomy and how these activities
contribute to the corresponding financial KPIs.
Type of work
Taxonomy
description
DOF activity description
Revenue
CAPEX
OPEX
Project and Subsea Services
TUSD
TUSD
Cable Repair/
Cable laying/
Quality Control
4.9 Transmission
and distribution
of electricity
The project involved subsea repair works on the export cable system of the
Hornsea 02 Offshore Wind Farm, located approximately 89 km off the Yorkshire
coast in the North Sea. Hornsea 02 comprises 165 Siemens 8.4 MW wind
turbines connected via offshore substations and reactor stations to an onshore
substation through 220 kV HVAC export circuits.
A fault was detected on the BMU2 export cable approximately 27.8 km from
the offshore reactor station in 17 m water depth. The scope of work included
subsea cable exposure, cutting and recovery of cable ends, temporary wet
storage, installation of a replacement inline joint, laying of the repaired cable
section, omega joint installation, redeployment to the seabed, protection of the
repair using burial and rock-bag placement, and final “as-left” surveys.
All activities were performed using a single-vessel approach, including
mobilisation, surveys, trenching, jointing, cable handling, and reinstatement
operations.
18 506 - 618
Preparation of
worksite and
offshore asset for
decommissioning and
recycling
3.2 Remediation
of contaminated
sites and areas
A The Northern Endeavour Decommissioning Project (Phase 1) covers the
physical decommissioning of the Laminaria–Corallina field facilities in the
Timor Sea. The scope includes hydrocarbonfreeing and depressurisation of the
Northern Endeavour FPSO, suspension and isolation of nine development wells,
disconnection of the FPSO from all subsea infrastructure, and tow preparation
in line with Commonwealth requirements.
The FPSO was permanently moored in approximately 380 m water depth, with
the wider field located between 356–410 m, requiring diverless intervention
techniques. The production system consisted of subsea wells tied back through
manifolds, flexible and rigid flowlines, umbilicals, and dynamic risers to the
moored FPSO, which previously stored and exported oil via tandem offtake.
Prior to decommissioning works, the facility had been fully shut in, with wells
secured and Subsurface Safety Valves closed. Phase 1 activities involved
cleaning and making the facility safe, isolating and preparing subsea and
topside systems for removal, and disconnecting the FPSO from risers, umbilicals
and moorings.
31 117
-
1 687
Accounting Policies
Taxonomy-eligible activities
In 2025, DOF applied an enhanced and more structured approach to identifying Taxonomy-eligible economic ac-
tivities in accordance with Regulation (EU) 2020/852 and the associated Delegated Acts.
A cross-functional working group representing Finance, Operations, ESG, HSEQ and regional Business Units per-
formed a comprehensive screening of all operational activities executed during the reporting period. Screening
was performed across all global regions in which DOF operates, following a consistent methodology aligned with
the Climate Delegated Act (2021/2139), the Complementary Climate Delegated Act (2022/1214) and the Envi-
ronmental Delegated Act (2023/2486).
DOF applied a structured and systematic approach to screening our operations for Taxonomy eligibility using the
below process:
1. DOF first reviewed its CRM system and operational portfolio to identify activities potentially falling within
the scope of the EU Taxonomy. A preliminary list of these activities was compiled and discussed with
key internal stakeholders. Cross disciplinary teams were engaged representing Finance, Operations,
ESG, and HSEQ. Using project documentation stored in the global document management system, the
team conducted a detailed assessment of each activity against the eligibility criteria in the Delegated
Acts concluding whether these activities corresponded with EU Taxonomy Climate Delegated Act. DOF
also evaluated its marine operations in consideration of eligible activities under the NACE code 6.10.
2. Concluded activities were transferred into an online platform.
3. Project Controllers, associated with the activities allocated Revenue, CAPEX and OPEX within the
platform to their respective activities.
DOF assessed operational activities performed in 2025 against the economic activities of the EU Taxonomy.
These disclosures include activities previously reported in 2024.
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The alignment assessment is led by the ESG Reporting Team in close collaboration with subject-matter experts
and operational functions across the organisation. As part of our continuous improvement, DOF is expanding
the scope and depth of its alignment work and is integrating Taxonomy considerations into capital allocation and
project planning processes.
Where an activity did not meet one or more of the required TSC components (Substantial Contribution, DNSH or
Minimum Safeguards), it was classified as not aligned. In several areas, DOF’s existing operational controls and
environmental management practices provide supporting evidence that overlaps with the requirements of the EU
Taxonomy. For activities that are central to DOF’s operations but do not meet the EU Taxonomy Technical Screening
Criteria (TSC), DOF provides a brief explanation of the reason for non-alignment within its internal platform. A key
economic activity that is not aligned is, Activity 6.10 “Sea and coastal freight transport. Justification for this is
that vessels for port operations and auxiliary activities” was assessed as not aligned because the vessels engaged
in this activity are dedicated to the transport and support of fossil fuel–related operations. Under the TSC, vessels
primarily used for transporting or servicing fossil fuels do not meet the Substantial Contribution requirements for
Climate Change Mitigation. As a result, these activities cannot be considered Taxonomy-aligned, even if other
operational or environmental controls are in place. DOF also performed a number of decommissioning activities
that were Taxonomy-eligible but did not meet the TSC due to insufficient project-level documentation to evidence
compliance with the Substantial Contribution or DNSH requirements. These activities have therefore been classified
as not aligned. DNSH assessments were conducted at the level of each eligible economic activity. For each activity,
DOF evaluated its compliance with environmental protection requirements including:
• Climate risk and vulnerability assessment (TPA 1.2),
• Pollution prevention and control,
• Circular economy and waste management,
• Water and marine resource protection,
• Biodiversity and ecosystems.
An activity is classified as Taxonomy-aligned only where DOF can evidence that all applicable Do No Significant
Harm (DNSH) criteria are met. This means that every DNSH requirement relevant to the activity must be supported
by verifiable project-level or vessel-level documentation. Where the evidence for one or more DNSH criteria is
incomplete, insufficient, or not available, the activity is reported as Taxonomy-eligible but not aligned, regardless
of operational practices or internal controls.
Type of work Taxonomy description Activity description
Decommissioning
projects
3.5 – Demolition and wrecking
of buildings and other
structures
Decommissioning refers to the process of safely retiring and removing facilities,
structures, or equipment from operation after they have completed their useful life,
followed by environmental restoration
Cable Repair/
Cable laying/
Quality Control
4.9 – Transmission and
distribution of electricity
Offshore activities involving cable repair, cable laying and quality control of electrical
cables DOF’s scope was to dismantle, retrieve and dispose of subsea infrastructure
within the Heimdal field
Operations of Anchor
Handlers & Platform
Supply Vessels
6.10 Sea and coastal freight
water transport, vessels for
port operations and auxiliary
activities
PSVs are specifically designed and built to transport freight to/from offshore
platforms and our AHTS vessels are fitted to move rigs and work with anchor chains,
some are even fitted with ROVs
Debris Recovery
5.5 Collection and transport
of non-hazardous waste in
source segregated fractions
Previously reported in 2024 in association with a waste recovery project involving the
recovery and transport of debris recovered from a seabed located off the Northwest
shelf, Western Australia in March 2024.
Preparation of worksite
and offshore asset for
decommissioning and
recycling
3.2 Remediation of
contaminated sites and areas
Activities typically performed in order to prepare topside assets for decommissioning,
including remediation of contaminated products and materials.
Solutions for GHG
emission reduction
8.2 Data-driven solutions for
GHG emission reduction
DOF has data-driven solutions for GHG emission reductions in their operations For
example, the Digital Fleet project is a programme to optimise maintenance, fuel
consumption and emissions Delivering a common platform for vessel sensor data
collection, visualisation, reporting and analysis This strengthens monitoring and
control of fleet performance and supports better decisions to continuously improve
Taxonomy Alignment activities
For an activity to be considered taxonomy-aligned it must meet all three of the following conditions:
Condition 1: It makes a substantial contribution to one of the environmental objectives by meeting the screening
criteria defined for this economic activity.
Condition 2: It meets the Do-No-Significant-Harm (DNSH) criteria defined for this economic activity.
Condition 3: It is carried out in compliance with the minimum safeguards, which relate primarily to human rights
and social and labour standards.
DOF assesses Taxonomy alignment by evaluating each relevant economic activity against the EU Taxonomy Technical
Screening Criteria (TSC). This includes determining whether the activity meets the Substantial Contribution
requirements, complies with all applicable Do No Significant Harm (DNSH) criteria, and satisfies the Minimum
Safeguards. The assessment focuses on the actual performance, processes and controls applied within the activity,
and compares these directly with the thresholds, tests and evidence set out in the Delegated Acts.
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Basis of Preparation:
DOF’s EU Taxonomy disclosures have been prepared in accordance with Regulation (EU) 2020/852 and Commission
Delegated Regulation (EU) 2021/2178.
The EU Taxonomy disclosures for 2025 cover the same consolidation perimeter as the Group’s financial statements.
The 2025 reporting period represents the first full-year integration of DOF Denmark following its acquisition on
1 November 2024.
The KPIs are presented in USD based on consolidated figures of the economic activity for the Group. The EU-
Taxonomy reported covers the same period as the Group’s financial statements for 2025.
In cases where DOF’s projects consist of several economic activities, the turnover, CAPEX and OPEX were allocated
to each executed economic activity by the below methodology dividing the turnover, CAPEX and OPEX into separate
parts. These estimates are based on the extent and scope a specific economic activity had in the project.
Minimum Safeguard Criteria
In the alignment assessment, eligible economic activities are assessed against the substantial contribution criteria
and the “do no significant harm” (DNSH) criteria. While the substantial contribution criteria and DNSH criteria
are economic activity-specific criteria, the minimum safeguards criteria are a Group-level policy requirement.
As outlined below;
Minimum Social Safeguard DOF Approach
Human Rights Guided by our values, DOF is committed to respecting human rights Our policies and standards ensure our
operations do not breach laws, conventions, or UN guidelines, upholding International Law and Labour Organisation
Conventions
We are committed to perform human rights due diligence DOF Group ASA and all its subsidiaries adhere to the same
guide-lines, procedures, and governing documents regarding human rights, and our due diligence assessments are
based up on the common risks identified in our unified Supply Chain Management system or any incidents reported
through our grievance mechanisms
Our approach to Human Rights Due Diligence is communicated in our Transparency Act statement, our Modern
Slavery Act statement, our Code of Business Conduct and expectations towards suppliers are outlined in our Supplier
Code of Conduct Information about the transparency act statement, and where it can be found on our web page is
also informed in our Annual report
DOF has not been found in breach of labour law or human rights, and there has not been any cases or allegations
brought for-ward through OECD National Contact Point or Business and Human Rights Resource Centre
Corruption The DOF Group is opposed to corruption in all forms, and promotes the highest level of integrity, ethical behaviour,
and accountability Our Anti-corruption Policy, Code of Business Conduct, and business ethics training is part of our
anti-corruption framework
DOF, or its senior management, including the senior management of its subsidiaries, have not been convicted in court
of corruption
Taxation The DOF Group aims to achieve excellence in all its operations in every jurisdiction it works By providing a Tax Policy,
the DOF Group ensures that all tax obligations are complied with in a timely, efficient and cost-effective manner, in
all project locations The DOF Group is mindful of its responsibility and committed to paying its fair share of taxes to
the countries in which it operates, in compliance with applicable laws and conventions and in accordance with DOF’s
Code of Business Conduct
DOF or its subsidiaries have not been found in violation of tax laws
Fair Competition Through our Business Integrity and Ethics Policy, Code of Business Conduct, and training, DOF promotes employee
awareness of the importance of compliance with all applicable competition laws and regulations
DOF, or its senior management, including the senior management of its subsidiaries, have not been found in violation
of competition laws
During the reporting period, DOF conducted regular internal reviews and compliance checks. No issues were
identified that would prevent the company from meeting the Minimum Safeguards requirement.
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The following boundaries have been applied to EU Taxonomy Reporting:
• Economic activities are considered irrespective of their geographical location, whether inside or outside of the
European Union.
• Economic activities from joint arrangements are not part of the reporting.
Turnover:
Total turnover is defined as the operating revenue following the IFRS definition of revenue, as presented in
the financial statements. Eligible turnover is defined as the operating revenue derived from eligible external
projects presented in the KPIs. If a project consists of eligible and non-eligible operation, allocation of revenue
is based on number of offshore days spent in the various activities. All eligible turnover in the subsea service
segment is within IFRS 15 “Revenue from contracts with customers” and IFRS 16 “Leases”. Turnover in the
marine operations is within IFRS 15 “Revenue from contracts with customers” and IFRS 16 “Leases”. For
more information about operating revenue, see note 7 ‘Operating revenue’ (see page 151) in the financial
statements.
The denominator is total DOF Group turnover for the reporting period.
See table see page 74: Proportion of turnover from products or services associated with taxonomy-aligned economic
activities
CAPEX:
Total CAPEX is defined as the Group’s additions to tangible assets and intangible assets (contract costs) in
accordance with IFRS, as presented in the consolidated financial statements. Contract costs represent expenditure
incurred in preparation for the delivery of long-term projects. Tangible asset additions include vessels, ROVs, other
equipment and right-of-use assets recognised under long-term lease agreements.
For EU Taxonomy reporting, DOF assesses whether any additions to vessels, equipment, right-of-use assets or
contract costs relate to projects that meet the criteria for Taxonomy-eligible economic activities. For 2025, no
capital expenditure was incurred on vessels or equipment directly involved in eligible-aligned activities. As a result,
the CAPEX KPI is 0%
Only new lease agreements that result in the recognition of a right-of-use asset under IFRS are included as CAPEX.
The denominator reflects the Group’s total additions to tangible assets and contract costs, consistent with the
amounts disclosed in the consolidated financial statements.
See table see page 75: Proportion of CAPEX from products or services associated with taxonomy-aligned economic activities
OPEX:
Total OPEX is defined as the sum of all research and development costs, payroll expenses and other operating
expenses directly related to the maintenance, repair and day-to-day servicing of vessels, ROVs and equipment,
and includes short-term lease costs recognised as operating expenses. Eligible OPEX comprises the direct costs
of maintenance, repair and other day-to-day servicing of vessels, ROVs and other equipment, corresponding to
cost items presented in the financial statements under “Operating Expenses”, including relevant short-term lease
expenses. Costs not directly related to maintenance or repair such as crew/personnel costs relating to parallel
activities are excluded. Research and development (R&D) costs for eligible activities include direct procurement
to specific projects and personnel costs for staff working directly on those projects, while administrative costs
and all other personnel costs are excluded.
In 2025, DOF has incorporated short-term leases into the OPEX denominator in accordance with the Article 8
requirements. The comparable figures in this year’s report have been updated to reflect the inclusion of short-term
leases, correcting an error in prior-period reporting. This adjustment enhances the completeness and consistency
of the OPEX definition in line with the EU Taxonomy Delegated Act.
See table see page 76: Proportion of OPEX from products or services associated with taxonomy-aligned economic activities
Internal Control and Governance for EU Taxonomy
DOF’s EU Taxonomy reporting is governed through established internal controls outlined within both the Finance
Manual and sustainability reporting framework. Executive responsibility rests with the CFO, with the Head of ESG
Reporting accountable for technical interpretation and compliance. Regional Finance Managers and Controllers
provide operational data inputs for turnover, CAPEX and OPEX, while the ESG Reporting team performs eligibility
and alignment assessments against the Technical Screening Criteria. Final disclosures are reviewed and approved
by Executive Management and the Board.
Data used for Taxonomy KPIs is sourced directly from consolidated financial systems under existing accounting
controls. Each project, vessel, or asset is mapped to the appropriate EU Taxonomy or NACE activity code, support-
ed by documentation demonstrating substantial contribution and DNSH compliance. KPI calculations are jointly
reviewed by ESG and Finance teams, ensuring reconciliation to IFRS figures. All disclosures are supported by
detailed working papers, including calculation files, eligibility assessments and DNSH evaluations.
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Proportion of turnover from products or services associated with taxonomy-aligned economic activities
Financial year N 2025 Substantial contribution criteria DNSH criteria
Economic activities Codes Turnover
Proportion
of
Turnover,
year N
Climate
mitigation
Climate
adaptation Water
Circular
economy
Pollution
prevention Biodiversity
Climate
mitigation
Climate
adaptation Water
Circular
economy
Pollution
prevention Biodiversity
Minimum
safeguards
Proportion
aligned
(A.1) or
eligible
(A.2)
Turnover,
year N-1
Category
enabling
activity
Category
transitional
activity
TUSD % Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N Y;N Y;N Y;N Y;N Y;N Y;N % E T
A. Taxonomy-Eligible Activities
A.1 Environmentally sustainable activities (Taxonomy-aligned)
Remediation of contaminated sites and areas PPC 24 31117 166% N/EL N/EL N/EL N/EL Y N/EL Y Y Y Y Y Y 000%
Transmission and distribution of electricity
CCA 49/
CCM 49
18506 099% Y Y N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 000% E
Turnover of environmentally sustainable activities (Taxonomy-aligned) (A.1)
49624 265% 000% 099% 000% 000% 166% 000% Y Y Y Y Y Y Y 115%
Of which Enabling
18506 099% 000% 099% 000% 000% 000% 000% Y Y Y Y Y Y Y 115% E
Of which Transitional
0 000% 000% 000% T
A.2 Taxonomy-Eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)
EL;N/EL EL;N/EL EL;N/EL EL;N/EL EL;N/EL EL;N/EL
Demolition and wrecking of buildings and other structures
CE 33 37396 200% N/EL N/EL N/EL EL N/EL N/EL 586%
Sea and coastal freight water transport, vessels for port operations and
auxiliary activities
CCA 610/
CCM 610
241797 1292% EL EL N/EL N/EL N/EL N/EL 1841%
Transmission and distribution of electricity
CCA 49/
CCM 49
29081 155% EL EL N/EL N/EL N/EL N/EL 025%
Turnover of Taxonomy-eligible but not environmentally sustainable
activities (not Taxonomy-aligned activities) (A.2)
308276 1648% 1448% 1448% 000% 200% 000% 000% 2508%
A. Turnover of Taxonomy eligible activities (A.1 + A.2)
357900 1913% 1547% 1547% 000% 200% 166% 000% 2623%
B. Taxonomy-Non-Eligible Activities
Turnover of Taxonomy-non-eligible activities (B)
1513211 8087%
Total (A + B)
1871111 10000%
Proportion of Turnover/Total Turnover
Aligned per objective Eligible per objective
CCM
099%
1547%
CCA
099%
1547%
WTR
000%
000%
CE
000%
200%
PPC
166%
166%
BIO
000%
000%
SUSTAINABILITY STATEMENTS - EU TAXONOMY
Nuclear energy related activities
1
The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative electricity generation facilities that produce energy from
nuclear processes with minimal waste from the fuel cycle
NO
2
The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for the purposes
of district heating or industrial processes such as hydrogen production, as well as their safety upgrades, using best available technologies
NO
3
The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity or process heat, including for the purposes of district
heating or industrial processes such as hydrogen production from nuclear energy, as well as their safety upgrades
NO
Fossil gas related activities
4
The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels
NO
5
The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels
NO
6
The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels
NO
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Proportion of CAPEX from products or services associated with taxonomy-aligned economic activities
Financial year N 2025 Substantial contribution criteria DNSH criteria
Economic activities Codes CAPEX
Proportion
of CAPEX,
year N
Climate
mitigation
Climate
adaptation Water
Circular
economy
Pollution
prevention Biodiversity
Climate
mitigation
Climate
adaptation Water
Circular
economy
Pollution
prevention Biodiversity
Minimum
safeguards
Proportion
aligned
(A.1) or
eligible
(A.2)
CAPEX,
year N-1
Category
enabling
activity
Category
transitional
activity
TUSD % Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N Y;N Y;N Y;N Y;N Y;N Y;N % E T
A. Taxonomy-Eligible Activities
A.1 Environmentally sustainable activities (Taxonomy-aligned)
Remediation of contaminated sites and areas
PPC 24 0 000% N/EL N/EL N/EL N/EL Y N/EL Y Y Y Y Y Y 000%
Transmission and distribution of electricity CCA 49/
CCM 49
0 000% Y Y N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 000% E
CAPEX of environmentally sustainable activities (Taxonomy-
aligned) (A.1)
0
000% 000% 000% 000% 000% 000% 000% Y Y Y Y Y Y Y 002%
Of which Enabling 0 000% 000% 000% 000% 000% 000% 000% Y Y Y Y Y Y Y 002% E
Of which Transitional 0
000% 000% 000% T
A.2 Taxonomy-Eligible but not environmentally sustainable
activities (not Taxonomy-aligned activities)
EL;N/EL EL;N/EL EL;N/EL EL;N/EL EL;N/EL EL;N/EL
Demolition and wrecking of buildings and other structures
CE 33 0 000% N/EL N/EL N/EL EL N/EL N/EL 007%
Sea and coastal freight water transport, vessels for port
operations and auxiliary activities
CCA 610/
CCM 610
21652 504% EL EL N/EL N/EL N/EL N/EL 3582%
Transmission and distribution of electricity
CCA 49/
CCM 49
0 000% EL EL N/EL N/EL N/EL N/EL 645%
CAPEX of Taxonomy-eligible but not environmentally sustainable
activities (not Taxonomy-aligned activities) (A.2)
21652
504% 504% 504% 000% 000% 000% 000% 4290%
A. CAPEX of Taxonomy eligible activities (A.1 + A.2) 21652 504% 504% 504% 000% 000% 000% 000% 4292%
B. Taxonomy-Non-Eligible Activities
CAPEX of Taxonomy-non-eligible activities (B) 408347
9496%
Total (A + B) 430000 10000%
SUSTAINABILITY STATEMENTS - EU TAXONOMY
Nuclear energy related activities
1
The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative electricity generation facilities that produce energy from
nuclear processes with minimal waste from the fuel cycle
NO
2
The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for the purposes
of district heating or industrial processes such as hydrogen production, as well as their safety upgrades, using best available technologies
NO
3
The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity or process heat, including for the purposes of district
heating or industrial processes such as hydrogen production from nuclear energy, as well as their safety upgrades
NO
Fossil gas related activities
4
The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels
NO
5
The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels
NO
6
The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels
NO
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Proportion of OPEX from products or services associated with taxonomy-aligned economic activities.
