Salmar ASA

The company has established a science-based target to reduce its Scope 1, 2, and 3 emissions by 42% between 2020 and 2030. Scope 3 emissions, at 1,305,000 tCO2e, constitute approximately 98% of its total emissions of 1,335,800 tCO2e, necessitating their inclusion in the Science Based Targets initiative.

The company's Scope 1, 2, and 3 emission reduction targets are aligned with the 1.5°C scenario by 2030. It has mentioned evaluating a Net Zero target but has not disclosed a commitment to setting one validated by the Science Based Targets initiative (SBTi).

The company states that fish feed comprises nearly 55% of its Scope 3 emissions. It is conducting trials with its feed suppliers to reduce these emissions by incorporating more climate-friendly ingredients and improving agricultural practices, including regenerative methods to enhance biodiversity and soil health. Through collaborations, such as the Råvareløftet initiative, the company has achieved a 29% reduction in total emissions from feed farming since 2020.

The company is collaborating with its feed suppliers on trials to reduce emissions from feed farming and is implementing solutions as new best practices are discovered. This includes using novel feed ingredients with lower carbon footprints and adopting innovative solutions for sustainable feed sourcing. It is also involved in research and development projects testing local feed ingredients like algae, insect meal, kelp, salmon oil, seafood trimmings, and surplus processing materials to minimise the environmental impact and reduce agricultural nutrient spills. Moreover, the company is striving to reduce its carbon footprint by optimising its feed conversion ratio.

The company aims to reduce emissions through local processing and innovative transport methods. In 2023, 36.3% of its salmon harvest was processed locally in Norway, decreasing transport-related emissions by over 90,000 tCO2e, or 17%, compared to transporting whole fish to markets. The company is investigating new transport methods by integrating sea, rail, and road in various projects. Since 2021, it has tripled its use of rail transport from Northern Norway, which emits nearly 300 times fewer greenhouse gases than road transport. Additionally, in 2021, the company conducted a life cycle assessment of the environmental impact of coastal farming technologies versus land-based recirculating aquaculture systems.

The company reports group GHG emissions for FY2023, distinguishing between its Norway and Iceland operations. Total Scope 1 emissions are 273,000 tCO2e, with 251,000 tCO2e from Norway and 22,000 tCO2e from Iceland. Scope 2 emissions total 35,000 tCO2e, originating entirely from Norway, while Scope 3 emissions amount to 1,305,000 tCO2e, including 1,245,000 tCO2e from Norway and 60,000 tCO2e from Iceland.

In its CDP 2023 climate change report, the company discloses Scope 1 and 2 emissions related to its fish farming smolt, fish farming, and processing and sales operations in Norway and Iceland. Scope 1 emissions were 85 tCO2e, 25,505 tCO2e, and 84 tCO2e, respectively. Scope 2 (market-based) emissions were 2,134 tCO2e, 2,022 tCO2e, and 2,479 tCO2e, respectively. The company also reports Scope 3 emissions covering 100% of supplier emissions, which include sourcing fish feed, packaging, and purchased lube oil, totalling 729,815 tCO2e. Additionally, 169,651 tCO2e of the company's GHG emissions come from land-use change, all related to feed farming operations within its value chain.

The company responded to the CDP Climate questionnaire in 2024 and states that its greenhouse gas (GHG) inventory data is audited and verified by EY.

The company reported an increase in its absolute total emissions, including Scopes 1, 2, and 3, from 1,276,000 tCO2e in 2022 to 1,335,800 tCO2e in 2023. However, its emission intensity decreased from 4,490 kgCO2e per tonne produced in 2022 to 4,315 kgCO2e per tonne produced in 2023. Between FY2020 and FY2023, total absolute emissions decreased by 16.8%, from 1,606,100 tCO2e to 1,335,800 tCO2e, an average annual reduction of 5.6%. Emissions from feed farming were reduced by 29% since 2020. The company reports Scope 1 emissions at 27,300 tCO2e, Scope 2 location-based emissions at 3,500 tCO2e, Scope 2 market-based emissions at 46,981 tCO2e, and Scope 3 emissions at 1,305,000 tCO2e.

