Lerøy Seafood Group ASA

The company aims to reduce absolute greenhouse gas emissions (Scopes 1, 2, and 3) by 46% by 2030, using 2019 as a baseline. This target aligns with the 1.5°C global warming limit, and has been approved by the Science Based Targets Initiative (SBTi). In its 2023 CDP Climate response, the company also plans to submit a FLAG target to the SBTi within the necessary timeframe. Scope 3 emissions are 1,021,417 tCO2e, constituting approximately 85.17% of the company’s total emissions of 1,199,240 tCO2e. Therefore, the company must include Scope 3 emissions in its science-based target.

The Science Based Targets initiative (SBTi) has approved the company's commitment to reduce absolute greenhouse gas (GHG) emissions across Scopes 1, 2, and 3 by 46% by 2030, using 2019 as the baseline. This target is aligned with limiting global warming to 1.5°C. The company is considering changing the base year for this target. Additionally, while the company aims for climate neutrality by 2050, it has not indicated whether this target will be validated by the SBTi.

The company collaborates with suppliers to advance sustainable feed development and reduce Scope 3 emissions, holding quarterly meetings with feed suppliers and engaging in dialogue with stakeholders. It also partners with transportation providers to innovate in low-emission goods transport. By maintaining communication with public authorities and participating in policy-making, the company aims to mitigate climate-related risks and stay ahead of regulatory changes.

The company prioritises raw materials that support its greenhouse gas emissions reduction targets while maintaining biodiversity and other ESG factors. It is engaged in innovative projects, such as developing alternative feed ingredients with a lower carbon footprint, including microalgae, kelp, insect meal, and mussel meal. For instance, it uses 1.5–2% insect meal in some freshwater feeds to replace fish meal. Through a joint venture with Bellona Holding AS, the company produces macroalgae, sugar kelp, blue mussels, and polychaete near several sea farms. Additionally, it invests in regenerative agriculture and new sources of soy that require less fertiliser, reduced processing, and adhere to higher land use standards. This approach positively impacts CO2 emissions, water use, and biodiversity.

The company discloses its joint venture, Ocean Forest, with NGO Bellona Holding AS, aimed at reducing emissions and capturing excess nutrients from salmon and trout production. This initiative focuses on macroalgae, blue mussels, and polychaeta cultivation, particularly using blue mussels to trap CO2 and absorb nutrients at several farming sites. The company is investing in Marine Gas Oil alternatives and implementing measures to reduce transportation emissions. It also reports various R&D projects to reduce nitrate, phosphorus, and carbon dioxide emissions. The goal is to capture and collect sludge from smolt and farming operations. While manure management is not innovative, some sites now use new equipment to capture and store it for bio-gas and fertiliser purposes. The company plans to equip all farming operations with this technology in the future.

The company reports Scope 1 emissions of 168,064 tCO2e in 2023. Its Scope 2 emissions are 9,759 tCO2e (location-based) and 58,359 tCO2e (market-based). Scope 3 emissions totalled 1,021,417 tCO2e.

The company discloses Scope 1 and Scope 2 emissions from its farming segment for FY2023, amounting to 54,952 tCO2e and 4,312 tCO2e, respectively. It reports Scope 3 emissions from the "Purchased Goods and Services" category at 519,581.3 tCO2e, based on purchase volumes. The company collects carbon intensity data for fish feed from suppliers, accounting for 99.5% of purchased feed. Its reported GHG emissions for purchased fish feed include transportation emissions, relevant Scope 3 emissions, and land use change emissions, calculated using economic allocation. The company indicates in its 2023 Sustainability Library that its main fish feed supplier (EWOS) attributes 25% of its total GHG emissions to land use change, amounting to 72,362.6 tCO2e. However, a detailed breakdown of emissions specifically from land use change is not provided.

The company completed the latest CDP Climate Change questionnaire in 2023. Its GHG inventory data is audited by PwC.

Between FY2022 and FY2023, the company reduced its total absolute emissions by 1.48%, from 1,217,274 tCO2e to 1,199,240 tCO2e. From FY2021 to FY2023, emissions decreased by 8.3%, averaging an annual decrease of 4.2%. In 2023, the company achieved a 1.635% reduction in Scope 3 emissions, attributed to decreased emissions from fish feed. The emissions per kg of feed produced fell to 1.93 CO2e from 2.02 CO2e in 2022. For 2023, the company reported Scope 1 emissions of 168,064 tCO2e, Scope 2 emissions of 9,759 tCO2e, and Scope 3 emissions of 1,021,417 tCO2e.

In 2021, the company conducted its first climate scenario analysis using the TCFD framework to identify key climate change risks and opportunities. In Q2 2023, it completed a review of these risks, evaluating their impact using a matrix that considered time horizon, likelihood, and financial implications. This evaluation highlighted the need to expand scenario analysis to include a well-below 2°C scenario and a 4°C scenario, indicating increased transition and physical risks respectively.