Financial year N 2025 Substantial contribution criteria DNSH criteria
Economic activities Codes OPEX
Proportion
of OPEX,
year N
Climate
mitigation
Climate
adaptation Water
Circular
economy
Pollution
prevention Biodiversity
Climate
mitigation
Climate
adaptation Water
Circular
economy
Pollution
prevention Biodiversity
Minimum
safeguards
Proportion
aligned
(A.1) or
eligible
(A.2)
OPEX,
year N-1
Category
enabling
activity
Category
transitional
activity
TUSD % Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N Y;N Y;N Y;N Y;N Y;N Y;N % E T
A. Taxonomy-Eligible Activities
A.1 Environmentally sustainable activities (Taxonomy-aligned)
Remediation of contaminated sites and areas
PPC 24 1687 082% N/EL N/EL N/EL N/EL Y N/EL Y Y Y Y Y Y 000%
Transmission and distribution of electricity CCA 49/
CCM 49
618, 030% Y Y N/EL N/EL N/EL N/EL Y Y Y Y Y Y Y 000% E
OPEX of environmentally sustainable activities (Taxonomy-
aligned) (A.1)
2306 112% 000% 040% 000% 000% 109% 000% Y Y Y Y Y Y Y 023%
Of which Enabling 618 030% 000% 040% 000% 000% 000% 000% Y Y Y Y Y Y Y 023% E
Of which Transitional 0
000% 000% 023% T
A.2 Taxonomy-Eligible but not environmentally sustainable
activities (not Taxonomy-aligned activities)
EL;N/EL EL;N/EL EL;N/EL EL;N/EL EL;N/EL EL;N/EL
Demolition and wrecking of buildings and other structures
CE 33 1914 093% N/EL N/EL N/EL EL N/EL N/EL 162%
Sea and coastal freight water transport, vessels for port
operations and auxiliary activities
CCA 610/
CCM 610
36473 1775% EL EL N/EL N/EL N/EL N/EL 2568%
Transmission and distribution of electricity
CCA 49/
CCM 49
3988 194% EL EL N/EL N/EL N/EL N/EL 001%
OPEX of Taxonomy-eligible but not environmentally sustainable
activities (not Taxonomy-aligned activities) (A.2)
42376 2062% 2623% 2623% 000% 124% 000% 000% 2757%
A. OPEX of Taxonomy eligible activities (A.1 + A.2)
44683, 2174% 2664% 2664% 000% 124% 109% 000% 278%
B. Taxonomy-Non-Eligible Activities
OPEX of Taxonomy-non-eligible activities (B) 160853,
7826%
Total (A + B)
205 536, 10000%
Proportion of OPEX/Total OPEX
Aligned per objective Eligible per objective
CCM
030% 1999%
CCA 030% 1999%
WTR
000%
000%
CE 000% 093%
PPC 082% 082%
BIO 000% 000%
SUSTAINABILITY STATEMENTS - EU TAXONOMY
Nuclear energy related activities
1
The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative electricity generation facilities that produce energy from
nuclear processes with minimal waste from the fuel cycle
NO
2
The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for the purposes
of district heating or industrial processes such as hydrogen production, as well as their safety upgrades, using best available technologies
NO
3
The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity or process heat, including for the purposes of district
heating or industrial processes such as hydrogen production from nuclear energy, as well as their safety upgrades
NO
Fossil gas related activities
4
The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels
NO
5
The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels
NO
6
The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels
NO
78 DOF INTEGRATED ANNUAL REPORT 2025 78 DOF INTEGRATED ANNUAL REPORT 2025
Identifying IROS
In 2025, a group-wide revision of the double materiality process, in accordance
with the ESRS requirements, was conducted to determine the material impacts,
risks and opportunities within our value chain. Details about IROs connected to our
workforce are provided below.
Own workforce
Throughout the year, DOF engaged with internal stakeholders, including subject-matter experts, HSE
departments, and Executive Management, as well as NGO’s and union representatives, to gather industry
and work group perspectives. In 2025, obtaining information from DOF Denmark employees, who joined
in late 2024, has been essential in assessing the acquisition’s impact, risks and opportunities.
During the process we evaluated our direct operations and value chain to understand material issues that
relate to the workforce across our global scope of operations.
The review included an analysis of employee-related data, employee surveys, labour metrics, health and
safety records, and training. Historical trends, including incidents of work-related injuries or labour disputes,
were also analysed to assess the scale, scope, and likelihood of workforce-related risks.
Action plans and resources to manage our material impacts, risks, and opportunities related to our workforce
are consolidated in our annual Global Improvement Programme (GIP). The GIP is reviewed annually to ensure
we meet or exceed the ambitions defined in our vision and strategic objectives. This programme, along
with the actions and objectives it encompasses, support our ongoing efforts in preventing and mitigating
significant negative impacts.
Social
S1 Own Workforce
The key to our success has always been our people. We are proud of our multi-national team and while challenges ahead
may vary, the importance of our people-factor never changes. An engaged, expert global team, acting with integrity,
has positive benefits for our people, the organisation, and has flow-on benefits for our customers, investors, and supply
chains. We believe a focus on sustainable development, human rights, and fair working conditions fosters an inclusive
working environment. It makes us a safer, more productive, inspirational place to work. One of the most important
tasks of the year was to continue to integrate the employees from DOF Denmark into our shared culture, values
and DOF way of working. The DOF Group Rolling Strategy also aims to create a workspace where people can apply
skills, develop, and unlock their potential in an inspiring, physically and psychologically safe environment.
IROS
MATERIAL IMPACTS,
RISKS AND OPPORTUNITIES
IRO
TYPE
VALUE
CHAIN
AREA
STAKE
HOLDER
PRIORITY
TIME
HORIZON
S1 Own Workforce
Wage and compensation
Compensation expectations may negatively affect DOF’s ability to attract and retain the required competence
AI
Direct
Occupational Health and Safety
High consequence low probability incidents can have fatal or serious consequences for workers
PI
Direct
Security risk
Increased operational activity in areas with high security risk may negatively affect health, safety and wellbeing of DOF
workforce
PI
Direct
Security risk management
Increased operational activity in areas with high security risk requires additional security risk management measures and
resources
!
Direct
Major accident event
DOF may have a major accident event involving multiple personnel
!
Direct
Inclusion and equality
There are perceived or actual barriers to inclusion and equality in a male dominated industry which can have a negative
effect within DOF
AI
Direct
Global availability of resources
The availability of resources and key competencies are becoming limited because of a smaller resource pool
!
Direct
Personnel continuity
Inability to meet competency demands within emerging markets, new technologies and stakeholder expectations
!
Direct
Data security
Exposure to data breaches, cyber attacks and unauthorised access to employee data
PI
Direct
Data privacy compliance
Breach of data privacy legislation may result in significant fines for the organisation
!
Direct
Key
IRO type Impact materiality Financial materiality
PI
Potential impact
AI
Actual impact
!
Potential risk
!
Actual risk
O
Opportunity
Stakeholder priority increasing unchanged decreasing
Time horizon
Short-term Short-to medium-term Medium-to long-term Long-term
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S1-1 Policies related to wage and compensation
Policy Equal Employment Opportunity Policy
Purpose
To support fair and equal treatment for applicants and employees, free association
and collective bargaining Ensures working hour requirements are upheld and fair
compensation for all employees
Key content
Equal opportunity commitments, non-discrimination, inclusion of people with disabilities,
labour rights and standards, and fair working conditions
Covers
All employees, business units and operations
Accountable
CEO
Available
Integrated Management System, Webpage, All DOF Worksites
Works with
CoBC, Human Resources Policy, Global Standard on Recruitment Management
Incorporates
Working hour requirements and timely payment of wages according to national legal
standards or industry benchmarks
Policy
Human Resources Policy
Purpose
Support employees to reach their full potential and ensure employees exemplify our vision
and values
Key content
Recruitment and competence, Equal opportunities and diversity, training and
development and knowledge retention
Covers
All employees, business units and operations
Accountable
CEO
Available
Integrated Management System, Webpage, All DOF Worksites
Works with
CoBC, Global Standard Recruitment Management; Equal Employment Opportunity Policy:
Incorporates
Compliance with local legislation
S1 Own Workforce
Working Conditions
DOF takes its responsibilities as an employer seriously and is committed to providing fair and decent working
conditions for all employees. Ensuring our employees’ rights to decent work and fair pay is crucial to building a
more sustainable future for our company and is a key part of our contribution to UN Sustainable Development Goal
8 (Decent Work and Economic Growth). Material risks and opportunities arising from impacts and dependencies
on our own workforce are included below.
IROs related to the sub-topic of “working conditions” focus on ensuring adequate wages for our workforce We
outline the policies that govern the specific material impacts and risks within our workforce and include policies
that safeguard human rights, as this is closely linked to working conditions.
IROS
MATERIAL IMPACTS,
RISKS AND OPPORTUNITIES
IRO
TYPE
VALUE
CHAIN
AREA
STAKE
HOLDER
PRIORITY
TIME
HORIZON
S1 Own Workforce
Wage and compensation
Compensation expectations may negatively affect DOF’s ability to attract and retain the required competence
AI
Direct
This chapter also covers the disclosure requirements regarding human rights, workforce engagement, remediation
of negative impacts, characteristics of DOF employees, collective bargaining and social dialogue, adequate wages,
social protection, incidents and complaints and relevant policies, actions and targets.
Key
IRO type
Impact materiality Financial materiality
PI
Potential impact
AI
Actual impact
!
Potential risk
!
Actual risk
O
Opportunity
Stakeholder priority increasing unchanged decreasing
Time horizon
Short-term Short-to medium-term Medium-to long-term Long-term
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S1-1 Policies related to human rights
Policy Code of Business Conduct
Purpose
The blueprint for conducting business ethically and responsibly, including human rights,
diversity, zero tolerance for bribery and corruption, transparency, anti-money laundering
laws compliance, and the protection of personal data
Key content
Expectations for safe, legal and ethical behaviour across all operations, requiring
compliance with laws and policies, integrity in business practices, respect for people and
human rights, protection of assets and the environment
Covers
All employees, onshore and offshore worksites, value chain workers and
downstream suppliers
Accountable
CEO, the Board
Available
IMS, Website, All DOF Worksites
Reviewed
Annual management review process
Incorporates /
encompasses
UN Guiding Principles for Business and Human Rights, OECD Guidelines for
Multinational Enterprises and ILO Declaration on Fundamental Principles and
Rights at Work
Policy Business Integrity and Ethics Policy
Purpose
Outlines core values, business conduct and behaviours expected in our companies and
employees to protect and build DOF’s reputation
Key content
Fair and honest commercial dealings, compliance with laws, respect for human rights and
cultures, zero tolerance for bribery and corruption, responsible international operations,
and ethical personal conduct by all
Covers
All employees, business units and operations
Accountable
CEO, the Board
Available
IMS, Website, All DOF Worksites
Reviewed
Annual management review process
Incorporates /
encompasses
UN Guiding Principles for Business and Human Rights and OECD Guidelines for
Multinational Enterprises
Statement
Transparency Statement
Purpose
Promote DOF’s respect for fundamental human rights decent working conditions and
prohibition of acts of modern slavery across our operations. The statement ensures the
public access to information regarding how adverse impacts on fundamental human
rights and decent working conditions are addressed
Key content
DOF’s Human Rights and modern slavery Due diligence process.
Covers
All employees, onshore and offshore worksites, value chain workers and
downstream suppliers
Accountable
CEO, The Board
Available
IMS, Website, All DOF Worksites
Reviewed
Annual management review process to meet June 30th update deadline in accordance
with §5 in “Åpenhetsloven”
Incorporates /
encompasses
UN Guiding Principles for Business and Human Rights, OECD Guidelines for
Multinational Enterprises and ILO Declaration on Fundamental Principles and Rights at
Work, Norwegian Transparency act Statement
Human Rights
DOF upholds human rights and ensures its workforce is treated with dignity and respect. We are committed to fundamental labour rights and adhere to international frameworks and conventions including UN Guiding Principles for Business
and Human Rights, the OECD Guidelines for Multinational Enterprises and the ILO Declaration on Fundamental Principles and Rights at Work and to local legislation where we have operations.
Fundamental labour rights and international framework principles are embedded in our policy framework to mitigate the risk of human rights abuse, including child labour, forced labour and trafficking in our operations and value chain.
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Engagement is conducted in digital and classroom training settings on and offshore. DOF’s inspection and audit
program consist of many one-to-one interviews, allowing direct workforce engagement and participation
Various inclusion and working environment committees convene regularly, with a minimum of four meetings per
year Regular working environment surveys and polls are conducted across different regions Audits and inspections
are ongoing activities, with over 2500 internal audits conducted in 2025 Additionally, vessel visits are carried out
as part of our efforts to engage with the workforce
The different committees engage with the workforce in direct meetings and via regional and local surveys.
The outcomes set the direction for improvement and change in the regional improvement plan and the Global
Improvement Programme.
To provide clarity on how these metrics are generated, internal audits are conducted using DOF’s standardised HSEQ
audit methodology, which includes predefined checklists, structured interviews, document reviews and verification
of corrective actions. Audits are scheduled using a mixture of mandatory requirements and a risk based approach
that considers vessel type, operational profile, incident history and regulatory requirements. Committee meetings
and employee surveys follow a group-wide process. Working environment surveys are conducted anonymously
and digitally to encourage participation across regions. The scope of vessel visits varies depending on operational
activities. Accordingly, these metrics should be interpreted with an understanding that geographical coverage,
participation levels, and local operational constraints.
The underlying records supporting these metrics (e.g., audit logs, committee minutes, working environment
documentation) are periodically reviewed by external bodies such as the Flag State, DNV, and ISO certification
auditors as part of regulatory and certification audits. However, these bodies do not independently validate the
numerical metrics reported. Therefore, these metrics have not been externally validated beyond the assurance
provider.
Workforce perspectives shape decision-making
Workforce perspectives are integral to the decision-making processes, particularly in managing the actual and
potential impacts on its employees. This commitment is reflected in our adherence to the Maritime Labour Convention
(MLC) 2006 and our collective bargaining agreements with trade unions representing seafarers.
Maritime labour compliance
The Maritime Labour Convention Certificate (MLC Certificate) is issued by the flag state after verifying compliance
with MLC standards. Verification is performed regularly by class authorities. Complying with the MLC 2006 ensures
seafarers’ rights to decent working conditions are upheld. The Declaration of Maritime Labour Compliance (DMLC)
mandates regular consultations with seafarers, allowing their perspectives to be heard and considered in decisions
affecting their work environment and rights.
Collective bargaining agreements
We have established collective bargaining agreements that represent our seafarers. These agreements facilitate
ongoing dialogue and feedback, ensuring that the workforce’s views are integrated into our policies and practices.
Regular meetings, surveys, and feedback sessions are conducted to gather insights from the workforce.
S1-2 Processes for engaging with own workforce and workers representatives about impacts
Employee feedback is essential in building a workplace that meets the diverse needs of our workforce and fosters
a thriving environment. We integrate employees’ perspectives into the decision-making processes and policies
development, actions, metrics, and targets. This approach is applied retrospectively and proactively in the
development and implementation of workforce-related policies.
Employee Surveys
In 2025 we conducted a comprehensive global employee survey aimed at measuring employee engagement and
gaining insights into key areas such as Satisfaction & Motivation and Employee Loyalty. The insights assist our
management teams to maintain and enhance employee engagement and performance levels. The survey was
accessible to all permanent employees with a minimum tenure of three months.
We received a 71% response rate with more than 3400 employees completing the survey. The results show
consistency with 2024 findings. The highest-scoring engagement drivers are again cooperation, job content, and
health and safety — showing consistency in what employee’s value most at DOF.
All managers are responsible for their own team and department results and for creating team and department
action- plans. The Executive Management team and regional management are responsible for creating strategic
focus areas and action plans for the group and regions. The outcome and actions from the employee survey is also
reflected in the Global Improvement Programme that is announced the following year.
In 2025 all employees were also invited to participate in a culture survey program. The purpose of the survey was
to gain a better understanding of DOF’s safety culture across regions and workplaces. The results will later be used
to tailor specific training and focus areas for employees, depending on the cultural challenges and opportunities
that their specific work environment has.
Accountability
The EVP People & Organisation is responsible for oversight of the process related to workforce engagement.
Regional management and local HR are responsible for monitoring the actions in response to the survey and
evaluate the effectiveness of implementation.
The culture survey programme is initiated by HSEQ and the Global HSEQ Lead is responsible for the global response
rate and facilitating action plans to be initiated based on the results.
Other types of engagement
Other engagement activities relating to both negative and positive impacts on all aspects of the working environment
are managed within DOF’s global structure. Many of our regional offices have dedicated safety delegates, working
environment committees, and employee representatives. The establishment of such bodies is mandatory in
many countries, and DOF strives to implement these practices across its global operations. Additionally, there
are requirements through flag states that vessels have their own PEC (Protection and Environment Committee).
Employees are encouraged to submit concerns, ideas, and suggestions for improvements to the working environment
committee, ensuring ongoing dialogue about working conditions.
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Though we have many processes in place to promote this channel, the 2025 employee survey response revealed
that 9% of our employees does not know where they can report harassment or other critical conditions. From
2024 to 2025 we have had an increase in number of employees and it is clear that we need to continue to focus
on promoting this channel to make employees aware of and confident in the grievance procedures we have in place.
Our Code of Business Conduct and our Quick Guide to the Ethics Helpline is available for all employees and states
that: Our Non-retaliation policy strictly prohibits acts of retaliation or harassment against any person who has
raised a concern in good faith, or anyone who participates in an investigation. This means you may raise concerns
without fear of your employment being negatively affected. Our commitment against retaliation protects anyone
who makes a report in good faith, even if you are found later to be mistaken.
All issues raised are taken seriously, all reports are treated with the utmost sensitivity, and confidentiality is
protected as far as possible. When a grievance is received, we conduct a due diligence process to collect facts
about the case, and when verified, we seek to remedy any adverse impacts. The type and nature of remedial action
will depend on the nature of the impact.
An alternative course is to raise complaints directly with supervisors, a senior member of staff, a human resources
manager or a member of the legal department. All complaints are dealt with, and the involved parties are consulted.
DOF’s organisation is matrix based, which means the people and organisation function can help with complaints
related to employee matters, as it is a separate function and does not operate as an employer. The people and
organisation team seek to ensure an investigation is dealt with in proper manner. The complaints may range from
quite straight forward conflict resolution to more serious accusations and complaints.
Complaints and grievances are handled under local standard procedures, as described in regional/local employee
handbooks or procedures available on the Integrated Management System/DOF Portal. These guides and procedures
include anti-bullying procedures, onboard complaints handling, workforce violence and harassment policies and
unacceptable conduct forms.
Grievances and complaints may also be addressed and reported through employee representatives/safety
representatives, via the unions, under the collective bargaining agreements, or Employee representatives elected
to the work environment committees. Regular meetings are held with union representatives and members of the
Work Environment Committees.
The MLC 2006, the IMO and ISO Certificates all require DOF to have complaints procedures in place. Our Onboard
Complaint Procedure is available for offshore workers, and describes the steps to file a complaint. The procedure
includes a formal complaint form and it strictly prohibits victimisation of the seafarer filing a complaint. There are
Dedicated Person Ashore roles, globally, that ensure seafarer cases are followed up.
The working environment committee issues yearly reports evaluating various aspects of its duties including workforce
grievance /complaints possibilities and improvements
Compliance officers produce a yearly report including the effectives of the ethics helpline.
DOF has established a channel to receive inquiries about human rights violations. This channel is referred to in our
transparency act statement and is not limited to our employees but available for all to ask or report human rights
violations in our value chain. In 2025 no inquiries were received through this channel.
Implementation and impact
The feedback mechanisms in place enable us to gather valuable insights from our workforce. These insights are
used to inform our decisions and activities, particularly those related to managing the impacts on our employees.
For example, based on workforce feedback, we have implemented enhanced safety protocols and improved
onboard living conditions.
Diverse strategies for understanding vulnerable workforce perspectives
A different approach is taken to gain the perspectives of people particularly vulnerable to impacts or marginalised
in our own workforce.
In 2025, DOF continued the Fifty-fifty programme - which is based on the UN Sustainable Development Goal 5
“Gender Equality” and brings women together from Norwegian and international companies to learn and share best
practices on how to improve gender balance in leadership positions, which also support DOF’s approach to mitigate
the Impact related to inclusion and equality. Participants from the programme propose annual recommendations
to the Executive Management team, such as setting-up diversity and inclusion committees, organising awareness
activities, and advocating for inclusive workplace practices Additionally, unconscious bias training sessions have
been ongoing. A global Diversity Equity and Inclusion committee was established in 2024. The committee focuses
on gaining insight into the perspectives of people in our workforce that may be particularly vulnerable.
The CEO has ultimate responsibility, however, in practice, it is the People and Organisation and HSEQ managers
globally that undertake the day-to-day management and inform our approach to engagement.
S1-3 Processes to remediate negative impacts and channels for own workforce to raise
concerns
Grievance/complaints mechanism
Our comprehensive grievance mechanism allows all internal and external stakeholders to report concerns and
complaints via our ethics helpline. The system is operated by a third party to ensure the confidentiality and the
psychological safety of individuals. The majority of complaints and grievances are handled through the ethics
helpline, and any report can be made anonymously or with an open reporter identity. All reports are investigated
at the highest level in DOF, by qualified, guaranteed impartial team. See S1-17 for more information on incidents
and complaints reported in 2025.
We ensure all employees are informed about and can effectively use this channel; we have integrated the grievance
mechanism into management touchpoints and throughout the onboarding process. The Ethics Helpline is readily
accessible through our portal and management systems, as well as on our website. It is standard in the onboarding
process to introduce the ethics helpline to new employees. The ethics helpline is also covered in the mandatory
CoBC e-learning module. Additionally, the CoBC is part of the welcome pack for all employees and available on-
board our vessels.
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our employees. This awareness supports the development
of our Global Improvement Programme and the actions
and objectives set up in the programme supporting
the continuous work on prevention and mitigation of
material negative impacts.
S1- 4 Taking action on material impacts on
own workforce, and approaches to managing
material risks and pursuing material
opportunities related to own workforce, and
effectiveness of those actions
Working conditions
The actions taken to meet compensation expectations
and attracting and retaining required competence relies
on the resources working under the EVP People and
Organisation. The People and Organisation department
is entrusted with the formulation of the action plans on
an annual basis to address these challenges. However,
their successful implementation is contingent upon
the collaboration and active participation of the entire
organisation in integrating these processes into their
daily operations.
Actions under working conditions:
Attracting and retaining employees with the required
competence is crucial for DOF. Ensuring that our
employees feel valued and receive fair, competitive
compensation, within applicable regulatory requirements,
is therefore essential. The necessary and appropriate
actions in response to the risks identified under “working
conditions” are initiated by the People and Organisation
function, based on feedback from employees and their
values, and trends in the market.
S1- 4 Actions taken on material impacts
Action plans and resources for managing our material
impacts, risks, and opportunities related to our workforce
are consolidated in our annual Global Improvement
Programme (GIP).
Every objective and action listed in our GIP is assigned
an accountable and a responsible resource; however, the
completion of these actions and objectives may require
contributions from multiple resources. The activities
are tracked and monitored through a business tool
application designed to manage objectives, processes,
and activities.
Annually, the double materiality assessment provides
a comprehensive overview of DOF’s material topics.
These topics are linked to the impacts, risks, and
opportunities we encounter, guiding the company’s
focus and necessary actions to mitigate potential
impacts and risks. Each function suggests actions
to address the outcome of the double materiality
assessment, and suggested actions are presented in
the Global Improvement Programme. The action plan
or improvement plan is approved by the CEO and is
published annually on the DOF Portal.
DOF ensures our practices do not cause or contribute
to material negative impacts to our own workforce by
upholding to the company values: SAFE the RITE (Respect,
Integrity, Teamwork and Excellence). The values are
supported within our integrated management system
through policies, guidelines, manuals and standards
that provide the highest safety standards and protect
employees. Our integrated management system, in
combination with our entity specific occupational health
and safety targets, allow us to continuously monitor,
detect trends and implement mitigating measures.
Conducting annual employee surveys and double
materiality assessments give us a more complete
understanding of the impacts we as a company have on
KEY ACTION
Adequate Wage
Position grading and mapping: Korn Ferry job evaluation is a system
for ranking positions logically and fairly, to determine the relative
weight of a position in an organisation. Korn Ferry job evaluation is
the world’s, and Norway’s, most widespread method for weighting
positions. Korn Ferry operates with four employee groups to cover
the various reference levels. These groups are applied for the salary
mapping in DOF for benchmark purposes. The groups are classified
into three categories: Staff, Managers/Seasoned Professionals and
Senior Managers/Executives. Each group covers a range of four
to eight Korn Ferry reference levels. External salary benchmark
reports are used during salary settlements to ensure fair and marked
adjusted pay. The company has an annual review of all eligible salary
placements in connection with yearly salary settlements.
