This statement describes the Holms Eftf Group’s work on due diligence assessments pursuant to the Norwegian Transparency Act. The purpose is to ensure respect for fundamental human rights and decent working conditions within our own operations, throughout our supply chain and among other business partners.

The due diligence assessments have been carried out in accordance with:

• Sections 4 and 5 of the Norwegian Transparency Act
• the OECD Guidelines for Multinational Enterprises
• the United Nations Guiding Principles on Business and Human Rights (UNGPs)
• recommendations issued by the Norwegian Consumer Authority

This report covers the Group’s overall activities for the period from 1 January 2025 to 31 December 2025.

Holms Eftf is the parent company of a Northern Norwegian group with a long history in transport, logistics, shipping and related services. The Group is headquartered in Tromsø and operates primarily in Norway, with certain international supplier relationships.

All Group companies are covered by common governance systems, policies and internal control procedures.

The Group comprises the following companies:

• Holms Eftf AS – parent company
• Holm Shipping AS
• Holm Cargo AS
• Holm Agency AS
• Holm Port Logistics AS
• Troms Fryseterminal AS
• Troms Seafood AS

The Group’s main activities include:

• domestic and international logistics and transport
• cargo handling and terminal operations
• freight forwarding and customs clearance
• port and logistics services
• cold-storage and warehousing services for seafood and food products

The Group’s operations are both capital- and labour-intensive and involve a high level of operational activity, the use of subcontractors and close interaction with customers in the transport and seafood industries.

The Board of Directors of Holms Eftf has overall responsibility for compliance with the Norwegian Transparency Act.

• Group management is responsible for:
• implementing policies and guidelines
• carrying out due diligence assessments
• following up identified risks

Day-to-day work is embedded within the Group’s administration and is carried out in close cooperation between management and the finance function.

The Group has established, or is currently developing, the following:

• Code of Conduct for employees – established
• Supplier Code of Conduct – established
• procurement and supplier follow-up procedures – under development
• whistleblowing procedures – under development
• health, safety and environment (HSE) management system – under development

The due diligence assessments are conducted as a risk-based process comprising the following main stages:

1. Mapping of operations, suppliers and business partners
2. Identification of actual and potential risks of adverse impacts
3. Prioritization of risks based on severity and likelihood
4. Implementation of preventive and risk-mitigating measures
5. Follow-up and evaluation

The assessments give particular consideration to:

• Country risk, based on international indices relating to workers’ rights
• Industry risk, including transport, construction, warehousing, staffing and technical services
• The Group’s ability to exercise influence, including the proportion of a supplier’s turnover represented by the Group

Within the Group’s own operations, the level of risk is considered low to moderate, with particular attention given to:

• HSE risks in operational activities, including terminals, quays, vehicles and vessels
• working hours, rest periods and workload
• the use of temporary or hired labour and subcontractors

No actual violations of fundamental human rights were identified during the reporting period.

The most significant areas of risk within the supply chain relate to:

• the use of transport providers and staffing agencies
• suppliers of construction, maintenance and technical services
• certain supplies of equipment and materials manufactured outside Norway

The main risks relate to:

• working conditions
• pay and working hours
• health and safety
• the use of hired labour

The Group has not identified any circumstances requiring remediation during the reporting period.

The main findings from our due diligence assessments are as follows:

• No circumstances have been identified that indicate actual adverse impacts or heightened risk in relation to any of our suppliers.
• Based on country risk and, in particular, industry affiliation, the Group has identified certain instances of general risk of adverse impacts.
• Further work is required to improve the implementation of and compliance with policies and guidelines, including raising awareness and competence among Group employees.

A total of 20 suppliers were reviewed.

All 12 suppliers classified by the Group as major suppliers have established and published their own Codes of Conduct relating to sustainability, fundamental human rights and decent working conditions.

For the remaining eight suppliers, the Group’s Supplier Code of Conduct was sent to the relevant parties. Responses have been received from 50% of the selected suppliers confirming compliance with our Supplier Code of Conduct.

We acknowledge that general, and in some areas particular, risks exist within certain parts of our value chains. The use of hired labour is one area receiving particular attention.

• further development of a common HSE management system across the Group
• regular safety inspections and risk assessments
• employee surveys and management follow-up
• systematic training of managers and employees

• qualification of new suppliers based on ethical requirements
• prioritized follow-up of suppliers operating in higher-risk industries
• dialogue with suppliers and requirements for compliance with the Group’s supplier standards
• contractual provisions relating to working conditions

Based on the due diligence assessments carried out, the Holms Eftf Group considers that:

• its work relating to the Norwegian Transparency Act is systematic and embedded within the organisation
• the risk of serious adverse impacts is limited, although such risks are present in certain parts of the value chain
• further work will place particular emphasis on supplier follow-up, HSE and competence development

Due diligence is an ongoing process and will continue to be developed and improved on an annual basis.

Enquiries relating to this statement may be directed to: erik@holmseftf.no.

Holms Eftf. AS
E-mail: post@holmseftf.no

Tromsø, 2. juni 2026

Lasse Holm
Chair

Kjersti L. Holm
Board Member

Esben Holm
Board Member/Managing Director

Knut B. Andreassen
Chair

Esben Holm
Board member

Lasse Holm
Board member/managing director

Østen Mortvedt
Board member

Lars J. Valdermo
Chair

Lasse Holm
Board Member

Esben Holm
Board Member

Christian A. Wiik
Managing Director

Knut B. Andreassen
Chair

Esben Holm
Board member

Lasse Holm
Board member

Østen Mortvedt
Board member

Esben Rørnes
Managing director

Lasse Holm
Chair

Kjersti L. Holm
Board member

Esben Holm
Board member

Christian A. Wiik
Managing director

Lasse Holm
Chair

Kjersti L. Holm
Board member

Esben Holm
Board member

Lars J. Valdermo
Managing director

Lasse Holm
Chair

Kjersti L. Holm
Board member

Esben Holm
Board member