The company has conducted a climate-related scenario analysis aligned with the Task Force on Climate-related Financial Disclosures (TCFD) framework. This analysis assesses risks, opportunities, and both the physical and transitional implications for its financial position. Acute physical events such as heatwaves and floods may affect the availability of crops used in feed ingredients, leading to increased costs. Scope 1 and 2 emissions primarily originate from boats, farming sites, power usage, and electricity, indicating a need to transition to zero-emission fuels. Scope 3 emissions are mainly due to downstream transport and feed production, with recommended solutions including zero-emission transport methods such as hydrogen-driven ships or low-emission airfreight.

The company notes that droughts, floods, and extreme weather events could affect fish feed production and export market access. To mitigate these risks, it ensures flexibility in feed sourcing and is exploring innovations for producing fish feed ingredients locally in controlled environments. The company is testing novel and local feed ingredients such as algae, insect meal, kelp, salmon oil, seafood trimmings, and excess raw materials from processing, which could reduce climate-related risks. Changes in seawater temperatures have been identified as a chronic risk, potentially compromising fish health and welfare by increasing disease-related events or favouring sea lice. The company monitors the marine environment and plans to move operations to more stable, exposed, and offshore areas to mitigate this risk. It acknowledges that maintaining fish health has led to increased veterinary and medicine costs, highlighting the financial incentives for these measures. To meet its climate targets, the company aims to transition to zero-emission technology and has introduced fully electric and hybrid boats to meet the demand for renewable energy. However, it does not address the impact of increased electricity demand or rising prices. Regarding carbon tax risks on electricity and transport usage, the company anticipates higher operational costs with potential carbon taxes on Scope 1, 2, and possibly Scope 3 emissions, estimating costs of over 30 million NOK for 2023 GHG emissions in Norway and Iceland, rising to 1,300 million NOK if Scope 3 is included. As a mitigation strategy, it is transitioning from diesel to alternative low-emission energy sources like onshore power and electrically powered boats, with 43% of its sites in Norway powered from shore by 2022, reducing diesel consumption. In its climate scenario analysis, the company indicates it is exposed to floods and droughts in its operations and supply chain but confirmed no financially material events or direct costs due to climate risk in the reporting period.

The company has linked its financing to sustainability efforts, aligning capital expenditures with greenhouse gas emission targets. In 2023, it refinanced its credit facilities through an agreement incorporating ESG KPIs. Additionally, it issued a green bond in early 2021, using the proceeds as per its green bond framework to support sustainable development. The company reported incurring no direct costs from climate risk during the reporting period.

The company discloses that 39% of its fish feed comprises vegetable raw materials, including soy sourced from Brazil. It requires all soy, from both direct and indirect suppliers, to be traceable to its region of origin. Additionally, the company ensures that 100% of its purchased soy for fish feed is certified according to ProTerra, Europe Soya, or an equivalent environmental standard, guaranteeing that it is non-GMO and not sourced from deforestation-threatened areas. The company procures soy from the Brazilian regions of Minas Gerais, Paraná, Mato Grosso, and Goiás.

The company requires all purchased soy to be certified by ProTerra or Europe Soya, in line with its deforestation policy to source only deforestation risk-free soy throughout its value chain. This commitment is upheld through periodic due diligence, and in 2023, all feed suppliers utilised exclusively certified soy. The company audits feed suppliers to ensure sustainability, verifying that all fish feed ingredients are deforestation-free and sustainably sourced. It collaborates with suppliers to assess feed resource availability and explore alternative ingredients. Additionally, joint efforts are made to optimise agricultural practices, such as crop rotation, organic farming, and minimising pesticide use. However, the company does not provide specific measures to further encourage deforestation-free production.

