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1 SUSTAINABILITY STRATEGY & CSR STATEMENT 2017-2018

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Page 1: SUSTAINABILITY - NorSea.dk · 2017-12-08 · This Sustainability Strategy applies to NorSea Group . Denmark A/S and provides detailed information on the HSSE activities carried out

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SUSTAINABILITYSTRATEGY & CSR STATEMENT 2017-2018

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0.0 Preface . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3

1.0 Rationale and Background Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4

2.0 Company Profile . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5

3.0 Intrepid - Digital Business Transformation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6

4.0 Sustainability Integration Strategy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7

5.0 Sustainability Data Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8

6.0 CSR – Strategy Statements and Involvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9

7.0 Safety Status – Action Matrix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

8.0 Health Status – CSR Involvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

9.0 Environmental Status – Energy Reduction Initiatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

10.0 Environmental and Energy Saving Initiatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

11.0 Responsible Business Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Appendix 1 Norsea Group Denmark – Principles of Conduct . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Appendix 2 Glossary of Terms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

TABLE OF CONTENTS

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DEAR READERThis Sustainability Strategy applies to NorSea Group Denmark A/S and provides detailed information on the HSSE activities carried out in our company. It also states the considerations made in relation to our Sustainability and CSR Strategy.

The document is a dynamic tool describing the current sustainability strategy of NorSea Group Denmark. It will be reviewed and updated whenever relevant.

If you have any comments, questions or suggestions regarding our Sustainability Strategy, I kindly urge you to e-mail me:

0.0

PREFACE

‘A DYNAMIC TOOL

DESCRIBING OUR STRATEGY

FOR SUSTAINABLE AND

ENVIRONMENTAL MEASURES’

StordAS Stordbase

BergenCCBMongstadbase

KristiansundVestbase AS

SandnessjøenHelgelandsbase

HarstadNordbase

HammerfestPolarbase

KirkenesKirkenesbase

StavangerNorSea AS Dusavik & Tananger

Esbjerg

MontroseAberdeen

Petershead

Scrabster

FlorøVestbase AS

Per Hjort Lorenzen HSEQ Manager [email protected]

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As a provider of services to the offshore industry, Health, Safety, Security and Environmental issues are a fundamental and fully integrated part of our business.

Corporate Social Responsibility (CSR) is the latest area of management practice. The EU Commission has defined CSR as:

‘THE RESPONSIBILITY OF ENTERPRISES FOR THEIR IMPACTS ON SOCIETY’

In NorSea Group Denmark we use “Sustainability” as an umbrella for HSSE and CSR initiatives. We integrate sustainability into our business processes and consider it a competitive advantage.

RATIONALE ANDBACKGROUND INFORMATION1.0

SUSTAINABILITY

HSSE CSR

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WORLDWIDE SOLUTIONS IN THE OFFSHORE INDUSTRYNorSea Group Denmark is part of NorSea Group – a global supplier of base operations and full-service logistics solutions with 50 years’ experience and financial capacity. NorSea Group is owned by one of the world’s largest maritime industrial groups, Wilhelmsen, and the shipping companies, Møkster and Eidesvik. We oper-ate 12 supply bases around the North Sea. The base in Esbjerg is Denmark’s largest.

UNDERSTANDING AND SETTING A NEW STANDARDAs an experienced and reliable one-stop shop, NorSea Group Denmark aims to set new industry standards of efficiency and safety. We supply all types of logistics solutions and base services to the offshore sector in the North Sea and beyond.

We seek to drive greater productivity by means of digi-talisation and automation – and the principles of sharing services and assets within the group.

Anchored in a thorough understanding of our custom-ers’ commercial interests and needs, we continuously innovate to produce safe, profitable solutions.

CERTIFIED PARTNER We have since 2015, been certified according to ISO 9001, ISO 14001 and OHSAS 18001. This was only pos-sible due to the consistent efforts of our staff and the fact that considering HSSEQ related issues has become second nature – our DNA.

ORGANISATIONNorSea Group Denmark (formerly Danbor) was estab-lished in 1974 where the company began supporting the offshore companies, working in the North Sea. As the offshore industry developed the company became a multi-service supplier delivering customised solutions to the offshore industry world-wide.

NorSea Group Denmark offers the following services:

• Total integrated logistics services

• Offshore supply base and port operations

• Offshore operation and maintenance

• Steel construction and surface treatment

• Facility service and infrastructure development.

