Interaction with water as a shared resource

Management and responsibility for freshwater withdrawals, wastewater treatment and discharge are located locally in each company in the Group. The overall responsibility to form policies, establish KPI`s and strategies for our withdrawals, treatment and discharge of water lies with the Group management. In addition, the Group has a responsibility to consolidate, and control reported water related data from all companies.

All Water withdrawal per source, and discharge per treatment type and destination are reported monthly through Cemasys (Cemasys.com). LSG has developed Apps in PowerBI to monitor, control and analyze all environmental data reported through Cemasys. Based on these tools our companies are better equipped to control their environmental accounting, recognize trends, and implement preventive actions to mitigate negative impacts, and potentially increase possible positive impacts. In addition, we can monitor if our actions have the desired effect. Actual and potential impacts, both positive and negative from our operations have been identified through Risk evaluations.

We have identified that our operations do not have any significant impact on water bodies which we have permits for water withdrawal and discharge water quality. There are some potential negative impacts of our operations. If we withdraw significantly more water over time than we are allowed to, it can in worst case cause irreparable damage to local flora and fauna in the area.  This will in turn impact our operations, potentially leading to reduced capacity, employment and downstream activities. Our most water intensive operation do not withdraw water from drinking water sources.

LSG report in accordance with guidelines from several third-party benchmarking organizations and stakeholders (Coller FAIIR, CDP). In 2024 LSG continued the risk assessment regarding water withdrawal, water discharge and consumption of freshwater for all locations in the group, using WRI Aqueduct (https://www.wri.org/aqueduct) as a tool to identify which of our operations are located in areas with medium to high risk of Water Stress and Water Depletion.

Locations identified as being at risk for Water Stress and/or Water Depletion (See table 4 below) are in a continuous process of monitoring their local impacts, form action plans and frameworks where needed. Where policies are established on a national level, companies in the group have been informed and are in dialogue with official representatives. This is an ongoing process which have generated actions to reduce water withdrawal and improve water treatment of discharged water (See table 5 below).

Each location is tracking their progress using our PowerBI solution. 2022 was the first year we had a complete dataset for all locations regarding Water withdrawal, water discharge and consumption of water. In 2024 we continued, on a monthly basis, to track the effectiveness of our actions taken, and track our target with base year of 2022.

Since our operations in large does not consume water, we shifted our target in 2023 to only include locations in medium to high risk of water stress. This was continued in 2024 to reduce water withdrawal with 5 % within 2025, with base year 2022. Locations included in this target can be found in table 4.

LSG is committed to ensure that all our employees have their basic needs regarding fresh water available in all our operations. This includes their right to access to clean quality fresh drinking water, sanitation facilities and clean working clothes. There have been no whistleblowing cases related this topic in 2024.

The Group has not registered any violations of regulations related to use of -and discharge of water in 2024.

Lerøy does not have any feed farming operations.

More information can be found in our LSG Water withdrawal and waste water discharge Policy.

CapEx and OpEx

CapEx in 2024 includes investments in RAS technology, water saving equipment, wastewater purifying facilities and technology and water efficiency equipment. OpEx in 2024 includes cost related to water permits, water use cost and wastewater treatment cost. The drop in CapEx is related to no new investments in RAS facilities in 2024.

Table 1: Water related CapEx and OpEx:

Water withdrawal

The worlds dependency on clean freshwater have never been greater. With an increasing global population, increased temperatures due to increased Co2 emissions and increased pollution, it has become even more important to govern our water resources in a sustainable manner.

LSG takes this responsibility seriously and strives to protect and safeguard the freshwater sources we draw water from, and the ocean where we have operations. We have devised strict protocols and procedures to make sure that we do not draw on more water than we are allowed to, pollute our Oceans or influence ecosystems negatively.

Lerøy have local engagement plans enabeling us to have dialogue with local stakeholders and communities in areas where we have farming activities. Thorough local meetings organized by Lerøy, we discuss concerns and questions they have related to our operations. To this date water withdrawal, water discharge and consummation of water has not been a topic at any of these meetings. We have neither had any enquiries or questions asked regarding our water management from Stakeholders. The local engagement plans are not only releated to our ASC certification. In locations where we do not have ASC certification we also have local communities engagement plans.