The company audited its feed suppliers in 2023, ensuring that 100% of the soy used in fish feed was certified by ProTerra, Europe Soya, or an equivalent standard. It manages non-compliance according to these certification standards. Additionally, the company ensures full traceability of the origin of all feed ingredients, sourced from both direct and indirect suppliers.

The company safeguards its fish feed by training employees and conducting ongoing research and development. It collaborates with primary feed suppliers to incorporate sustainable ingredients and improve agricultural practices and nutrient management. The company is involved in various R&D projects exploring innovative feed ingredients such as algae, insect meal, kelp, salmon oil, seafood trimmings, and surplus processing materials. In 2023, the company continued to progress its R&D initiatives and maintain collaborations with its key feed suppliers.

The company reports that 99% of its sites are certified, including full certification in Norway and 83% in Iceland. It also provides a list of farms that are ASC certified and those currently undergoing assessment.

The company discloses its feed ingredient composition as follows: 40% vegetable proteins, 23% vegetable oil, 12% marine proteins, 11% marine oils, 10% carbohydrates, and 3% microingredients. It requires suppliers to use soy certified by ProTerra or Europe Soya, achieving 100% certified soy content in 2023. Additionally, all marine ingredients must be certified by Marine Trust, MSC, or equivalent, with certification rates of 94% in Norway and 96% in Iceland. The company reports its forage fish dependency ratios using the ASC methodology. In FY2023, these ratios were 0.49 for fishmeal and 1.48 for fish oil. It provides breakdowns for Norway and Iceland, with ratios of 0.49 and 0.46 for fishmeal, and 1.45 and 1.91 for fish oil, respectively. However, there is no year-over-year breakdown of ingredient sourcing provided.

The company reports that all soy used in its fish feed is certified by ProTerra, Europe Soya, or equivalent standards. However, certification of marine ingredients stands at 94% by Marine Trust, MSC, or equivalent in Norway, and 96% in Iceland. The biological feed conversion ratio (bFCR) in Norway slightly increased from 1.11 in 2022 to 1.12 in 2023, while in Iceland, it decreased from 1.26 to 1.19 over the same period. Overall, the group's aggregate bFCR improved from 1.13 in 2022 to 1.12 in 2023, with details provided on the calculation method. The forage fish dependency ratio for fishmeal (FFDRm) rose from 0.46 in 2022 to 0.49 in 2023. In Norway, FFDR for fishmeal increased from 0.47 to 0.49, and in Iceland, it grew from 0.34 to 0.46. Meanwhile, the forage fish dependency ratio for fish oil (FFDRo) increased from 1.36 in 2022 to 1.48 in 2023. FFDR for fish oil in Norway rose from 1.36 to 1.45, while in Iceland, it surged from 1.38 to 1.91. The company sources 27% of its fishmeal and 26% of its fish oil from trimmings. It used a total feed volume of 368,000 tonnes, comprising 44,160 tonnes of fishmeal (11,923 tonnes from trimmings) and 36,800 tonnes of fish oil (9,568 tonnes from trimmings). The protein conversion efficiency reported for 2023 is 1.72, with provided calculation methodology.

The company is collaborating with its primary feed suppliers to incorporate sustainable ingredients into its fish feed. It is participating in various research and development projects to explore novel feed ingredients, such as algae, insect meal, kelp, salmon oil, seafood trimmings, and excess raw materials from processing. Once validated through R&D, these sustainable feed ingredients will be applied across the company’s operations. By 2024, the company aims to increase its use of trimmings and by-products in feed. Currently, 27% of its marine ingredients stem from trimmings, a decrease from 32% in the previous reporting period. Through the Råvareløftet partnership, the company is addressing barriers to the large-scale implementation of innovative feed ingredients. Despite not setting a public numerical target for the inclusion of novel ingredients, it is committed to enhancing the use of such ingredients, guided by regular risk assessments. These assessments have identified climate change, and the increased frequency of floods and droughts, along with global events, as risks to feed supply, potentially impacting future operations.

