Business ethics

Lerøy Seafood Group has a strict policy to promote and ensure compliance with all applicable laws and regulations. Failure to comply with relevant requierments can result in legal penalties, fines and reputational damage. 

Consistent compliance ensuring has positive impact on the organisation. It reduces risk, builds trust, improves reputation, strenghtens business relationships, promotes evidence-based decision making and provides competative advantage.  

Lack of compliance can have several negative impacts on the organisation and its business relationships. This includes legal and financial penalties, reputational damage, increased risk, lack of trust as well as negative impact on the economy, environment, people and their human rights such as violation of fundamental rights, discrimination, injustice and overall negative impact on the society. 

The Group constantly determines, and monitors compliance requirements related to its business activities and evaluates how these should be applied to the organisation. Relevant compliance requirements such as ensuring and enabling anti-corruption, anti-bribary, anti-money laundering, environmental protection, compliance with health and safety requirements etc. are taken into account when planning, implementing and maintaining the Group’s compliance obligations as well as assessing its compliance performance.

The Group is a signatory of UN Global Compact and has committed to both avoiding corruption as well as developing policies and implementing measures to address corruption internally and within our supply chain. Every effort shall be made to safeguard local, regional and global environmental aspects. Aspects regarding animal ethics shall also be given full consideration. 

Compliance Reporting

In order to monitor if Lerøy is involved with negative compliance-related impacts through its activities or as a result of its business relationships, all companies within the Group complete detailed compliance reporting quarterly. The reporting contains information on various compliance-related matters such as compliance with laws and regulations, breaches of laws and regulations (if any), ongoing legal procedures as well as ensurance of decent working conditions and protection of human rights.

Significant instances of non-compliance are identified through this reporting. (Significant instances of non-compliance are occurrences or events that have an actual or potential impact on the outcome of a situation. The significance of an instance is determined by its relevance to the specific situation and its potential to influence future events).

The impact of significant instances can range form minor to major, depending on the context and parties involved. All instances that meet the criteria above shall be reported.

The reporting covers such issues as compliance breaches, business code of conduct, whistleblowing, concerns regarding customers, credit policy, potential corruption cases and other issues of concern. In case of discrepancies an appropriate action is taken. The nature of the action taken is defined by the nature and severity of the discrepancy.  

Compliance reporting helps providing knowledge and insights from past compliance failures and successes. Lerøy is constantly working with developing strong compliance culture – through risk assesments and information campaingns which are aimed at explaining compliance requirements and expectations as well as be aware of potential compliance-related risks. 

Lerøy provides frequent compliance-related training to its employees and hired staff to ensure that they are equipt to identify problematic compliance issues and report them. The content/focus areas of the information campaigns/training can be defined by the nature of recent and relevant compliance-related cases. 

Lerøy is aiming at strenghtening its compliance reporting by providing clear and transparent information the Group’s compliance-related activities to its stakeholders. Transpartent compliance reporting is important to building trust and credibility as well as demonstrate that the company is commited to ethical and responsible behaviour. 

Reporting of Critical Concerns

Concerns regarding compliance and business conduct can be reported anonymously via an independent whistleblowing channel (for more information, please, visit chapter on Whistleblowing).  

Critical concerns are reported to the Management team and the Board quarterly as a part of the Group's Compliance report.

Compliance is an ongoing process which it requires coninuous monitoring and improvement measures to ensure that the Group remains compliant with all relevant requirements. 

Anti-Competative Behavior

The European Commission (the ”Commission”) initiated, on 19 February 2019, an investigation relating to suspicions of anti-competitive cooperation in the market for farmed Norwegian Atlantic salmon.

On 25 January 2024, the Commission announced that it had sent a Statement of Objections (”SO”) to several exporters of Norwegian salmon. The SO sets out the Commission’s preliminary assessment that the exporters, in some instances, may have exchanged commercially sensitive information in relation to spot market sale of whole Norwegian farmed salmon to the EU in the period 2011–2019. Lerøy Seafood Group is one of the companies that has received the SO.

Lerøy Seafood Group strongly rejects the Commission’s allegations. The SO is not a final decision and has been issued in accordance with the Commission’s ordinary procedures for such an investigation. The SO includes the Commission’s preliminary assessments only. The company has thoroughly refuted the allegations in its comments submitted to the Commission. The company has cooperated with the Commission throughout the Commission’s investigation, and will continue to work constructively with the Commission. It is standard practice that these investigations last several years. It is not possible at this stage to make any statement on whether the case will result in sanctions or other negative consequences for the group, or when the case will end.

In the wake of the Commission's investigation, a group of British supermarket chains in February 2024 issued claims for damages in the UK against several Norwegian-owned aquaculture companies, including companies in the Lerøy Seafood Group. In February 2025, another British supermarket chain issued claims for damages in the UK. A class action lawsuit on behalf of consumers has also been issued in the UK. The Group strongly rejects the claimants’ allegations and considers such claims from customers to be baseless. In Europe, this type of claims are first and foremost relevant if the Commission adopts a decision in its ongoing investigation and the decision is upheld. 