COMPANY PROFILE2.0

For more than 40 years NorSea Group Denmark has provided logistic services to the oil and gas industry. We are among the largest and most expe-rienced offshore service providers in Denmark.

OUR EMPLOYEES - OUR MOST VALUABLE RESOURCE

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Digitalisation and automation is not just the new buzz-word used by management. It does have an impact too, on a more sustainable and safer operation.

In addition to this, we are able to improve our pricing, the customer experience and provide an integrated platform for the entire value chain.

As a logistic service provider and offshore supply base & port operator, we move a lot of cargo and special equipment for our customers on an annual base. By executing a digital transformation strategy, we are able to improve the utilisation of machines, equipment and facilities which not only has a positive sustainable impact by reducing energy consumption and greenhouse gas emissions, it also reduces the footprint of required main-tenance and thereby total costs.

The aim of our digital mission is to establish a market-place for our one-stop-shop services. Reduced friction by integration and sharing the logistic assets between the stakeholders is ultimately to be capitalised in both monetary- and environmental terms.

Our new Digital Customer Service Centre instantly col-lects data and information for safe operational planning and corrective actions. We have introduced systems, tools, IOT’s and provided new services for our custom-ers, from which they also can benefit on their corporate social responsibilities.

INTREPID - DIGITAL BUSINESS TRANSFORMATION3.0

Leading the business towards the centre of the digital vortex, is a bold move. But we do believe it does make a difference to sustainable business.

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OUR FUTURE DESTINATION DEPENDS ON THE COURSE WE SET TODAYThe UN has agreed upon 17 sustainable development goals and aims to involve private companies in address-ing these goals.

In Denmark the sustainability strategy focuses on sustainable energy, quality education, gender equality, health and climate changes.

NorSea Group Denmark acknowledge our responsibility to support the transition to a sustainable planet and society. We are aware of the fact, that we as an organisa-tion, is linked to and thereby affect upon environment, health and welfare.

The purpose of our sustainability strategy is to articulate leadership and set a strategic direction for the company. We want to turn sustainability into a mid- to long term driver for profitable business.

The aim is to fully strategise, innovate and grasp business opportunies that arise from our sustainability approach in our markets.

The above four focus areas are all vital and supported by our Values, Policies and our Principles of Conduct, which is incorporated into strategies, policies and procedures. We strive to develop and implement “Sustainability” in all our operations.

This means that we operate in ways that, meet legis-lation and fundamental responsibilities in the areas of human rights, labor, environment and anti-corruption.

The strategy outlines three priorities that will drive inte-gration of sustainability into our operational processes:

• Sustainability as an element in performance manage-ment

• Trend spotting and stakeholder engagement as part of doing new business and influence regulations

• Sustainability is considered in all our investment decisions.

SUSTAINABILITYINTEGRATION STRATEGY4.0

SUSTAINABILITY VISIONOur mission is to be a responsible and profitable enterprise, balancing economic, social and environ-mental concerns for the benefit of the company and the community.

FOUR FOCUS AREAS TO BE INTEGRATED INTO BUSINESS PROCESSES

Health and Safety Environment and Climate Change Social Responsibility Responsible

Business Practises

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Bearing the above in mind, we wish to present our sus-tainability performance in a transparent and meaningful way.

We want to be accountable to both internal and exter-nal stakeholders for organisational performance towards the goal of sustainability development. We do that by:

• Improving our organisation to create a better under-standing of the environmental and social implications of our business activities

• Sharing information about how we operate

• Providing meaningful information to our stakeholders

• Contributing to trustworthiness and credibility.

NorSea Group Denmark prepares an annual data report “Sustainability Highlights” on the following sustainability issues:

• Social performance

• Safety performance

• Energy consumption

• Greenhouse gas emissions

• Other air emissions

• Waste control

• Water consumption

• Economic performance.

The process of gathering all relevant data is described in the “Internal Sustainability Reporting Control Proce-dure”.

The result of the above issues will be presented in “Sustainability Highlights”. Both “Sustainability Strategy” and “Sustainability Highlights” are accessible from www.norseagroup.dk.

SUSTAINABILITY DATA REPORTING5.0

TRANSPARENCYConsumer trends clearly indicate that consumers trust less, care more, and have far greater access to information than ever before.

