Whistleblowing policy

Owner/approver: Group Director HR

Last audited: 2026-01-06

Purpose

Lerøy shall foster an organisational culture characterised by a positive and constructive climate for expression, alongside a safe, secure, and open whistleblowing culture. The purpose of the whistleblowing policy is to encourage and facilitate the reporting of censurable conditions. Employees should feel confident that they will not face negative consequences for speaking up about such matters. Lerøy relies on its employees to help uncover censurable conditions, and everyone is encouraged to report if they hear about or witness any such issues. Employees are obliged to report if a colleague is discriminated against or harassed, as well as regarding circumstances that may pose a danger to life and health.

Whistleblowing of censurable conditions

Whistleblowing means reporting censurable conditions within the company or the Group. Censurable conditions are matters that violate legal regulations, the group’s written ethical guidelines, or ethical norms that are broadly supported in society, for example, situations that may involve:

• a danger to life or health
• a danger to the climate and the environment
• corruption or other economic crime
• the abuse of authority
• an unsatisfactory working environment 
• breach of personal data privacy (GDPR)

Statements concerning matters that relate solely to the employee’s own working conditions are not considered whistleblowing. 

Procedure for whistleblowing

A report can be submitted either verbally or in writing, with a full name or anonymously. Anonymous reporting may limit the employer’s ability to follow up on or clarify the content of the report.

The report should preferably be submitted via Lerøy’s digital whistleblowing portal. Alternatively, the report can always be submitted to the nearest manager, shipmaster, HR, trade union representative, safety representative, or the management, who will then register the report in the whistleblowing portal. Oral notifications will also be registered in the whistleblowing portal.

Follow-up

All reports are registered and followed up. The Group has established a central reception that monitors the whistleblowing portal and forwards reports for processing in the relevant segment. In all segments, whistleblowing committees have been established with responsibility for following up the report and ensuring that the case is handled by the correct company, person, or body. Those who are to investigate and handle the report must be impartial and have no interests in the case.

The whistleblower shall receive confirmation of receipt of the report within seven days and shall be informed about the further process. The whistleblower shall receive feedback on the report within a reasonable time, and no later than three months from the receipt of the report. The investigation and proceedings will be adapted to the nature and seriousness of the case.

The person(s) to whom the report relates have the right to be assisted by a representative and have the right to contradict. Case processing shall be carried out in accordance with applicable data protection regulations. The identity of the whistleblower and information in the case shall not be disclosed to more people, or to a greater extent, than is strictly necessary. The obligation of confidentiality also applies after the whistleblowing case has been concluded.

If the assessment of the report reveals that there are censurable conditions, this may have consequences for the person concerned.

The whistleblower shall be informed that the report has been followed up. The whistleblower does not, as a rule, have the right to information about any personnel-related consequences for the individual(s) concerned.

Protection against retaliation 

The whistleblower is protected against retaliation. Retaliation means any unfavourable action, practice, or omission that results from or is a response to the employee having made a report. The employer must ensure that the whistleblower has a fully satisfactory working environment, and must, if necessary, implement measures suitable for preventing retaliation. Anyone who believes they have been subjected to retaliation must report this via the whistleblowing portal or to their immediate manager, HR, trade union representative, safety representative, or the management.

Reporting

The whistleblowing committees report the status of whistleblowing cases to group management and the board on a quarterly basis.

Valid for

Applies to all employees and hired personnel at Lerøy.

Framework and principles

Lerøy’s Code of Conduct, whistleblowing poster and procedure for handling reports.

Local laws and regulations applicable to the Lerøy entity concerned by the report, regarding whistleblowing in employment relationships and the processing of personal data, such as:

Norway:

• Lov om arbeidsmiljø, arbeidstid og stillingsvern mv. (Working Environment Act), Chapter 2A.
• Lov om stillingsvern mv. for arbeidstakere på skip (Ship Labour Act), § 2-6 og § 2-7.
• Lov om behandling av personopplysninger (The Personal Data Act).

EU-countries:

• Directive (EU) 2019/1937 – Whistleblower Protection Directive
• Regulation (EU) 2016/679 - Protection of natural persons with regard to the processing of personal data (GDPR)

Roles and responsibilities

• All employees and contracted personnel in Lerøy are responsible for complying with the policy, as well as contributing to the creation and maintenance of a good and proper working environment.
• Top management in each company is responsible for ensuring that the company has competent personnel who ensure local compliance.
• Managers shall guide employees who wish to report concerns.

Policy ownership and implementation

• The CHRO of Lerøy Seafood Group ASA is the owner of the policy and responsible for all updates. 
• The policy has been approved by the Corporate Management Group, presented to the Audit Committee and approved by the Board of Directors.
• The CEO of Lerøy Seafood Group has overall responsibility for the policy.