The company acknowledges several climate-related risks and mitigation efforts, though the level of detail varies. Physical risks such as droughts and floods impacting feed ingredients like soy, wheat, rapeseed oil, and corn are recognised, with mitigation efforts including risk assessments and partnerships for alternative feed solutions. The impact of increased water temperatures on salmon is also highlighted, with references to physiological stress, disease, parasites, and harmful algal blooms, but without clear mitigation plans for heat stress itself. Increased adaptation costs related to veterinary services, medication, and relocation of facilities are mentioned, with mitigation efforts including Recirculating Aquaculture System (RAS) technology, cleaner fish, and semi-closed facilities, alongside significant investments in 2022. Financial risks from rising energy prices and potential carbon taxes are acknowledged, with electrification initiatives cited as mitigation, though uncertainty regarding future carbon pricing complicates planning. Carbon tax risks associated with reliance on Marine Gas Oil and diesel are noted, with mitigation through R&D into alternative fuels and low-carbon technologies. Finally, extreme weather events are acknowledged as a risk to assets and operations, though no detailed mitigation measures are disclosed, and the company reports no significant financial losses or damages from climate events in 2023.

The company does not disclose its commitment to align capital expenditures with its GHG targets.

The company requires raw materials to be ProTerra/Eurosoy certified and sourced from deforestation-free supply chains. Soy, wheat, rapeseed oil, and corn are key feed ingredients. According to its CDP disclosure, 70% of soy protein concentrate is sourced from Brazil, certified by ProTerra and deforestation-free, while the remaining 30% comes from non-deforestation-risk areas. Soy protein concentrate accounts for about 18% of the raw materials used in the company's fish feed. It reports that all sourced soy is ProTerra certified, traceable, and deforestation-free, with sourcing regions including Croatia, the Russian Federation, Ukraine, and the USA. A press release identifies three deforestation-free suppliers: Caramuru, CJ Selecta, and Imcopa/Cervejaria Petrópolis. Information on its website mentions engagement with Cargill regarding aquafeed. It also states that EWOS, owned by Cargill, supplies soy from Brazil; however, EWOS cannot be confirmed as entirely deforestation-free. The company conducted a comprehensive risk assessment of major feed ingredients, including soy, with independent research institution SINTEF. It acknowledges Brazil as a high-risk country for sourcing and purchases soy from Europe and the USA to mitigate this risk.

The company aimed to achieve a 100% deforestation-free value chain for soy by 2020, using 2008 as the baseline year, and has successfully met this target. It established an August 2020 cut-off date for three soy protein suppliers to ensure they are completely free from deforestation and land alteration activities.

The company discloses that 100% of its sourced soy is covered by its commitment, which applies to Brazil, the sole forest-risk country from which it sources soy.

The company has fulfilled its commitment to source only deforestation-free soy, with all soy from Brazil being ProTerra certified and verified as deforestation-free by a third party, DNV. It also completed the CDP Forests questionnaire in 2023.

The company states that sustainability is a central focus in its procurement processes and prioritises suppliers who maximise value while minimising environmental impact. It confirms that the soy used is sustainably produced and deforestation-free. If soy is not certified by a sustainability standard, suppliers must prove it meets equivalent requirements. The company discloses that its involvement in the 'Aquaculture Dialogue on Sustainable Soy Sourcing in Brazil' has ensured its three soy protein concentrate suppliers are 100% deforestation and land alteration-free. These suppliers also plan to implement a monitoring, reporting, and verification (MRV) system for full value chain traceability.

The company exclusively purchases ProTerra certified soy from Brazil, ensuring soy from other regions meets the same standard if not certified. It demands detailed information from feed suppliers regarding deforestation exposure and has clearly communicated that raw materials from deforested areas are unacceptable. The company has mapped its soy supply chain up to Tier 3 suppliers, achieving 100% coverage. Additionally, it addresses non-compliance by developing time-bound targets and milestones for suppliers to regain compliance.

The company is committed to incorporating new raw materials, such as microalgae, into its feed and conducts research and development to explore other materials, including blue mussels and sugar kelp. It has production facilities at seven locations, with five for sugar kelp and two for blue mussels. In 2022, the company produced 230 tons of sugar kelp, yielding 2.3 tons of protein, and anticipates a significant increase in 2023. Additionally, it produced 3 tons of blue mussel protein.

The company states that all its localities are 100% GLOBAL G.A.P/ASC certified for farming and has listed the certified farms. Additionally, its Lerøy facilities have certifications including GlobalG.A.P., ASC, MSC, BRC Global Standard for Food Safety, and FSSC 22000, with specified coverage locations.