The company has not disclosed the percentage of its R&D budget allocated to developing novel ingredients. It also does not provide information on the average EPA and DHA content of its salmon. Although the company intends to increase the use of novel feed ingredients, it has not set a public numeric target due to varying industry definitions.

The company provides a graph showing historical data from 2021 to 2023, but it does not disclose the actual average number of lice, making interpretation difficult. It reports that the share of sea lice observations exceeding national limits in Norway decreased from 3.3% in 2022 to 0.9% in 2023, with data available for Nordic sites via Barentswatch. However, the company does not disclose sea lice counts for its Icelandic operations. Norwegian regulations limit sea lice to a maximum of 0.5 adult female lice per fish, with some areas having a threshold of 0.2. Fish farmers report lice numbers weekly on the government’s online portal, Altinn. In 2023, 0.9% of sea lice observations were above these national limits.

The company focuses on preventive measures to reduce treatments, including lice skirts, reducing cycle time, fallowing, and risk-based use of in-house cleaner fish. It has developed non-medicinal delousing capabilities, ensuring personnel are trained in handling policies. In 2022, the company introduced lice lasers and the OptoScale optic solution to monitor fish welfare, weight, and lice counts. To maximise cleaner fish survival, the company farms robust cleaner fish in healthy living conditions and uses dedicated feed. However, it does not provide quantitative data on cleaner fish mortalities. The company is involved in R&D projects on cleaner fish husbandry, exploring species, size, feed, and living conditions. It enhances the well-being of cleaner fish with artificial kelp in net pens, offering a familiar environment.

The company reports three fish escape incidents in Norway and none in Iceland during 2023, totalling 168 escaped fish. It emphasises daily monitoring, technical equipment checks, and improved handling protocols to mitigate escape risks. A significant decrease in escape incidents was achieved from 2020 to 2022. The company collaborates with net pen suppliers to test and enhance pen designs for better escape prevention and environmental benefits. It is investing in a programme to further reduce escapes and aims to achieve zero incidents. As part of its initiatives, it participates in a salmon surveillance project in Trøndelag, focusing on tracking and mapping escaped farmed salmon. No financial costs were recorded from fish escapes in 2023. Regular improvements to net pens are being made to meet targets for fish welfare and sustainability, alongside participation in tracing projects for escaped salmon.

The company has identified wild salmon as a biodiversity risk and is engaged in initiatives to monitor wild salmon populations and track escaped farmed salmon. It is also undertaking a project specifically focused on tracing escaped farmed salmon. The company aims for zero human-wildlife interactions but has yet to disclose a timeline for achieving this goal. An internal task force has been established to explore best practices and prioritise equipment that minimises harm to wildlife at its sites.

The company conducts periodic seawater sample analysis around its sea farms to monitor potential algal blooms and unusual fish behaviour, particularly before delousing operations. However, it does not disclose specific management actions during algal blooms.

The company mandates responsible and sustainable water practices from its suppliers and requires feed suppliers to set freshwater reduction targets and develop strategies for mitigating water risks in feed sourcing. It engages with suppliers operating in medium to high water risk areas to improve water use efficiency and manage freshwater availability, water stress, and value chain risks. It has identified its soy suppliers as facing significant potential water scarcity risks and holds all feed suppliers accountable for their activities and impacts. Continuous dialogues are maintained to implement best practices. Analyses conducted by its main feed suppliers provide insights for establishing priority facilities for water stewardship, with guidance and support given to farmers. The company ensures all soy used for feed is certified by ProTerra or Europe Soya, requiring compliance with water management principles, including resource conservation and best practices. Through the partnership platform Råvareløftet, the company fosters the development of innovative feed ingredients focusing on local, low-carbon options that reduce water use, emissions, and improve circularity. Furthermore, its feed suppliers have set water restoration and pollution reduction targets in water-stressed regions through third-party partnerships.