SCOPE OF ACTION
Covers all eligible positions within the company
CORRESPONDING POLICY
Equal Opportunity Policy:
• Pay wages in-full and on time using national legal standards or
industry benchmarks as a minimum requirement
PROGRESS
Ongoing, with reviews during salary settlements
TIME HORIZON FOR COMPLETION*
Long-term
KEY ACTION
Adequate Wage
Together with Slave Free Alliance, DOF produces a yearly report with
information on minimum and living wage benchmarks in all countries
where we have operations and employees.
This report is used as a tool to assist in verifying that all employees
are paid an adequate wage.
Since these numbers fluctuate and are dynamic in many areas of
the world, it is important to continue to map what is considered a
living and minimum wage to be confident that we offer fair wage
accreditation for our own employees going forward.
SCOPE OF ACTION
Covers all countries of operations associated with Own Workforce
CORRESPONDING POLICY
Equal Opportunity Policy:
• Pay wages in-full and on time using national legal standards or
industry benchmarks as a minimum requirement
PROGRESS
Performed Annually.
Complete for 2025
TIME HORIZON FOR COMPLETION*
Short-term
KEY ACTION
Flexible Work Arrangements
Flexible work options are available for our onshore employees’. Regular
surveys validate that hybrid working arrangements contribute to better
work-life balance, without compromising people’s work performance.
SCOPE OF ACTION
Hybrid working arrangement is available for all onshore employees in
all regions as a permanent arrangement allowing up to two weekdays
as home office
CORRESPONDING POLICY
HR Policy:
• Endeavour to meet individual needs in the workplace to ensure a
mutually beneficial work relationship, encouraging employees to
maintain a work life balance,
• Continually striving to make DOF a great place to work by
improving the work environment, recognising and rewarding
excellence, encouraging individual development, removing barriers
to change and promoting innovation and foster work collaboration
PROGRESS
Application form available for employees via employee handbook
TIME HORIZON FOR COMPLETION*
Long-term
*Short-term (1 year), medium-term (2-5 years), and long-term (5+ years) horizons
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TABLE 1 Number of employees (headcount)
2025 2024
Total employees* 5487 4744
Male 4670 4002
Female 817 742
*Total number of employees excluding non-employees using end of year numbers
Data collection
Employee-related data for CSRD is collected by each region, per legal entity, using their respective source systems.
At group level, Corporate consolidates HR data on a monthly basis. The consolidated dataset consists of a
combination of automated data integrations and manually reported data. Automated datasets include predefined
logic and calculations used to generate KPIs and metrics.
During 2025, efforts have been made to increase the number of entities reporting through automated integrations.
However, a significant share of the reporting remains based on manual submissions.
TABLE 2
Number of employees (headcount)
2025
2024
Angola 87 98
Argentina 34 43
Australia 749 278
Brazil 2164 1807
Canada 324 265
Denmark 524 597
Ghana 2 2
Indonesia 3 3
Mexico 9 47
Norway 982 914
Philippines 72 69
Singapore 188 335
United Kingdom 200 152
United States 149 134
Total 5487 4744
Note: Employees excluding non-employees,
S1-5 Targets related to managing material negative impacts, advancing positive impacts, and
managing material risks and opportunities
DOF sets rolling targets to monitor working conditions. In 2025, voluntary turnover is targeted to be kept at 7%
or less for workforce stability, and a rolling average of 80% on performance review completion target to ensure for
adequate feedback loops throughout the organisation.
These targets directly support DOF’s People and Working Environment policy objectives by promoting workforce
stability, strengthening employee engagement, and ensuring continuous performance dialogue across the organ-
isation. The scope of these targets covers DOF’s own workforce, including both onshore and offshore employees;
non-employees such as contractors are not included in the calculation of voluntary turnover or performance review
completion rates. These are rolling operational targets that DOF maintains annually rather than fixed-duration
strategic targets. As such, no formal base year or baseline value is applied.
By year-end, voluntary turnover was 7.7%, and performance review completion was 69%.
In addition, we track the effectiveness of our actions related to this target based on feedback from employees,
employee surveys, retention and turnover analysis, and by engaging with external benchmarking reports and
industry standards.
S1-6 Characteristics of DOF’s employees
We define the workers in our workforce as employees who are in an employment relationship with the undertaking,
and non-employees who are either individual contractors supplying labour to the undertaking, such as self-employed
people, or people provided by undertakings primarily engaged in “employment activities”.
In 2025, our employees consisted of 1000 onshore, 1207 offshore and 3280 marine employees, located across
the globe, spread among our core regions: Atlantic, Asia-Pacific, North America and South America. The total
employee turnover rate was *12.7% and 591 employees left during the reporting year. The tables below provide
more details about the make-up of our workforce.
2025 2024
*Employee turnover rate 127 1244
Number of employees who left 591 433
*Includes: resignation, pension, end of contract and redundancy.
The employee turnover rate is calculated as the number of total leavers in the company relative to the average
number of permanent employees in the financial year.
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Data collection
Non-employee data—including agency workers, contractors,consultants, and third-party workers—is collected
regionally, per legal entity, and consolidated at the group level. Classification is based on employment relationship.
For HR KPI reporting, DOF uses a consolidated dashboard reflecting contractor activity or hours for each month.
For CSRD reporting, regional entities report point-in-time headcount as of 31 December 2025, rather than
monthly usage.
Internal HR KPI reporting groups casual workers and contracted personnel together as “contracted workforce,” so
all types of non-employee arrangements are not fully differentiated; this category may include various contractual
conditions, such as non-guaranteed hours. Both datasets use the same source systems but differ in methodology
by reporting purpose.
The growing number of non-employees in 2025 compared to 2024, reflects increased project activity across
all regions.
S1-8 Collective bargaining and social dialogue
74% of our employees are covered by collective bargaining agreements. There is more than one collective bargaining
agreement covering our workforce, and differences vary between countries. These figures exclusively represent
employees and exclude non-employees.
Collective bargaining coverage Social dialogue
Coverage rate
Employees – EEA
*By country
Employees Non-EEA
*By region
Workplace representation - EEA
*By country
0-19% Atlantic (Minus EEA)
20-39% Denmark
40-59% Denmark North America, Asia Pacific
60-79%
80-100% Norway South America Norway
S1-10 Adequate wages
All employees receive a fair and adequate wage. The company has conducted a comprehensive mapping exercise,
examining the minimum wages in the countries where we operate, and ensured that the wages provided are above
these thresholds. DOF ensures wages are paid in full and on-time, using national legal standards or industry
benchmarks as a minimum requirement. Our broader policy framework ensures working hour requirements are
upheld and fair compensation for all employees.
S1-11 Social Protection
As of 2025, the majority of DOF employees are covered by social protection against income loss for sickness,
unemployment (from start of employment), employment injury/acquired disability, parental leave, and retirement,
through statutory systems and/or employer benefits. Coverage is not yet universal across all geographies.
Deviations from 2024
The total number of employees increased by 743 from 2024 to 2025.
A part of this increase is related to the acquisition of DOF Denmark and the integration of vessels and associated
workforce following the transaction. The transfer of vessels into the DOF fleet required recruitment and onboarding
of crew in several regions.
By country we see increased workforce in most areas, especially in Brazil where we had the highest operational
activities and increase driven by vessels transferred to the Brazilian fleet, which required recruitment of Brazilian
crew in accordance with local regulations.
We also see an increase in Australia, however, the gap is mainly due to incorrect entity reporting for DOF Singapore
in 2024, where the majority of the employees should be reported under Australian legal entities.
In Mexico we see a reduction due to the scaling down of activities.
TABLE 3 2025 2024
FEMALE MALE TOTAL FEMALE MALE TOTAL
Number of employees (headcount) 817 4670 5487 742 4002 4744
Number of permanent employees (headcount) 734 3950 4684 674 3546 4220
Number of temporary employees (headcount) 38 141 179
37 156 193
Number of non-guaranteed hours employees (headcount) 45 579 624 31 300 331
Non-guaranteed hours.
Non-guaranteed hours are employment arrangements without fixed contracted hours, offering flexibility to meet
operational needs. At DOF, these contracts help manage workforce demand fluctuations, especially in regions
with variable project work. In the maritime and offshore industry, flexible contracts allow staffing to match project
cycles and client requirements while ensuring access to skilled personnel.
S1-7 Characteristics of Non-employees in own workforce
In addition to employees, our workforce is comprised of 866 “non-employees”. This number is comprised of self-
employed workers, independent contractors, freelancers and personnel provided by staffing or manning agencies.
2025 2024
Total number of non-employees 866 696
Numbers indicate headcount as of 31.12.2025. The headcount per region is reported to the corporate function
and consolidated into one report for the entire group.
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The sections below identify the countries and types of employees where coverage gaps exist:
Angola: Employees are not protected against unemployment.
Ghana: Employees are not protected against unemployment.
Singapore: Employees are not protected against unemployment.
USA: Employees does not have paid parental leave.
S1-17 Incidents, complaints and severe human rights impacts
In 2025, we received a total of 96 complaints through our various grievance mechanisms, and 23 of the cases
were incidents of discrimination and harassment. Of which, 87 were raised via the whistleblowing system and
the remaining cases from HR or DPA channels. Among the incidents reported via the ethics helpline, 32 were
substantiated and resulted in disciplinary action, training or review of policies. Seven (7) cases led to dismissal.
Collecting data on severe human rights incidents, discrimination and harassment incidents, and complaints,
including fines, penalties, and compensation involves multiple sources and steps to ensure accuracy. We use
the Ethics Helpline, legal representatives, human resources and Dedicated Persons Ashore (DPAs) to gather
comprehensive data. The Ethics Helpline allows for reports of all cases made through our grievance mechanism,
legal representatives ensure thorough documentation of legal issues, including fines and penalties. Collaboration
with Dedicated Persons Ashore adds another layer of validation, ensuring our data is reliable and that all cases
are captured. After gathering and verifying information, it is consolidated into a single dataset. By continuously
improving our grievance mechanisms, we aim to uphold high ethical standards and protect human rights.
In DOF we analyse all cases that come through our ethics helpline and classify their severity. Severe incidents
are classified as cases that are substantiated and show a breach to our code of conduct and ethical values, and
severe human rights incidents are cases where human rights have been substantiated and proven to violate or
impact human rights in our value chain. There were no reported severe human rights incidents, nor did we receive
any complaints through the National Contact Point for OECD Multinational Enterprises. There were no significant
fines or monetary sanctions related to workplace discrimination, complaints, or severe human rights incidents
under the jurisdictions where DOF operates during the year.
2025 2024
Severe human rights incidents connected to workforce 0 0
Total amount paid in fines, penalties and compensation for damages 0 0
Incidents of discrimination & harassment 23 17
Complaints filed through grievance / complaints mechanisms 96 41
The cases reported for 2025 are severe incidents or complaints that have formally been reported via one of our
channels for raising concern
In addition to our established grievance mechanism, DOF conducted a comprehensive employee engagement
survey in 2025. This survey was administered by a third party and was anonymous. It provided our employees
with the opportunity to respond to questions about their experience of any incidents of sexual harassment and
bullying in the workplace.
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S1-1 Policies related to own workforce - occupational health and safety
Providing employees with a safe working environment and ensuring the health and safety of our employees
is our highest priority. The mechanisms to monitor compliance with international instruments are described
in S1-1 Working Conditions.
Policy Health, Safety and Working Environment Policy
Purpose
To manage a safe and healthy working environment
Key content:
Commits DOF to provide a safe and healthy workplace by systematically
identifying and reducing risks, aiming for an incident free organisation
through strong safety systems, legal compliance, worker participation,
continuous improvement, and a culture where health and safety are equal
to all other business objectives.
Covers
All onshore and offshore worksites and all individuals present on our sites
Accountable
CEO
Available
IMS, Website, All DOF Worksites, Occupational Health and Safety
e-learning module
Works with Policy Documents
CoBC , SCoC, Security Policy
Certified
ISO 45001 and BMS under ISO 45001:2018
Supports IRO:
Occupational Health and Safety
Major accident event
Policy
Security Policy
Purpose
To manage safety and protect personnel, physical assets, and intellectual
property
Key content
DOF’s Security Policy commits the Group to protecting its people, assets
and intellectual property by implementing effective physical, operational
and cyber security measures, prioritising employee safety, managing
security risks and incidents, and ensuring compliance with international
security standards such as the ISPS Code
Covers
All onshore and offshore worksites and all individuals present on our sites
Accountable
CEO
Available
IMS, Website, All DOF Worksites
Works with Policy Documents
CoBC , SCoC
Supports IRO:
Security risk
Security risk management
S1 Occupational Health and Safety
DOF puts health and safety first and strives for zero harm to our people, contractors and suppliers.
Through standard operations, personnel working for or on behalf of the organisation are exposed to occupational
health and safety hazards as an inherent part of activities. DOF has a duty-of-care to manage safety for personnel
in our operations and on our worksites. During the year one of our most important tasks was to continue to
integrate all employees from DOF Denmark safely into DOF practice. Introducing a large group of new employees
into the company stressed the importance of good culture, values and a comprehensive and supportive integrated
management system.
Health and safety incidents can cause negative outcomes for affected individuals, such as injuries. Negative
outcomes for our employees’ wellbeing can in turn affect the company’s reputation and performance. Managing
these risks effectively and maintaining a strong safety performance underpins our operations as it is essential to
our ability to recruit and retain a productive workforce and maintain our reputation with all stakeholders.
IROS
MATERIAL IMPACTS,
RISKS AND OPPORTUNITIES
IRO
TYPE
VALUE
CHAIN
AREA
STAKE
HOLDER
PRIORITY
TIME
HORIZON
S1 Own Workforce
Occupational Health and Safety
High consequence low probability incidents can have fatal or serious consequences for workers
PI
Direct
Security risk
Increased operational activity in areas with high security risk may negatively affect health, safety and wellbeing of DOF
workforce
PI
Direct
Security risk management
Increased operational activity in areas with high security risk requires additional security risk management measures and
resources
!
Direct
Major accident event
DOF may have a major accident event involving multiple personnel
!
Direct
Key
IRO type Impact materiality Financial materiality
PI
Potential impact
AI
Actual impact
!
Potential risk
!
Actual risk
O
Opportunity
Stakeholder priority increasing unchanged decreasing
Time horizon
Short-term Short-to medium-term Medium-to long-term Long-term
Workforce in greater risk of harm
Our health and safety reports and analysis show that the incidents or near misses that occur, and are classified as
serious, more often impact deck workers, engineers, AB (Able Seaman) and electricians who are involved in anchor
handling operations and heavy lifting. This workforce is identified to be at greater risk of health and safety risks and
impacts than other groups onboard. In addition, the potential negative impact associated with operating in locations
with a high-security risk can affect employees working in these areas of the world. Even though these areas can
be dynamic, DOF has good systems to monitor and implement necessary security measures to mitigate the risk.
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Our integrated management system helps embed a culture of safety across all our operations. This covers all workers,
both contractors and employees, onshore and offshore. The management system is certified for Occupational
Health and Safety. The system covers workplace accident prevention policies, manuals, standards and guidelines
as tools for our workforce, and a robust HSE incident reporting software for reporting, follow-up and analyse of
all workplace incidents.
Regional HSEQ managers are responsible for health and safety in their locations and are supported by their regional
HSEQ teams, and report to the global HSEQ function. The global HSEQ Lead reports directly to the CEO, however,
the development of a robust safety culture is a continuous focus for all levels of management. All incidents are
escalated to group management level for information and guidance purposes.
S1-4 Actions under Health and Safety:
Health and safety has been a material consideration since the company’s establishment in 1981. The actions
relate to impacts and risks based on health and safety metrics and incident trends analysis. New actions may
be implemented throughout the year to address specific incidents or trends. Many actions set during the year,
such as health and safety campaigns, safety themes, and emergency response training, are predetermined but
with adaptable content, allowing DOF to respond to trends and identified risks and impacts throughout the year.
The actions taken to meet the health and safety risks rely on management teams across all worksites and are
supported by regional and corporate HSEQ departments. The functions are responsible for developing action plans
annually to meet these challenges, but it is a collective responsibility for all employees, onshore and offshore, to
complete and follow the actions required to make DOF a safe place to work.
KEY ACTION
Health and Safety Campaigns
In Q2 DOF established a “5+2+1=Zero’ campaign” to share focus and
awareness on the importance of taking the time needed for safety,
for yourself and for your colleagues to mitigate any health and safety
risks before starting a job.
SCOPE OF ACTION
Global Fleet
CORRESPONDING POLICY
Health, Safety and Working Environment Policy:
• Promote and maintain a working culture which empowers all
personnel to achieve best practice and performance in Health
and Safety through management communications and training
programs,
• Encourage all personnel to use products and technical solutions
with the least impact to their health and environment,
• Openly communicate and share Health and Safety experiences with
all personnel, industry organisations and the wider community
PROGRESS
Complete in 2025
TIME HORIZON FOR COMPLETION*
Short-term
KEY ACTION
Health and Safety Campaigns
Throughout the year, the HSEQ department produced and published
monthly safety themes These videos and presentations focused on
health and safety trends within the company and highlighted areas that
required increased awareness or improvement To enhance usability, we
developed these presentations as user-friendly videos, making them
easier to learn from and utilise in HSE meetings onboard the vessels
Each month this feedback is considered in global HSEQ meetings where
new and relevant themes are discussed and set for the coming months
Reported accidents are analysed to evaluate if these measures have
affected the injury or accident rates
SCOPE OF ACTION
Across DOF Fleet and Worksites
CORRESPONDING POLICY
Health, Safety and Working Environment Policy:
• Promote and maintain a working culture which empowers all
personnel to achieve best practice and performance in Health
and Safety through management communications and training
programs,
• Openly communicate and share Health and Safety experiences with
all personnel, industry organisations and the wider community
PROGRESS
Complete for all months in 2025
TIME HORIZON FOR COMPLETION*
Long-term
KEY ACTION
Improvement of Occupational Health and Safety
management system
In 2025, DOF Improved its Occupational Health and Safety
management system to reduce complexity and bureaucracy. The
system has been made easier to operate and navigate for crew
members onboard to retrieve correct and accurate information. By
utilizing electronic tools for issuing permits to work, toolbox talks,
and checklists, the safety work has become more dynamic and less
bureaucratic with increased quality in execution
SCOPE OF ACTION
Organisation wide
CORRESPONDING POLICY
Health, Safety and Working Environment Policy:
• Implement and maintain OHSAS 18001 / ISO 45001 compliant
Health and Safety Systems,
• Ensure Health and Safety systems are provided and maintained,
considering the continued need to protect personnel, assets and
the environment,
• Encourage all personnel to use products and technical solutions
with the least impact to their health and environment
PROGRESS
Completed in 2025
TIME HORIZON FOR COMPLETION*
Short-term
KEY ACTION
Monitoring and cooperation on security risks
DOF is continuously working closely with its partners, Risk Intelligence,
DNK, and International SOS, to prevent incidents in high-risk areas
where security risks may negatively affect the health, safety, and well-
being of the DOF workforce. Their tools help us monitor and evaluate
risks on a 24/7 basis and provide immediate assistance in case of
emergency. It also helps us be proactive and take necessary safety
actions before entering high-risk areas.
SCOPE OF ACTION
Organisation wide
CORRESPONDING POLICY
Health, Safety and Working Environment Policy, Security Policy:
• Consider all accidents, incidents and occupational illnesses to be
preventable,
• Implement and maintain OHSAS 18001 / ISO 45001 compliant
Health and Safety Systems,
Ensure Health and Safety systems are provided and maintained,
considering the continued need to protect personnel, assets and the
environment
PROGRESS
Continuous monitoring and cooperation with partners
TIME HORIZON FOR COMPLETION*
Long-term
KEY ACTION
New emergency response system
In 2025 DOF implemented a new emergency management tool. The
tool improved the way DOF is handling any major incident event and
stakeholder expectations
SCOPE OF ACTION
Organisation wide
CORRESPONDING POLICY
Health, Safety and Working Environment Policy, Security Policy:
• Implement and maintain OHSAS 18001 / ISO 45001 compliant
Health and Safety Systems,
• Ensure Health and Safety systems are provided and maintained,
considering the continued need to protect personnel, assets and
the environment,
• Encourage all personnel to use products and technical solutions
with the least impact to their health and environment
PROGRESS
Fully implemented in 2025
TIME HORIZON FOR COMPLETION*
Short-term
KEY ACTION
Emergency Management
Emergency response training exercises range from a variety of
offshore scenarios to more universal themes of business continuity for
DOF to ‘Stress Test’ and improve where necessary
SCOPE OF ACTION
Encompasses global operations and fleet
CORRESPONDING POLICY
Health, Safety and Working Environment Policy, Security Policy:
• Implement and maintain OHSAS 18001 / ISO 45001 compliant
Health and Safety Systems
• Ensure Health and Safety systems are provided and maintained,
considering the continued need to protect personnel, assets and
the environment,
• Monitor health and safety performance and address deficiencies
were identified
PROGRESS
Ongoing, as part of Integrated Management System.
During the year, there were over 10000 drills performed on our
vessels and over 80 performed level 2 exercises logged in our
emergency management system.
TIME HORIZON FOR COMPLETION*
Long-term
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KEY ACTION
Global survey – “Safemind”
The SafeMind Culture Survey Program conducted by Sayfr. The
purpose of this survey is to gain a better understanding of DOF’s
safety culture. The results will provide valuable insight and provide
foundation to continue working on the DOF Culture in 2026 and
beyond.
SCOPE OF ACTION
Organisation wide
CORRESPONDING POLICY
Health, Safety and Working Environment Policy:
Promote and maintain a working culture which empowers all personnel
to achieve best practice and performance in Health and Safety
through management communications and training programs,
Openly communicate and share Health and Safety experiences with
all personnel, industry organisations and the wider community
PROGRESS
Conducted in Q4 2025
TIME HORIZON FOR COMPLETION*
Short-term
*Short-term (1 year), medium-term (2-5 years), and long-term (5+ years) horizons
Aligned with the reporting year, by end-of-year, we measure whether the targets have been achieved. Additionally,
we monitor progress throughout the year using a rolling average to track development and ensure continuous
improvement.
There was an increase in incidents throughout the fleet and by end-of-year we were above some of our health and
safety targets, including lost time injuries, recordable and first-aid cases. The trend suggested an increase in incidents
that occurred as a result of routine and high frequency activities. Investigation to understand the root cause of
the increase was conducted. The results of the investigation form the foundation for mitigating actions in 2026.
During 2024, while evaluating health and safety targets, DOF concluded further focus should be placed upon
high-potential-near-miss incidents. We considered targets to miss important information regarding incidents
classified as serious. Many of our targets capture the overview over our incidents but did not look specifically
at the incidents that score high on the risk register. In 2025, DOF introduced the new target “Serious Incident
Frequency” to capture these cases. For calculating the SIF,Serious Incident Frequency, only serious incidents and
near misses with actual/potential consequence to people and/or environment are included.
S1-14 Health and Safety metrics
Workers covered by an occupational health and safety management system
All workers on vessels and worksites are covered by the Occupational Health and Safety management system.