The company discloses its feed composition as 31% marine raw materials (16% fishmeal and 15% fish oil) and 69% vegetable raw materials, including 17% soy protein concentrate. Of the soy used, 83% is ProTerra certified, and 97% of marine materials are certified by MSC and IFFO/Marine Trust, including FIP. The company reports a forage fish dependency ratio (FFDR) of 0.58 for fishmeal and 1.52 for fish oil. However, it does not provide separate FFDR figures for its Scottish and Norwegian salmon production.

As of 2023, the company reports that 97% of its marine ingredients in feed are certified, an increase from 94.6% in FY2022. However, the percentage of Proterra certified soy fell to 83% from 100% in 2022. The company's Biological Feed Conversion Ratio (FCR) for salmon increased from 1.14 in 2022 to 1.15 in 2023, while the FCR for trout decreased from 1.28 to 1.17. The Fishmeal and Fish Oil Dependency Ratio for marine ingredients (FFDRm) rose from 0.53 to 0.58, whereas the FFDR for oil (FFDRo) declined from 1.60 to 1.52. The company provides detailed data on the sourcing of fishmeal and fish oil, with forage fish comprising 60% and trimmings 40% of the marine raw materials. It utilised 36,222 metric tonnes of fishmeal and 36,129 metric tonnes of fish oil. In 2023, the company calculated a Protein Efficiency Ratio (PER) of 2.07 for its salmon production.

The company has partnered with the NGO Bellona to research alternative ingredients from lower trophic species. Although insect meal has been incorporated into its feed, the volumes remain small and costs high. The company aims to maximise the use of trimmings from its wild catch operations, with a minimum of 5% of marine raw materials for salmon feed consisting of trimmings. The wild catch segment focuses on reducing food loss by preserving residual raw materials and producing meal and oil for reintegration into the company's value chain. It is optimising the production of meal, oil, and ensilage on its trawlers. By 2025, all by-products from the white fish segment are to be used in feed for salmon and trout. The company is involved in projects to increase the use of alternative feed ingredients, such as blue mussels and sugar kelp, and emphasises maintaining communication with feed providers to promote sustainable ingredients. It is also part of the Ocean Forest joint venture, which produces microalgae and blue mussels near farming sites. Additionally, it utilises insect meal as a feed ingredient and has conducted a forward-looking risk assessment to identify potential risks related to dependence on soy, fish meal, and fish oil in the short term (2025), medium term (2030), and long term (>2030).

In 2023, the company allocated 50% of its R&D expenditure towards novel feed ingredients, investing approximately NOK 350 million over the past four years. It supports this initiative by purchasing algae oil and insect protein. The company's feed oil contains 7.5% EPA and DHA, and it reports Omega-3 levels in its salmon as at least 2.9g/100g. A graph reveals average EPA/DHA levels of 1.19g/100g in 2023. The company is investigating alternative sources for high-quality feed ingredients from the oceans and provides a roadmap detailing the planned increase in novel feed ingredients usage up to 2030. Currently, it utilises insect meal and microalgae as novel ingredients.

The company reports an average adult female lice level of 0.18 in 2023 but excludes its Scottish operations. It states it remained below Norway's regulatory limits for sea lice in the last reporting year but does not discuss regulatory limits for its Scottish farms. Thus, the disclosure only partially covers its operations.

The company has implemented measures to reduce lice by limiting sea exposure through the use of RAS technology to produce larger smolt and shorten sea production periods. It further employs preventive strategies such as biological control with cleaner fish, non-medicinal and medicinal methods, and semi-closed technology. The company reports the treatment of sea lice in cages and the quantities of delousing agents used but does not disclose the number or percentage of cleaner fish mortalities. It acknowledges occasional mortality rates above expected levels, primarily due to bacterial diseases, and states that remaining cleaner fish are euthanised after salmon harvesting. Additionally, the company has invested in cleaner fish husbandry, focusing on optimal environmental conditions, nutrition, logistics, handling, monthly health assessments by authorised personnel, and production biology.

In 2023, the company reported a total of 15,030 fish escapes from its aquaculture facilities, an increase from 10,544 in 2022 and only 4 in 2021. Contingency plans for escape incidents, recorded in the Quality Management System and communicated to the Directorate of Fisheries, are in place. The company has adopted the NYTEK standard and is collaborating with suppliers to improve equipment. It details strategies to prevent escapement, such as regular inspections of moorings, facilities, vessels, and equipment, along with using divers and remotely operated vehicles (ROVs). Employees receive comprehensive training in escape prevention, and costs attributed to escapes are disclosed as 3,500,000 NOK for 2023. The company aims for zero fish escapes by 2024 and has implemented measures to enhance safety during fish capture and relocation after sea lice inspections. Additionally, it has established Sporbarhet AS to provide efficient traceability services for salmon escapes through genetic tracing.