We also continue our effort to switch all flow through systems for Salmon farming over to RAS and invest in water saving equipment in our downstream operations (See table 1). 

Table 2: Overview in m3 and Megaliter of freshwater withdrawals, discharged water and freshwater withdrawal per kg produced in LSG 2021, 2022, 2023 and 2024 with % change last year

*Incomplete dataset for 2021

**excluding farming operations (Farming, Smolt production, cleanerfish production and parentfish production)

*** Including all segments

Seawater withdrawn is discharged directly back into the sea (See table 3 for Seawater withdrawal).

Our water withdrawals have increased by 3,6 % in 2024 compared to 2023. Our smolt production operations increased production volume contribute to a significant part of the increase . The VAP segment also had a water withdrawal increase of 14,9 % compared to 2023, but only 6 companies contributed to the increase. Below is listed main reasons for the decrease and increase in water withdrawal pr company:

• Water saving initiatives, investment in water saving equipment and decreased production volumes have resulted in a decrease in water withdrawal in our processing plants compared to 2023:
  
  • Lerøy Bulandet AS - 6,6 % reduction
  • Lerøy Norge AS - 6,2 % reduction
  • Lerøy Portugal Lda - 44,4 % reduction
  • Lerøy Seafood Denmark AS - 1,2 % reduction
  • Lerøy Sweden AB - 6,8 % reduction
  • Lerøy Turkey - 1,3 % reduction
  • Sjømathuset AS - 33,5 % reduction
• Reduced production volume, water saving initiatives and investment in water infrastructure and equipment in the Farming segment
  • Laksefjord - 5,1 % reduction
  • Kjærelva - 8,4 % reduction
  • Sagen - 18,7 % reduction
  • Saltverket - 7,6 % reduction
  • Flatråker - 2 % reduction
• Increase in waterwithdrawal because of increased production volume:
  • Belsvik - 47,6 % increase
  • Botn - 12,5 % increase
  • Lensvik - 8,5 % increase
  • Saga - 13,3 % increase
  • Skorild - 27,9 % increase
  • Jøsnøya - 7,2 % increase
  • Bjørsvik - 15,7 % increase
  • Lerøy Austevoll - 94,9 % increase
  • Lerøy Italy SRL - 147,8 % increase

Table 3: Water withdrawal per source in m3 and Megaliter (2024)

All seawater reported is discharged back into the sea.

In 2024 our juvenil fish production units used on average 7,33 m3/kg fish, and the Farming segment in total used 0,27 m3/kg produced. Our VAP segment used on average 0,005 m3/kg fish. Wildcatch segment used 0,005 m3 per kg fish produced. 

Our main target is to reduce water withdrawal with 5 % within 2025 in areas with medium to high water stress risk. In 2023 Lerøy withdrew 167 ML in these areas, while in 2024 we withdrew 184,6 ML (increase of 10,5 %). The majority of the increase is related to increased production volumes in our operations in the Netherlands and in Spain.

Water related impacts and risks

In our operations, and mainly the Smolt operations, there have been identified risks which may have a negative impact on our operations. Long term drought og long periods with freezing temperatures has the highest consequences for our operations and may cause severe impacts on both fish welfare and economics. Long term drought which will deplete our water reserves in magazines is however deemed unlikely since access to clean high quality freshwater in Norway is good. Long periods with below 0°C temperatures which can lead to is-cloging in the intake water to our juvenilefish production is also deemed unlikely. Our rutines and preventive measures is and have been sufficent to prevent this happening. Lerøy only produce protein in Norway where water sources has a low risk of water stress. 0 % of revenue is therefore dependent on protein from water- stressed areas. In addition we have long term permits and agreements for water withdrawal from Water sources which mitigates some of the Risk of water shortages.

In addition, all processing factories located in areas with medium to risk of Water stress (See table 4), there can be risk associated with access to clean freshwater. To date no such problems have been reported, but we are planning for the eventuality that it may become an issue. 