This includes both employees and non-employees. Our integrated management system is audited yearly and every
third year recertified by DNV, to the ISO 45001 standard certification. Under the ISO certification, DNV conducts
interim audits every year to ensure the company is still in compliance and a more comprehensive recertification
audit conducted at three-year interval.
There were no fatalities due to work-related injuries and work-related ill health in the year There were 29 recordable
work-related accidents, and the rate of accidents was 2.03.
KPI 2025 2024
% workforce covered by H&S management system 100% 100%
Number of fatalities 0 0
Number of recordable injury** 29 32
Recordable injury rate*
11 203 29
* Equivalent to Total Recordable Injury Rate (TRIR)
** A recordable accident at DOF is any work related injury that results in: lost time, restricted work, or medical treatment, or fatality or permanent
disability.
S1-5 Targets related to managing material negative impacts, advancing positive impacts, and
managing material risks and opportunities
HSEQ Targets set to manage material impacts and risks
OHS Input/Outputs Base year Unit of measurement
Global Targets - 2025
Metrics
Performance 2025
Number of LTI’s 2025 Number 0 13
Lost Time Injury Frequency Rate
(LTIFR) 2025 LTIs per million man-hours
< 03 / 1 000 000 man-hours 091
Total Recordable Injury Rate (TRIR
= LTI, RWC, MTC) 2025 TR per million man-hours
< 11 / 1 000 000 man-hours 203
First Aid Cases 2025 FACs per million man-hours < 75 / 1 000 000 man-hours 89
Serious Incident Frequency (SIF) 2025 SIF per million man-hours < 1 / 1 000 000 man-hours 07
Physical Security Incidents (# of
actual or high potential security
breaches) 2025 Number <1 0
0 Incident close out-rate 2025 % of closed out 90% closed within 90 days
899% (Excl. Safety Observation
Cards (SOB)
612% (Incl. SOB)
Emergency Response Exercises -
Level 2 logged in UniSea 2025 Number 2 per Region per year
All regions have conducted more
than two exercises
Management Visits (digital or
physical presence logged in
UniSea) 2025 Visits per 200000 man-hours 5 visits / 200 000 man-hours
77
The targets align with the objectives listed in our health, safety and working environment policy, are entity specific,
set by the HSEQ function and based on industry standards. Approved by the CEO, the targets are displayed in
our Global Improvement Programme, and any concern about the targets can be communicated or reported via our
different grievance mechanisms. All employees and non-employees are covered by these targets.
The targets and their value of measurement are evaluated during the annual management review and are monitored
through our Health and Safety Management system, and Power BI reports, which allow us to identify if progress
is in line with the targets, analysis of trends, and significant variance to achieving the target.
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S1 Equal Treatment and Opportunities for All
DOF strives to promote a workplace where all are treated fairly, accepted equally, without exclusion, in a harassment-
free workplace. We are committed to equal opportunity and equal pay; recruiting, training and developing a diverse
workforce where everyone can succeed.
With employees in more than 15 countries and most working on vessels in remote locations, ours is a large and
diverse workforce in conditions with the potential for unequal or unfair treatment. DOF works to ensure employees
are included and have a strong sense of belonging. Our training and skills development programme plays a role in
attracting and retaining the talent we need to meet our goals.
IROS
MATERIAL IMPACTS,
RISKS AND OPPORTUNITIES
IRO
TYPE
VALUE
CHAIN
AREA
STAKE
HOLDER
PRIORITY
TIME
HORIZON
S1 Own Workforce
Inclusion and equality
There are perceived or actual barriers to inclusion and equality in a male dominated industry which can have a negative
effect within DOF
AI
Direct
Global availability of resources
The availability of resources and key competencies are becoming limited because of a smaller resource pool
!
Direct
Personnel continuity
Inability to meet competency demands within emerging markets, new technologies and stakeholder expectations
!
Direct
Key
IRO type Impact materiality Financial materiality
PI
Potential impact
AI
Actual impact
!
Potential risk
!
Actual risk
O
Opportunity
Stakeholder priority increasing unchanged decreasing
Time horizon
Short-term Short-to medium-term Medium-to long-term Long-term
The under-representation of women in the oil and energy industry, especially offshore, is recognised within the
industry and can be attributed to a combination of historical, cultural, social, and organisational factors. We believe
in a diverse and inclusive workspace and have strategies to address the imbalance and increase the number of
entry level candidates from diverse backgrounds to help develop skilled and experienced individuals.
As the energy sector evolves, so does the need for new skills and areas of knowledge, making it difficult to attract
and retain a competent workforce. Inability to recruit and retain the right people with the right knowledge can
pose reputational risks, lead to dissatisfied and lost customers, disruptions caused by key person dependencies
and inefficient processes. This could result in increased costs, loss of consultants, projects and revenue streams.
S1 Policies related to own workforce - equal opportunities for all
Our commitment to diversity, equity and inclusion is embedded in our Policy Framework. We adhere to applicable
laws and regulations, and our actions and decisions align with, and are informed by, our core values. Diversity, equity
and inclusion is important, and our fundamental principle is to treat all individuals with dignity and respect in the
workplace. All employees undertake mandatory and regular values-based training, and our values are embedded
in many other business and discipline related training materials.
S1-1 Policies related to own workforce - equal opportunities for all
Policy Code of Business Conduct
Purpose
A blueprint for ethical and responsible business conduct, including equality and inclusion
Key Content
Expectations for safe, legal and ethical behaviour across all operations, requiring
compliance with laws and policies, integrity in business practices, respect for people and
human rights, protection of assets and the environment
Covers
All employees, onshore, offshore worksites, value chain workers and downstream
suppliers
Accountable
CEO, the Board
Available
IMS, Website, All DOF Worksites
Reviewed
Annual management review process
Incorporates
UN Guiding Principles for Business and Human Rights,
OECD Guidelines for Multinational Enterprises and
ILO Declaration on Fundamental Principles and Rights at Work
Supports IRO:
Inclusion and equality
The Dignity & Respect in the Workplace guide is an addition to the CoBC, available for all employees,
value chain workers and downstream suppliers to better understand what constitutes bullying and
harassment, sexual harassment, the possible consequences and how to report any breaches.
The Ethics helpline provides a confidential reporting channel that protects the rights of the reporter and
potential subject Internal and external stakeholders are encouraged to report misconduct The reporting
process and reporting options are stated in the Code of Business Conduct and in the Ethics Helpline
guide It is managed by a third party and is a 24/7-hour accessible tool
Global Standard for Internal Training Requirements provides guidance for internal training
requirements
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Policy Workplace Harassment Policy
Purpose
Supports a zero-tolerance policy for any form of harassment in the workplace
Key Content
DOF’s Workplace Harassment Policy establishes zero tolerance for all forms of
harassment and abuse, committing the Group to a respectful and inclusive work
environment with safe reporting without retaliation, thorough investigation of
allegations, and appropriate disciplinary action where harassment occurs.
Covers
All employees, onshore and offshore worksites, value chain workers
Accountable
CEO, the Board
Available
IMS, Website, All DOF Worksites
Works with
CoBC, Dignity & Respect guide, Equal Employment Opportunities policy
Supports IRO:
Inclusion and equality
Policy
Equal Employment Opportunities Policy
Purpose
To support fair and equal treatment for applicants and employees, free association
and collective bargaining Ensures working hour requirements are upheld and fair
compensation for all employees
Key Content
Equal opportunity commitments, non-discrimination, inclusion of people with
disabilities, labour rights and standards, and fair working conditions
Covers
All applicants and employees,
Accountable
CEO, the Board
Available
IMS, Website, All DOF Worksites
Works with
CoBC, HR Policy, Global Standard Recruitment Management
Supports IRO:
Inclusion and equality
Global availability of resources
Personnel continuity
S1-1 Policies related to own workforce - equal opportunities for all. Policy commitments
on inclusion and support for vulnerable groups
Policy Equal Employment Opportunities Policy
Purpose
To support fair and equal treatment for applicants and employees, free association
and collective bargaining Ensures working hour requirements are upheld and fair
compensation for all employees.
Key Content
Equal opportunity commitments, non-discrimination, inclusion of people with
disabilities, labour rights and standards, and fair working conditions
Covers
All applicants and employees,
Accountable
CEO, the Board
Available
IMS, Website, All DOF Worksites
Works with
CoBC, HR Policy, Global Standard Recruitment Management
Policy
Human Resource Policy
Purpose
To support compliance and equality in the recruitment process and meet individual
needs in the workplace
Key Content
Recruitment and competence, Equal opportunities and diversity, training and
development and knowledge retention
Covers
All employees, onshore and offshore worksites
Accountable
CEO, the Board
Available
IMS, Website, All DOF Worksites
Works with
CoBC, Dignity & Respect guide, Equal Employment Opportunities policy, Global
Standard Recruitment Management
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S1-4 Equal treatment and opportunity for all actions
The actions to meet the risks and impacts related to ‘Equal Treatment and Opportunity for All’ are the responsibility
of the EVP People and Organisation. Supported by the global team, the EVP People and Organisation develop
actions plans to mitigate the barriers to inclusion and equality, ensures we attract and retain key competence and
that DOF and our people meet the competency demands to match emerging markets and technology demands.
All leaders are expected to conduct their work in accordance with DOF leadership principles, set a good example
and ensure their team is provided with equal opportunities to develop and grow. Our workforce has an active role
in embracing the opportunities given and expected to act according to our Code of Conduct. As people we have a
duty to act responsibly and ethically, and to speak up if we see or experience something that is not right.
KEY ACTION
Continuing the Fifty-fifty programme
The Fifty-fifty programme presented by AFF has educated women
from both Norwegian and international companies since 2017 The
programme is based on the UN Sustainable Development Goal 5
“Gender Equality” and brings women together from Norwegian and
international companies to learn and share best practices on how
to improve gender balance in leadership positions.
Participants have proposed recommendations to the Executive
Management team, such as setting up diversity committees,
organising awareness activities, and advocating for inclusive
workplace practices Unconscious bias training sessions have
been ongoing.
SCOPE OF ACTION
Women across all regions and business units
CORRESPONDING POLICY
Equal Employment Opportunity Policy:
• Consider employment of people regardless of age, sex, race,
political, religious or sexual orientation/preference, or national
origin,
• Employ persons on a non-racial discriminatory basis.
PROGRESS
In 2025 DOF presented the fourth group to take part in the
programme.
TIME HORIZON FOR COMPLETION*
Short-term
KEY ACTION
The DOF Ambassador programme
The DOF Ambassador programme serves as a platform for employee
career growth, providing structured professional development
opportunities for the next generation of leaders within the DOF
Group The programme combines employees with diverse cultural and
organisational backgrounds from various locations and is considered
a key future management pipeline The female representation in the
programme is gradually increasing.
The ambassador programme has grown to become a success,
developing and inspiring visible leadership within the company The
participants have made a huge contribution to the programme, to DOF
and within their teams’ The programme has continued to evolve, and
it now includes mentorship opportunities where previous participants
provide guidance and support to the new cohort of Ambassadors.
SCOPE OF ACTION
Across all regions and business units
CORRESPONDING POLICY
Equal Employment Opportunity Policy:
Consider employment of people regardless of age, sex, race, political,
religious or sexual orientation/preference, or national origin
HR Policy:
• Ensure Equal Opportunities for all, with a diverse and cross-cultural
workforce, valuing and respecting everyone,
• Deliver planned training and development opportunities so
employees are well-trained and highly knowledgeable, exemplifying
our vision and values,
• Continually striving to make the DOF Group a great place to work by
improving the work environment, recognising and reward excellence,
encouraging individual development, removing barriers to change
and promoting innovation and foster work collaboration.
PROGRESS
Ongoing, the fourth cohort continued in 2025/2026
TIME HORIZON FOR COMPLETION*
Long-term
KEY ACTION
LeaderShip programme
In 2025, we introduced the official Leadership programme
Leadership training is a key part of our organisational development,
with demands to lead through change, with a psychologically
safe team, a high level of trust, and respect for diversity The DOF
LeaderShip programme is about personal leadership development
aligned with our DOF Leadership principles The programme aims
to strengthen trust, cooperation, and relationships among leaders
across the organisation We track and assess the effectiveness of this
programme by tracking interest from the workforce and outcomes
from the participating cohort.
SCOPE OF ACTION
Leaders across the organisation
CORRESPONDING POLICY
HR Policy:
• Deliver planned training and development opportunities so
employees are well-trained and highly knowledgeable, exemplifying
our vision and values,
• Continually striving to make the DOF Group a great place to
work by improving the work environment, recognising and reward
excellence, encouraging individual development, removing barriers
to change and promoting innovation and foster work collaboration.
PROGRESS
Official DOF LeaderShip Programme launched in 2025
TIME HORIZON FOR COMPLETION*
Medium-term
KEY ACTION
DOF Graduate and trainee programmes
During 2025, DOF offered a variety of graduate, apprenticeship,
and traineeship programmes across its global operations, designed
to foster collaboration and standardised practices for the next
generation of professionals. These initiatives span the Survey
Department, ROV operations, and Engineering disciplines, ensuring
participants gain strong technical, project execution, and operational
skills through hands-on experience and engaging training. DOF also
collaborate with STEM Workforce, a platform dedicated to increasing
interest and participation in science, technology, engineering and
mathematics (STEM) by inspiring young people to pursue careers
within STEM fields.
The programmes have demonstrated success in developing skilled
graduates, pilots, and engineers from diverse backgrounds inspiring
employees to expand their skills and knowledge and promoting equal
access to opportunities within the company.
SCOPE OF ACTION
Organisation-wide
CORRESPONDING POLICY
HR Policy:
• Deliver planned training and development opportunities so
employees are well-trained and highly knowledgeable, exemplifying
our vision and values,
• Continually striving to make the DOF Group a great place to
work by improving the work environment, recognising and reward
excellence, encouraging individual development, removing barriers
to change and promoting innovation and foster work collaboration.
PROGRESS
Ongoing
TIME HORIZON FOR COMPLETION*
Medium-term
Workforce in greater risk of harm
An identified actual impact is the perceived or actual barriers to inclusion and equality in a male dominated industry.
The underrepresentation of women in the oil-and energy industry creates a gender imbalance which effects
availability of female candidates during hiring and promotions. Unconscious bias is not specific to DOF, but as we
operate in a predominantly male environment offshore, there is a heightened risk that unconscious bias can impact
decision-making during recruitment, performance evaluations and promotion decisions. As a global company with
people employed world-wide, most working on vessels in remote locations, DOF has a large and diverse workforce.
We are dedicated to creating a workplace where everyone feels valued, respected, and empowered to contribute
their unique perspectives.
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KEY ACTION
DOF celebrates International Women’s Day each year
as a global event with a panel discussion on Teams
DOF celebrates International Women’s Day (IWD) each year as a global
event with a panel discussion on Teams. International Women’s Day
provides an important opportunity for groups worldwide to embrace
and cultivate an ongoing commitment to diversity, equity, and
inclusion. The theme for IWD 2025 was “Accelerate Action”.
By celebrating and promoting this important day, we reinforce the
great women in our workforce, the importance of diversity and
equality and to highlight the challenges that DOF, the industry and the
women of the world face. The effect is awareness and each year we
see this celebration growing.
SCOPE OF ACTION
Organisation-wide
CORRESPONDING POLICY
HR Policy
• Ensure Equal Opportunities for all, with a diverse and cross-cultural
workforce, valuing and respecting everyone,
• Equal Employment Opportunity Policy,
• Consider employment of people regardless of age, sex, race,
political, religious or sexual orientation/preference, or national
origin,
• Employ persons on a non-racial discriminatory basis.
PROGRESS
On track Celebrated every March
TIME HORIZON FOR COMPLETION*
Long-term
KEY ACTION
Update of employer branding within recruitment
DOF has updated its employer brand and tone-of-voice to
attract and retain a more diverse candidates pool The Employer
brand continuously developed to expand our talent pool,
and there has been a high focus on challenging biases in the
recruitment process.
As an undertaking in the maritime industry, we are aware
traditionally it is an industry with less diversity than others We aim
to ensure that our approach and tone-of-voice are not influenced
by unconscious bias By being able to reach out to a wider and
more diverse pool of applicants, we can create an inclusive
workplace that values diversity and promotes equal opportunities
for all employees.
Our advertisements encourage women and minorities to apply
for positions As a result of these actions, DOF has gained a
larger applicant pool, and a brand that reaches a larger and more
diverse audience.
SCOPE OF ACTION
Organisation-wide strategy
CORRESPONDING POLICY
Equal Employment Opportunity Policy:
• Consider employment of people regardless of age, sex, race,
political, religious or sexual orientation/preference, or national
origin,
• Employ persons on a non-racial discriminatory basis.
PROGRESS
Ongoing program
TIME HORIZON FOR COMPLETION*
Medium-term
KEY ACTION
Global Employee Survey
Every year, DOF carries out a worldwide employee survey. This survey
helps the company examine and track its progress on diversity,
equality, and inclusion within the DOF Group, as well as pinpoint areas
that could be improved. Based on the results, new global action plans
are created each year.
SCOPE OF ACTION
Organisation-wide
CORRESPONDING POLICY
HR Policy
• Continually striving to make the DOF Group a great place to
work by improving the work environment, recognising and reward
excellence, encouraging individual development, removing barriers
to change and promoting innovation and foster work collaboration,
• Working pro-actively to retain the Group’s human capital
investments,
• Create and maintain the safest environment for our people: putting
safety first,
• Endeavour to meet individual needs in the workplace to ensure a
mutually beneficial work relationship, encouraging employees to
maintain a work life balance.
PROGRESS
On track Conducted annually
TIME HORIZON FOR COMPLETION*
Long-term
KEY ACTION
Global Exchange Programme
DOF is a company that values its people, striving to create a
safe, diverse, and inspiring workplace that promotes inclusivity.
Emerging from innovation and a flagship DOF Ambassador project, a
programme was initiated to shape the future leadership within DOF.
The programme has been created with the belief that knowledge and
experience should know no boundaries.
SCOPE OF ACTION
Organisation-wide representation
CORRESPONDING POLICY
HR Policy:
• Ensuring Equal Opportunities for all, with a diverse and cross-
cultural workforce, valuing and respecting everyone
• Equal Employment Opportunity Policy
• Consider employment of people regardless of age, sex, race,
political, religious or sexual orientation/preference, or national
origin,
• Employ persons on a non-racial discriminatory basis.
PROGRESS
Ongoing
TIME HORIZON FOR COMPLETION*
Medium-term
KEY ACTION
Maritime Traineeships programme
The programme offers a unique combination of academic development
and hands-on experience in the maritime industry. It plays a key role
in attracting new talent to the ocean sectors and preparing them for
future leadership roles.
SCOPE OF ACTION
Atlantic region
CORRESPONDING POLICY
HR Policy:
• Ensuring Equal Opportunities for all, with a diverse and cross-
cultural workforce, valuing and respecting everyone,
• Equal Employment Opportunity Policy,
• Consider employment of people regardless of age, sex, race,
political, religious or sexual orientation/preference, or national
origin,
• Employ persons on a non-racial discriminatory basis.
PROGRESS
Ongoing
TIME HORIZON FOR COMPLETION*
Medium-term
KEY ACTION
NSA and ETO Cadetships programme
Cadetships develop the next generation of maritime professionals
by combining hands on experience, safety culture, and advanced
technology training, ensuring a strong pipeline of skilled seafarers for
DOF’s global operations.
SCOPE OF ACTION
Organisation wide representation
CORRESPONDING POLICY
HR Policy
• Ensuring Equal Opportunities for all, with a diverse and cross-
cultural workforce, valuing and respecting everyone,
• Equal Employment Opportunity Policy,
• Consider employment of people regardless of age, sex,
race, political, religious or sexual orientation/preference, or
national origin,
• Employ persons on a non-racial discriminatory basis.
PROGRESS
Ongoing
TIME HORIZON FOR COMPLETION*
Medium-term
*Short-term (1 year), medium-term (2-5 years), and long-term (5+ years) horizons
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S1-5 Targets related to managing material negative impacts, advancing positive impacts, and
managing material risks and opportunities
DOF’s target is to reach 25% female leaders in the seasoned professionals and management group onshore, by
2025.
Definition of position groups:
Staff: Advisors, accountants, analysts and other staff positions.
Managers and seasoned professionals: Senior consultants and line-manager positions.
Senior Managers: Senior Vice President, Vice Presidents and Group Managers.
This target is aligned with the Diversity and Inclusion policy objectives. The policy aims to create a diverse and
inclusive workplace, addressing gender imbalance and promoting equal opportunities The specific target level is
25% female representation within professionals and managers onshore within 2025:
• Is relative and measured as a percentage of female representation within the specified workforce categories
• Applies to the onshore workforce
• Was first announced in 2021, initiated by the stakeholders involved and
because of the commitment to the “Fifty-fifty” programme
• Is evaluated by end of each reporting year, monitored throughout the year by
Power BI reports, and reported and monitored in the quarterly reports
By the end of reporting year 2025 the performance status was:
• Female Onshore leaders: 24.6 %
• The target of having minimum 25% female representation within
professionals and managers onshore will continue in 2026.
Although no KPI is set the offshore workforce, we monitor development, and see there is significant work to improve
female representation in the offshore and marine workforce DOF uses recognised programmes and pathways to
deliver this target.
Base year 2021 2024 2025
175% 237% 246%
S1-9 Diversity metrics
Respecting cultural diversity while working towards the same goals is a key success factor for DOF.
Staff Managers Senior Managers
Female 703 (17%) 62 (10%) 7 (20%)
Male 3486 (83%) 577 (90%) 28 (80%)
% of total 4189 (86%) 639 (13%) 35 (1 %)
* Employees excluding non-guaranteed hours and non-employees.
Employees by age groups
Under 30 30 – 50 Over 50
1025 3110 1352
S1-16 Remuneration metrics (pay gap and total remuneration)
In the year, the average hourly wage of a female employee was approximately 79.6% of the average male
employee’s remuneration across all employees. This was calculated based on the average gross hourly pay of all
women employees and all male employees.
The total remuneration of the highest paid individual was 20.4 times the median total remuneration for the company
in 2025.
Unit 2025 2024
Gender pay gap %
203 1833
Remuneration ratio of the highest paid individual ratio 204 189
DOF has not adjusted the ratio for purchasing power differences between countries. Neither have we included
information regarding how objective factors such as type of work and country of employment may influence the
gender pay gap.
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S1-1 Policies related to data security and data privacy compliance
DOF deals with sensitive and proprietary information related to projects, client data, and our people. Ensuring
robust data privacy measures is crucial to maintaining trust with clients, complying with regulations, and
safeguarding the integrity of business processes. The policy and standards listed below all relate to the
potential negative impact and risk related to data privacy and data security:
Policy Security Policy
Purpose
To manage the safety and protect personnel, physical assets, and
intellectual property
Key Content
DOF’s Security Policy commits the Group to protecting its people, assets
and intellectual property by implementing effective physical, operational
and cyber security measures, prioritising employee safety, managing
security risks and incidents, and ensuring compliance with international
security standards such as the ISPS Code
Covers
All onshore and offshore worksites and all individuals present on our sites
Accountable
CEO
Available
BMS, Website, All DOF Worksites
Works with Policy Documents
CoBC , SCoC, the International Ship and Port Facilities Security Code
(ISPS) Recruitment Management Standard,
S1 Other Work-Related Rights
Safeguarding employee’s data privacy is essential to DOF. With a portfolio that includes the collection and
management of diverse types of data, including privacy, commercial, and client data, the number of worksites and
employees increases vulnerability to data security risks. Cyber security threats have become a prominent risk to
business continuity, and threats to our systems have become more frequent and sophisticated.