The company is implementing several initiatives to mitigate its impact on biodiversity, such as allowing sites to lie fallow for two months biennially, reducing plastic usage to prevent ghost fishing, enforcing feed control measures, and employing sustainable trawling methods. It has set species quotas to prevent overfishing and participates in the 'Fishing for Litter' initiative, which collects marine litter and debris. Additionally, the company aims to eliminate human-wildlife conflicts by 2028 and employs anti-predator nets around farms to prevent attacks.

The company monitors algae, focusing on risk periods and potential algal bloom indicators. If a risk is identified, nearby stakeholders are promptly notified. In the event of an algal bloom affecting its locations, a comprehensive action plan is enacted to mitigate the impact on the fish. Discussions with authorities and relevant parties may occur to consider relocating fish from the affected area if necessary.

The company has conducted a water-related risk assessment, revealing that 1-10% of its water withdrawal originates from water-stressed areas, as per WRI Aqueduct data. It identifies ten factories in Europe, specifically in the Netherlands, Spain, Turkey, France, and Portugal, as being in regions with medium to high water stress. In 2023, the company reported water consumption of 55,364.5 m3 in its production facilities, with 10,833 m3 sourced from water-stressed areas. It is committed to reducing freshwater withdrawals through initiatives like investing in water-saving equipment and technology, implementing RAS technology in smolt production, providing employee water management training, using advanced solutions to protect habitats, wildlife, and ecosystems, and exploring water purification technologies.

The company lacks a specific target for reducing overall water consumption but aims to reduce water withdrawal by 5% by 2025 in areas identified as having medium to high water stress risk, with 2022 as the baseline year. This target is limited in scope, as only 1-10% of its water withdrawal is from water-stressed areas. In its 2023 CDP water response, the company reported a 13.7% increase in water withdrawal from 2021 to 2022, attributed mainly to increased production volumes.

The company reports a total water withdrawal of 88,423,892 m3 for FY2023, comprising 86,390,969 m3 from surface water, 2,022,771 m3 from municipal sources, 10,155 m3 from groundwater, and 33,103,734 m3 from seawater. This marks an 8.63% reduction from FY2022. In FY2023, water consumption totalled 55.4 megalitres, with 10,833 m3 consumed in water-stressed areas, an increase from 3,023 m3 in the previous year. However, the overall water consumption decreased from 145,258 m3 to 55,364 m3. The company's water-related capital expenditure (CAPEX) was 47,270,929 NOK, and its operating expenditure (OPEX) was 31,789,065 NOK in 2023. Bellona acts as a third-party advisor on sustainable water quality and nutrient management, although the company does not confirm if its water-use data is third-party audited. Data was provided to CDP Water in 2023.

The company reports an increased focus on managing feed suppliers and ensuring efficient freshwater use in raw material production. According to its 2023 CDP Water response, water-related requirements are included in supplier contracts. In medium to high water stress areas, suppliers must develop KPIs for water reduction and implement efficiency programmes. Although feed suppliers are not explicitly required to have water reduction targets, it is implied this is expected. The company is addressing water scarcity concerns in some raw material production countries by partnering with fish feed suppliers. This collaboration has resulted in water conservation and efficiency plans, including risk assessments using the WRI Aqueduct tool, monitoring water stress, KPIs for reducing water withdrawals and improving water quality, and preventive actions. The company actively works with suppliers to evaluate progress, engaging in dialogue to find solutions if requirements are not met. Additionally, the company, with feed producers and Sintef, has completed a raw material climate risk analysis. This analysis includes factors such as availability, CO2 emissions, pricing, climate risk, and water usage. The tool will be continuously updated with new raw materials to serve as a comprehensive decision-making resource.

The company reports a feed water intensity of 0.024 m3/kg for 2023. It also discloses the WRI water scarcity scores for regions from which it sources feed ingredients. In Brazil, 70% of soy comes from areas with low water stress (WRI score <10%). In Europe, 30% of soy and 100% of wheat are sourced from areas with low to medium water stress (WRI score <20%), while 100% of rapeseed is sourced from regions with medium-high water stress (WRI score <40%).

All water-related non-conformities are managed and documented within the company's Quality Management System, enabling trend monitoring and implementation of corrective actions. In 2023, there were no major wastewater spill incidents or regulatory violations related to water use or discharge. The company utilised the WRI Aqueduct tool for a risk assessment in 2023, identifying four facilities in varied risk areas. Facilities in Italy, Sweden (Lerøy Smøgen Seafood AB and Lerøy Kungälv AB), are in low to medium risk zones, while the facility in Turkey operates in a medium to high risk area. The company's goal is for all facilities to comply with national regulations and discharge limits, adhering to World Bank standards where applicable. However, the company's high-risk Turkish site has a wastewater Chemical Oxygen Demand (COD) of 800 mg/L, exceeding the World Bank target of 125 mg/L. Additionally, the targets for Total Phosphorus (TP) and Total Nitrogen (TN) in a high-risk French facility are 50 mg/L and 150 mg/L, above the World Bank standards of 2 mg/L and 10 mg/L. This indicates that standard compliance is not consistently achieved. The company aims to reduce wastewater volume by 5%. Although the target date is unspecified, there was a reported 9% decrease in wastewater volume in 2023.

