ESG Performance Report 2022

()3 What we do and how we create value
04 Letter from our CEO
05 2022 ESG performance in brief
06 Governance and reporting
07 Sustainability priorities
1() Cost-effective decarbonization
20 Always safe and secure
24 Trusted and responsible partner
26 Transparency Act
27 Additional ESG topics
GRI Index 31
36 Independent assurance report from EY

What we do and how we create value

Klaveness Combination Carriers ASA (KCC, Company) is the world leader in combination carriers. The fleet consists of 16 vessels, eight CABU vessels and eight CLEANBU vessels.

The CABU (Caustic Soda-Bulk) and CLEANBU (Clean Petroleum Product-Bulk) vessels mainly transport Clean Petroleum Products (CPP) or Caustic Soda Solution (CSS) from refineries and production plants located in Middle East/India, Far East or US Gulf to end users or distributors in Australia and South America, the world's main export hubs of dry bulk commodities. On the return voyage the combination carriers transport dry bulk commodities including alumina, bauxite, grains, salt, iron ore and coal.

The aluminum/alumina industry through the transportation of CSS, bauxite and alumina accounted for 39% of KCC's transported volumes in metric tons (MT) in 2022. KCC had six coal shipments in 2022 (6%), and total fossil fuel shipments including clean petroleum products and coal accounted in total for 25%*. Iron ore shipments for mining companies or steel plants accounted for 15% in 2022.

Split of Cargo transported

Caustic soda · Alumina and bauxite Iron ore · Fossil fuels* · Agriculture products ● Other cargos

*Fossil fuels include gasoil, coal, gasoline and other CPP. Naphta and condensate to the petrochemical industry included in other cargo

KCC strives to solve inefficiencies by maximizing the utilization of its fleet and by minimizing ballast between the laden voyages through consecutively switching between dry and wet cargo shipments.

1. Lower carbon emissions: Fuel consumption and hence emissions are 30-40% lower than standard tanker and bulk vessels per ton-mile transported cargo
1. Lower earnings volatility: Diversified market exposure as the vessels transport both dry bulk and tanker products and a positive correlation to bunker prices
1. Premium earnings: Higher asset utilization compared to standard vessels due to two laden legs, giving a higher number of revenue days

l etter from our CFO

We have been through a close to three-year period marked by the COVID-19 restrictions disrupting the shipping industry and seaborne supply chains. These restrictions hit our seafarers unjustifiably hard through interruptions and strict limitations to crew changes and shore leaves as well as extensive testing and long hotel quarantines for on-signers to our vessels. From the middle of 2022, restrictions were eased and from the end of the year repatriation of seafarers after end of service period were back to pre-COVID normal. The lifting of the strict Chinese COVID-19 policies in January 2023 hopefully marks the end of this difficult period.

KCC and its ship manager Klaveness Ship Management AS (KSM) have throughout this difficult time had our crew's wellbeing and safety as our priority number one. Overall, KCC's health and safety performance has improved further in 2022 with no major or medium crew injuries. During the year we have, despite widespread COVID-19 restrictions, succeeded to carry through most crew changes with limited delays through frequent ports deviations. Additional initiatives were made to support the crew in relation to their mental health. Irrespective of our efforts, we appreciate the hardship of our seafarers and their families, and we are immensely grateful for the sacrifices and the dedication of our crew during this difficult period.

The incomprehensive and brutal Russian attack on Ukraine in February left its marks on 2022. KCC has been spared any significant negative effects of the ongoing war with no Russian and Ukrainian seafarers and with main trading area far away from the war zone. The closeness of these war atrocities to the home of our Romanian seafarers is however a reminder of the fragilities of the world order and the obligations of our company to support ongoing Western economic sanctions towards Russia. A strict Russia- trade policy has been implemented where our vessels under no circumstances shall sail to or from Russian ports, transport Russian or Belarusian originated cargoes and no business should be done with companies controlled by Russian or Belarussian interests.