Our downstream units are mainly located in industrial zones. These zones have both heavy and low water intensive industry. Our operations and withdrawal of water in these zones are considered low compared to the other industries. Our business could however be influenced if water shortages and or regulatory changes divert water permissions to high intensive industries in periods of shortages. This has not occurred, and we see it as unlikely to influence our operations.

Water saving technology

RAS (Recirculating Aquaculture Systems) technology allows Lerøy Seafood Group to produce fish with up to 99% reduction in water use compared to conventional flow-through systems. The Group started to use RAS-technology already in 2005.

In 2024, approximately 80% of all salmon smolt in Lerøy Seafood Group was reared with this technology, using 24 478 211 m3 freshwater. That is 27,09 % of the water drawn in the Farming segment.  RAS technology also entails that we recycle and clean the water before discharge. There are requirements to use waste water particle filters on several of our smolt facilities (Laksefjord, Belsvik, Kjærelva, Botn, Eidane and Bjørsvik). This represent more than 90 % of the total volume in ton of Smolt produced in Lerøy.

Table 5: List of water saving and quality initiatives in companies with locations in medium to High risk of water stress (WRI Aquaduct)

Units which are not in water stress areas have also implemented water reducing initatives and water quality improvements during 2024. This will, in addtion to improve our impact on the environment, also improve food safety and finances.

Water discharge - Effluents

We continue our work with water treatment and discharge data. During 2024 we have improved our procedures and guidelines for reporting water discharge data. Subtraction of Ice -and Brine production from the total wastewater discharge figures have made it possible to calculate our consumed water with better accuracy. From 2023 we have also included water evaporation from Rice cooking in our Sushi production.

Our main target throughout our operations is that all facilities in Lerøy comply with National regulations and discharge limits in the country of operations. In 2024 zero non-conformity regarding volume and quality of discharged water has been registered in our operations. Lerøy have different operations in many different countries and will as such have as many discharge limits to comply with. Many are also regulated through discharge permits specific to the operation and geographical area.

Our reduction target for wastewater volume is related to our 5 % reduction target for water withdrawl. We also have a 5 % reduction target for wasterwater volume. In 2024 we had a 3,6% increase in wastewater discharge volumes. The increase is related to an increase in production volumes.

From 2023 Lerøy also have a complete reporting on seawater withdrawn and discharged in our Farming segment. Seawater is not used in the VAPS&D segment. In total 36 229 megalitres of seawater was withdrawn and discharged back into the sea in 2024.

All our processing factories, new and old, are equipped with fat separators and UV light treatment. In some factories, where it’s necessary, we also have chemical treatment (Chlorine) of wastewater in addition to mechanical treatment before discharge.

See table 4 for discharge volumes per segment, and factories in areas with medium to high water stress risks.

Management of Water discharge related impacts

The group had no water related incidents or accidents related to water withdrawal and water discharge (volume and quality) in 2024.

Discharge water is analysed and tested in accordance with local regulations/requirements or permits (See tables 6-9), and deviations is handled in our quality management system. For our operations in Norway we report all water data (volume withdrawn, discharge and quality) to local government and all results of these are public information.

Depending on location and local requirements parameters analysed can be TOC (Total Organic Carbon), N_tot (Total Nitrogen, NT) and P_tot (total phosphor, TP) for Juvenile fish production, or Biological oxygen demand (BOD), Chemical oxygen demand (COD) fats and solids for factories. The limit, or degree purified water for these can wary depending on permit, regulations and area of operations. The permits also describes which type of analyze must be done within each Limit (Phosphorus in ml/l, Nitrogen in ml/l, fat in mg/l, COD and BOD and Total Settled solids (TSS) in ml/l).

Nitrogen loading rate for farming operations is calculated based on the formula below:

((Multiplier Nitrogen feed per kg (USDA) * Kg feed put into sea)) – ((Multiplier Nitrogen fish per kg * Kg fish taken up from sea)) /1000

((0,061 * 267 710 932)) - ((0,003264 * 206 429 360)) = 9593  

Phosphorus loading rate for farming operations is calculated based on the formula below: 

((Multiplier Phosphorus feed per kg (USDA) * Kg feed put into sea)) – ((Multiplier Phosphorus fish per kg * Kg fish taken up from sea)) /1000

((0,008*267 710 932)) - ((0,002 * 206 429 360)) = 1729

All our processing facilities discharged wastewater to third party treatment plants which purify the water in accordance with local regulatory limits before released to water source. Lerøy have no discharge of wastewater directly to freshwater sources.