The company does not disclose feed water intensity or the proportion of feed sourced from water-stressed areas. Furthermore, the company does not provide evidence that it is investing in sustainable feed production from a water-use perspective.

The company reports no incidents of non-compliance with water quality or discharge permits in 2023. All facilities are situated in areas with low water risk, as per the WRI Aqueduct Map, considering water stress and quality. The company has implemented recirculating aquaculture systems (RAS) technology in its onshore hatcheries, achieving a 16% reduction in freshwater withdrawal in 2023 and a 24% reduction over the past two years. It targets a 20% reduction in freshwater withdrawal from 2022 to 2030. Monthly measurements of total organic carbon (TOC), oxygen demand, total nitrogen, and total phosphorus in wastewater are conducted and reported to local authorities, though specific pollutant targets are not disclosed. The company states that its wastewater volume target is aligned with its water withdrawal target, as all withdrawn water, after proper treatment, is discharged since it does not store water.

The company complies with discharge permits, treating wastewater prior to discharge at all operational sites and conducting monthly measurements of total organic carbon, oxygen demand, total nitrogen, and total phosphorus, which are reported to local authorities. However, the company does not explicitly detail the quality of the discharged wastewater. In FY2023, the company discharged 38,950,000 m3 from Norwegian sites and 19,801,000 m3 from Icelandic sites, and claims its freshwater withdrawal equals its consumption and discharge. EY has verified the company's freshwater withdrawal data, yet it has not verified its wastewater data. Furthermore, the company has not disclosed data to CDP Water.

The company utilises a drying facility at its Senja hatchery to dry sludge to 95% solid, which is then used by third parties for soil improvement. At the Follafoss hatchery, sludge is sedimented to 18% solid for biogas production. It also participates in a large industrial project in Central Norway, using sludge from its smolt facility for biogas production. All its harvesting, processing facilities, and onshore hatcheries comply with discharge permits for wastewater. However, the company has not disclosed the quality of discharged wastewater for the reporting period. It reports a decline in water withdrawal from 62,538,000 m3 in 2022 to 58,751,000 m3 in 2023, corresponding to reduced wastewater discharge, with all withdrawn water undergoing appropriate treatment before release.

The company acknowledges soil health and nutrient management as critical agricultural challenges and requires its feed suppliers to manage these aspects responsibly and sustainably. It collaborates with suppliers to reduce nutrient spill and invests in projects for innovative feed ingredients. The company monitors the ingredients and nutritional value of feed used in its hatcheries and sea farms through regular inspections. The company mandates that feed suppliers establish Nutrient Management Plans and set requirements for their own suppliers at the farm level. It works with suppliers to optimise agricultural practices, such as crop rotation of soy and wheat, to enhance nutrient cycling, interrupt pest cycles, and improve soil health and biodiversity. Efforts are also underway to increase organic farming practices and limit pesticide use. The company does not mention forming partnerships with third parties to support its sourcing and farming strategy, including managing nutrient pollution and fertiliser use.

The company invests in projects involving novel feed ingredients such as algae, insect meal, kelp, salmon oil, seafood trimmings, and excess raw materials from processing, in collaboration with feed suppliers, to reduce nutrient spill from agriculture. The company uses soy in feed production that adheres to the Proterra standard, which prohibits highly hazardous pesticides and complies with contaminant limits. However, this restriction appears to apply only to soy and within a limited geographic scope, raising questions about the use of these pesticides in other raw materials.

The company conducts regular risk assessments to evaluate the pollution sensitivity of current and potential sea sites, avoiding operations in high-sensitivity areas. It has carried out B-analysis environmental surveys, revealing that 89% of operational sites in Norway and 100% in Iceland received a "very good" or "good" benthic score of ≤ 2. It monitors organic and inorganic loading by tracking uneaten feed and salmon faecal matter and is exploring Integrated Multi-Trophic Aquaculture (IMTA) with kelp and mussels as a mitigation strategy. The company also uses optical technology to optimise feed conversion ratios, aiming to reduce feed spillage. The company targets a MON-B score of 2 or less for all sites to ensure low benthic impact and implements fallowing primarily to manage sea lice numbers.