KCC vessels' substantially higher efficiency delivers a cost effective decarbonization to KCC's customers. By replacing standard vessels with KCC's combination carriers, customers can cut emission from their ocean freight by

30-40%. KCC has high ambitions to improve this competitive advantage further. We have during 2022 made considerable progress with our decarbonization initiatives focusing on harvesting untapped efficiency potentials throughout our operations. The trading efficiency of KCC's fleet has been further improved during the year. Combination trading improved from 68% in 2021 to 83% in 2022 and the time our vessels sail empty without cargoes onboard, so called ballast, was reduced from 17% in 2021 to 12% in 2022, a fraction of the ballast of standard vessels. To achieve further improvements in trading efficiency we target to strengthen further the co-operation with our customers and has developed a contractual framework for co-operation. This framework focuses on improving reporting, developing joint emission reduction targets and a carbon pricing linking emission performance and freight costs. After a successful trialing in 2022, we are pleased to implement the first such carbon pricing mechanism into one of our freight contracts with effect from 2023.

We have furthermore expanded the installation of energy and voyage efficiency measures on our vessels. A major milestone was reached during spring of 2022 with the conclusion of contracts for a trial installation of an air lubrication system in combination with a new shaft generator to be made on two vessels during 2023. Subject to successful installation on the two first vessels, KCC intends to roll out this system on the whole modern KCC fleet in the period 2024-2026. This is just the start and KCC in co-operation with KSM will continue its focus on identifying, testing and installation of additional new energy and voyage efficiency measures over the coming years.

Focus on Environment, social and governance (ESG) is a centerpiece in KCC's strategy. Our ambitions for reducing KCC's environmental footprint are outlined in KCC's environmental strategy, an updated strategy will be presented 29 March 2023. We are committed to transparency and information sharing with respect to our ESG performance through our quarterly reporting and this annual sustainability report. We believe long term success requires willingness to take serious action and being at the forefront when it comes to ESG challenges and opportunities. We are future bound!

Engebret Dahm | CEO, Klaveness Combination Carriers ASA

2022 ESG performance in brief

Environmental performance

Carbon intensity (EEOI)

6.9 Ambition 2022 <5.8 CO / vessel year

17,900 tons Ambition 2022 <17,700 Trialed carbon pricing in a cargo contract

Started more than 15 energy efficiency initiatives on the existing fleet

NODP DISCLOSER 2022 Score: B

Social performance LTIF 0.3 Ambition <0.5

0 Major or medium injuries

Average high-risk SIRE observations 0.7 Ambition <2

Governance performance

100% of employees attended dilemma training

0 confirmed incidents of corruption

The Transparency Act implemented in policies and procedures

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Governance and reporting

Governance description
Board of Directors (BoD)	· Review, discusses with management, and approves the strategy and business plans including ESG topics and management of climate-related risks and opportunities · Reviews, approves, and monitors specific short-term goals and ambitions and monitors implementation and performance of objectives including climate-related ambitions and targets · Approves and oversees the environmental policy and strategy · Approves the risk management policy
Audit Committee of the BoD	· Monitors and oversees the risk management policy and framework · Discusses with management the quarterly risk review, including climate-related risks · Together with the administration plans and follow-up internal audits, including audit of environmental KPIs and other climate-related reporting
Chief Executive Officer	· Main responsible for developing and implementing the general strategy and the environmental policy and strategy · Main responsible for managing climate-related risks and opportunities and reporting these to the Board of Directors · Main respnsible for making sure the service providers (with focus on ship management, commercial operations, and project development) adapts relevant targets and ambitions
Chief Financial Officer	· Main responsible for risk review framework and policy, performing risk reviews and for establishing mitigation plans, including for climate-related risks and opportunities

Management approach

Sustainability is an integral part of KCC's overall strategy and all business activities from daily operations to discussions and decisions made on Board level. The Board of Directors ensures that appropriate goals and strategies are adopted, that the adopted strategies are implemented in practice, and that the results achieved are subject to measurement and follow-up. The Board of Directors considers sustainability-related issues when reviewing and guiding KCC's strategy and business plans, action plans and major capital expenditures. Moreover, the Board of Directors considers sustainability-related issues in the monitoring, implementation, and performance of strategic objectives. The five-years strategy plan for 2021-2025 was resolved by the Board of Directors in November 2020 and is reviewed and adjusted on an annual basis. Some of the main building blocks in this strategy period are built on risks and opportunities related to decarbonization. KCC published its first Environmental Policy and Strategy for the period 2020-2050 in January 2020, including short- and long-term ambitions approved by the Board of Directors. This environmental strategy has been reviewed and an updated strategy will be published on KCC's website within the end of March 2023.