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Considering the CSR process, and in compliance with our “Principles of Conduct”, we are committed to com-ply with the following statements:

• We will act sustainably in accordance with the overall policies.

• When possible and relevant, we will make use of local labour in all our operations.

• We will strive to achieve a mutual understanding of the cultural differences in the business environment in general as well as between employees.

• Within all business activities, we will strive to minimise the environmental footprint and we will support solu-tions preventing the climate from changing.

• When using local labour we will ensure that personnel are in possession of relevant qualifications. In agree-ment with our customers we will make arrangements for relevant supplementary education, if needed.

• Apart from full legislation compliance, we will con-tribute to a continuous, constructive dialogue with local politicians, interest groups, etc.

• In order to establish a common understanding of our activities, we will integrate sustainability in all business operations and make performances transparent to all stakeholders.

• We will ensure that discrimination due to cultural differences, race, religion or ethnic nationality will not occur in connection with our business activities.

• We will ensure that all employees are introduced to and live by the values of NorSea Group.

Jørn Bue Madsen CEO

Per Hjort Lorenzen HSEQ Manager

CSR – STRATEGY STATEMENTS AND INVOLVEMENT6.0

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Safety is a top priority in NorSea Group Denmark, and we constantly strive to improve our safety efforts.

For many years zero LTA’s has been the ultimate safety target, ambitious but possible.

Due to an impressive safety performance by more than 230 employees, we managed to reach the ultimate safe-ty target of “0” LTA’s in both 2015 and 2016. If we can keep this high safety standard into 2018, we will achieve a LTA frequency of “0”!

On 3 October 2017 the base in Esbjerg celebrated 2000 days without an LTA. This achievement was the result of our constant focus on safety.

SAFETY STATUS AND KPI’SThe purpose of our Health and Safety Programme is to keep employees, customers and other interested parties updated on our safety goals.

Each year, and in connection with the management review, the Health and Safety Programme will be re-viewed.

The HSEQ department will, in cooperation with relevant personnel, prepare new health and safety objectives for the following year. New initiatives will be implemented in the project “Sikker NorSea Group Denmark - Zero incidents”.

Safety objectives must always be consistent with the company’s “Health, Safety and Security Policy”.

In order to maintain constant focus on personnel safety, the below slide is kept updated and presented in all monthly department meetings.

SAFETY STATUS – ACTION MATRIX7.0

SAFETYWithout exception, “safety” is by far the most important sustainability initiative for us. Excellent safety performance is our license to operate.

Projekt ”Sikker NorSea Group Denmark – Zero incidents”

Revision 13-11-2017

Total number of ”personnel injuries”, over the last 4 years, divided into 5 types of incidents.(Approx. 400 employees)

Last 4 years LTA and TRI frequency, plus total number of reported incidents divided into 3 categories.

First Aid

Medical Treatment

RWDC

LTA

FATALITY0 00

01 0

0 22

1

63 1

14

2015(650488)

2016(633714)

2014(750722)

YTD

0

1

0

0

0 Unsafe Condition

Unsafe Act

Near Miss

TRIF

LTAF0,1 00

1,321,04 0,59

18 121

13

1912 40

1512

YTD

0,43

0,43

1

0

20

*

*

* based on 200.000 work hours.

2014(750722)

2015(650488)

2016(633714)

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SAFETY ACTION PLAN

Title Description Actions

Safety Awareness Safety awareness is being aware of safe-ty issues and of potential hazards to yourself and others in the workplace.

Safety Awareness courses for all new employees will be held.

Subcontractors working on our premises

To ensure that all contractors working on ourpremises, or on our behalf, con-tribute to an incident-free workplace.

Local procedures and a checklist will be forwarded in advance to relevant contractors.

Safety AwarenessInspections

In order to reduce the potential for accidents, a weekly safety inspection will be performed in working areas.

A safety inspection procedure and a detailed checklist has been devel-oped and implemented for both the production facility in Måde and at the base.

First Aid First aid is the provision of initial taking care of an illness or injury. It is usually performed by non-experts.

We will aim to educate as many as possible in First Aid. Yearly new courses will be arranged.

“Projekt Sikker NorSea Group”

All relevant parties have participated in the development of a new safety pro-gram comprising the whole company.

We will continue to bring focus on safety in all our operations. Quarterly meetings with repre-sentatives from all levels of the organisation will be held.