The company reports discharging 88,365,472 m³ of wastewater in 2023 but does not disclose the actual quality of wastewater across all operations for the period. While some ESG indicators are audited by PWC, it does not specify that water-related data is audited. Additionally, this audit information is not included in its online sustainability library for 2023. Wastewater information was disclosed in the company's 2023 CDP Water report.

The company discloses that sludge from juvenile fish production wastewater is composted to create fertiliser or used for biogas production. All wastewater from Lerøy Smøgen Seafood AB is directed to an external biogas facility. Sludge is collected via a fine-mesh groove at the cage's base, filtered, and stored in a surface tank. The company reports an 8.6% reduction in wastewater discharge, from 96,630,139 m³ in 2022 to 88,365,472 m³ in 2023. However, it does not provide information on improvements in overall wastewater quality compared to the previous period.

The company has engaged Bellona as a third-party advisor on sustainable water quality and nutrient management within its supply chain, though it is unclear if this extends to its feed supply. It does not specify whether it requires feed to be sourced from suppliers with a nutrient management plan. The company collaborates with its feed suppliers on water risk and nutrient management plans, aiming to understand suppliers' risk profiles concerning water and waste management and the necessary actions to mitigate these risks. It encourages suppliers to implement regenerative agriculture practices to reduce fertiliser use and improve soil health. In 2023, the company purchased approximately 10,000 tonnes of materials produced using these methods. In collaboration with its feed producer, the company is investing in regenerative agriculture and sourcing soy grown with reduced fertiliser use to minimise the risk of nutrient pollution.

The company is implementing new feed ingredients, including insect meal and microalgae, and is exploring the use of kelp and mussels for fish feed. In partnership with its feed producer, the company is investing in regenerative agriculture and new soy sources that require less fertiliser. The company is finalising a risk assessment survey to better understand suppliers' risk profiles concerning water infrastructure, sustainable water withdrawal, buffer zones, and pesticide use in agriculture. While the challenges with pesticide use in soy protein concentrate production are acknowledged, no further information on mitigation efforts is provided.

The company conducts MOM-B evaluations, performed by an independent third party, both before approving operations and during fish farming at its facilities. These evaluations involve collecting seabed samples beneath and near the cages, focusing on fauna, chemical, and sensory investigations. Additionally, all active fish farms undergo routine monitoring programs. MOM-B and/or MOM-C environmental surveys are performed annually around each fish farm, especially during biomass peaks or at maximum production capacity. The company aims for all non-organic waste to be reused or materially recovered. In 2023, the recycling rate of inorganic waste remained stable at around 45%, with targets to increase to 50% by 2025 and 65% by 2030. However, it does not provide detailed metrics or methods in its disclosure. The company reports MOM-B assessment results, which measure organic loading and other factors. These third-party assessments show an average score of 1.32, with a target of less than 1.5 per location. 76% of sites achieved a MOM-B score of 1, and 17% scored 2, indicating most operations do not exceed their carrying capacity. The company has a detailed fallowing policy to minimise infection pressure and environmental impact. All sites are fallowed and washed every two years. In regions where the company operates, fallowing and stocking periods are coordinated within zones defined by the Norwegian Food Safety Authority, with companies participating in an Area Based Management scheme.

The company discloses that it engages local stakeholders through community meetings to discuss concerns and questions related to its operations.

The company has an antibiotics policy emphasising restricted antibiotic use, aligning with WHO guidelines. Antibiotics are considered a last resort, only used under veterinary supervision in confirmed disease cases. Preventative measures, such as vaccination and disease control, are highlighted to minimise antibiotic need, demonstrating a strong commitment to managing antibiotic resistance. In aquaculture operations, the policy prohibits routine antibiotic use and their use for growth promotion. Antibiotics are only employed when necessary, under authorised fish health personnel's supervision, ensuring adherence to WHO guidelines. While the policy does not adopt a 'no antibiotics ever' stance, it ensures controlled use when medically indicated. The company has implemented welfare measures to reduce antibiotic use, including biosecurity, sterilisation practices, and vaccination programmes. It employs functional feeds with innovative ingredients like insect meal and microalgae to enhance fish health. Other strategies include selective breeding, early diagnosis, routine health monitoring, and extensive training in fish welfare. Additionally, the company engages in research and development, focusing on fish health improvements and alternative feeds. However, it does not address routine mutilation, and maximum stocking density remains undisclosed.