Key performance indicators (KPIs) have been defined for material sustainability topics. Ambitions, performance, and action plans are reviewed and reported to the Management team and to the Board of Directors and sustainability topics are assessed and monitored as part of the Company's overall risk review which is discussed with the Audit Committee (AC) and the Board of Directors several times every year.

The Audit Committee has increased its focus on nonfinancial reporting through 2022. It ensures that objectives, metrics, and policies related to ESG are appropriate, reported transparently and reviewed regularly in line with statutory requirements.

Further information on corporate governance can be found in the Board of Directors' Corporate Governance Report for 2022 and on KCC's website. The below table is an overview of governance for climate-related risks and opportunities in line with the Task Force on Climate-related Financial Disclosures (TCFD) requirements.

Reporting standards

The ESG Performance Report for 2022 is aligned with the Global Reporting Initiative Standards (GRI), the Task Force on Climate-related Financial Disclosures (TCFD) and the Greenhouse Gas Protocol initiative (GHG Protocol), Corporate Accounting and Reporting Standard Revised edition. Reference to relevant UN Sustainable Development Goals (SDGs) is included as well.

Third party verification

EY has for 2022 provided an independent limited assurance report on the environmental key performance indicators (KPIs) and the Carbon Accounts (in line with the GHG Protocol). The auditor's report is included at the back of this report.

Sustainability priorities

This report highlights KCC's 2022 Environmental, Social and Governance related activities and performance, and outlines future ambitions and plans. The report focuses on the most significant topics, while additional topics are covered on page 27 in the report under Additional ESG topics.

Stakeholder engagement

Priorities in this report are identified based on stakeholder expectations, significant impacts, and internal strategic priorities and assessments. It is important for KCC to be transparent and build trust with its stakeholders. Continuous learning and improving are key to KCC, hence having an open dialogue with the main stakeholders is fundamental. The following stakeholder groups are prioritized when establishing our material ESG issues: customers, suppliers, equity investors, debt providers, regulators and employees.

Stakeholder expectations are mapped through a combination of inquiries and dialogues as part of daily business and feedback received at corporate level with investors, regulators, and finance institutions. News about future regulations and technological developments are as well important input. More information about stakeholders and stakeholder engagement can be found on www.combinationcarriers.com. KCC's stakeholders are particularly concerned about safety, emissions, anti-corruption, ship recycling, labour and human rights and sanctions.

Materiality assessments

KCC applies the principle of double materiality in determining how sustainability topics may constitute responsibilities or risks, enabling KCC to understand and report those topics where KCC has significant responsibility to mitigate potential negative impact on society or to the environment and where topics may pose significant risk to the business.

The different sustainability topics are ranked in terms of impact to the market, environment and people (outwards) and financial materiality in influencing business value (inwards).

The priorities have been slightly adjusted compared to the 2021 Sustainability Report. The Governance section this year focuses on "Compliance program and training" and "Counterparty Code of Conduct and Know Your Counterparty Procedures" instead of "Cyber security" and "Related Party Transactions". COVID-19 still had impact on KCC's crew and operations in 2022, but somewhat less impact than in 2021, which is reflected in the Social section. Category one (purchased goods and services) and category four (upstream transportation and distribution), both considered relevant in 2021 but not included due to limited data availability, have been included as part of scope 3 emission reporting in 2022.

Impact On Enterprise Value

Delivering cost-effective decarbonization

KCC is well positioned to deliver cost-effective decarbonization

We aim to deliver a cost-effective low carbon shipping service primarily through driving efficiency improvements in all parts of our business.