IROS
MATERIAL IMPACTS,
RISKS AND OPPORTUNITIES
IRO
TYPE
VALUE
CHAIN
AREA
STAKE
HOLDER
PRIORITY
TIME
HORIZON
S1 Own Workforce
Data security
Exposure to data breaches, cyber attacks and unauthorised access to employee data
PI
Direct
Data privacy compliance
Breach of data privacy legislation may result in significant fines for the organisation
!
Direct
Key
IRO type Impact materiality Financial materiality
PI
Potential impact
AI
Actual impact
!
Potential risk
!
Actual risk
O
Opportunity
Stakeholder priority increasing unchanged decreasing
Time horizon
Short-term Short-to medium-term Medium-to long-term Long-term
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Policy Cyber Security Management System
Purpose
The purpose of the CSMS is to provide a systematic approach to managing
and protecting the information assets and systems of DOF Group.
Our CSMS is implemented with a systematic, risk-based approach to
identify and mitigate potential threats. It integrates into DOF’s Integrated
Management System and details the principles and practices related
to Cyber Security. This system ensures that the information assets and
systems managed by DOF are resilient, secure, and compliant with all
relevant regulations, and thereby supporting our commitment to operational
excellence and stakeholder trust.
Key Content
DOF’s Cyber Security Management System establishes a systematic, risk-
based framework to protect the confidentiality, integrity and availability of
the Group’s information assets and systems by identifying and mitigating
cyber threats, integrating cyber security into the Integrated Management
System, and ensuring resilience and regulatory compliance.
Covers
All employees, business units and operations
Accountable
The Chief Executive Officer of DOF Group is accountable to the Board
of Directors for ensuring that the DOF Group Cyber Security Policy is
implemented, and that this CSMS identifies the principles and tools
used by all levels within DOF Group to manage Cyber Security. Seniors
Management’s commitment and leadership is a precondition for an effective
CSMS
Available
Integrated Management System
Works with Policy Documents
DOF Security Policy
Stakeholders’ concerns are confidentiality, integrity, and availability of data, as well as the resources
allocated to safeguard against internal and external threats. They seek assurances of lawful protection
for personal data pertaining to employees and third parties. Non-compliance with GDPR regulations could
result in significant financial and reputational repercussions for DOF. Investors, employees, and clients
are particularly apprehensive about the organisation’s continued ability to uphold data privacy laws and
requirements.
Standard Personal Data Protection (Privacy) Standard
Purpose
DOF’s overall obligations with regards to data protection is to ensure that
personal data is processed according to applicable legislation and best
practices.
Key Content
Provides the principles applied in developing, implementing, maintaining,
improving and managing personal data within the DOF Group.
The document is also providing all internal rules and aspects connected to
securing privacy of data given in the General Data Protection Regulations
(GDPR) issued by the European Union, as well as facilitating compliance
with local legislation in countries where DOF operates, for example LGPD in
Brazil
Covers
All employees, business units and operations
Accountable
DOF Group Executive Management
Available
IMS
Works with Policy Documents
CoBC , SCoC, the International Ship and Port Facilities Security Code
(ISPS) Recruitment Management Standard
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S1-4 Taking action on material impacts on own workforce. Other work-related rights
Other work-related rights - Data security and privacy
The actions taken to meet the impacts and risks related to data security and data privacy relies on the IT function.
They have the overall responsibility of making sure that we are not exposed to data breaches, cyber-attacks or
unauthorised access, as well as making sure our people are trained and have the tools needed to protect our data.
With the growing technological development, the risks follow and more than ever it is crucial for all employees to
follow our managing documents and training on the area to mitigate this risk.
Actions under Data privacy:
Data privacy has been a material topic for the DOF Group for several years, and we have established activities
based on the identified impacts and risks. In 2025 the Cyber security Committee registered that the majority of
the employees were behind schedule on completing their cyber awareness training. Therefore, the decision was
made to go for a new and improved product that offered a new approach to cyber security training.
KEY ACTION
Cyber Security Awareness and Training Programmes
All DOF employees complete mandatory cyber security and GDPR
Awareness training during the onboarding process, as outlined in
the competence matrices. This training shall also be repeated every
two and four years to ensure compliance and keep skills up to date.
All mandatory training is mapped and monitored through our training
portal. This gives us the opportunity to detect negative trends and to
focus more where necessary.
DOF provides its employees with an automated cyber security
training. The system consists of e-learning and phishing simulation
addressing relevant cyber security topics. A major goal of our cyber
security awareness program is to teach employees how to avoid
falling for phishing emails When it comes to cyber security it is a
joint effort to safeguard our organisation and ourselves Together our
personal awareness and knowledge of cyber threats is crucial, as our
reliance on technology is increasing.
SCOPE OF ACTION
Covers all DOF Employees
CORRESPONDING POLICY
DOF Security Policy and Information Technology and GDPR
Compliance Standard:
• Protect the confidentiality and integrity of our intellectual property
and prevent any unauthorised access or use,
• Adhere to the Group’s access control procedures,
• Ensure operational resilience to cyber risks.
PROGRESS
Implemented Ongoing compliance monitoring through the
training portal
TIME HORIZON FOR COMPLETION*
Long-term
KEY ACTION
Cyber Security Awareness Month
October is the Cyber Security Awareness month, and in 2025
DOF conducted extra awareness using campaigns and articles on
our internal social platforms These awareness activities included,
among other, phishing awareness, digital assets and how to report
cyber security incidents. The effect of these campaigns is increased
awareness among our workforces.
Our Cyber Security Officer also held Cyber security awareness
presentation on our Offshore Leadership Conferences in 2025.
SCOPE OF ACTION
Covers all DOF Employees, tailored simulations towards employee
profile
CORRESPONDING POLICY
DOF Security Policy:
• Protect the confidentiality and integrity of our intellectual property
and prevent any unauthorised access or use,
• Adhere to the Group’s access control procedures,
• Ensure operational resilience to cyber risks.
PROGRESS
Annually, with specific activities in October
TIME HORIZON FOR COMPLETION*
Medium-term
KEY ACTION
Cyber Security Drills
This includes selecting one or more scenarios that can occur onboard
the vessel and guiding questions to get a complete Cyber Crisis
Management Exercise All emergency response training conducted
in DOF in 2025 was reported/logged in our Integrate Management
System This training acts as a drill for our employees and prepares
them for cyber risks that may occur in the day-to-day operations.
SCOPE OF ACTION
Includes scenarios that can occur onboard vessels, involving all
relevant stakeholders
CORRESPONDING POLICY
DOF Security Policy:
• Protect the confidentiality and integrity of our intellectual property
and prevent any unauthorised access or use,
• Adhere to the Group’s access control procedures,
• Ensure operational resilience to cyber risks.
PROGRESS
Implemented, and tracked within Crisis Manager
TIME HORIZON FOR COMPLETION*
Long-term
KEY ACTION
Implemented DOF Cyber Security Management
System
In 2025 DOF has implemented a Cyber Security Management system
according to the ISO 27001 standard. The system is integrated
into existing ISO Processes in the organisation. This improves the
management of Cyber Security and support.
SCOPE OF ACTION
Covers all DOF Employees.
CORRESPONDING POLICY
DOF Security Policy:
• Protect the confidentiality and integrity of our intellectual property
and prevent any unauthorised access or use,
• Adhere to the Group’s access control procedures,
• Ensure operational resilience to cyber risks.
PROGRESS
Completed 2025
TIME HORIZON FOR COMPLETION*
Short-term
*Short-term (1 year), medium-term (2-5 years), and long-term (5+ years) horizons
S1-5 Targets related to managing material negative impacts, advancing positive impacts and
managing risks and opportunities
DOF has not established any measurable or time-bound outcome-oriented targets to evaluate the effectiveness
of our activities connected to the IROs under the sub-topic of “other work-related rights” (data privacy).
Nevertheless, we track the effectiveness of our actions based on monitoring data breaches and regular reports on
how many of our employees that complete the awareness training and status on the simulated attacks.
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Workers in the Value Chain
Stakeholder engagement included:
Internal supply chain management and procurement teams, regional executives, and operational managers were
consulted to identify specific worker-related challenges and risks within the supply chain.
External supplier engagement and audits provided additional perspectives on workers’ conditions, employment
practices, and alignment with DOF’s Business and Supplier Code of Conduct.
The process included mapping the value chain, identification of key suppliers, subcontractors, and business
partners globally, with emphasis on high-risk geographies and sectors.
Supplier audits and vendor evaluations are evaluated towards supplier practices related to human rights, labour
standards, and health and safety, including compliance with international frameworks such as the UN Guiding
Principles on Business and Human Rights and the ILO Core Conventions.
Historical data was reviewed and past incidents, such as breaches of supplier codes of conduct or labour violations
reviewed, to determine the likelihood and severity of future risks.
Risk Segmentation: classification of suppliers based on risk factors, including geographic location, industry type,
and reliance on vulnerable worker populations (e.g., migrant labour or contract workers).
As outlined in SBM-1, our business model relies heavily on an extensive network of suppliers to produce goods
and services as part of our value chain.
Global supply chains servicing our industry are unbalanced and instances of abuse of rights and unfair treatment
are recognised as a material risk. DOF has identified exposure in activities that involve vessel yard stays, and when
outsourcing our services to third-party companies.
Our stakeholders expect us to deliver all our services in a manner where we demonstrate fair conditions for workers
in our value chain. We take our responsibility to identify, prevent and address the mistreatment of workers in our
value chain seriously. Our engagement strategy spans the entire supply chain, from supplier selection to regular
reviews. This ensures consistent oversight and responsiveness to workers’ needs. The process is guided by UN
Global Compact principles and involves risk-based inspections and audits. The EVP Marine & Asset Operations
and global supply chain teams oversee the strategy, incorporating insights into policies and practices.
Workers in the value chain are defined as:
Upstream: Workers from our tier 1 suppliers, who we purchase goods or services from - workers who produce the
goods and services - Suppliers providing goods/materials/parts etc.
Downstream: Representatives from clients onboard our vessels and service workers in catering or welders onboard
during mobilization and maintenance work.
Downstream: Includes workers undertaking activities on DOF’s owned assets but are not employed on a permanent
basis. This includes self-employed workers, or workers provided by third party, workers working for clients, logistical
and agent support and workers working in the operations as part of DOF joint venture.
Own Operations: Non-employees - suppliers contracted by the undertaking, for example seafarers from OSM.
These workers are disclosed in S1.
S2 Workers in the Value Chain
DOF’s business model relies heavily on an extensive network of suppliers to produce goods and services as part
of our value chain. DOF’s suppliers vary from small local entities to global suppliers delivering goods and services
to DOF. Stakeholders expect us to deliver all our services in a manner where we demonstrate fair conditions
for workers in our value chain. We take our responsibility to identify, prevent and address the mistreatment of
workers in our value chain seriously. The action plans and resources to manage our material impacts, risks, and
opportunities related to workers in the value chain are consolidated in our Global Improvement Programme (GIP).
The GIP is established annually to ensure that DOF meets or exceeds the ambitions defined by the Group’s vision
and strategic objectives. This programme, along with the actions and objectives it encompasses, supports our
ongoing efforts in preventing and mitigating significant negative impacts.
IROS
MATERIAL IMPACTS,
RISKS AND OPPORTUNITIES
IRO
TYPE
VALUE
CHAIN
AREA
STAKE
HOLDER
PRIORITY
TIME
HORIZON
S2 Workers in the Value Chain
Child and forced labour within extended value chain
DOF is exposed to the use of child and forced labour as a result of business relationships with shipyards, manning
agencies and the use of some manufactured of products
PI
Upstream
Labour conditions
DOF is not always able to assure the labour conditions of its extended value chain, exposing it to non-compliance to UN
Global Compact
PI
Upstream
Occupational Health and Safety
High consequence low probability incidents can have fatal or serious personnel consequences for workers
PI
Upstream
Occupational Health and Safety at shipyards
Maintaining adequate health and safety standards within shipyards is a significant challenge as tasks are performed
using third-party management systems
PI
Direct
Global availability of resources
The availability of resources and key competencies are becoming limited because of a smaller resource pool
!
Upstream
Personnel continuity
Inability to meet competency demands within emerging markets, new technologies and stakeholder expectations
!
Upstream
Key
IRO type Impact materiality Financial materiality
PI
Potential impact
AI
Actual impact
!
Potential risk
!
Actual risk
O
Opportunity
Stakeholder priority increasing unchanged decreasing
Time horizon
Short-term Short-to medium-term Medium-to long-term Long-term
Identifying IROS 2025
In 2025, a group-wide revision of the double materiality process, in accordance with the ESRS requirements, was
conducted to determine the material impacts, risks and opportunities within our value chain. Details about IROs
connected to workers in the Value Chain are provided below.
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Value chain workers in greater risk of harm
The risk of child or forced labour within our broader value chain is concentrated within DOF’s use of shipyard
facilities, manning agencies and utilization of manufactured goods received via upstream value chain. Although no
shipbreaking was performed this year, several vessels were sold to third parties. It is crucial to maintain effective
extended due diligence processes across these transactions to monitor what happens to verify the legitimacy of the
prospective client and intended use post transaction. Whilst due diligence is a governance topic, the effectiveness
of these processes ensure that vessel sale transactions do not expose DOF to child or forced labour practices in
extended areas of the value chain.
Forced labour and poor working conditions can manifest in many ways. DOF addresses these issues through
supplier audits, concentrating on concerns such as withheld payments or identification documents, recruitment
fees, and inadequate workplace environments.
Occupational health and safety hazards affect everyone working on vessels or in shipyards, including both hired
and contracted staff. With many contracted employees onboard, DOF also faces increased responsibility for the
safety of offshore and shipyard workers throughout its value chain.
Special attention is given to understanding the unique experiences of vulnerable or marginalised groups within the
supply chain, such as women, migrant workers, workers with disabilities and workers within the LGBTQ+ society.
Training and awareness
We take care to communicate effectively and protect value chain workers and suppliers in high-risk areas.
DOF offers regular training sessions for employees involved in procurement and supply chain management. We
welcome questions or comments about the SCoC from our suppliers and consider this an opportunity to promote
understanding of our compliance requirements. In 2025, in-person training sessions have focused on our values
and policies. Most meetings throughout the organisation, start with a value moment to create awareness and
discussions around these topics.
Webinars are supplemented with comprehensive materials, such as handbooks and online resources, and are
accessible for all relevant personnel and available in English and Portuguese, the two business languages in DOF.
The training sessions outline expectations for conduct and ensure that participants understand the impacts, risks
and opportunities associated with labour practices, human rights, health and safety, the environment, and bribery
and corruption within the value chain.
DOF offers e-learning modules to our value chain workers. The training covers Occupational Health and Safety,
permit to work, management of change and the CoBC.
S2-1 Policies related to Workers in the Value Chain
The Supplier Code of Conduct addresses potential labour practices, human rights, health and safety, environmental
and bribery and corruption risk in the supply chain. It is integrated into purchase agreements with suppliers, made
available on our website and business management system. All new suppliers must commit to the code as a pre-
requisite for transacting business with our company. Both the Supplier Code of conduct and the Supply chain
Management manual relate to all IROs in this chapter.
Policy Supplier Code of Conduct
Purpose
To manage supplier obligations to comply with international human rights
standards and national laws regarding child and forced labour, working
hours, wages and benefits, and non-discrimination
Key Content
DOF’s Supplier Code of Conduct outlines the ethical, legal, environmental,
and governance standards expected of all suppliers, subcontractors, and
third parties, requiring them to conduct thorough due diligence, uphold
DOF’s values, ensure compliance across their own supply chains, and report
concerns through DOF’s Ethics Helpline.
Covers
The supply chain
Accountable
CEO
Review
Periodically, within management review process
Available
IMS, Website, All DOF Worksites
Works with Policy
Documents
CoBC, Supply Chain Management Manual
Aligned to
International Bill of Human Rights,
International Labour Organization (ILO) conventions,
UN Guiding Principles on Business and Human Rights
Policy Supply Chain Management Manual
Purpose
Outlines engagement responsibilities, including vessel officer involvement
and supplier feedback loops
Key Content
The Supply Chain Management Manual establishes DOF’s global framework
for contract management, vendor management, procurement, and logistics,
defining leadership expectations, authority levels, responsibilities, and
supporting systems, while setting out consistent processes for supplier
selection, monitoring, auditing, and continuous improvement across the
supply chain
Covers
The supply chain
Accountable
CEO
Review
Periodically, within management review process
Available
IMS, Website, All DOF Worksites
Works with Policy
Documents
CoBC, SCoC
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Through targeted research and focused discussions, facilitated by our NGO partners and Slave free Alliance, we
seek to address marginalised groups’ specific needs and challenges, ensuring that our engagement efforts are as
inclusive and impactful as possible.
S2-3 Processes to remediate negative impacts and channels for value chain workers to raise
concerns
When entering a DOF worksite, the induction programme outlines what workers should expect of a decent working
environment. The programme is part face-to-face introduction and part e-learn modules, focusing on the CoBC
and Occupational Health and Safety.
Some of our regular value chain workers onboard our vessels are included in the regular polls and working environment
surveys we conduct.
We provide information to our value chain workers on how to speak-up and how to report situations that do not meet
policy and CoBC standards, when performing work at a DOF sites offshore and onshore. DOF does not execute
a systematic measure to check or validate if value chain trusts the structures and processes as a way to raise
concerns. Nevertheless, spot checks are performed during inspections, audits and onboardings.
The Ethics Helpline is publicly available, and reports may be made through the website, or telephone numbers
available 24/7 in various languages. The database allows communication with the reporter in an anonymous and
secure way.
Reporters are also protected by our non-retaliation policy, which is embedded in our Code of Business Conduct.
“Our Non-retaliation Policy strictly prohibits acts of retaliation or harassment against any person who has raised a
concern in good faith, or anyone who participates in an investigation. This means you may raise concerns without
fear of your employment being negatively affected. Our policy against retaliation protects anyone who makes a
report in good faith, even if you are found later to be mistaken”.
The closing timeline of grievance will depend on each case. Irrespective of whether a complaint is accepted or not,
a response to the reporter must be promptly provided in an understandable and transparent way. DOF ensures
that records and evidence are kept within the Ethics Helpline database.
All stakeholders, including value chain workers, can raise concerns regarding financial or legal impropriety through
DOF’s whistle-blowing system, detailed in G1-1.
For more information regarding tracing and monitoring of issues raised and handled, this is described in more
detail in S1-3.
The main concern is exposure to non-compliance labour and human rights practices, using short-term contracts
and temporary employment through manning agencies, which may weaken worker’s rights
The Supplier Code of Conduct is aligned with the UN Global Compact and available online via our portal and webpage.
Updates and other information regarding the SCoC are readily available to global value chain workers and suppliers
via online platforms and portals, ensuring real-time access to policy changes, best practice, and relevant training
modules.
Value Chain workers that are working onboard our vessels or in any of our facilities all fall under the same safety
and ethical policies and procedures as DOF employees. This ensures that we take responsibility to include all
workers and help manage our material impacts on the value chain workers in our value chain.
Supplier engagement is monitored through our platforms, and where suppliers have not undertaken mandatory
training, noncompliance is addressed as a part of ongoing supplier management.
S2-2 Processes for engaging with value chain workers about impacts
Our engagement strategy unfolds at various stages of the supply chain process, beginning with the selection
of suppliers and extending through regular, biannual reviews of working practices and conditions. Structured
engagement allows us to maintain consistent oversight and respond to the needs of workers. The selection process
is built on UN Global Compact requirements and followed up with risk criteria inspections and audits.
The EVP Marine & Asset Operations oversees the engagement strategy in close collaboration with supply chain
managers. They ensure the insights and feedback obtained through our engagement influence our policies and
practices.
Supply chain engagement is described in the Supply Chain Management manual, and part of the integrated
management system. Additionally, officers’ onboard vessels are responsible for engagement. The feedback loop to
suppliers is managed through regular evaluation and meetings. Special training has been given to our audit teams
visiting yards and production facilities to evaluate upstream activities performed by workers in our value chain.
Our Shipyard assessment form has been improved to enhance focus on human rights.
In general, engagement occurs directly with value chain workers when they work under, or in connection with,
the organisation. Sometimes engagement is organised by contracting organisations, with unions and other
representatives of the value chain workers.
Engagement with value chain workers onboard vessels occur in daily meetings, inspections and direct dialogue
with the workers in safety meetings. At shipyards, the engagement occurs through audits, day-to-day follow-up
and collaboration with workers and their supervisors.
DOF has also established Client feedback surveys to obtaining feedback from our clients. As this is a crucial part of
business development, it allows us to understand how well we meet our client’s needs, measure their satisfaction,
identify areas that require improvement, and identify areas we are performing well. By actively engaging with client
feedback, we can foster stronger relationships, enhance client satisfaction, and ultimately, contribute to our success.
To measure the effectiveness of our engagement, we monitor the outcomes of our initiatives, assess improvements
in working conditions and the fulfillment of our agreements. This evaluation process includes examining the tangible
impacts on the lives of the workers and the overall sustainability of our supply chain.
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S2-4 Taking action on material impacts on value chain workers, and approaches to managing
risks and pursuing opportunities related to value chain workers, and effectiveness of those
actions
DOF’s resources allocated to manage these material impacts are embedded in the organization and way of working.
The areas that are involved and responsible on a day-to-day basis are mainly the following functions in the company:
- HSEQ and ESG resources; Supply Chain, including procurement and logistics. The HR function for contract and
training: Officers onboard, to oversee alignment with the ILO principles.
KEY ACTION
Humans Rights and Modern Slavery due diligence
Risk of human and forced labour within the supply chain was
identified as a material issue in our Double materiality assessment.
In accordance with national laws, DOF annually performs a Human
Rights due diligence assessment.
SCOPE OF ACTION
DOF Value Chain
CORRESPONDING POLICY
Supplier Code of Conduct:
• The Code covers DOF’s entire supply chain and is aligned with
the International Bill of Human Rights, core International Labour
Organization (ILO) conventions, and the UN Guiding Principles on
Business and Human Rights.
PROGRESS
Assessment Complete for 2025 reporting period Ongoing evaluations
incorporated within the DOF Integrated Management System
TIME HORIZON FOR COMPLETION*
Long-term
KEY ACTION
Expanding our vendor evaluation questionnaire
During 2025 DOF has enhanced our Vendor Evaluation Questionnaire
to include information and questions regarding the welfare of workers.
One enhancement has been to include questions on minimum wage
and overtime pay. This will give DOF increased information and can
raise awareness and understanding of the challenges in our value
chain.
SCOPE OF ACTION
DOF Value chain
CORRESPONDING POLICY
Supplier Code of Conduct:
• The Code covers DOF’s entire supply chain and is aligned with
the International Bill of Human Rights, core International Labour
Organization (ILO) conventions, and the UN Guiding Principles on
Business and Human Rights.
Under the Code, suppliers must comply with international human
rights standards and national laws regarding child and forced labour,
working hours, wages and benefits, and non-discrimination.
PROGRESS
Implemented 2025
TIME HORIZON FOR COMPLETION*
Short-term
KEY ACTION
Regional supplier workshops
During the year, various regional business areas in DOF has
invited suppliers to join on workshops and gatherings to enhance
collaboration, communication, exchanging ideas and clarifying
concepts. These sessions often include sharing our values, human
rights policies and presenting our grievance mechanism.