Incident-Free Life-Saving Rules

All personnel are given the opportuni-ty to attend the Maersk Oil “Incident- Free Life-Saving Rules” Course.

All employees have completed the course by 2017 and a refresher course is scheduled before 2020.

“HIGH”2015

“Best in Class”2016

“Excellent SafetyPerformance”

2017

“World Class SafetyPerformance”

2018

Safety Ambition

ACCIDENTS BEGINS - WHERE SAFETY ENDS

• Maintain NorSea Group Denmark’s LTAF at “0” throughout 2018

• Maintain NorSea Group Denmark number of “Unsafe Acts” at “0” throughout 2018

• Ensure that NorSea Group Denmark leaves 2018 with a TRIF on “0”

Safety targets for ”Projekt Sikker NorSea Group Denmark – Zero Incidents” 2018

Through proactive cooperation and good communication, we will strengthen relationships with our customers, thus ensuring that NorSea Group Denmark is emerging as a safe and reliable supplier and partner.

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In order to improve health and welfare throughout the entire organisation, it is important for all parties to play an active role.

As part of occupational health, an annual health check of relevant employees is conducted and corrective actions are carried out in close cooperation with the employee, authorities and labour unions.

HEALTH PROMOTION OFFERS Based on relevant information from workplace assess-ments, engagement surveys, etc. we will strive to offer all employees a wide palette of health promoting offers such as:

• Alcohol and drug therapy

• Flu vaccination

• Medicals

• Psychological therapy

• Ergonomic therapy

NorSea Group Denmark considers our employees our most valuable resource, which is why their health and welfare have a high priority.Through our “Absence and Sickness Policy” we want to emphasise that both the company and our employees are responsible for minimising and preventing possible long-term sickness.

Fitness training facilities are available to all groups of personnel. Exercise and fitness is given a high priority.

SOCIAL PERFORMANCE

Our employees 2014 2015 2016 2017 2018

Number of employees * Number 405 347 391 214 -

Gender (female/total) % 21 20 21 18 -

Employee engagement favorable** % n/a*** 76 59 77 -

Performance appraisals % n/a*** 24 24 78 -

* Average number of full time employees excluding jointly con-trolled entities and discontinued operations.

** The number reflects the percentages of satisfied employees who participated in the annual engagement survey. “Satisfied” is the combination of satisfaction, pride, referral and intent to stay in the organisation.

*** For 2015 and 2016, interviews have only been performed with onshore personnel. From 2017 and onwards, all employees will be offered an interview.

HEALTH STATUS – CSR INVOLVEMENT8.0

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HEALTHNorSea Group Denmark’s health strategy seeks to promote a healthy lifestyle and to provide our employ-ees with health advice. For instance, employees should, when appropriate, be given advice on healthy dieting and good exercising routines.

A crucial part of boosting employee health and safety is ensuring that the relationship between personal habits and overall well-being is clearly understood as there is an individual dimension as well. The responsibility for personal lifestyle choices, such as eating, drinking, smoking habits remains with the individual. This is why we seeks to motivate all employees to play an active role in promoting their personal health.

OUR CSR INVOLVEMENTMost of our activities are located at the harbour of Esbjerg which means that we are very close to many of our most important stakeholders. A large number of our employees are resident in the local community and involved in many different social activities.

We therefore find it natural and in line with our CSR strategy, to contribute to and support a number of different local events and activities, such as:

• EfB - (football in Esbjerg)

• Vestkystløbet - (local running race)

• Stafet For Livet - (social arrangement i favour of The Danish Cancer Society)

• Familier med kræftramte børn - (support to families with children who have cancer)

• Danske Hospitalsklovne - (support to clowns working in Danish hospitals).

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NorSea Group Denmark considers sustainability not only a business opportunity but also an opportunity for our stakeholders to see, that we as a supplier act responsible, sustainable, and transparent in all of our operations.

Due to the fact that we are constantly facing increasing demands on HSSE performance from especially the oil industry, we believe that a strategic approach to HSSE and CSR should mitigate risk and thereby bring new business opportunities to the company.

In relation to the environment, NorSea Group Denmark will undertake initiatives to promote greater environ-mental responsibility. The main task will be to pursue energy efficiency in our daily operations and thereby lower emissions and optimising costs.