Area of focus

· Emission reductions from our vessels

Always safe and secure

Safety is priority number one

Our goal is that no one shall be injured doing work for Klaveness. Every day we work to improve our safety performance, believing that operational accidents are preventable.

Area of focus

· Crew health and safety
No spills to the environment and serious vessel accident
· Crew retention and development

Trusted and responsible partner

We set high standards on how we conduct our business

We strive to have a high level of corporate governance securing accountability and transparency for all stakeholders.

Area of focus

Anti-corruption and business ethics
Responsible ship recycling
· Strong counterparty procedures
Human and labour rights

Relevant sustainability development goals

Cost-effective decarbonization Main Environmental priority

Cost-effective decarbonization

Climate-related risks

Climate-related issues have been high on the agenda in KCC for years and have been incorporated in strategy processes and business planning, as well as in daily operations and stakeholder dialogues. Management of climaterelated risks is part of KCC's risk management framework and follows the same governance as KCC's general risk assessment. The risk assessment is based on an impact and probability matrix, potential mitigating actions are outlined for, and responsible persons are allocated the main risks. The risks are discussed by the Management and the Board of Directors normally on a quarterly basis.

KCC's main climate-related risks and opportunities with a potential material financial impact are summarized in the table below. KCC's assessment is that the three main risks are transition risks related to decarbonization and that physical risks have a lower impact on KCC's activities.

KCC has not identified any non-compliance with environmental laws and/or regulations in 2022.

Risk type	Description	Potential financial impact	KCC impact example
Technology	There is still high uncertainty related to future propulsion technology and which zero-emission fuels that will fully decarbonize deep-sea shipping	Existing vessels might be outdated prior to the expected life of the vessel resulting in early recycling and hence write-downs Existing vessels might become less competitive, which might impact revenue negatively Higher capital expenditures in relation to retrofit or new vessel investments Risk of investing early in technology that will not be the preferred solution long-term Lack of access to capital if existing fleet is out of favor	The impairment risk related to KCC's remaining five first generation, CABU I vessels built 2001-2007, which will be recycled in the period 2026-2032 is limited as the vessels have been depreciated over many years. The risk of impairment is mainly linked to KCC's 11 vessels built 2016-2021 for which new propulsion technology and the emergence of zero-emission fuels might lead to lower vessel values and impairment in the longer term (10 years +) when new technology matures. If the 11 vessels built 2016-2021 become outdated five years prior to expected life of 25 years, the financial impact/impairment is approximately in total USD 90 million (range USD 6 - 9 million per vessel).
Market	Demand for fossil fuels and hence demand for transpor- tation of fossil fuels will decrease over the next decades	New trade flows and changes in existing trade flows might affect the combination trading pattern and revenue Decarbonization may negatively impact supply-demand balance in both the dry bulk and tanker markets resulting in more vessels competing for lower freight volumes or different types of cargo and freight rates might deteriorate and revenue decrease Vessels might be unfit for service and hence might need to be recycled early resulting in write-downs	Energy transition or lower demand for clean petrochemical industry in countries served by the CLEANBU vessels will impact KCC directly. Loss of 50% of the transported volume of fossil fuels imply approximately 40% lower combination trading for the CLEANBU vessels, estimated to impact the revenue by approximately USD 13 million per annum based on 2022 numbers (approx. 1,000 days combi-trading of in average \$33,500/day substituted by TCE earnings for a standard dry vessel of in average \$20,700/day = 1,000 days x lost earnings of \$12,800/day = ~ USD 13 million).
Policy and legal	Introduction of new global and/or regional environmental regulations	· Future regulations might give the industry the wrong incentives when it comes to improving efficiency of the operations and trading to reduce fuel consumption New regulations may require investments in retrofit/ upgrading to reach compliance Introduction of new regulations such as the EU Taxonomy and initiatives as the Poseidon Principles might impact the access to and pricing of capital	If future carbon taxes are based on fuel consumption per deadweight (theoretical intake) and not per ton cargo transported, the regulations will not incentivize the industry to reduce fuel consumption by improving efficiency. AER (the carbon intensity indicator currently adopted by the IMO) uses the registered deadweight and not actual cargo, and favour ballast voyages and less transport work. Sailing in laden condition requires more energy than ballast and due to the efficiency of the KCC vessels with increased time laden, the AER of the KCC vessels will likely be 10% higher than the standard vessels. Given USD 81 /mt CO, global tax (EUA price average 2022) and annual emission of 300.000 mts CO , 10% more energy per nm could result in USD 2.4 million in higher taxes for KCC.