Lerøy’s Business Code of Conduct 

The Group has developed a Business Code of Conduct which outlines the Group’s fundamental standards and principles for business conduct and ethics, human and labour rights, environment, anti-bribery and anti-corruption, whistleblowing and data privacy protection.

The commitments in the Code of Conduct stipulate applying the precautionary principle.

All Lerøy employees and workers, as well as governance body members, in all operating regions across the globe, shall be able to apply the principles laid out in the Business Code of Conduct and have received Business Code of Conduct and Ethics training (incl. relevant policies and procedures) to raise awareness of various compliance related issues and challanges. The information provided in the training consists of following topics: Group’s fundamental standards and principles for business conduct and ethics, human and labour rights, environment, anti-bribery and anti-corruption, whistleblowing and data privacy protection.

All new employees and hired staff have to familiarise themselves with the Business Code of Conduct and the Group’s set of values. Existing employees as well as others who are required to respect and comply with the Business Code of Conduct can suggest changes and updates in the Code. All employees and hired staff are invited to revisit and review The Group’s Business Code of Conduct al least annually.  

The Code of Conduct is reviewed by the Board annually. It is a permanent agenda item of the first Board meeting of each year.

All Lerøy's business partners have to read and confirm that they will comply with the Company's Business Code of Conduct

The Business Code of Conduct is reviewed annually in order to evaluate its relevance and appropriateness with regards to organisational context changes, social developments, particular cases as well as feedback form relevant stakeholders. 

If appropriate and necessary, the Business Code of Conduct is amended, updated or explained in greater detail in case there is a necessity for more clarity regarding how an issue should be handled or resolved.  

Lerøy's Code of Conduct is available on the company's website.

Supplier Code of Conduct 

The Business  Code of Conduct  is complemented by the Group’s set of values which define our behaviours at work. The Group has developed a new Lerøy Supplier Code of Conduct and a Lerøy Supplier Declaration Form that can be found on the Group`s website, see link below. 

In order to verify whether and to what extent the Leroy’s Business Code of Conduct is applied by the Group’s suppliers, they are requested to fill out a questionnaire which requires the suppliers to explain in detail how the Business Code of Conduct is applied and complied with.

The questionnaire addresses such issues as governance, certifications, digital infrastructure and cybersecurity, supply chain, sustainability practices, human and labour rights and other subject specific requirements.   

All our suppliers are informed of and have to commit to our Business Code of Conduct, and they are expected to conduct their business in an ethical and manner as well as act with integrity complying with international and local laws and standards.   

Supplier agreements shall contain requirements stating  the principles in the Business Code of Conduct  shall be followed. Particular care must be taken when engaging intermediaries and associated payments.  

Corruption refers to the abuse of power for personal gain. The negative effects of corruption are wide-ranging. Corruption affects individuals, organisations, and society as a whole. It increases inequality, decreases accountability, and reduces political responsiveness. Corruption and bribery are harmful to business.

Corruption has significant negative impacts on human rights, such as undermining the independence and integrity of the judiciary. It can negatively impact freedom of expression, freedom of association, the right to education, the right to health, the right to basic services, and the right to work. It is therefore important to contribute to fighting corruption.

The Group has zero tolerance for corruption and money laundering. Lerøy has developed an Anti-Corruption policy and procedures that express the Group’s core values of integrity and responsibility, as well as aim to effectively counter corruption and money laundering. Taking appropriate measures to target these issues has been defined as one of the material topics for the Group.

Implementing anti-corruption measures is an integral part of our corporate responsibility. It helps to protect our reputation and the interests of our stakeholders.

Lerøy has completed a risk assessment for risks related to corruption within its operations.

The company has identified the following significant risks through the assessment:

The business and its profile (global sales in countries with high corruption risk);
Customers/distribution channels (large, global customer base with complex ownership structures);
Suppliers (large, global customer base with complex supply chain structures).

Risk assessments are completed annually or more frequently if necessary.

Lerøy reports compliance-related matters quarterly and, to the best of our knowledge, the company has not been involved in any negative impacts through our activities or as a result of our business relationships.

In 2025 there were no confirmed incidents where business partners were terminated or not reviewed due to violations related to corruption. No public legal cases regarding corruption were brought against the organization or the employees/ workers during the reporting period.  

The Group does not support individual political parties or individual politicians but does engage in public debate when in the interests of the Group. 

Lerøy is committed to cooperating in the remediation of negative impacts. One of the mechanisms to ensure this is whistleblowing. 

Grievance 

Internal whistleblowing channel: 

The Group has established comprehensive 
whistleblowing procedures to ensure that all reports 
of suspected misconduct, breaches of laws and 
regulations, or violations of the Group’s Code of 
Conduct and internal policies are handled with 
objectivity, fairness, and integrity. When cases of 
nonconformity are identified, appropriate measures 
are implemented to rectify the situation. 