The company reports that 0 kg of antibiotics were used in both seawater and onshore operations for 2023, using industry-standard units. This data, along with several ESG indicators, is audited by PwC, the group’s independent auditor.

The company is committed to high animal welfare standards, focusing on protecting fish from unnecessary stress and impact. It adheres to the "Five Freedoms" of animal welfare, utilising the Fishwell standard to monitor conditions such as eye reflex and skin health. Key measures include selective breeding, rigorous biosecurity, vaccinations, and rapid diagnosis and treatment. Water quality is maintained, especially during transport, through semi-closed and submersible cages to ensure comfort. Comprehensive employee training is mandatory, covering legislation, fish health biology, stress management, and humane handling protocols, including stunning techniques for slaughter. The company discloses handling protocols specifically designed for animal welfare and monitors welfare indicators throughout the production cycle and during harvest. Higher welfare stunning techniques, either electrical or percussive, are employed across operations to anaesthetise fish before bleeding, ensuring a humane treatment process.

The company reports an average stocking density of 7.7 kg/m³ for salmon in 2023 but does not guarantee this density is maintained consistently throughout the production cycle. It discloses animal welfare metrics, including stocking densities for various aquatic species and monitors the proportion of fish at sea without lesions or wounds. Welfare indicators include skin health, deformities, fin damage, eye status, and maturation, following the Fishwell standard. Additionally, the company employs a risk-based water quality monitoring and control programme during transport, tracking temperature, dissolved oxygen, and pH to ensure optimal conditions.

The company invests over 500 million NOK in R&D to improve fish welfare and environmental conditions. This funding supports new coastal production technologies, such as semi-closed and submerged cage systems, focused on sea lice management and fish health enhancement. Additionally, it implements measures for cleaner fish, including customised habitats with artificial kelp, species-specific feed, and daily care by dedicated personnel.

The company discloses mortality data for its sea and freshwater operations across all regions for 2023, with survival rates recorded at 91.5% at sea and 91.3% on land. It also provides detailed incident-based mortality data for various causes, reporting in 2023 that sea lice treatments resulted in the death of 1.1 million fish (2,544 tonnes of biomass), Cardiomyopathy Syndrome (CMS) resulted in the death of 1 million fish (3,698 tonnes of biomass), and bacterial wounds led to the death of 2.2 million fish (4,346 tonnes of biomass). The company has set a target to improve survival rates to 94.5% at sea and 93% on land by 2024. However, in 2023, the company fell short of these targets, achieving 91.5% survival at sea and 91.3% in freshwater.

The company reports on disease outbreaks and mortality causes from 2021 to 2023, detailing the loss in fish and biomass. There is no clear downward trend in disease outbreaks during this period. Biomass lost to Cardiomyopathy Syndrome (CMS) increased from 3,653 tonnes in 2021 to 3,698 tonnes in 2023, and biomass loss due to bacterial wounds fluctuated without consistent decline. The company uses non-medicinal methods to prevent disease, focusing on biosecurity and strategic pen placement. Measures include enhancing fish resilience during the freshwater phase, vaccinating fish before sea transfer, and employing submerged and semi-closed cages to reduce sea lice impact and improve health.

The company has disclosed a comprehensive human rights policy, committing to the International Bill of Human Rights, relevant human rights conventions, the ILO's declaration on fundamental principles and rights at work, the UN's guiding principles on business and human rights, and the OECD guidelines for multinational enterprises.

The company has conducted a risk assessment to identify potential or actual adverse impacts on fundamental human rights and working conditions, in accordance with OECD guidelines, by mapping industrial, geographical, product/service, and company risks based on severity and likelihood. It conducts physical audits of major suppliers and evaluates its supply chain risks, with a focus on health and safety, discrimination, and harassment. As part of its compliance with the Norwegian Transparency Act in 2023, the company undertook due diligence assessments, with findings to be published by June 2024. The company has developed a new Supplier Code of Conduct and Supplier Declaration Form, emphasising human rights, decent working conditions, anti-corruption, and anti-money laundering measures. It has a robust system for monitoring and auditing supplier practices and actively identifies and addresses human rights risks, conducting due diligence and publicly reporting its actions and findings. The company takes accountability for negative impacts and sets follow-up actions with assigned responsibilities and deadlines. Continuous improvement efforts focus on communicating ethical standards and providing regular training for employees, including managers trained to handle human rights incidents. The company has instituted risk mitigation measures, such as ethical guidelines for suppliers, enhanced follow-up actions, reporting channels, and regular e-learning courses for employees.

The company reports no actual human rights abuses or significant risks in its 2023 Human Rights Due Diligence process, as disclosed in its Transparency Act Report. It plans to focus efforts on health and safety, discrimination and harassment, and corporate governance for both suppliers and customers. Proactive measures include setting goals to increase female leadership representation, collaborating with Norwegian fishing groups to combat harassment, and conducting regular employee surveys to assess workplace experiences. The company is encouraged to provide more detail on preventative measures in future reports.