Strategy and climate-related opportunities

KCC has in early 2023 updated its Environmental Policy and Strategy, initially developed in January 2020. The updated Environmental Strategy will be published in late March 2023.

In the Environmental Policy and Strategy presented in 2020, KCC's decarbonization ambitions for the period 2020-2022 were a 15% reduction in average CO2 emission per vessel year and a 25% reduction in the carbon intensity of KCC's fleet (EEOI) relative to KCC's actual performance in 2018. During this first phase of KCC's decarbonization journey, there have been several challenges and learnings. KCC can in this period, however, show to many achievements including a 14% reduction in average CO2 emission per vessel year relative to 2018, more or less meeting the ambition of a 15% reduction. Other ambitions have proved more difficult to meet, including the ambition for carbon

intensity reductions which in 2022 ended 8% lower than in 2018 versus the ambition of a 25% reduction.

KCC has a strong starting point as the sole global player in combination carriers having a 30-40% lower carbon emissions per transport work compared to standard vessels in the same trade patterns. In its updated strategy, KCC reconfirms its ambition to be in lead in decarbonizing the shipping industry and further strengthen this competitive advantage versus standard vessels. KCC is in a strong position to deliver on the revised strategy and targets based on extensive experience and competency built in

KCC and Klaveness Ship Management ("KSM") during 2020- Decarbonization of the shipping industry is both a risk 2022. Over the first phase of the next strategy period, 2023- and an opportunity. Building a strong competitive 2026, KCC's focus is to harvest the still untapped potential advantage with respect to decarbonization likely will be of efficiency improvements in every part of KCC's business with an intense focus of improving the carbon intensity (EEOI) of its current fleet over the coming years by 20% compared to 2022 actual and 28% vs. 2018 actual. While requirements are becoming stricter. KCC has identified the KCC will start preparing for use of new fuels over the next following main climate-related opportunities based on the four-year period, KCC believes that the use of new fuels - Task Force on Climate-Related Financial Disclosures (TCFD) in any scale will only be possible towards the end of this - recommendations. decade and into the 2030-ies.

even more important when new emission regulations including carbon taxes and possibly mandatory blending of low carbon fuels are implemented, and customers'