Dedicated whistleblowing committees have been set 
up in all segments across the Group. These 
committees are responsible for conducting 
preliminary assessments of reported cases and 
subsequently referring each matter to the relevant 
business unit for handling. They oversee adherence to 
case processing routines and ensure that necessary 
actions are implemented before cases are formally 
closed.

Employees in Lerøy may raise concerns at any time 
with their manager, union representative, employee 
representative, HR or by using the Group’s digital 
whistleblowing channel. Hired workers can also report 
censurable conditions within Lerøy. 

Submissions may be made verbally or in writing, and 
every concern is duly recorded by the recipient within 
the whistleblowing channel. Upon submission, 
whistleblowers receive notification that their report has been received, along with information about the case handling 
process and the subsequent steps. 

The whistleblowing channel provides employees with 
the flexibility to submit reports either under their full 
name or anonymously.The whistleblowing channel is 
designed by a third party.

To safeguard the interests of reporting individuals, 
the whistleblowing channel is designed to be highly 
secure ensuring that all data and communications 
are protected through robust encryption and strict 
access controls. This ensures the confidentiality and 
integrity of information throughout the entire process.

The channel is subject to continuous monitoring to 
ensure that all reported cases are processed.

All whistleblowing cases are registered, investigated 
and processed in accordance with the Group’s 
whistleblowing policy and established routines, with 
investigations involving all relevant parties. If any 
individual believes they have been subjected to 
retaliation following a whistleblowing report, they 
may submit a complaint in the whistleblowing 
channel.

Every reported case is regarded as unique. 
Investigations are conducted by local management, 
the COO of the respective business segment, the CEO, 
or, in exceptional situations, the Board of Directors. 
The selection of investigating parties depends on the 
nature, scope, and severity of the issue, with remedial actions determined by the specific circumstances and 
seriousness of the matter. 

Any negative consequences related to 
whistleblowing, as well as corresponding remedies, 
are addressed on a case-by-case basis. Follow-up 
actions may involve local management, the relevant 
COO, the CEO, or, in special cases, the Board of 
Directors. Whistleblowing cases are reported to the 
Group management the Audit committee and the 
Board of Directors on a quarterly basis. 

The Group has not conducted a direct assessment of 
the level of awareness and trust among its workforce 
regarding these structures or processes for raising 
concerns. Nevertheless, feedback from the annual 
employee survey indicates a positive sentiment, with 
employees expressing confidence in their ability to 
speak up when they observe unacceptable incidents 
or actions in the workplace. 

The effectiveness of the internal grievance 
mechanism is regularly evaluated by the 
whistleblowing committees, which reviews case 
handling, guidelines, and procedures. Necessary 
changes and updates are implemented on an 
ongoing basis. 

The Group ensures that employees have access to the 
whistleblowing channel through a variety of 
established routines. Information about the 
whistleblowing policy, reporting procedures, and 
protections against retaliation is made available via 
the Group's intranet, Lerøy Connect, quality management system, HR system, whistleblowing channel, as well as posters displayed throughout the workplace. Furthermore, mandatory e-learning 
modules, regular training sessions, and employee 
surveys are conducted to keep employees informed 
and encourage the use of these channels if concerns 
arise. 

Dedicated whistleblowing committees, a clear 
reporting structure, and policies prohibiting 
retaliation against both the whistleblower and their 
representative are all measures designed to ensure a 
safe and secure environment for reporting concerns.

The local management in each company is 
responsible for implementing the whistleblowing 
policy and conduction regularly assessment in 
collaboration with relevant stakeholders.

 Internal whistleblowing cases in 2025: 22

The Group is continuously working to improve the current situation regarding various whistleblowing cases by conducting manager training (as part of the Lerøy Leadership Program), further developing the Leadership handbook, and organising professional gatherings. The HR department also provides guidance and support to help identify and handle cases.

Grievance Mechanisms

External whistleblowing Channel

The Group has established a digital channel for 
whistleblowing, for all stakeholders or other external persons who wish to contact the Company or report a matter of concern. Contact is made through the Group’s web page (www.leroyseafood.com), which directs users to an external whistleblowing channel.

All external whistleblowing cases are handled and 
responded to in accordance with relevant internal 
procedures. Our whistleblowing policy states that all 
parties involved in a whistleblowing case shall be 
protected. Retaliation against externals who whistleblow is prohibited It is also possible to contact the Group via its website (contact form) to report other matters, complaints or 
ask questions.

Both external whistleblowing channel and the contact form are available to all interested parties. If they wish to give their feedback regarding available grievance mechanisms, the same contact form on the company’s website can be used. 

Effectiveness of both external and internal grievance mechanisms is measured on regular basis. All reported cases are handled according to relevant procedures. Necessary changes and updates are made continuously. 

External whistleblowing cases in 2025: 5