SCOPE OF ACTION
DOF Value Chain
CORRESPONDING POLICY
Supplier Code of Conduct:
• The Code covers DOF’s entire supply chain and is aligned with
the International Bill of Human Rights, core International Labour
Organization (ILO) conventions, and the UN Guiding Principles on
Business and Human Rights,
• Under the Code, suppliers must comply with international human
rights standards and national laws regarding child and forced
labour, working hours, wages and benefits, and non-discrimination.
PROGRESS
Conducted
TIME HORIZON FOR COMPLETION*
Short-term
*Short-term (1 year), medium-term (2-5 years), and long-term (5+ years) horizons
S2-5 Targets related to managing material negative impacts, advancing positive impacts,
and managing material risks and opportunities
DOF has not committed to any targets that align with CSRD to manage material negative impacts, advancing
positive impacts, and managing material risks and opportunities within this area.
Though we have not set any targets, we have, from 2025, enhanced our data collection from our vendors to
include information regarding minimum wages and overtime pay for their workers. This action can lay the basis
for mapping our supplier’s adherence to pay an adequate wage and can be the foundation that DOF needs to
set targets in this area in the future. For 2026 DOF will evaluate the data that has come in and analyse whether
the quality of the data is reliable and if it can be used for developing our targets in this area going forward.
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IROS
GOVERNANCE
MATERIAL IMPACTS,
RISKS AND OPPORTUNITIES
IRO
TYPE
VALUE
CHAIN
AREA
STAKE
HOLDER
PRIORITY
TIME
HORIZON
G1 Business Conduct
Exposure to differing cultural norms
DOF’s global footprint exposes operations to different cultural
norms that may result in breaches of our core values
PI
Direct
Compliance to anti-corruption and bribery legislation
DOF may encounter corruption and bribery within the high-risk areas we work
PI
Direct
Supplier exposure to corruption and bribery
Through its operational footprint DOF may work with suppliers that do not comply with UN Global Compact conditions
!
Upstream
Lifecycle management of end-of-life assets
DOF needs to ensure adequate levels of due diligence in the process of divestment of assets to avoid severe reputational
and financial damage because of non-compliance.
PI
Down
stream
G1 Business Conduct
G1-1 Business conduct policies and corporate culture
DOF operates in a rapidly evolving and increasingly complex business environment. As the company expands,
exposure to business conduct risks grows, and compliance obligations become more fragmented. To address
this, every aspect of DOF’s business conduct is anchored in a robust governance framework that clearly defines
expectations for employees and third parties. The framework incorporates Anti-Bribery and Anti-Corruption
policies, which are consistent with the United Nations Convention against Corruption. The Audit Committee (‘AC’)
is responsible for preparing and making recommendations to the Board on regulatory and compliance issues that
may have a material impact on DOF. The Board monitors adherence to the Code of Business Conduct (CoBC) and
any reports raised through the whistleblowing system on a quarterly basis.
Executive Management is responsible for the implementation of the CoBC and building a culture of compliance
towards it. Compliance matters are embedded into weekly, monthly and quarterly agendas so function owners at
business-unit, regional and corporate levels regularly review, escalate and resolve compliance issues. Recognised
as a principal risk domain, DOF maintains a zero-tolerance risk appetite for compliance and monitors operational
performance with targeted key risk indicators that track compliance across core business areas.
The project management function, supply chain workers and officers on our vessels have been identified as having
high exposure to corruption and bribery risks due to their direct involvement in obtaining permits and ongoing
interface with external stakeholders, including government officials. DOF mitigates this risk through targeted
anti-bribery and anti-corruption training for these individuals.
Key
IRO type
Impact materiality Financial materiality
PI
Potential impact
AI
Actual impact
!
Potential risk
!
Actual risk
O
Opportunity
Stakeholder priority increasing unchanged decreasing
Time horizon
Short-term Short-to medium-term Medium-to long-term Long-term
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Policy Business Integrity and Ethics Policy
Purpose
Outlines core values, business conduct and behaviours expected in our companies
and employees to protect and build DOF’s reputation. This policy outlays DOF’s
commitment towards compliance with international laws and regulations,
international standards and conventions. The policy extends to committing
towards upholding consistent and high standards for business integrity through
the application of ‘high common standards.
Key Content
The Business Integrity and Ethics Policy strengthen these commitments by
outlining behaviours required to safeguard DOF’s reputation, including accurate
record-keeping, avoidance of conflicts of interest, refusal of bribery or facilitation
payments, and adherence to legal requirements in every jurisdiction where DOF
operates. It mandates fair and transparent dealings with suppliers, reinforces
compliance with UN Global Compact-aligned expectations, and supports robust
due diligence processes, particularly relevant when managing supplier integrity
risks and the lifecycle or divestment of end-of-life assets, where non-compliance
could result in serious financial or reputational harm.
Covers
All employees, business units and operations
Accountable
CEO, the Board
Available
Integrated Management System, Website, All DOF Worksites
Reviewed
Annual management review process
Incorporates /
encompasses
UN Guiding Principles for Business and Human Rights and OECD Guidelines for
Multinational Enterprises
The Ethics helpline provides a safe reporting channel that maintains confidentiality and protects the rights
of both the reporter and potential subject Internal and external stakeholders are encouraged to report
misconduct. The reporting process and reporting options are stated in the Code of Business Conduct and
in the Ethics Helpline guide. It is managed by a third party and is a 24/7-hour accessible tool accessible
via phone or website portal.
G1-1 Business Conduct Policies
Policy Code of Business Conduct (CoBC)
Purpose
The blueprint for conducting business ethically and responsibly, including
human rights, diversity, zero tolerance for bribery and corruption, transparency,
anti-money laundering laws compliance, and the protection of personal data.
This policy incorporates the organisations expectations towards ‘Operating
Responsibly’, covering compliance with export, import and trade laws as well as
anti-money laundering principles.
Key Content
The Code of Business Conduct provides clear expectations for safe, legal and
ethical behaviour across DOF’s multinational operations, helping employees
navigate differing cultural norms by promoting consistent standards of conduct,
integrity and respect regardless of location. It reinforces strict compliance with
anti-corruption and anti-bribery laws, prohibits improper payments, and guides
employees in acting professionally and responsibly when engaging with external
stakeholders. These principles help prevent misconduct linked to cultural variation
and support ethical decision-making throughout DOF’s global footprint.
Covers
All employees, onshore and offshore worksites, value chain workers and
downstream suppliers
Accountable
CEO, the Board
Available
IMS, Website, All DOF Worksites
Reviewed
Annual management review process
Incorporates /
encompasses
UN Guiding Principles for Business and Human Rights, OECD Guidelines for
Multinational Enterprises and ILO Declaration on Fundamental Principles and
Rights at Work.
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Lifecycle Management of End-of-Life Assets
In 2025, DOF underwent a process of divesting assets from its portfolio that do not align with its current strategy
of portfolio optimization and long-term value creation. An Implication of this activity is that the divestment of assets
must be underpinned by robust governance and due diligence processes.
DOF’s approach to asset divestment is addressed under G1 as the related IRO concerns business conduct,
governance and due diligence rather than the environmental performance of assets post-sale. The identified IRO
relates to the risk of inadequate due diligence in divestment transactions, which could expose DOF to reputational,
legal or financial impacts if assets are transferred to buyers that do not meet required ethical, regulatory or
corporate responsibility standards.
In line with DOF’s Code of Conduct and Business Integrity and Ethics Policy, asset divestment due diligence must
meet a standard that provides assurance of compliance with export, import, and trade laws as well as anti-money
laundering principles. This involves DOF executing Know Your Client (KYC) and due diligence processes applied on
a case-by-case basis. These processes assess buyer compliance with applicable sanctions regimes, export control
requirements, anti-money laundering regulations, ship management standards, and broader ESG considerations,
with enhanced scrutiny applied where transactions involve higher-risk jurisdictions.
DOF’s Foreign Trade Controls and Management of Sanctions Guideline outlines compliance measures with
international sanctions and export control regulations. The guideline outlines the responsibilities of adhering to
foreign trade control policies, including the requirement to consult with the DOF Legal team for any concerns or
uncertainties. Sanctions screening and due diligence shall be performed on third parties based on risk, to review
potential buyers and partners against international sanctions watch lists. DOF utilises both an in-house compliance
desktop tool and specialist third parties to perform extended due diligence and determine beneficial ownership,
assess connections to government officials, confirm the third party’s ability to operate compliantly, and ensure they
are not subject to sanctions. This process is mandatory for all compliance-sensitive transactions and is especially
critical when divesting assets, as it helps identify and mitigate legal, financial, and reputational risks associated
with non-compliance.
While DOF does not have specific actions or quantitative targets related to asset divestment, these policy-driven
due diligence controls ensure responsible decision-making and to mitigate risks associated with post-divestment
outcomes across the value chain. Ultimately, DOF maintains a position of zero risk appetite for compliance risks.
During the year, 3 vessels have been sold to third parties. All instances of vessel sales have undergone extended
due diligence, and there have been no identified instances of non-compliance with international rules or regulations.
Whistleblowing
We have a whistle-blower system which can be used by internal and external stakeholders to raise concerns about
breaches of the governance framework and CoBC, and other matters that relate to financial and legal integrity.
The system is hosted by an independent risk and compliance solution provider that has 30 years of expertise in
the area, via an online portal and can be accessed from a link on our website. All reports submitted via the whistle-
blower system are promptly assigned and thoroughly investigated with objectivity.
Whistle-blowers are protected from any kind of retaliation, discriminatory or disciplinary action in line with EU law
and other relevant legislation in Norway, Denmark, Australia, Brazil,Singapore, UK, US, and Canada.
During the year, a total of 87 cases were reported through our grievance channel. Of these, 26 reports were
identified as being the same as or related to other cases, and 75% of the cases originated from South America,
with the remainder distributed across other regions globally.
Analysis of the unique closed cases in 2025 revealed that 32% were classified as substantiated and 34% as
unsubstantiated. In addition, 14% of cases were closed due to insufficient information, while 6% were referred to
other responsible areas of handling.
The most serious reports concerned sexual harassment, moral harassment, and abuse of power. Seven cases
resulted in dismissals, including five DOF employees and two hired employees. There was also one termination of
agreement with a supplier.
The average time to close cases is 48 days for the year, and falls within the target of 80 days. 81 cases reported
on the hotline website and 6 by hotline phone. More detail on cases raised through the whistle-blower mechanism
and other details and complaints are given in S1-17.
Training and awareness
Training and awareness activities are essential in building a culture of integrity and creating a common understanding
of what is expected from our employees. CoBC conduct, whistleblowing and other compliance training sessions
are mandatory for all new employees as part of their onboarding process In the year, we also roll-out mandatory
training for existing employees, to refresh their knowledge on different topics in the Code. DOF has dedicated
sessions on topics including Labour Rights and Modern Slavery, Conflicts of Interest and Gifts and Hospitality on
a 4-year rolling basis These are targeted to different functions and regions. Given the changes in the compliance
environment across 2025, DOF introduced a series of company specific tailored E-learning Modules, related to Dawn
Raids, Competition and Antitrust Law and Foreign Trade Controls and Sanctions. These modules are considered
mandatory for Regional Management Teams, procurement and Business Acquisition and Chartering Departments.
1973 employees have conducted CoBC training in 2025 and the total for the last 3 years is 3990. In addition,
1320 employees have completed the Business and Ethics training, and in total 4615 courses conducted by
employees the last three years.
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G1-2 Management of relationships with suppliers
DOF’s ability to deliver safe, high-quality, and timely operations relies on strong relationships with suppliers who
share our business principles. Expectations and standards for supplier conduct are clearly defined in our Supplier
Code of Conduct (SCoC), which is incorporated into our standard terms and conditions. We require suppliers to
share the SCoC with their subcontractors and business associates involved in delivering goods and services under
DOF contracts. This requirement applies to all suppliers globally, covering 100% of procurement spend unless
otherwise restricted by local legislation or exempted by scope of subcontracted work (see exemption section).
Policies, Standards and Scope
Vendors must complete the self-assessment process and due diligence is performed for them to become prequalified
by DOF. A risk-based approach is used where sustainability related risk, spend-level and operational criticality
determine the need for additional assurance and enhanced screening. For all vendors, they must complete Vendor
Evaluation Questionnaire Part 1 (VEQ Part 1). Those determined to be higher risk, are required to supplement their
submission by completing VEQ Part 1 and 2. Certain vendors are exempted from this requirement as outlined in
the ‘Exemption’ section. All vendors, other than local Brazilian vendors, are pre-qualified using this process. All
vendors are ultimately consolidated into ERP for global control and visibility.
Regional Variations
To comply with local regulatory requirements, DOF Brazil operates a regional vendor evaluation system (EFCAZ)
for local entities. Tier 1 high risk category suppliers in Brazil undergo enhanced assessments aligned with the UN
Global Compact principles and DOF’s HSEQ risk considerations.
Vendor Assessment and Due Diligence Process
DOF’s supplier evaluation process is risk-based and aligned with The Ten Principles of the UN Global Compact ,
covering human rights, labour, environment, and anti-corruption. The level of evaluation considers both sustainability
indicators and whether the vendor has HSEQ or operational implications when delivering their scope of work.
Where required by the complexity or risk of the subcontracted activity, vendors complete the enhanced Vendor
Evaluation Questionnaire (VEQ Part 1+2). VEQ Part 1 covers baseline compliance, integrity, and basic ESG criteria.
VEQ Part 2 covers extended Health, Safety, Environmental and Quality controls.
The primary objective of the Vendor Evaluation Process is to ensure that DOF works only with reputable, capable,
and responsible suppliers who align with DOF’s values and sustainability commitments. The process includes:
What
How
Vendor Prequalification Request
The Supply Chain Manager reviews a Vendor Prequalification Request Form and approves or rejects the request.
Dealings involving Highly Sanctioned Countries require prior approval from DOF Legal. Approved requests are
registered in Factlines, and a survey link is issued for completion of VEQ Part 1 or Part 1+2, depending on risk level.
Submission of questionnaire Vendors complete and submit the questionnaire through the Factlines platform or, for Brazil, via EFCAZ.
Review questionnaire
Factlines generates an automated score based on the self-evaluation. This score, alongside identified red flags,
forms the basis for DOF’s approval decision.
Sustainability-related red flags include but are not limited to evidence of labour rights breaches, lack of
environmental permits, absence of anti-corruption policies, or inadequate HSEQ management systems. High-risk
findings trigger enhanced due diligence or onsite assessment.
Handling approval
Depending on the vendor level, approvals are provided by the Supply/Procurement Manager and, where applicable,
the HSEQ Manager. Additional stakeholders such as Finance or HR are consulted depending on subcontracted
activity.
In the Factlines system:
Scores ≤55% require formal justification and approval by the EVP or regional delegate.
Scores ≥55% but with red flags require follow-up and documented mitigation actions before approval.
Vendors approved electronically are transferred into UBW.
Non-approval
Vendors not approved undergo further review by Supply Chain , with input from HSEQ, Finance, HR, Legal and other
departments where required.
Non-approved vendors may be temporarily restricted, approved provisionally (AP) or permanently excluded based on
risk severity. Conditional approvals must include time-bound remediation and monitoring requirements
Vendor re-evaluation
All vendors must be re-evaluated within a maximum of 48 months Any significant change in the scope of the delivery
will require a re-evaluation.
2025 Assessment
DOF’s supplier assessment program ‘Basic A1’ evaluation is connected to the UN Global Compact and all suppliers are
required to complete this. Basic A2 is connected to ISO 9001, 14001 and 45001, providing a more comprehensive
overview and evaluation of suppliers across the realms of quality, safety and environmental management systems.
Total number of assessments undertaken in 2025 is 633 vendors.
Exemptions
In some cases, a full evaluation process is not considered necessary. In cases where procurement has been for
minor purchases like restaurant meal, magazines, booklets, newspapers, as well as invoices from local government,
police, fire brigade a formal vendor evaluation is not normally performed. In cases like this, the regional supply chain
managers are authorised to rate the suppliers as “exempted” from the approval process. A “vendor prequalification
- emergency exemption form” must be completed to formalise the exemption.
Monitoring, Audits, and Supplier Engagement
Suppliers are subject to risk-based onsite audits and follow-up assessments. High Criticality suppliers (Level 2),
high spend, or high HSEQ dependency) receive periodic onsite audits at a frequency aligned to their risk rating.
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The CoBC and its associated policies are reviewed and approved by the Audit Committee. DOF’s executives review
the CoBC annually, and the Board receives quarterly updates on cases raised through the whistle-blowing system.
Executive Management has implemented additional controls in higher-risk areas such as finance, procurement,
contracting and facilities management. All members of the DOF workforce, including new starters regardless of role,
must complete anti-bribery and corruption e-learning modules, refreshed every 2–4 years. In 2025, this training was
supplemented through the introduction of the Foreign Trade Controls and Management of Sanctions global guideline.
Supporting this document, DOF introduced additional e-learning modules on Dawn Raids, Competition and Antitrust
Law, and Foreign Trade Controls and Sanctions. These modules are intended for Regional Management Teams,
especially those in higher risk functions such as procurement, Business Acquisition and Chartering departments.
Awareness initiatives ensure all employees understand the importance of preventing bribery and corruption.
DOF communicates its policies through multiple channels, including email, value moments, intranet and training
sessions both onshore and offshore. Where needed, additional targeted or activity-specific training is provided to
employees and third parties. All training is delivered in DOF’s two business languages, English and Portuguese.
Policies are available in printed form, within DOF’s management systems, on the intranet and are displayed on all
vessels and at all sites globally.
Details of training delivered during the year are as follows:
Anti-corruption and bribery e-learning Nature and scope of training 2024 2025
DOF Code of Business Conduct DOF’s Code of Business Conduct for all employees 1223 1973
DOF Workbook - 2 A value-driven organisation Learn why we conduct business responsible 181 145
DOF Workbook - 4 Business Integrity and ethics
Corporate compliance, ethical behaviour and operational
excellence 1716 1320
Human Rights and Business
Human Rights and Business Awareness interactive video
produced by Amnesty International in cooperation with DOF 61 60
Introduction to the Maritime Labour
Convention (Maritime) Produced by DNV 7 4
Modern slavery awareness
Modern slavery Awareness e-learning produced by Slave
Free Alliance 8 3
Unannounced Investigation – Dawn Raids
Insights to what a Dawn Raid is and what a DOF employee
must know about these investigations.
Not available
in 2024 73
Competition and Antitrust Law Compliance in DOF
Supplementary information on competition and antitrust law
within the context of DOF and its business environment
Not available
in 2024 66
Foreign Trade Controls and Management of Sanctions
What sanctions and export controls are, why they matter and
how they can impact DOF operations.
Not available
in 2024 79
Grand Total 3196 3723
The business codes of conduct include a clear anti-corruption policy that outlines DOF’s position regarding
corruption and bribery and sets out expected behaviours and ethical standards for all employees. DOF conduct
All suppliers must meet DOF’s expectations regarding ethics, HSEQ, and sustainability performance. DOF conducts
performance monitoring throughout the contract lifecycle.
DOF provides suppliers with guidance on compliance expectations through the SCoC, CoBC and E-Learning
Modules. DOF has also held Supplier Workshops in Brazil to further align expectations in relation to Business
ethics, human rights and workplace harassment. These workshops are two-way conversations whereby ideas can
be exchanged and concepts clarified.
Misconduct, Escalation, and Termination
In cases of misconduct, DOF takes proportionate corrective action to mitigate risk. Triggers for escalation or
termination include whistle-blower cases, bribery and corruption, breaches of the SCoC, inadequate remediation
efforts, and serious health and safety violations. DOF has no cases of contract termination because of vendor
misconduct in 2025.
Sustainable procurement
Our sustainable procurement process includes qualifying suppliers based on their capability to safely and ethically
complete the subcontracted scope of work in addition to onsite assessments for major suppliers, and assessments
of indirect suppliers based on an evaluation of sustainability related risks.
DOF also recognises the importance of timely payments for small to medium enterprises (SMEs), ensuring fair
financial practices. For the purposes of this disclosure, small enterprises are defined as entities with 1-20 employees,
while medium-sized companies range from 21-100 employees.
DOF’s standard payment terms, as stated in its terms and conditions, are 60 days However, for the reporting year,
the average actual payment period was 41 days (Reference: ESRS G1-6 Payment).
To enhance payment efficiency, DOF uses electronic invoicing systems, including Peppol and EHF (Elektronisk
Handels Format, Norway).
SMEs facing payment issues can contact DOF at suppliers@dof.com, referencing the PO number This inbox is
monitored daily to ensure prompt assistance.
G1-3 Prevention and detection of corruption and bribery
DOF maintains a zero-tolerance approach to bribery and corruption, as outlined in our Code of Business Conduct
(CoBC). All employees, contractors and suppliers are encouraged to report any concerns through the dedicated
channel in our independent whistle-blowing system.
Investigations conducted via the ethics hotline are handled by a team that operates independently from the
management involved in the issue. DOF has established a structure where investigators are appointed based on
the nature of each report, ensuring they have the relevant expertise and understanding of any complexities. As
an additional safeguard, the system automatically excludes any individuals named in a case from participating
in its investigation. Investigation assignees bring a range of competencies, including HR, HSE, finance, marine
operations, and legal. Their role is to assess the case and provide recommendations to the Executive Management
Team or the CEO to ensure appropriate closure. Conclusions are implemented at the relevant organisational level.
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risk assessments to identify areas where corruption and bribery risks are highest. As part of our membership of
the Maritime Anti-Corruption Network (MACN) we also receive updates on recent developments and incidents. DOF
has implement robust financial controls to detect and prevent corrupt practices and have established systems to
monitor transactions and activities for signs of corruption.
G1-4 Incidents of corruption or bribery
No incidents related to fraud, corruption, bribery or breach of anti-trust or competition laws were reported in 2025.
The company did not receive any convictions or fines for violations of anti-corruption or anti-bribery law in the
year, nor has it been subject to any legal action relating to corruption and bribery.
G1-6 Payment practices
Payment terms listed in our General terms for Purchase is 60 days, unless agreed separately. Some specific
agreements may have payment terms of 30 or 45 days. In DOF the average days from invoice day until payment
for 2025 were 41 days and the percentage of invoices paid within 60 days is 87% .This is continuously monitored
through a payment analysis dashboard linked with the ERP system.
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Responsibility statement
Christine Morris
Director
Adrian Geelmuyden
Director
Storebø, 7 April 2026
The Board of Directors of DOF Group ASA
Svein Harald Øygard
Chair
Harald Thorstein
Director
Erik Bergöö
Vice Chair
Kristin H.Holth
Director
Mons S. Aase
CEO
Daniela Davila
Director
109 DOF INTEGRATED ANNUAL REPORT 2025 109 DOF INTEGRATED ANNUAL REPORT 2025
The consolidated financial statements have been prepared in accordance with IFRS® Accounting
Standards as adopted by EU, European Single Electronic Format (ESEF) regulations as well as additional
information requirements as per the Norwegian Accounting Act The financial statements for DOF Group
ASA have been prepared and presented in accordance with simplified IFRS pursuant of the Norwegian
Accounting Act.