Opportunity type	Description	Potential financial impact	KCC impact example
Resource efficiency	Efficient combination trading and voyage execution	In KCC's opinion the starting point for any decarbonization journey is to solve the current large inefficiencies in deep-sea shipping. KCC evaluates this as an opportunity as KCC's combination carriers have substantially higher trading efficiency and hence a lower carbon footprint than the competitors, the standard tankers and dry bulk vessels, forming an important competitive advantage for KCC. KCC's vessels have far higher utilization than standard vessels by consecutively switching between dry and wet cargo shipments with minimum ballast between the laden voyages. By further improving the trading patterns and the execution of the performed voyage, KCC's competitive advantage will improve further.	By improving the combination trading from 83% (2022 actual) to 90%, the impact on revenue in 2022 is estimated to be approximately USD 4.7 million. In 2022, KCC had 5,518 on-hire days for the CABU and CLEANBU fleet. 7%-points incease from 83% to 90% com- bi-trading amounts to 386 days. Given a dry bulk market in 2022 of on average 19,300 \$/d (P4TC) and average earn- ings in combination pattern (dry leg + wet leg) estimated at approximately 31,400 \$/d, the difference in earnings per day between trading dry and combi is approximately 12,000 \$/day. The financial impact example is hence: (12,000 \$/d x 386 days = USD 4.7 million).
Resilience	Carbon pricing	KCC's combination carriers have a lower exposure to carbon taxes as the vessels have substantially lower carbon emission levels than competing standard vessels for the same transport work mainly due to considerably less ballast. For example, in a round voyage with naphtha from Europe to Brazil and iron ore on the return leg to Europe the CLEANBUs have around 35% lower CO2 emissions than standard LR1 tanker and Kamsarmax bulkers doing the same transportation work. The standard vessel either ballast into Europe or have long ballast before loading the cargo to Europe, while the KCC combination carriers are laden both in and out of Europe.	In an example with a round voyage with naphtha from Europe to Brazil and iron ore on the return leg to Europe and assuming both shipments in and out of EU are taxed in line with the EU ETS (50% for voyages in and out of EU fully implemented 2026), a KCC combination carrier would have USD 104,000 lower carbon tax relative to the total for the LR1 tanker and the Kamsarmax bulker based on a cost of €81 per metric ton (EUA price average 2022). Measured in TCE-earnings per day for the CLEANBU vessels, the carbon tax difference implies around 1,800 \$/d higher earnings on voyage basis. Based on an example where KCC employs two of eight CLEANBU vessels in trades subject to carbon taxes and assuming the same price of €81 per metric ton, the impact on revenue in 2022 would be USD 1.3 million. If carbon taxes are implemented on a global basis with payment for 100% of emissions, the effect on earnings will be 3,800 \$/d which for all 16 vessels would equate to approximately USD 22 million per year.
Products, servicecs	Shift in consumer preferences	As fossil fuels are being phased out over time, there will likely be demand for transportation of new types of cargoes, one example being spodumene to produce lithium batteries like the lithium refinery industry in Australia are as well expected to increase imports of caustic soda for refining spodumene to lithium hydroxide being used in batteries, increasing demand for transportation in one of KCC's main trades. However, increased demand for new cargo types must fit into a combination trade pattern to be valuable for KCC.	KCC is less dependent on transportation of hydrocarbons than its competitors, and KCC's ambition is to increase transportation of non-fossil cargos. Coal accounts for around 40-50% of the total cargo volume transported by Panamax/Kamsarmax dry bulk vessels while coal accounted for only 6% of commodities transported in 2022 for KCC. LR1 tankers are employed close to 100% in transportation of clean petroleum products, while the share for KCC's vessels was limited to 19% in 2022. Of total volumes transported by KCC in 2022, 25% were fossil fuels. As a rough calculation, assuming that 10%-points of this in the future will be substituted with non-fossil cargoes and that these 10%-points equals 10% of revenue in 2022, the financial impact is estimated to be USD 16 million.

KCC's Decarbonization Efforts

KCC has divided its decarbonization initiatives into the following three categories:

How to reach the ambitions

1. Optimize trading efficiency

KCC works actively to:

· Maximize cargo intake
· Maximize loaded voyages and minimize ballast through maximizing combination trading patterns
Minimize waiting time in port and avoid high speed voyages through better scheduling and customer co-operation

Performance and ambition1	2022 ambition	2022 actual	2026 ambition
% of days in combination trades	>85%	83%	>90%
Ballast days in % of total on-hire days	<13.5%	12%	<10%

During 2022:

KCC has demonstrated the combination trading concept at scale after taking delivery of the three last CLEANBU newbuilds during 2021 and completing reorganization of the CABU trading pattern during first half 2022. This resulted in lower number of ballast days and an increased number of switches between dry bulk and wet cargos, positively impacting the ambition of increased combination trading and reduced time in ballast
· KCC has developed a framework for co-operation with its customers with respect to emission reductions, the so-called Sustainability-linked Contract of Affreightment. Co-operation to maximize the trading efficiency of each shipment is central in this framework and includes maximizing cargo intake, improve port turnaround, voyage execution and fleet planning and minimize waiting time and demurrage
· KCC has in co-operation with one customer trialled a carbon pricing mechanism into shipping contracts to incentivize trading efficiency. With this mechanism, freight will depend on KCC's actual emission performance of each voyage relative to an established baseline increasing freight if KCC overperforms the baseline and reducing freight if KCC underperforms the baseline