Using the WRI Aqueduct tool (Physical risk Quality) we performed in 2024 a risk assessment identifying 4 facilities operating in areas with low-medium and medium to high risk. Three are located in low to medium risk (Lerøy Italy Srl, Lerøy Smøgen Seafood AB and Lerøy Kungelv AB (Sweden)) and one in a medium to high risk area (Lerøy Turkey). We have invested in a new waste water treatment facility in Lerøy Turkey, see table 5. Lerøy Kungelv AB is a new facility that opened in May 2022 and is equipped with new wastewater treatment systems. Lerøy Smøgen Seafood AB sends all its wastewater to a Biogas production facility.

Below are tables showing examples of regulatory limits for operations in areas with low and medium to high risk of water stress.

Table 6: Discharge limits for a Juvenil fish production location in LSG 2023. Low risk of water stress.

Table 7: Discharge limits and results for Lerøy Turkey (VAPS&D segment). High risk of water stress

Table 8: Discharge limits for Lerøy France – Fishcut factory (VAPS&D segment) High risk of water stress

 Table 9: Discharge limits for Lerøy Portugal  (VAPS&D segment) medium to high risk of water stress

Table 10. Average quality (BOD, COD, TN, TOC, TP TSS, pH) of dischage water in LSG (where there are legal demand to analyse discharged water).

Lerøy have the last few years increased focus on water quality and reduced the impact and load on local envionment, and municipal water treatment plants. There is a postive downward trend for all peramaters regarding the quality of our discharge water. Not all our operations have analysis requirements in their discharge permits. In 2024 there are several plants in Lerøy that deliver its discharge water untreated to Biogas production facilities. These results are included in table 10, influencing the results.

In Holland there are no regulations for discharge water for our operations, they are only required to analyse their wastewater before release to municipal water treatment plant once pr year (BOD and TN). They also analyse weekly for COD.

In our farming segment our most water intensive operations are land based juvenile fish production, and discharged wastewater from these operations are managed through approvals from local governments. Sludge from wastewater is collected on-site and are either composted to soil improvement (Fertilizer) or Biogas.

Lerøy is testing new technology to collect sludge/manure from our farming activities. Testing is ongoing and being evaluated on different locations. The results from testing are promising and can lead to further investments at other locations in the future. If testing is successful we aim to include this in our nutrient management plan and to implement this technology on all farming locations. 

New technology and proximity to a biogas facility in Sweden have made it possible to send wastewater for giogas production. This has resulted in eliminating treatment on site which is beneficial for all parties.

Using RAS technology allows us to discharge the recycled water directly to the sea according to our permits. These permits for release of discharge water have different parameters which needs to be fulfilled based on location (See table 6-9 above). In addition we perform MOM-B and/or MOM-C in areas where we discharge water to identify the profile of the receiving waterbody.

Lerøy strive to material recover 100 % of our by-products from our operations. In 2024 we material recovered 91 % of our organic by-products. By-products are either sold as Animal feed ingredients, converted to fertilizer or sent to biogas production (effluents).

In partnership with a feed supplier Lerøy has invested in regenerative agriculture. 20% of wheat and rapeseed crops are sourced from regenerative farms. We aim to continue and grow our investment to ensure that our suppliers of vegetable ingredients can diversify or rotate crops, move away from monoculture and develop cover crops. Lerøy has also invested in alternative feed sources such as macro-Algae and insect protein.

Lerøy has a broad collaboration with various third-party companies regarding water use, water discharge and nutrient management in our farming operations. We rely on third party knowledge, know-how and expertise to continuously improve or operations and how we influence the environment. Mainly we collaborate with Åkerblå, Multi consult and our Feed suppliers regarding water use, water discharge and Nutrient management. We also have a joint venture, Ocean Forest, with the environmental protection organisation Bellona. Bellona and Lerøy collaborate on using excess nitrogen, phosphorus and nutrient salts from our production of salmon and trout to produce Blue Mussels and Macro-Algae. More Information can be found here Ocean Forest.