The company prohibits child labour, forced labour, abuse, discrimination, and harassment. Its compensation policy is designed to ensure all employees' wages cover their basic needs. All company farms have received Global Gap or ASC certification and are audited annually by independent parties on human rights matters. The company's code of conduct, integrated into supplier and subcontractor contracts, reinforces the prohibition of child labour, forced labour, abuse, discrimination, and harassment. Although the code does not explicitly mention compensation or fair wages, the 2023 Annual Report suggests these requirements are shared with suppliers, presumably promoting fair wages. The company confirms that all employees receive sick pay regardless of contract type, and its operations meet living or minimum wage standards. In Norway, the company covers any difference between state-provided sick pay and the employee's salary, or follows collective agreements in its trawler company. However, while it advances wages during sick leave in Italy and Spain, there is no clear evidence that these match the same standards as in Norway. Therefore, while the company provides adequate sick pay disclosure for most operations, it lacks comprehensive coverage.

The company conducts regular audits and monitors suppliers to ensure compliance with its Code of Conduct. It provides an anonymous whistleblowing system for internal and external parties, with grievances submitted via a digital platform initially processed by Ernst & Young. The company's whistleblowing committee oversees follow-up actions. It is unclear if stakeholders contributed to the system's creation. The company also has an anonymous grievance mechanism for its supply chain. In 2023, it reported nine internal whistleblowing incidents: three related to workplace harassment, two concerning sexual harassment, and four involving breaches of the Code of Conduct/Policies. Additionally, there was one uncategorised external whistleblowing incident. The company noted 22 external cases in 2023, resulting in a total of 31 cases, which included three external instances concerning the Norwegian Transparency Act and 18 complaints from neighbours.

The company aims to maintain safe and healthy workplaces, prevent occupational injuries and diseases, and continually improve health and safety performance. It confirms compliance with occupational health and safety laws in all operating countries and follows the principles of ISO 45001:2018, though it does not declare ISO 45001 certification. The company states that 83% of its group entities have formal joint management-worker health and safety committees or safety representatives. In smaller group entities where these committees are not required, safety representatives have been appointed. The company conducted an evaluation in 2023 to assess employee resistance to antibiotics but does not disclose further details or the results and is encouraged to do so.

The company reports an increase in the H1value/Lost Time Injury Frequency Rate (LTIFR) from 13.31 in 2022 to 18.73 in 2023. There were no fatalities in 2022 and 2023, compared to one fatality in 2021. The turnover rate for 2023 is disclosed as 11.56%, but this figure is not broken down by seniority level.

The company supports employees’ rights to freely associate and engage in collective bargaining across its operations, with suppliers, and in various regions. In 2023, 1,564 employees were members of trade unions. To promote these rights, union representatives participate in orientation sessions for new hires, emphasising the importance of association freedom and collective bargaining. Contact information for employee representatives is available on the company’s intranet, in the employee manual, or on notice boards. Additionally, union representatives maintain a dedicated bulletin board for information dissemination. The company also mandates that its suppliers, subcontractors, and business partners adhere to its supplier code of conduct, which includes commitments to freedom of association and collective bargaining agreements.

Collective bargaining agreements cover 65% of the company's workforce in Norway and 59% of its international employees. Employees not covered by unions receive the same employment terms and conditions as unionised counterparts. For the fiscal year 2023, the company reported a total employee count of 6,013, including 5,342 directly employed staff and 671 subcontracted employees. Additionally, it employs 768 temporary staff and 757 part-time workers.

The company's processing facilities are certified under GFSI-recognised standards, including IFS, BRC, and FSSC 22000, and hold chain of custody certifications for ASC, GlobalGAP, organic, and Lerøy SalmonTM. In 2023, 93% of these facilities have achieved GFSI certification, with a goal of reaching full certification by 2025. The company requires all raw material suppliers to obtain GFSI certification where applicable. However, it is unclear if all current suppliers meet this standard, though it is likely that most do.

In 2023, the company conducted 973 internal audits and 66 supplier audits for food safety. It has implemented consumer-facing technology for food safety with its Fishtrack system, offering comprehensive traceability for all seafood products from parent fish to processing stages, including details on brood stock, juvenile fish, sea farm location, feed, treatments, and quality analyses. Additionally, the company launched a blockchain-based traceability system via IBM Food Trust, providing consumer-facing QR codes in retail locations.