We confirm to the best of our knowledge that:
►
The 2025 financial statements for the Company and the Group have been prepared in accordance
with applicable accounting standards,
►
The 2025 consolidated financial statements have been prepared in accordance with the
requirements of the Commission Delegated Regulation (EU) 2019/815 on the European Single
Electronic Format (ESEF Regulation) and regulation pursuant to Section 5-5 of the Norwegian
Securities Trading Act,
►
The information in the financial statements gives a true and fair view of the Company’s and the
Group’s assets, liabilities, financial position and result per 31 December 2025,
►
The integrated report 2025 meets the information requirements of the Norwegian accounting act
with regard to the Report of the Board of Directors and statements on corporate governance.
The integrated report for the Company;
►
Gives a true and fair view of the Company’s and the Group’s development, performance and financial
position, and includes a description of the principal risks and uncertainty factors facing the Company.
We further confirm to the best of our knowledge that:
►
The 2025 Sustainability Statements have been prepared in accordance with and meets the
information requirements of the Norwegian Accounting Act, European Sustainability Reporting
Standards (ESRS), EU taxonomy (Article 8 of EU Regulation 2020/852).
We confirm to the best of our knowledge that:
►
The Sustainability Statements have been prepared according to the Corporate Sustainability
Reporting Directive (CSRD) and the European Sustainability Reporting Standards ( ESRS).
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SUSTAINABILITY STATEMENTS - Responsibility Statement
Consolidated Statement of Profit or Loss
AMOUNTS IN USD MILLION Note 2025 2024
Operating revenue 5, 6, 7, 15 1 871 1 385
Payroll expenses
8, 30, 31
-616
-476
Other operating expenses
9, 14, 15, 30
-601
-480
Share of net profit of joint ventures and associates
16
Net gain (loss) on sale of tangible assets
13
Operating expenses -1 153 -910
Operating profit before depreciation and impairment - EBITDA 718 475
Depreciation
13
-203
-160
Impairment (-)/reversal of impairment
13
Operating profit - EBIT 523 413
Finance income
10
Finance costs
10
-131
-113
Realised currency gain (loss)
10
-53
-18
Unrealised currency gain (loss)
10
-127
Net change in unrealised gain (loss) on derivatives
10
Net financial items -16 -229
Profit (loss) before taxes 507 184
Tax income (cost)
11
-40
-6
Profit (loss) for the year 467 178
Attributable to;
Non-controlling interest
Controlling interest
Earning per share (USD)
12
Diluted earnings per share (USD)
12
Consolidated Statement of Comprehensive Income
Profit (loss) for the year 467 178
Other comprehensive income, net of tax
Items that may be reclassified to profit or loss
Currency translation differences
-2
Cash flow hedge
Share of other comprehensive income of joint ventures and associates
16
Total other comprehensive income for the year, net of tax 38 3
Total comprehensive income for the year net of tax 505 181
Attributable to;
Non-controlling interest
Controlling interest
FINANCIAL STATEMENTS - DOF GROUP
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Consolidated Balance Sheet Consolidated Balance Sheet
AMOUNTS IN USD MILLION Note 31.12.2025 31.12.2024
Assets
Tangible assets
13, 15, 22 2 427
Contract costs
14 42
Goodwill
33 3
Deferred tax assets
11 147
Investments in joint ventures and associated companies
10, 16 311
Other non-current assets
17, 26 150
Total non-current assets
Trade receivables
18, 26 444
Other current assets
19, 26 131
Current assets excluding cash
Restricted deposits
Unrestricted cash and cash equivalents
Cash and cash equivalents
20, 26
Total current assets
Total assets
AMOUNTS IN USD MILLION
Note 31.12.2025 31.12.2024
Equity and liabilities
Share capital
21 58 58
Other equity
21 1 986 1 714
Non-controlling interests
Total equity 21 2 044 1 772
Bond loan
22, 26 148 53
Debt to credit institutions
15, 22, 26 1 275 1 410
Lease liabilities
15, 22, 26 67 26
Other non-current liabilities
23, 26 24 31
Non-current liabilities 1 514 1 521
Current portion of debt
15, 22, 26 165 145
Current portion of lease liabilities
15, 22, 26 43 23
Trade payables
24, 26 250 219
Other current liabilities
25, 26 133 103
Current liabilities
Total liabilities
Total equity and liabilities 4 150 3 783
Christine Morris
Director
Adrian Geelmuyden
Director
Storebø, 7 April 2026
The Board of Directors of DOF Group ASA
Svein Harald Øygard
Chair
Harald Thorstein
Director
Erik Bergöö
Director
Kristin H. Holth
Director
Mons S. Aase
CEO
Daniela Davila
Director
FINANCIAL STATEMENTS - DOF GROUP
112 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
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Consolidated Statement of Changes in Equity
AMOUNTS IN USD MILLION
Share
capital
Other
contributed
capital
Retained
earnings
Currency
translation
differences
Cash flow
hedge
Total other
equity
Non-
controlling
interest Total equity
Balance at 01.01.2025
-4
-
Profit (loss) for the year
Other comprehensive income net of tax
Total comprehensive income for the year
Share option program
Dividend paid
-234
-234
-234
Total transactions
Balance at 31.12.2025
AMOUNTS IN USD MILLION
Share
capital
Other
contributed
capital
Retained
earnings
Currency
translation
differences
Cash flow
hedge
Total other
equity
Non-
controlling
interest Total equity
Balance at 01.01.2024
-7
Profit (loss) for the year
Other comprehensive income net of tax
-2
Total comprehensive income for the year
Share issues
Dividend paid
-1
-1
Changes in non-controlling interest
-8
-8
Other adjustments
-1
Total transactions
Balance at 31.12.2024
Consolidated Statement of Cash Flows
The statement of cash flows is prepared in accordance with the indirect model.
AMOUNTS IN USD MILLION Note
2025
2024
Operating profit
Depreciation and impairment
13
Profit (loss) on disposal of tangible assets
13
-15
-2
Share of net income of joint ventures and associates
16
-48
-43
Dividend from joint venture
16
Amortisation of contract cost
14
Additions contract costs
14
-33
-19
Change in trade receivables
18
-55
-13
Change in trade payables
24
Change in other working capital and other effects
-15
Cash from operating activities
Interest received
10
Interest and other finance costs paid
10
-123
-99
Tax paid
11
-40
-26
Net cash from operating activities
Payments received for sale of tangible assets
13
Purchase of tangible assets
13
-271
-97
Payment additions to right-of-use assets
-21
Consideration paid for acquisition of subsidiary net of cash acquired
33
-384
Payment received on sale of shares
Purchase of other shares
-11
Net cash flow from other non-current receivables
Net cash used in investing activities
-229 -442
Proceeds from borrowings
22
Repayment of debt to financial institutions
22
-1 339
-220
Repayment of lease liabilities
22
-34
-37
Share issues
Dividend paid
-234
Dividend paid to non-controlling interest
-1
Net cash from financing activities
-308 307
Net changes in cash and cash equivalents
-10 239
Cash included restricted cash at the start of the period
20
Exchange gain (loss) on cash and cash equivalents
-24
Cash included restricted cash at the end of the period
20
For further information, please see note 20 ‘Cash and cash equivalents’.
FINANCIAL STATEMENTS - DOF GROUP
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Financial reports / DOF Group
Notes to the Consolidated Financial Statements
Notes to the accounts group
1. Corporate information and going concern 114
2.
Summary of significant accounting policies 115
3. Financial risk management 116
4.
Climate Risk 118
5.
Management reporting 119
6. Segment information 120
7.
Operating revenue 121
8.
Payroll expenses 122
9. Other operating expenses 122
10.
Financial income and expenses 122
11. Tax 123
12.
Earnings per share 125
13.
Tangible assets 126
14. Contract cost 128
15.
Leases 129
16.
Joint arrangements and associates 131
17. Other non-current assets 132
18.
Trade receivables 133
19.
Other current assets 133
20. Cash and cash equivalents 133
21.
Share capital and share information 134
22.
Interest bearing debt 136
23.
Non-current liabilities 138
24.
Trade payables 138
25. Other current liabilities 138
26.
Financial assets and liabilities: Information on the balance sheet 138
27. Derivatives 140
28.
Guarantee 140
29.
Related parties 141
30. Remuneration to management, Board of Directors and auditor 142
31.
Share option scheme 143
32.
Companies within the Group 145
33. Significant acquisitions and disposals in the year 146
34.
Contingencies 147
35. Subsequent events 148
FINANCIAL STATEMENTS - DOF GROUP
114 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
115 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
116 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
2. Summary of significant accounting policies (continued)
FINANCIAL STATEMENTS - DOF GROUP
117 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
3. Financial risk management (continued)
FINANCIAL STATEMENTS - DOF GROUP
118 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
119 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
120 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
121 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
122 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
123 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
124 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
11. Tax (continued)
FINANCIAL STATEMENTS - DOF GROUP
125 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
126 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
127 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
13. Tangible assets (continued)
FINANCIAL STATEMENTS - DOF GROUP
128 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
129 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
130 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
15. Leases (continued)
FINANCIAL STATEMENTS - DOF GROUP
131 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
132 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
16. Investments (continued)
FINANCIAL STATEMENTS - DOF GROUP
133 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
134 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
20. Cash and cash equivalents (continued)
FINANCIAL STATEMENTS - DOF GROUP
135 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
21. Share capital and share information (continued)
FINANCIAL STATEMENTS - DOF GROUP
136 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
137 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
22. Interest bearing debt (continued) Changes in the interest bearing debt
FINANCIAL STATEMENTS - DOF GROUP
138 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
139 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
26. Financial assets and liabilities (continued)
FINANCIAL STATEMENTS - DOF GROUP
140 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
141 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
142 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
143 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
30. Remuneration to management, Board of Directors and auditor (continued)
FINANCIAL STATEMENTS - DOF GROUP
144 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
145 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
146 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
147 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
33. Significant acquisitions and disposals in the year (continued)
FINANCIAL STATEMENTS - DOF GROUP
148 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
FINANCIAL STATEMENTS - DOF GROUP
149 DOF INTEGRATED ANNUAL REPORT 2025
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
Statement of Profit or Loss
AMOUNTS IN USD MILLION Note 2025 2024
Operating revenue - -
Payroll expenses
2
-1
-1
Other operating expenses
3, 12
-3
-7
Operating expenses -4 -8
Operating profit (loss) before depreciation - EBITDA -4 -8
Depreciation
-
Operating profit - EBIT -4 -8
Finance income
4
789
4
Finance costs
4
167
128
Realised currency gain (loss)
4
-4
-20
Unrealised currency gain (loss)
4
5
-2
Net financial items 4 958 111
Profit (loss) before taxes 954 103
Tax income (expense)
5
-9
-1
Profit (loss) for the year 945 102
Statement of Comprehensive Income
AMOUNTS IN USD MILLION Note 2025 2024
Profit (loss) for the year 945 102
Other comprehensive income, net of tax
Currency translation differences
-
-
Other comprehensive income, net of tax - -
Total comprehensive income for the year 945 102
Balance Sheet
AMOUNTS IN USD MILLION Note 31.12.2025 31.12.2024
Assets
Investments in subsidiaries
4, 6
2 393
1 478
Investments other shares
-
-
Other non-current receivables
7, 9, 11
10
-
Total non-current assets
2 403 1 478
Trade receivable
8, 9, 11
1
2
Receivable Group companies
9
50
23
Other current assets
9, 11
2
2
Current assets excluding cash 53 26
Restricted deposits
-
-
Unrestricted cash and cash equivalents
205
7
Cash and cash equivalents
10, 11
205 7
Total current assets
258 34
Total assets
2 661 1 512
151 DOF INTEGRATED ANNUAL REPORT 2025
FINANCIAL STATEMENTS - DOF GROUP ASA
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
Balance Sheet
AMOUNTS IN USD MILLION
Note
31.12.2025 31.12.2024
Equity and liabilities
Share capital
58
58
Share premium
1 124
1 124
Other equity
907
195
Equity 2 088 1 376
Bond loan
148
-
Deferred tax liabilities
-
-
Other non-current liabilities
2
-
Non-current liabilities 151 -
Trade payable
9, 11
1
2
Debt to group companies
9, 11
418
12
Debt related to guarantees
13
-
120
Other liabilities
4
1
Current liabilities
422 136
Total liabilities
573 136
Total equity and liabilities 2 661 1 512
Storebø, 7 April 2026
The Board of Directors of DOF Group ASA
Statement of Cash Flows
AMOUNTS IN USD MILLION Note 2025 2024
Operating profit
-4
-8
Depreciation and impairment
-
-
Change in trade receivables
-
-
Change in trade payable
-2
2
Change in other working capital
1
-16
Cash from operating activities
4 -22
Interest received
14
4
Interest and other finance cost paid
-9
-
Tax paid
-
-
Net cash from operating activities
1 -17
Payment from sale of shares
2
-
Payments purchase of shares
-
-540
Dividend received
1
-
Receivable intragroup balances ‘cash pool’
-47
-
Payments other non-current intragroup balances
-74
-2
Net cash used in investing activities
-120 -542
Proceed bond loan
148
-
Proceed intragroup loan
74
-
Debt intragroup balances ‘cash pool’
332
-
Share issue
-
567
Dividend paid
-234
-
Net cash flow from financing activities
321 567
Net changes in cash and cash equivalents
201 8
Cash and cash equivalents at the start of the period
7 -
Exchange gain/loss on cash and cash equivalents
-2
-1
Cash and cash equivalents at the end of the period
206 7
Christine Morris
Director
Adrian Geelmuyden
Director
Svein Harald Øygard
Chair
Harald Thorstein
Director
Erik Bergöö
Vice Chair
Kristin H. Holth
Director
Mons S. Aase
CEO
Daniela Davila
Director
152 DOF INTEGRATED ANNUAL REPORT 2025
FINANCIAL STATEMENTS - DOF GROUP ASA
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
Statement of Changes in Equity
AMOUNTS IN USD MILLION
Share
capital
Share
premium
Paid-in
equity
Retained
earnings
Other
equity
Total
equity
Balance at 01.01.2025
58 1 124 1 182 195 195 1 376
Profit (loss) for the year
-
945
945
945
Other comprehensive income net of tax
-
-
-
-
Total comprehensive income for the year - - - 945 945 945
Share option scheme
-
-
-
1
1
1
Dividend paid
-
-
-
-234
-234
-234
Total transactions with owners - - - -233 -233 -233
Balance at 31.12.2025 58 1 124 1 182 907 907 2088
Balance at 01.01.2024
42
572
614
92
92
706
Profit (loss) for the year
-
102
102
102
Other comprehensive income net of tax
-
-
-
-
Total comprehensive income for the year
- - - 102 102 102
Share issues
16
551
567
-
-
567
Total transactions with owners 16 551 567 - - 567
Balance at 31.12.2024 58 1 124 1 182 195 195 1 376
On 18 February 2026 the Board of Directors resolved to distribute a dividend in the amount of USD 0.35 per
share. The resolution was made by use of the authorisation granted by the Company’s annual General Meeting
on 20 May 2025. The dividend was paid in NOK at NOK 3.344635 per share and with payment date 5 March
2026.
153 DOF INTEGRATED ANNUAL REPORT 2025
FINANCIAL STATEMENTS - DOF GROUP ASA
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
Financial reports / DOF Group ASA
Notes to the Financial Statement
1 Accounting principles 175
2
Payroll and number of employees 175
3 Other operating expenses 175
4
Financial income and expenses 175
5
Tax 176
6 Investments in subsidiaries 176
7
Other non-current receivables 176
8
Trade receivables 177
9 Intragroup balances 177
10
Cash and cash equivalents 177
11 Financial assets and liabilities: Information on the balance sheet 177
12 Remuneration to auditor 178
13 Guarantee commitments 178
14 Contingencies 178
15 Subsequent events 178
16 Confirmation from the Board of Directors and CEO 179
154 DOF INTEGRATED ANNUAL REPORT 2025
FINANCIAL STATEMENTS - DOF GROUP ASA
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
1. Accounting principles
The financial statements for DOF Group ASA have been prepared and presented in accordance with simplified
IFRS pursuant of the Norwegian Accounting Act and are based on the same accounting principles as the Group
statement with the following exceptions:
Investments in subsidiaries, joint venture and associates
Investments are based on the cost method.
Dividends
Dividends and group contributions are treated in accordance with the Norwegian Accounting Act and deviates
from IAS 10 no. 12 and 13.
For further information, reference is made to the consolidated accounts.
2. Payroll and number of employees
2025 2024
Fee to the Board of Directors
-1
-1
National insurance contributions
-
-
Other costs
-
-
Total -1 -1
See the Group’s accounts note 30 for information about the remuneration to the Board of Directors.
The Company has no employees.
3. Other operating expenses
2025 2024
Audit fee
-
-1
Consultants fee
-2
-6
Other operating expenses
-1
-
Total -3 -7
4. Financial income and expenses
2025 2024
Dividends from subsidiaries and other investments
714
-
Group contributions with tax exception
31
-
Interest income
13
4
Gain on sale of shares
-
-
Other financial income
31
-
Financial income 789 4
Interest costs
-16
-
Impairment (-)/Reversal of impairment (+) investment in subsidiaries
69
97
Impairment (-)/Reversal of impairment )+) receivable
-
23
Loss on sale of shares
-6
-
Net (loss) gain and accruals on guarantees *)
120
8
Other financial costs
-
-
Financial costs 167 128
Net gain (loss) on operational capital
-4
-20
Realised currency gain (loss) -4 -20
Net unrealised gain (loss) on operational capital
5
-2
Unrealised currency gain (loss) 5 -2
Total 958 111
*) Net (loss) gain on accruals on guarantees amount is USD 120 million (gain USD 8 million)
155 DOF INTEGRATED ANNUAL REPORT 2025
FINANCIAL STATEMENTS - DOF GROUP ASA
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
5. Tax
Tax consists of:
2025 2024
Tax payable
-9
-1
Change in deferred tax
-
-
Tax income (expense)
-9 -1
Reconciliation of nominal and effective tax rate
Profit before tax
954
103
Estimated tax income (expense) (22%)
-210 -23
Tax effect of;
Tax effect of non-taxable income and non tax-deductible costs
42
24
Income not subject to tax
161
-
Impact of Global Minimum tax
-2
-
Not included in deferred tax
-
-
Tax effect from taxation of result in Norwegian kroner (NOK)
-
-3
Tax income (expense) -9
-1
Reconciliation of tax payable in the balance sheet
Tax payable in the tax income (expense)
-9
-1
Tax effect on given group contribution
7
1
Tax effect on deferred tax assets, adjustment previous year
-
-
Tax effect on share issue costs recognised directly to the equity
-
-
Tax payable *) -2 -
*) The tax payable is recognised as other non-current liabilities on the balance sheet.
Basis of deferred tax 2025 2024
Total temporary differences 2 -
Loss carried forward
- -
Not included in deferred taxes
-
-
Basis for calculation of deferred tax / deferred tax assets (-)
2
-
Total deferred tax / deferred tax assets (-) (22%)
- -
6. Investments in subsidiaries
Directly owned subsidiaries Main business Nationality
Registered
office
Ownership
and voting
share
Result for
the year
(100%)
Equity
31.12
(100%)
Carrying
value
31.12
DOF Offshore Holding AS
Shipowning
Norway
Bergen
100%
213
1 399
1 504
DOF Subsea AS
Subsea engineering
Norway
Bergen
100%
471
920
682
Norskan AS
Shipowning/management
Norway
Austevoll
100%
112
13
187
DOF AS
Corporate
Norway
Austevoll
100%
-2
12
12
DOF Management AS
Management
Norway
Austevoll
100%
1
18
7
Total 2 393
Due to impairment indicators related to the DOF Group ASA’s activity in general, impairment testing has been
performed in order to calculate the recoverable amount for the company’s investments in subsidiaries. Each
subsidiary is a separate cash generating unit, which is tested separately for impairment. The recoverable amount
is tested against the fair value for each subsidiary. In the event that the calculated recoverable amount is lower
than book value of the investment, impairment is made to reflect recoverable amount.
Please see the Group’s account for information about impairment testing of non-current assets.
The impairment tests have resulted in reversal impairment of investments in subsidiaries with total USD 69
million (impairment USD 98 million).
7. Other non-current receivables
Note 2025 2024
Non-current receivables
10
-
Provision for losses
-
-
Total
10 -
156 DOF INTEGRATED ANNUAL REPORT 2025
FINANCIAL STATEMENTS - DOF GROUP ASA
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
11. Financial assets and liabilities: Information on the balance sheet
This note gives an overview of the carrying and fair value of the Company’s financial instruments and the
accounting treatment of these instruments. The table is the basis for further information regarding DOF Group
ASA’s financial risk. The table also shows the level of objectivity in the measurement hierarchy of each method
of measuring the fair value of the Company’s financial instruments.
31.12.2025
Financial
instruments
at fair value
through profit
or loss
Financial
instruments
measured at
amortised cost Total
ASSETS
Financial investment
-
-
Other non-current receivables
10
10
Trade receivable
1
1
Other current assets
53
53
Cash and cash equivalents
205
205
Total financial assets - 268 268
LIABILITIES
Bond loan
148
148
Other non-current liabilities
2
2
Trade payable
1
1
Other current liabilities
421
421
Total financial liabilities 572 572
Total financial instruments - -304 -304
31.12.2024
Financial
instruments
at fair value
through profit
or loss
Financial
instruments
measured at
amortised cost Total
ASSETS
Financial investment
-
-
Other non-current receivables
-
-
Trade receivable
2
2
Other current assets
25
25
Cash and cash equivalents
7
7
Total financial assets - 34 34
LIABILITIES
Trade payable
2
2
Other current liabilities
134
134
Total financial liabilities - 136 136
Total financial instruments - -102 -102
Prepayments and non-financial liabilities are excluded from the disclosures above.
8. Trade receivables
2025 2024
Trade receivable
-
-
Trade receivable to intragroup
1
2
Total 1 2
9. Intragroup balances
2025 2024
Non-current receivables
10
-
Provisions for losses
-
-
Total non-current receivables
10 -
Trade receivables
1
2
Receivable cash pool
47
-
Other current receivables
4
23
Total current assets
51
25
Trade payables
-
-
Debt cash pool
332
-
Other current debt
86
12
Total current debt
418
12
Net intragroup balances
-357 13
10. Cash and cash equivalents
2025 2024
Restricted cash
-
-
Unrestricted cash and cash equivalents
165
7
Money market funds
40
-
Total 205 7
157 DOF INTEGRATED ANNUAL REPORT 2025
FINANCIAL STATEMENTS - DOF GROUP ASA
DOF 2025
MANAGEMENT
REVIEW
CORPORATE
GOVERNANCE
SUSTAINABILITY
STATEMENTS
FINANCIAL
PERFORMANCE
12. Remuneration to auditor
Specification of auditor's fee AMOUNT IN TUSD 2025 2024
Audit
354
232
Fee for attestation required by law
77
197
Fee for other services
32
512
Total 463 941
All amounts in the table are excl VAT, except for fee related to share acquisition.
13. Guarantee commitments
The Company has issued guarantees to financial institutions on behalf of its wholly owned subsidiaries on
maritime mortgage/loans on a general basis.
In addition the Company has issued a guarantee in favour of debt of credit institution on behalf of DOFCON
Brasil Group (50% owned) in the amount of USD 94 million (USD 39 million).
A guarantee in favour of BNDES is given by DOF Subsea AS with USD 134 million and this guarantee is in
process to be moved to DOF Group ASA.
The Company has earlier years accrued debt related to guarantees on behalf of the subsidiary Norskan Offshore
Ltda. Based on improved earning, backlog and forecast going forward the accrual at year end 2025 is USD zero
(USD 120 million).
