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