The company has a product recall system with central and local emergency preparedness groups, regular tests, and established communication protocols with customers and authorities. This process is designed to initiate and complete recalls within four hours, allowing a rapid response. All recalls are documented in the quality system, with corrective actions taken to prevent recurrence. In 2023, the company reported three recalls: two due to listeria detection and one from a labelling error, totalling 568 kg of products. Corrective actions and root cause analysis were conducted to prevent future issues. The company employs a robust food safety approach through integrated systems. Its Live Food Safety Microbiological Reporting System detects and responds to non-conformities by receiving lab results directly, featuring Automated Alerts and Trend Analysis to issue warnings and visualise data for preventive actions, such as blocking equipment when Listeria is detected. Food Safety Culture Surveys assess attitudes and behaviours to enhance the safety culture.

The company reports no market bans on its products in 2023.

The company's board oversees sustainability and ESG issues, including strategic oversight, risk management, and climate targets. The CEO primarily handles sustainability, requiring Group management approval before matters proceed to the audit committee or board. The Head of ESG & Quality coordinates these efforts across the Group, delegating specific responsibilities to the Managing Directors of each subsidiary. The company conducts a materiality assessment and publicly discloses the results. This assessment, last carried out in 2022, aligns with GRI Standards 2021. A review in November 2023, involving stakeholders such as PwC and the Norwegian Seafood Federation, confirmed 12 material topics, including Climate Emissions, Biodiversity, and Supply Chain Traceability. These outcomes were evaluated by the Management Team, Audit Committee, and Board of Directors. A double materiality assessment is planned for 2024, in line with the EU’s Corporate Sustainability Reporting Directive. The board includes members with sustainability expertise. Britt Kathrine Drivenes, on the board since 2008, brings extensive industry and ESG experience and serves as the key resource on these matters. Didrik Munch, a member since 2012, contributes significant ESG knowledge from his board roles in major Norwegian companies. In 2024, Linda Kidøy Pedersen, with expertise in food safety, joined the board. Munch offers extensive experience in product development and innovation, having led efforts in product and service marketing and innovation programme management during his tenure as CEO of Bergens Tidende AS and Schibsted Norge AS.

The company links executive remuneration to sustainability performance, offering performance-based bonuses for achieving ESG and water-related targets. However, it does not specify the percentage of variable compensation tied to these metrics. The company actively engages with public policy officials and trade associations on ESG issues. It collaborates with organisations such as the Norwegian Seafood Federation, aligning sustainability goals with the UN Sustainable Development Goals. Its memberships in groups like the UN Global Compact, Global Sustainable Seafood Initiative, and Amnesty International underscore its consistent stance on climate change, animal welfare, and ESG disclosure. Additionally, the company partners with NIFES to research the impact of algal toxins on fish and consumers. It participates in public debates when aligned with its interests but does not support individual political parties. The company is committed to policy engagements that adhere to the goal of limiting global temperature rise to 1.5°C, consistent with the Paris Agreement. It aims to reduce GHG emissions by 46% by 2030 from a 2019 baseline, supported by its Science Based Target.

The company is committed to sustainable innovation, investing in research and development to enhance sustainable food production and next-generation proteins while reducing environmental impact. Initiatives include high-voltage shore power plants, the "One Lerøy" Product Development Team, and the Ocean Forest project for seaweed production. The company seeks growth through innovative solutions and alliances, using local expertise to reduce food waste and meet changing customer needs. It explores sustainable raw materials such as algae, insects, and krill, collaborating with Ocean Forest AS to focus on low trophic species like macroalgae and blue mussels. Benchmarking its sustainability and innovation against peers, the company uses the Coller FAIRR Protein Producer Index, CDP, and ESG100. Its sustainability reporting follows the GRI framework and its ESG performance is evaluated by various organisations.

The company recognises the growing consumer interest in plant-based fish alternatives, anticipating a rapid increase similar to other alternative proteins, driven by macro trends specific to the fish and shellfish industry. It notes the expansion of the vegan market, aligning with the demand for sustainable food, and plans to offer a variety of fish and plant-based fish alternatives to meet customer needs. The company does not provide sales or revenue data from alternative proteins. It is adopting technological advancements in alternative protein production to meet market demand and is encouraged to establish goals for diversifying protein sources.

The company observes an increasing interest in plant-based fish alternatives, consistent with the expanding vegan market driven by the demand for sustainable food. It plans to meet this demand with a diverse range of fish and plant-based alternatives. The company is encouraged to provide more details on this strategy. In 2021, the company initiated an R&D project aimed at diversifying into plant-based protein products and sought partners to find suitable fish protein replacements. While trials in 2022 did not meet desired standards in texture, taste, and appearance, testing continued into 2023. The primary goal is to launch a vegan burger using vegetable protein, featuring ingredients like vegetable puree and dried sugar kelp. It is also developing products from vegetable raw materials and sugar kelp from Ocean Harvest, such as sugar kelp pesto and salads. The company faces challenges in replicating the texture of Atlantic salmon but intends to introduce its plant-based products to market by 2024.