14. Contingencies
In the ordinary course of business, the Company is part in certain disputes of various scope. The resolution of
these disputes is associated with uncertainty, as they depend on legal proceedings, such as negotiations between
the parties affected.
Contingent liabilities are recognised in the accounts if there are more likely than not to occur. At year end 2025
there are no contingent liabilities in the accounts.
15. Subsequent events
Dividend
On 18 February 2026, the Board of Directors of the Company resolved to distribute a dividend in the amount of
USD 0.35 per share. The resolution was made by use of the authorisation granted by the Company at the annual
General Meeting on 20 May 2025. The dividend was paid in NOK at NOK 3.344635 per share. The payment
date was 5 March 2026.
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16. Confirmation from the Board of Directors and CEO
We confirm, to the best of our knowledge, that the financial statements for the period 1 January to 31 December
2025 has been prepared in accordance with approved accounting standards, and gives a true and fair view of the
Company’s consolidated assets, liabilities, financial position and result of the operations and that the Report of
Board of Directors provides a true and fair view of the development and performance of the business and the
position of the Group and the Company together with a description of the key risks and uncertainty factors that
the Company is facing.
Storebø, 7 April 2026
The Board of Directors of DOF Group ASA
Christine Morris
Director
Adrian Geelmuyden
Director
Svein Harald Øygard
Chair
Harald Thorstein
Director
Erik Bergöö
Vice Chair
Kristin H. Holth
Director
Mons S. Aase
CEO
Daniela Davila
Director
Confirmation from the Board of Directors and CEO
159 DOF INTEGRATED ANNUAL REPORT 2025
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PERFORMANCE
Independent auditor’s report
Independent Sustainability Auditor’s Limited Assurance Report
PricewaterhouseCoopers AS, org.no.: 987 009 713 MVA, Statsautoriserte revisorer, medlemmer av Den norske Revisorforening og autorisert regnskapsførerselskap
Advokatfirmaet PricewaterhouseCoopers AS, Org.no.: 988 371 084 MVA, Medlemmer av Advokatforeningen. advokatfirmaet@pwc.com
PwC Tax Services AS, Org.no.: 962 066 321 MVA, Autorisert regnskapsførerselskap, Medlem av Regnskap Norge
Torgallmenningen 14, 5014 Bergen, P.O, Box 3984 - Sandviken, NO-5835 Bergen, T: 02316 (+47 952 60 000) www.pwc.no
To the General Meeting of DOF Group ASA
Independent Sustainability Auditor’s Limited Assurance Report
Limited Assurance Conclusion
We have conducted a limited assurance engagement on the consolidated sustainability statement of DOF Group ASA
(the «Company») included in Sustainability Statements of the Board of Directors’ report (the «Sustainability
Statement»), as at 31 December 2025 and for the year then ended.
Based on the procedures we have performed and the evidence we have obtained, nothing has come to our attention that
causes us to believe that the Sustainability Statement is not prepared, in all material respects, in accordance with the
Norwegian Accounting Act section 2-3, including:
• compliance with the European Sustainability Reporting Standards (ESRS), including that the process carried out
by the Company to identify the information reported in the Sustainability Statement (the «Process») is in
accordance with the description set out in the subsection "IRO-1 Description of the process to identify and
assess material impacts, risk and opportunities"; and
• compliance of the disclosures in the subsection "EU Taxonomy" within the Environment section of the
Sustainability Statement with Article 8 of EU Regulation 2020/852 (the «Taxonomy Regulation»).
Basis for Conclusion
We conducted our limited assurance engagement in accordance with International Standard on Assurance Engagements
(ISAE) 3000 (Revised), Assurance engagements other than audits or reviews of historical financial information («ISAE
3000 (Revised)»), issued by the International Auditing and Assurance Standards Board.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our conclusion. Our
responsibilities under this standard are further described in the Sustainability Auditor’s Responsibilities section of our
report.
Our Independence and Quality Management
We have complied with the independence and other ethical requirements as required by relevant laws and regulations in
Norway and the International Code of Ethics for Professional Accountants (including International Independence
Standards) issued by the International Ethics Standards Board for Accountants (IESBA Code), which is founded on
fundamental principles of integrity, objectivity, professional competence and due care, confidentiality and professional
behaviour.
The firm applies International Standard on Quality Management 1, which requires the firm to design, implement and
operate a system of quality management including policies or procedures regarding compliance with ethical
requirements, professional standards and applicable legal and regulatory requirements.
Responsibilities for the Sustainability Statement
The Board of Directors and the Managing Director (Management) are responsible for designing and implementing a
process to identify the information reported in the Sustainability Statement in accordance with the ESRS and for
disclosing this Process in the subsection "IRO-1 Description of the process to identify and assess material impacts, risk
and opportunities" of the Sustainability Statement. This responsibility includes:
• understanding the context in which the Group's activities and business relationships take place and developing
an understanding of its affected stakeholders;
• the identification of the actual and potential impacts (both negative and positive) related to sustainability matters,
as well as risks and opportunities that affect, or could reasonably be expected to affect, the Group’s financial
2 / 4
position, financial performance, cash flows, access to finance or cost of capital over the short-, medium-, or long-
term;
• the assessment of the materiality of the identified impacts, risks and opportunities related to sustainability
matters by selecting and applying appropriate thresholds; and
• making assumptions that are reasonable in the circumstances.
Management is further responsible for the preparation of the Sustainability Statement, in accordance with the Norwegian
Accounting Act section 2-3, including:
• compliance with the ESRS;
• preparing the disclosures in the subsection "EU Taxonomy" within the Environment section of the Sustainability
Statement, in compliance with the Taxonomy Regulation;
• designing, implementing and maintaining such internal control that Management determines is necessary to
enable the preparation of the Sustainability Statement that is free from material misstatement, whether due to
fraud or error; and
• the selection and application of appropriate sustainability reporting methods and making assumptions and
estimates that are reasonable in the circumstances.
Inherent limitations in preparing the Sustainability Statement
In reporting forward-looking information in accordance with ESRS, Management is required to prepare the forward-
looking information on the basis of disclosed assumptions about events that may occur in the future and possible future
actions by the Group. Actual outcomes are likely to be different since anticipated events frequently do not occur as
expected.
Sustainability Auditor’s Responsibilities
Our responsibility is to plan and perform the assurance engagement to obtain limited assurance about whether the
Sustainability Statement is free from material misstatement, whether due to fraud or error, and to issue a limited
assurance report that includes our conclusion. Misstatements can arise from fraud or error and are considered material if,
individually or in the aggregate, they could reasonably be expected to influence decisions of users taken on the basis of
the Sustainability Statement as a whole.
As part of a limited assurance engagement in accordance with ISAE 3000 (Revised) we exercise professional judgement
and maintain professional scepticism throughout the engagement.
Our responsibilities in respect of the Sustainability Statement, in relation to the Process, include:
• Obtaining an understanding of the Process, but not for the purpose of providing a conclusion on the
effectiveness of the Process, including the outcome of the Process;
• Considering whether the information identified addresses the applicable disclosure requirements of the ESRS;
and
• Designing and performing procedures to evaluate whether the Process is consistent with the Company’s
description of its Process set out in the subsection "IRO-1 Description of the process to identify and assess
material impacts, risk and opportunities".
Our other responsibilities in respect of the Sustainability Statement include:
• Identifying where material misstatements are likely to arise, whether due to fraud or error; and
• Designing and performing procedures responsive to where material misstatements are likely to arise in the
Sustainability Statement. The risk of not detecting a material misstatement resulting from fraud is higher than for
one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the
override of internal control.
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Independent auditor’s report (continued)
4 / 4
Bergen, 7 April 2026
PricewaterhouseCoopers AS
Hanne Sælemyr Johansen
State Authorised Public Accountant – Sustainability Auditor
(This document is signed electronically)
3 / 4
Summary of the Work Performed
A limited assurance engagement involves performing procedures to obtain evidence about the Sustainability Statement.
The procedures in a limited assurance engagement vary in nature and timing from, and are less in extent than for, a
reasonable assurance engagement. Consequently, the level of assurance obtained in a limited assurance engagement is
substantially lower than the assurance that would have been obtained had a reasonable assurance engagement been
performed.
The nature, timing and extent of procedures selected depend on professional judgement, including the identification of
disclosures where material misstatements are likely to arise in the Sustainability Statement, whether due to fraud or error.
In conducting our limited assurance engagement, with respect to the Process, we:
• Obtained an understanding of the Process by:
o performing inquiries to understand the sources of the information used by management (e.g.,
stakeholder engagement, business plans and strategy documents); and
o reviewing the Company’s internal documentation of its Process; and
• Evaluated whether the evidence obtained from our procedures with respect to the Process implemented by the
Company was consistent with the description of the Process set out in the subsection "IRO-1 Description of the
process to identify and assess material impacts, risk and opportunities".
In conducting our limited assurance engagement, with respect to the Sustainability Statement, we:
• Obtained an understanding of the Group’s reporting processes relevant to the preparation of its Sustainability
Statement by:
o Obtaining an understanding of the Group’s control environment, processes, control activities and
information system relevant to the preparation of the Sustainability Statement, but not for the purpose of
providing a conclusion on the effectiveness of the Group’s internal control; and
o Obtaining an understanding of the Group’s risk assessment process;
• Evaluated whether the information identified by the Process is included in the Sustainability Statement;
• Evaluated whether the structure and the presentation of the Sustainability Statement is in accordance with the
ESRS;
• Performed inquiries of relevant personnel and analytical procedures on selected information in the Sustainability
Statement;
• Performed substantive assurance procedures on selected information in the Sustainability Statement;
• Where applicable, compared disclosures in the Sustainability Statement with the corresponding disclosures in
the financial statements and other sections of the Board of Directors’ report;
• Evaluated the methods, assumptions and data for developing estimates and forward-looking information;
• Obtained an understanding of the Company’s process to identify taxonomy-eligible and taxonomy-aligned
economic activities and the corresponding disclosures in the Sustainability Statement;
• Evaluated whether information about the identified taxonomy-eligible and taxonomy-aligned economic activities
is included in the Sustainability Statement; and
• Performed inquiries of relevant personnel and substantive procedures on selected taxonomy disclosures
included in the Sustainability Statement.
FINANCIAL STATEMENTS - DOF GROUP
161 DOF INTEGRATED ANNUAL REPORT 2025
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Independent auditor’s report (continued)
Report on the Audit of the Financial Statements
PricewaterhouseCoopers AS, org.no.: 987 009 713 MVA, Statsautoriserte revisorer, medlemmer av Den norske Revisorforening og autorisert regnskapsførerselskap
Advokatfirmaet PricewaterhouseCoopers AS, Org.no.: 988 371 084 MVA, Medlemmer av Advokatforeningen. advokatfirmaet@pwc.com
PwC Tax Services AS, Org.no.: 962 066 321 MVA, Autorisert regnskapsførerselskap, Medlem av Regnskap Norge
Torgallmenningen 14, 5014 Bergen, P.O, Box 3984 - Sandviken, NO-5835 Bergen, T: 02316 (+47 952 60 000) www.pwc.no
To the General Meeting of DOF Group ASA
Independent Auditor’s Report
Report on the Audit of the Financial Statements
Opinion
We have audited the financial statements of DOF Group ASA, which comprise:
• the financial statements of the parent company DOF Group ASA (the Company), which comprise the balance
sheet as at 31 December 2025, the statement of profit or loss, statement of comprehensive income, statement of
changes in equity and statement of cash flows for the year then ended, and notes to the financial statements,
including a summary of significant accounting policies, and
• the consolidated financial statements of DOF Group ASA and its subsidiaries (the Group), which comprise the
balance sheet as at 31 December 2025, the statement of profit or loss, statement of comprehensive income,
statement of changes in equity and statement of cash flows for the year then ended, and notes to the financial
statements, including material accounting policy information.
In our opinion
• the financial statements comply with applicable statutory requirements,
• the financial statements give a true and fair view of the financial position of the Company as at 31 December
2025, and its financial performance and its cash flows for the year then ended in accordance with simplified
application of international accounting standards according to section 3-9 of the Norwegian Accounting Act, and
• the consolidated financial statements give a true and fair view of the financial position of the Group as at 31
December 2025, and its financial performance and its cash flows for the year then ended in accordance with
IFRS Accounting Standards as adopted by the EU.
Our opinion is consistent with our additional report to the Audit Committee.
Basis for Opinion
We conducted our audit in accordance with International Standards on Auditing (ISAs). Our responsibilities under those
standards are further described in the Auditor’s Responsibilities for the Audit of the Financial Statements section of our
report. We are independent of the Company and the Group as required by relevant laws and regulations in Norway and
the International Ethics Standards Board for Accountants’ International Code of Ethics for Professional Accountants
(including International Independence Standards) (IESBA Code) as applicable to audits of financial statements of public
interest entities, and we have fulfilled our other ethical responsibilities in accordance with these requirements. We believe
that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.
To the best of our knowledge and belief, no prohibited non-audit services referred to in the Audit Regulation (537/2014)
Article 5.1 have been provided.
We have been the auditor of the Company for the 4 financial years from the incorporation 26 September 2022.
2 / 4
Key Audit Matters
Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the
financial statements of the current period. These matters were addressed in the context of our audit of the financial
statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters.
Valuation of vessels in a shipping company normally requires attention from the auditors. During 2025 we focused on the
Impairment indicator assessment for vessels. The prior year focus area Accounting for Business Combination – Maersk
Supply Services A/S (MSS) related to a non-recurring event and is consequently no longer an area of focus for the 2025
audit.
Key Audit Matters
How our audit addressed the Key Audit Matter
Impairment indicator assessment for vessels
As at 31 December, 2025, the Group
owned vessels with
a carrying value of
USD 2,130 million, including the
carrying value of
capitalised periodic maintenance.
During
the year,
no indicators of impairment or reversal of
material
previously recognised impairments were
identified at the balance sheet date.
Management considers each
separate vessel, together
with
its associated contract, to be a cash generating unit
(“CGU” o
r “vessel”) in their assessment of impairment
indicators
.
The changes that can be observed over a short period,
based on short contracts and individual events etc., must
be given a character of
a certain stability and duration
before the Group concludes that there is a significant
change that would require a new impairment assessment.
If a vessel
enters into a new long-term contract in the
reporting period with significant changes in the rates or
there are any specific events with impact on the cash
flow, there are indications of significant changes in value
for t
he specific vessels. Management assessed the
development in Price
-to-Book ratio of the Group, how the
market sentiment is, development in average broker
valuations
, average EBITDA per vessel type as well as
changes to the weighted average cost of capital.
We focused on this area due to the significant carrying
value of the vessels
and the judgement inherent in the
assessment of indicators of impairment or reversal of
previously recognised impairment.
Refer to note 13
- Tangible assets, where management
explains how they assess the value of the vessels and
ROVs.
We evaluated and challenged management’s assessment
of indicators of impairment
or reversal of previously
recognised impairment
and the process by which this was
performed.
We assessed management’s accounting
policy against IFRS
’ and obtained explanations from
management as to how specific requirements of the
standards, in particular IAS 36
– Impairment of assets,
were met.
We also assessed the consistency year on
year of the application of the accounting policy.
We
interviewed management and challenged the
assumptions
made in their assessment of potential
impairment indicators
. For certain key assumptions we
compared management’s assessments towards
external
market data
and reports. We considered changes in third-
party
broker valuations of the vessels, development in
day
rates for specific vessel types
, and development in the
Price
-to-Book ratio of the Group, as well as the
commercial terms of the
contract awards achieved by the
Group throughout 2025.
We read note 13
- Tangible assets, and assessed this to
be in line with the requirements.
Other Information
The Board of Directors and the Managing Director (management) are responsible for the information in the Board of
Directors’ report and the other information accompanying the financial statements. The other information comprises
information in the annual report, but does not include the financial statements and our auditor’s report thereon. Our
opinion on the financial statements does not cover the information in the Board of Directors’ report nor the other
information accompanying the financial statements.
In connection with our audit of the financial statements, our responsibility is to read the Board of Directors’ report and the
other information accompanying the financial statements. The purpose is to consider if there is material inconsistency
between the Board of Directors’ report and the other information accompanying the financial statements and the financial
statements or our knowledge obtained in the audit, or whether the Board of Directors’ report and the other information
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Independent auditor’s report (continued)
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• obtain sufficient appropriate audit evidence regarding the financial information of the entities or business
activities within the Group to express an opinion on the consolidated financial statements. We are responsible for
the direction, supervision and performance of the group audit. We remain solely responsible for our audit opinion.
We communicate with the Board of Directors regarding, among other matters, the planned scope and timing of the audit
and significant audit findings, including any significant deficiencies in internal control that we identify during our audit.
We also provide the Audit Committee with a statement that we have complied with relevant ethical requirements
regarding independence, and to communicate with them all relationships and other matters that may reasonably be
thought to bear on our independence, and where applicable, actions taken to eliminate threats or safeguards applied.
From the matters communicated with the Board of Directors, we determine those matters that were of most significance
in the audit of the financial statements of the current period and are therefore the key audit matters. We describe these
matters in our auditor’s report unless law or regulation precludes public disclosure about the matter or when, in extremely
rare circumstances, we determine that a matter should not be communicated in our report because the adverse
consequences of doing so would reasonably be expected to outweigh the public interest benefits of such communication.
Report on Other Legal and Regulatory Requirements
Report on Compliance with Requirement on European Single Electronic Format (ESEF)
Opinion
As part of the audit of the financial statements of DOF Group ASA, we have performed an assurance engagement to
obtain reasonable assurance about whether the financial statements included in the annual report, with the file name
DOF-Group-ASA-2025-12-31-en.zip, have been prepared, in all material respects, in compliance with the requirements of
the Commission Delegated Regulation (EU) 2019/815 on the European Single Electronic Format (ESEF Regulation) and
regulation pursuant to Section 5-5 of the Norwegian Securities Trading Act, which includes requirements related to the
preparation of the annual report in XHTML format, and iXBRL tagging of the consolidated financial statements.
In our opinion, the financial statements, included in the annual report, have been prepared, in all material respects, in
compliance with the ESEF regulation.
Management’s Responsibilities
Management is responsible for the preparation of the annual report in compliance with the ESEF regulation. This
responsibility comprises an adequate process and such internal control as management determines is necessary.
Auditor’s Responsibilities
For a description of the auditor’s responsibilities when performing an assurance engagement of the ESEF reporting,
see: https://revisorforeningen.no/revisjonsberetninger
Bergen, 7 April 2026
PricewaterhouseCoopers AS
Marius Kaland Olsen
State Authorised Public Accountant
(This document is signed electronically)
3 / 4
accompanying the financial statements otherwise appears to be materially misstated. We are required to report if there is
a material misstatement in the Board of Directors’ report or the other information accompanying the financial statements.
We have nothing to report in this regard.
Based on our knowledge obtained in the audit, it is our opinion that the Board of Directors’ report
• is consistent with the financial statements and
• contains the information required by applicable statutory requirements.
Our opinion on the Board of Directors' report applies correspondingly to the statement on Corporate Governance.
Our opinion on whether the Board of Directors’ report contains the information required by applicable statutory
requirements, does not cover the Sustainability Statement, on which a separate assurance report is issued.
Responsibilities of Management for the Financial Statements
Management is responsible for the preparation of financial statements of the Company that give a true and fair view in
accordance with simplified application of international accounting standards according to the Norwegian Accounting Act
section 3-9, and for the preparation of the consolidated financial statements of the Group that give a true and fair view in
accordance with IFRS Accounting Standards as adopted by the EU. Management is responsible for such internal control
as management determines is necessary to enable the preparation of financial statements that are free from material
misstatement, whether due to fraud or error.
In preparing the financial statements, management is responsible for assessing the Company’s and the Group’s ability to
continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern
basis of accounting unless management either intends to liquidate the Group or to cease operations, or has no realistic
alternative but to do so.
Auditor’s Responsibilities for the Audit of the Financial Statements
Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from
material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion.
Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with
ISAs will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are
considered material if, individually or in aggregate, they could reasonably be expected to influence the economic
decisions of users taken on the basis of these financial statements.
As part of an audit in accordance with ISAs, we exercise professional judgment and maintain professional scepticism
throughout the audit. We also:
• identify and assess the risks of material misstatement of the financial statements, whether due to fraud or error.
We design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient
and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement resulting
from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional
omissions, misrepresentations, or the override of internal control.
• obtain an understanding of internal control relevant to the audit in order to design audit procedures that are
appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the
Company's and the Group's internal control.
• evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and
related disclosures made by management.
• conclude on the appropriateness of management’s use of the going concern basis of accounting and, based on
the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast
significant doubt on the Company's and the Group's ability to continue as a going concern. If we conclude that a
material uncertainty exists, we are required to draw attention in our auditor’s report to the related disclosures in
the financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based
on the audit evidence obtained up to the date of our auditor's report. However, future events or conditions may
cause the Company and the Group to cease to continue as a going concern.
• evaluate the overall presentation, structure and content of the financial statements, including the disclosures, and
whether the financial statements represent the underlying transactions and events in a manner that achieves a
true and fair view.
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Performance measurements definitions
DOF Group ASA financial information is prepared in accordance with international financial
reporting standards (IFRS). In addition DOF Group ASA discloses alternative performance
measures as a supplement to the financial statement prepared in accordance with IFRS. Such
performance measures are used to provide an enhanced insight into the operating performance,
financing and future prospects of the company and are frequently used by securities analysts,
investors and other interested parties.
The definitions of these measures are as follows:
Financial reporting - Financial Reporting according to IFRS.
Management reporting - Investments in joint ventures (JV) is consolidated on gross basis in
the income statement and the statement of financial position. See the Group Accounts note 5 for
presentation of the bridge between the management reporting and the financial reporting.
EBITDA - Is defined as profit (loss) before depreciation, impairment, amortisation of financial
items, net financial costs and tax income (cost). EBITDA is measure which is useful for
assessing the profitability of operations, as it is based on variable costs and excludes depreciation,
impairment and amortised cost of financial items. EBITDA is also important is also in evaluating
performance relative to competitors.
EBIT - Is defined as profit (loss) for the year before net financial items and tax income (cost).
Interest bearing debt - Total of non-current and current borrowings.
2025 2024
Bond loans (non-current)
148
53
Debt to credit institutions (non-current)
1 275
1 410
Lease debt (non-current)
67
26
Current portion debt to credit institutions
165
145
Current portion of lease debt
43
23
Total bond loan, debt to credit institutions and leases 1 698 1 657
Accrued interest expenses
-5
-2
Total interest bearing liabilities 1 693 1 655
Net interest bearing debt - Is defined as Interest bearing debt less current and non-current
interest-bearing receivables and cash and cash equivalents. The use of the term “net debt” does
not necessarily mean cash included in the calculation are available to settle debts if included in
the term. See the Groups Accounts note 22 for presentation of net interest bearing debt.
Net interest-bearing debt is a non-IFRS measure for the financial leverage of the Group, a
financial APM the Group intends to apply in relation to its capacity for dividend distribution and/
or for doing investments, when and if the Group will be able to carry out its dividend distribution
and/or investments policy.
Debt ratio - Is defined as net interest bearing debt divided on total assets.
In addition the Group has the following performance indicators:
Utilisation of vessel - Utilisation of vessel numbers is based on actual available days including
days at yard for periodical maintenance, upgrading, transit or idle time between contracts.
Contract Back-log - Sum of undiscounted revenue related to secured contracts in the future.
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