The greenhouse gas emissions covering NorSea Group Denmark’s activities can be found in the brochure “Sus-tainability Highlight”.

ENVIRONMENTAL STATUS –ENERGY REDUCTION INITIATIVES9.0

SUSTAINABILITY DATA REPORTINGIn accordance with our policies we will measure and report the following data relevant to NorSea Group Denmark:

Energy consumption• Heating oil consumption• Electricity consumption• District heating• Diesel consumption

Direct greenhouse gas emission• CO2, CH4, N2O

Local air emissions• SOx, NOx, VOC, SO2, NO2

Water consumption• Total water withdrawal by source

Waste generated• Total waste by method of disposal

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ENVIRONMENTAL REDUCTION TARGETSThe above reduction targets in % are “relative” and linked to our revenue, meaning, that if the revenue increases by 10%, the energy consumption is expected to follow as a consequence of this increasing activity.

In order to pursue energy efficiency and the above GHG reductions, an assessment of all energy consumers within our operational control has been performed.

After an economic prioritising of the suggested initia-tives, the above “GHG Reduction Targets” have been determined, with 2014 as base year.

With the introduction of LEAN principles and digitalisa-tion of our processes, we have become more productive and thus reduced our energy consumption.

CLIMATE CHANGEThe global attention to climate change is on top of the agenda everywhere.

We are continuously committed to finding ways to re-duce our GHG emissions, as this is our primary environ-mental impact.

For several years we have registred our energy con-sumption in order for us to monitor our environmental footprint.

In 2016 our ISO 14001 Environmental certification was expanded with the the energy review according to chapter 4.4.3 in the recent ISO 50001 standard.

RELATIVE GHG REDUCTION TARGETS (SCOPE 1 AND 2 GHG PROTOCOL)

Year 2014* 2015 2016 2017 2018 2019 2020

Reduction target - 0% 3% 5% 8% 10% -

Actual reduction achieved - 1,7% +8,45% ** - - -

Actual emission (ton) 3.088 3.036 3.373 ** - - -

Revenue (mill/DKK) 401 364 414 tbn - - -

Development in revenue - -9,3% +3,14 tbn - - -

*(baseline) ** figure available in March 2018

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Description of target areaPreliminary

study

Estimatedenergy

saving in %

Financial year

Status

Heating and ventilation: The “Property service” department features many square meters for own and rental use. Heating and ventilation should be adjusted according to the amount of rented/not rented square meters.

2-5% 2016 ongoing

Property manager is informed when-ever changes are made and ventilation and heating is adjusted by caretakers.

Diesel consumption at the Base: A lot of activity is going on at the base and diesel is used for trucks and crane. Whenever a truck has to be replaced it will be replaced with a new more environ-mental friendly truck.

2016 0-5% 2017 ongoing

2 new forklift trucks has been aquired in 2017 on a lease contract. The aim is to keep our fleet of forklifts as effec-tive as possible.

Diesel consumption in trucking department: We have 23 vehicles, that all uses diesel; the vehicles are being replaced ongoing whenever needed. A system from TomTom will be installed in all vehicles in 2018; this to evaluate driving and promote "green driving".

2016 2-5% 2017 ongoing

3 new vehicles has been bought in 2017. All drivers has been instructed according to “green driving”. A compe-tition for drivers is planned for 2018, this to reduce diesel consumption with 6% within a periode of 6 months.

Paint shop, Måde Industrivej 36: Since the painter’s cabin has a high energy consump-tion, an external company has in 2017 investigated whether the existing heat exchanger, ventilation can be optimized. Energy consumption should be evaluated according to actual amount of invoiced work.

2017 ? History of invoiced work has been collected back from year 2012. The process of optimizing work and min-imizing energy consumption has not yet been planned.

Smithy, Måde Industrivej 36: The energy consumption at the smithies are somehow high compared to the company’s total energy con-sumption. In 2017 an external company has investi-gated whether the existing energyconsumption can be optimized. In the future energy consumption should be evaluated according to actual amount of invoiced work.

2016 ? History of invoiced work has been collected back from year 2012. The process of optimizing work and min-imizing energy consumption has not yet been planned.

Refurbishing of Kanalen 1: Will affect energy consumption within the follow-ing areas: Facade insulation, isolation on the roof, centralization of cooling, night savings partly through natural ventilation, CTS management, passive heating in the winter, passive cooling during summer, energy subsidies e.g. solar cells.