The company discloses a community engagement strategy, holding monthly meetings with local communities to discuss operational impacts and gather feedback. This has resulted in the implementation of site-specific pollution plans as improvement actions.

The company has a robust antibiotic policy for its aquaculture operations, prohibiting the use of antibiotics for growth promotion at any stage of the salmon lifecycle. Antibiotics are only used when absolutely necessary and prescribed by a veterinarian, indicating a commitment to non-routine antibiotic use. To minimise the need for antibiotics, the company employs several measures aimed at maintaining fish health and welfare. These include vaccination programmes, optimal welfare conditions, zoning boundaries to prevent bacterial infections, and strict biosecurity and sterilisation procedures. Furthermore, the company adheres to lower-than-required stocking densities, utilises cleaner fish for salmon lice management, and ensures regular health monitoring by veterinarians and welfare coordinators.

The company reports that no antibiotics were used in its operations in Norway or Iceland for the reporting year 2023. This data is audited by Ernst & Young (EY) as part of their limited third-party verification process.

The company emphasises animal welfare with strict protocols for the well-being of its fish, including health and thermal comfort monitoring through regular visits and comprehensive metrics. Efforts to reduce fear and stress involve training personnel in proper handling protocols and using non-medicinal delousing methods like lice lasers. Handling protocols include regular risk assessments and ongoing training for personnel to safeguard welfare. Trained staff conduct all fish handling activities following established procedures to minimise stress. The company ensures humane slaughter by rendering fish unconscious through monitored methods. It uses percussion stunners at most operations and electrical stunning at Vikenco. All operators complete fish welfare training led by a licensed veterinarian or expert.

The company reports an average stocking density of 8.45 kg/m³ for salmon in Norway and 3.74 kg/m³ in Iceland for 2023, with a maximum limit of 13 kg/m³ in Iceland during winter. Although these figures are under the threshold of 17 kg/m³, the company does not confirm consistently maintaining stocking density below this level. It also provides information on several animal welfare metrics, including stocking densities, fish appetite, growth rate, skin health, wound status, and oxygen uptake during transport across all sites.

The company is investing approximately NOK 500 million in the Salmon Living Lab initiative, aimed at advancing fish welfare and addressing challenges in salmon farming. This project will include constructing an innovation and R&D centre to enhance knowledge and innovation within the sector.

The company provides survival rates as a proxy for mortality rates at sea, reporting a 94% rate in Norway and 86% in Iceland for 2023. It defines incident-based mortality as exceeding three per cent in a single period or five per cent across multiple periods from one incident, noting a reduction of 3,528 tonnes from such occurrences in 2023. The company has set quantitative, time-bound targets to enhance survival rates, demonstrating a commitment to reducing mortality. In Norway, it aims for a 97% survival rate by 2030, and in Iceland, 95% by 2028. These targets were revised due to challenges from jellyfish attacks and elevated sea lice levels, which affected rates. The company reports a decrease in survival rates for 2023 to 93% in Norway and 86% in Iceland, compared to 94.6% and 89.7% respectively in 2022, indicating an ongoing effort against its mortality reduction targets.

The company provides information on fish health and welfare but does not disclose the number of disease outbreaks or biomass lost due to these outbreaks in the reporting period. It employs non-medicinal and non-chemical strategies, such as lice skirts, reduced cycle times, and in-house produced cleaner fish, to prevent disease outbreaks. The company also invests in advanced technologies like lice lasers and OptoScale optics for monitoring welfare, while prioritising vaccination and effective feed utilisation to promote health and prevent diseases.

The company claims to support and respect all internationally recognised human rights as outlined by the International Bill of Human Rights, the UN Universal Declaration of Human Rights, and the ILO's declarations and conventions on human and labour rights.