All Water related non-conformites are reported, handled and stored in our Quality Management system. This system enables us to keep track of trends and implement correct corrective and preventive actions. Lerøy had no major incidents regarding wastewater spills or unwanted/unplanned discharge in 2024.

Water Consumption

In Accordance with CDP reporting framework we started to measure consumption of fresh water in January 1st 2022. Please see table 4 above for consumption data for the entire Group in 2024. The consumption of freshwater is calculated based on water withdrawal and water Discharge (Water withdrawal – Water discharge = Water consumption). Our 2024 target to reduce consumption of water in water stressed areas with 2 % was not reached in 2024. We increased from 10,8 ML (megaliter) in 2023 to 16,9 ML in 2023. The entirety of the volume consumed is related to rice cooking in Lerøy Spain, Madrid. All other locations have reduced or eliminated their consumption of water during 2023 and 2024.

We continue with our 2 % reduction target also for 2025. 

The reasoning behind our low reduction target for consumption of water is because we are dependent on water for ice production to cool our products and maintain food safety and quality, to produce Brine for our smoked products and rice cooking for our Sushi products.

Regarding the groups withdrawal of seawater for our processing operations (see table 3), all withdrawn seawater is discharged directly back to the sea or municipal treatment centre.

Lerøy do not use any water storage (facilities or reservoirs).

Water management Suppliers

Lerøy cares about our footprint through the supply chain. This goes beyond CO2-emissions, and we have set water use, run-off of nutrients and fertilizer usage in crops in our supply chain on the agenda. Applying regenerative agriculture practices on crops in our supply chain helps to reduce water use through irrigation, creates a reduction in use of nitrogen fertilisers whilst ensuring crop yields and builds up soil health and resilience.  At the same time, emissions reductions and removals can be generated, for example through decreased use in nitrogen fertilisers and reduced tillage, as well as the use of cover or companion crops.  Lerøy bought 12,000 tons of this raw materials in 2024 and we want to be a long term supporter that incentivizes crop farmers to produce vegetable raw materials as sustainably as possible.

An important part of Lerøys strategy is ensure that our suppliers operate and perform sustainably, also regarding water use, pollutants and consumption of water. Through dialogue, support and partnerships we will ensure that all of our value chain operate in accordance with sustainable principles. Lerøy have among other a collaboration with feed suppliers on water risk management and nutrient management plans. It is important to determine the full risk profile and understand the actions needed to minimize risks linked with water use, water discharge and nutrient management related to agriculture operations and feed raw materials.  We have finalized a evaluation survey together with our partnered feed supplier to understand their risk profile and which actions have to been taken on water related infrastructure, sustainable water withdrawal, sustainable water supply, buffer zones and the protection of water bodies from pollution. This also includes the use of pesticides in Agriculture. The result is a set of minimum requirements (see below) and requirements to have in place water conservation and efficiency plans where applicable. In addition, we collaborate closely with our feed suppliers on nutrient management to improve the fish welfare, growth rates and ecological footprint. More information can be found in our Supplier Code of Conduct and Code of conduct .

Water withdrawal and intensity Feed

We are working with our suppliers to increase data quality for water withdrawal, water discharge and consumption of water in the feed supply chain. Data regarding total water use in m3 for 2024 are Calculated using LCA Coefficients : Water use.

Water scarcity in feed supply chain

Based on available data, our feed suppliers have done a risk assessment (WRI Aquaduct) of water scarcity to determine which main vegetable raw materials in fish feed are sourced from areas with water stress. The WRI Aquaduct tool have restrictions when analysing based on Raw material. The analysis is therefore based on average score on country level, presented as Europe.

Example, Rapeseed is sourced from Belgium (WRI Score 48), France (WRI score 31), Netherlands (WRI score 29) and Russia (WRI Score 15). The average is between 20-40 % score and presented as having a medium to high risk of water stress.

We are, together with our feed suppliers, in dialogue to better understand the methology and data quality needs to be able to disclose a complete and accurate data set. We are in the process, but it will take time still because of the availability and on current methology.

For more information please see our Fish feed Policy