2016 45% 2017 Awaiting final accept.

Intrepid: After implementation of all projects within “Intrepid” it is estimated that the diesel consumption at the base, will be reduced approx. 30% in relation to ton of goods handled on the quay side.

2017 30% 2018 Start up in Q1 2017 – Ongoing.

KAESER compressor in Bulk: In connection with moving of the bulk plant to a new position on the base, new piping has been introduced. It is expected that the bigger piping diameter has a positive impact on the amount of bulk material trans-ported with the same energy input.

2017 ?? 2017

Start up in Q2 – ongoing.

ENVIRONMENTAL AND ENERGY SAVING INITIATIVES10.0

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SECURITYAs a supply base for the wind, oil and gas industry, we have a special commitment to take all necessary pre-cautions to maintain high security standard and security awareness within our organisation, both onshore and offshore.

Our supply base located at the harbour of Esbjerg is operating in full compliance with the ISPS (International Ship and Port Security) code.

In order to respond to incomming threats, terrorism etc. and to ensure security awareness from all employees, a “Security Handbook” describing the most common questions in relation to security, has been prepared. The Security Handbook is easily accessible and available in the online management system D4.

Apart from physical security, we seek to protect the company and its employees from illegal acts with respect to security and to show constant care in order to prevent breaches of security associated with our operation.

ANTI–CORRUPTION PROGRAMMECorruption including bribery is against the law and against our “Fraud and Bribery Policy”. We will work against corrupt practices by constantly focusing on the anti-corruption measures, that we can take as a group.

Our “Fraud and Bribery Policy” has been elaborated to facilitate the development of controls with the purpose to detect and prevent any possible fraud against our company.

“No employee at any level may offer, promise, author-ize or give anything of value to any public official in any country, or to any business partner, in order to gain any improper business advantages of any kind. Nor may any employee solicit or accept any form of bribe from any person”.

The guidelines from the “Fraud and Bribery Policy” must be followed and all fraud cases will be reported.

RESPONSIBLEBUSINESS PRACTICES11.0

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NORSEA GROUP DENMARK– PRINCIPLES OF CONDUCTAppendix 1

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Accident An undesired event, or series of events, that results in injury or illness to people.

Audit A systematic and independent examination to determine whether activities and related results comply with the Management System and whether the system arrangements are suitably implemented, and documented to achieve the desired objectives.

CSR Corporate Social Responsibility.

Fatality A death directly resulting from a work related injury regardless of time between the injury and death.

First Aid Case (FAC) Work related injuries that are not sufficiently serious to be reported as medical treatment or more serious cases but nevertheless require minor first aid treatment.

HSEQ Health, Safety, Environment and Quality.

HSS Health, Safety and Security.

Incident An undesired event that results in harm to personnel (injury or illness), environ-mental damage, property damage/loss, or business interruption (loss of process) that may have an adverse impact on NorSea Group Denmark.

Incident Frequency Cases multiplied by 1 million, and divided by the number of exposure hours. Allows for comparable measuring of incident types. Eg: (Number of LTIs) x 1,000,000 exposure hours.

Lost Time Accident (LTA) Any work related accident or injury which results in a person being unfit for work for a period of 24 continuous hours immediately after the occurrence of the incident. This period includes rest hours, discharge and sign-off days, weekend days, public holidays or days after ceasing employment.

Medical Treatment Case Work-related injuries that are not severe enough to be reported as Lost Time Accident cases or Restricted Work Accident cases but are more severe than requiring simple first aid treatment i.e. treatment by a doctor, physician, dentist, surgeon, registered medical personnel or Radio Medical advice, however the injured person is able to carry out all his duties after treatment.

Near Miss An event or sequence of events which under slightly different circumstances could have resulted in harm to personnel.

Sustainability Sustainable development is development that meets the needs of the presen without compromising the ability of future genera¬tions to meet their own needs. In essence we should manage our resources efficiently to ensure future prospects.

Risk Assessment The proper identification, measurement and prioritizing of risk. Also known as Safe Job Analysis (SJA).

GLOSSARY OF TERMSAppendix 2

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NORSEA GROUP DENMARKKanalen 1DK-6700 Esbjerg

Tel. +45 7911 1900

WWW.NORSEAGROUP.DK