The company conducts annual due diligence in line with OECD principles for multinational enterprises and the Norwegian Transparency Act. It assesses potential adverse impacts on human rights and working conditions related to its operations, products, services, supply chain, or business partners. The company employs software for risk assessments and uses a self-assessment questionnaire, requiring suppliers to provide information on their practices regarding human rights, workers' rights, health and safety, governance, tax, and supply chain management. Ongoing due diligence and audits are conducted for its supply chain and operations. The company commits to implementing measures to mitigate risks identified in its assessments and tracks the success of these actions, providing remediation where necessary. Monitoring of these mitigation measures is overseen by the Director of Quality and HSE. In terms of addressing adverse impacts, the company implements measures to cease, prevent, or mitigate identified issues, monitoring the progress and participating in remediation and compensation efforts when required. It also emphasises employee education and training to promote a safe and healthy work environment. However, while the company clarifies its expectations for suppliers, it is unclear if it engages in risk mitigation measures such as capacity building for suppliers.

The company reports no violations identified in due diligence assessments within its supply chain. However, it notes risks among suppliers using subcontracted labour in Asia, specifically concerning working hours, living wages, health, safety, environment, auditing, and documentation. While the company intends to conduct follow-ups and has clarified its expectations of suppliers, it does not disclose evidence of actions taken to remediate these risks.

The company prohibits child labour, forced labour, discrimination, harassment, and abuse across all its operations. It reports that 96% of employees are covered by collective agreements, ensuring fair remuneration relative to the cost of living. Ethical guidelines specify that salaries should meet employees' and their families' basic needs. Compliance with these ethical guidelines is audited by third parties and customers, as well as through internal controls, with appropriate actions taken based on results. The company requires suppliers to follow the same prohibitions regarding child labour, forced labour, discrimination, and harassment as outlined in its human rights policy. Additionally, the company provides employees with sick pay according to national laws, but it does not clarify whether this aligns with the National Minimum Wage or National Living Wage standards, or if sick pay applies to all workers, including subcontracted staff.

The company audits suppliers on human rights policies, including forced and child labour, fair wages, harassment, abuse, violence, young worker risk assessments, collective bargaining, freedom of association, unionisation, discrimination, and compliance with ILO conventions. The company has a whistleblowing system managed by the third-party BDO AS, supporting anonymous reporting. This system, developed in collaboration with employees and trade unions, allows employees, customers, suppliers, and stakeholders to report concerns. In 2023, 12 whistleblowing reports were recorded; however, the company only provides partial categorisation, making it unclear what specific issues the grievances encompass or if any relate to health, safety, or human rights.

The company aims to limit work-related injuries and reports that all facilities have a health and safety representative or committee with worker representatives. Each department undergoes two safety inspections annually. Although all operations are Global G.A.P certified, which includes workplace health and safety requirements, the exact number of sites with worker-representative committees is unclear. The company also disclosed that it did not use antibiotics in its operations in 2023.

The company reports a slight increase in its H-factor (lost time injuries per million hours worked) from 5.3 in 2022 to 5.4 in 2023. It maintained a zero fatality rate across 2021, 2022, and 2023. The company does not disclose the employee turnover rate for the reporting year.

The company respects the right to freedom of association, as articulated in the Universal Declaration of Human Rights. Collective bargaining agreements cover 96% of its workforce, although unionisation rates are not disclosed. The company negotiates with unions to ensure wages align with the cost of living and involves them in labour-related decision-making. Whistleblowing cases are handled jointly with unions and the company's Working Environment Committee, which includes management and elected employees, reports to the unions. Suppliers are required to meet specific standards, potentially including freedom of association and the right to collective bargaining, and undergo audits for compliance. However, it is unclear if suppliers must establish a policy on freedom of association.