Focus 2023 and onwards:

· The carbon pricing mechanism piloted in 2022 has been integrated into the Contract of Affreightment with one customer with effect from 1 January 2023. KCC targets to expand this mechanism into contracts with multiple customers over the coming years
· KCC has from 2023 as a part of its updated Environmental Strategy implemented an internal shadow carbon cost into all chartering decisions involving long ballasts. The voyage alternative with the longest ballast will be penalized by adding a carbon cost reflecting the additional carbon emission of the voyage in question, priced equal to EU's traded carbon pricing (EUA)
· consumption and carbon emission. In this work improved planning and customer co-operation are essential. All KCC's voyage planning shall assume a service speed of maximum 12.5 knots irrespective of market conditions, and a "speed limit" of 12.5 knots will be implemented where practically possible in the daily operation.
· KCC will as well implement a new digitized fleet scheduling tool in 2023 to improve the fleet planning
· Furthermore, KCC will in parallel work with its customers to improve voyage and port planning and target over the next years to establish a "virtual arrival" arrangement in loading and /or discharge ports in its trade patten to amongst others reduce high speed voyages and reduce waiting time

2. Perfecting voyage efficiency

KCC invests in:

KCC has:

Better decision support systems onboard vessels and crew training to ensure the crew has the best tools and knowledge to improve weather routing, ensure optimal trim, constant load and optimal use of energy consumers onboard the vessel. The onboard vessel performance systems will also supply shore organization access to key vessels data in order to better assist the fleet with energy efficiency support and actions.

Dedicated onshore resources using data from the vessels, generated through digitalization of the vessels, to attain insight in vessel performance. Based on this, KCC implements actions to improve the performance of the vessels and make proactive actions basis the actual technical condition and the planned operations

During 2022:

Decarbonization has been a topic of video conferences with crew waiting to sign on vessels, and a topic in the officer conferences
· A computer-based training course related to the vessel performance system was developed and rolled out onhoard
· Several new instructions related to energy efficiency were included in the Voyage Procedures
· A new position, an Operational Energy Efficiency Manager, was established within Klaveness Ship Management AS. The position shall improve utilization of energy efficiency tools implemented to the fleet, challenge and establish best energy efficiency practices, proactively safeguard clean hulls, as well as other daily tasks related to operational energy efficiency
· A roll-out of a vessel performance system onboard all CABU vessels was started. This includes the retrofitting of high-quality mass flow meters and other sensors providing high frequency data to assist the crew to operate the vessel in the most fuel-efficient way during a voyage. The system also provides further possibilities of performance analysis from shore
· A pilot study combining vessel sensor data and weather hindcast for future weather routing was initiated. This will be further developed over 2023 with an ambition to roll out large scale on the fleet
The use of strategic power routing advisory was scaled-up significantly, optimizing the main engine load over a voyage to reduce emissions

Focus 2023 and onwards:

· The initiatives related to crew training and improved procedures will be further developed in 2023
· Vessel performance systems will be installed on all remaining vessels in 2023
· feasible CABU I vessel
Test and compare alternative weather routing services, including sensor-based performance models on actual voyages
Increased focus with energy efficiency included in the monthly meetings with the ship board management team on each vessel, and dedicated energy efficiency vessel visit reports included as part of the management procedures

3. Maximize energy efficiency

KCC invests in:

· KCC invests in its vessels to reduce hull resistance, improve propeller and hull effectiveness and optimize the vessels' energy utilization and evaluate alternative energy generation.