The company reports that 96% of its employees are covered by collective bargaining agreements. In 2023, it employed 2,674 full-time equivalents from 58 countries, including 2,331 full-time, 148 part-time, 114 temporary, and 81 employees on non-guaranteed hours. However, the company does not provide the number of subcontracted workers used during the reporting year.

The company reports that its facilities and production units are certified with Global GAP, BRC, and IFS, all recognised by the Global Food Safety Initiative (GFSI). It also requires all relevant suppliers to hold GFSI-recognised food safety certifications. The entire value chain holds Global GAP certification, and all processing facilities are certified with either IFS or BRCGS.

The company conducted 356 internal audits and safety inspections in 2023, alongside 289 external audits, to ensure food safety. However, it does not disclose corrective action rates for non-conformances at its facilities. While the company employs the Keep-It® shelf-life indicator for product temperature and shelf life, and asserts that all products are traceable throughout the value chain, there is no mention of consumer-facing technologies, such as blockchain, that enhance traceability or transparency from farm to shelf.

The company acknowledges the significance of managing product recalls and has established routines for addressing customer complaints. However, it does not provide a detailed description of a comprehensive recall system, including protocols, roles and responsibilities, documentation, or disposal procedures. The company reports zero product recalls in the reporting year.

The company reports no product recalls or market bans during the reporting period.

The company discloses that its Board is formally mandated to oversee sustainability and ESG issues, with the Board of Directors primarily responsible for climate change mitigation and strategy, as mentioned in its CDP disclosure. In 2023, the company began conducting a double materiality analysis to comply with the forthcoming Corporate Sustainability Reporting Directive. It also conducted an annual reassessment of its current materiality assessment, which received approval from the Board. Key topics identified include fish escapes, fish welfare, safe and healthy food, salmon lice, sustainable feed, biodiversity, GHG emissions, human rights, regulatory compliance, and safe workplaces. Three Board members—Gustav Witzøe, Leif Inge Nordhammer, and Margrethe Hauge—have expertise in sustainability and food safety. Additionally, Margrethe Hauge and Morten Loktu possess expertise in product development and innovation.

The company discloses that senior executives are eligible for performance-based incentives linked to sustainability KPIs, though the specific percentage of this variable compensation is not stated. The company collaborates with the Norwegian Veterinary Institute and the University of Life Sciences on projects to advance animal welfare practices. It engages with policymakers on responsible antibiotic use and works with research institutions and industry peers to progress in recirculating aquaculture systems. Additionally, the company partakes in activities with industry bodies to align ESG disclosures with regulations, but it is unclear if this engagement aims at enhancing the broader sector's ESG transparency. The company is a member of the Norwegian Seafood Federation (Sjømat Norge), the Confederation of Norwegian Enterprises (NHO), OrAqua – Organic Aquaculture, and the Federation of European Aquaculture Producers (FEAP). In its CDP climate questionnaire, the company commits to aligning its engagement activities with the Paris Agreement. It is also dedicated to aligning its strategy with a 1.5°C scenario.

The company has established The Salmon Living Lab, an R&D centre aimed at promoting sustainable growth in the aquaculture sector through collaboration and innovation. It prioritises fish health and welfare in its sustainable innovation efforts. Additionally, the company invests in projects to enhance circularity and reduce greenhouse gas emissions and water use in its feed ingredients. The company also acknowledges its ranking in several ESG indexes, including The Coller FAIRR Protein Producer Index and PwC's annual Climate Index.

Research indicates a rapid increase in the number of vegetarians and vegans, particularly among younger, climate-conscious individuals. The company acknowledges a potential risk from vegan proteins encroaching on the salmon market but also sees it as an opportunity. The company highlights the importance of educating the public on salmon's benefits, including health advantages, low carbon emissions, and strict regulatory welfare and environmental standards. To mitigate risks, it plans to emphasise these points. However, the company does not provide evidence of tracking or reporting revenue from alternative protein sources and has not set a timebound target for diversifying its protein offerings.

The company does not indicate an approach to diversifying its product range to include plant-based and alternative protein options.