Performance and ambition	2022 ambition	2022 actual	2026 ambition
Reduce the fuel consumption corrected for draft, weather, and speed.	10% reduction versus KCC's 2018 performance	9.3% reduction versus 2018 performance	18% reduction versus 2018 performance

In 2022, KCC invested and committed in total USD 8.1 million in energy efficiency measures in its fleet. The investments made in 2022 and that will be further rolled-out in 2023 can be divided into the following categories:

Minimize hull friction - as friction forces on the hull during sea passage are estimated to represent about 70% of energy use, KCC has focus on and has implemented the following technologies, measures and procedures to minimize hull friction:

· The application of silicone antifouling hull coating on two out of three vessels which were dry-docked
· Epoxy fearing of hull plate welding seams to smoothen the hull on one vessel during dry-dock. This technology will be further evaluated and developed in 2023
· With the newly appointed Operational Energy Efficiency Manager, further efforts are being made to monitor hull performance and optimize hull cleaning by divers in port
· Piloting, testing and development of semi-autonomous cleaning robots for in-transit cleaning of hulls (ITCH) have been scaled up to prevent further marine growth of the vessels' hull. Five additional robots were purchased at the end of 2022, increasing the number of ITHC robots from currently four in operation to nine within 2023
Contracts concluded for installation of air lubrication systems on two vessels in 2023 reducing the frictional resistance by creating a carpet of bubbles coating the full flat bottom of the vessels. In addition, KCC has options and the intention to install this system on all its additional nine 2016-2021 built vessel during the period 2024-2025, pending successful testing of the installation on the first two vessels

Improve propeller and hull efficiency:

· Installations of Mewis ducts have continued in 2022 with the installation on one CLEANBU vessel and two CABU vessels. The solution has been installed on in total five vessels from every class of KCC tonnage, with plans for another five vessels during 2023. The duct is designed to optimize the flow going into the propeller, reducing the fuel consumption between 3-6% depending on type of vessel and operation
Propeller boss cap fins have been installed on additional two CABU I vessels, with only one CABU I vessel remaining which will be installed in 2023. This will reduce propeller vortex and thus reduce ship drag and is estimated to provide a 1.5% average emission saving
· In combination with the installation of the air lubrication system. KCC has concluded contracts to retrofit a shaft generator on two vessels which will be installed during 2023. KCC has options and intention to install the shaft generator together with the air lubrification system on additional nine vessels in 2024-2025, pending successful testing of the installation on the first two vessels

Other emission reduction initiatives are under evaluation, such as:

· An engineering study has been initiated on structural integration of potential wind solutions on the vessels, with intention of creating a technical and economic feasibility study of such an investment during 2023
· A project looking closer into battery hybrid system for KCC type of vessels and operation has been made in 2022. The technology is not yet feasible to retrofit on existing tonnage as the emission savings are minimal, but it may be interesting for potential newbuilds

The Company raised USD 25 million in equity in November 2021 dedicated to fund energy efficiency investments on the vessels. Investments in energy efficiency measures will likely be considerably larger and raised equity will be likely be supplemented by raising debt to fund a likely total investment for the existing fleet of USD 40-50 million in the period up to 2026.

In parallel with costly and complex measures as the installation of the air lubrication system and shaft generator approved by the Board of Directors for two vessels in March 2022, the Board has given the management a mandate to invest up to USD 2.5 million per year in energy efficiency improvement initiatives.

Total greenhouse gas emissions

The GHG footprint has been reported based on the Greenhouse Gas Protocol (GHG). The full GHG accounts have been made available on www.combinationcarriers.com.

19% 81% 0%

After delivery of the last three CLEANBU newbuilds and the sale of the CABU vessel Banasol in 2021, KCC had approximately 0.3 less vessel-years in 2022 compared to 2021, resulting in total scope 1 emissions decreasing slightly Y-o-Y. Positive effects on scope 1 emission came as well from more efficient vessel operation and energy saving devices installed on drydocked vessels. Scope 1 emissions hence decreased by 7% from 2021 to 2022.

Scope 1 KCC's operations

vessels

Direct emissions from financially

Nearly 100% of Scope 1 emissions come

from combustion of fossil fuels on KCC's

282,800 tons CO.e

(2021: 297,400 CO_/ 302,700 CO_e)

controlled operations

Scope 2 emissions related to electricity consumed in office buildings were somewhat higher compared to 2021 as people where fully back working in the office, but this had a negligible effect on the overall GHG emissions.

Scope 3 emissions in 2022 were down 67% compared to 2021 even though two new scope 3 categories have been included in 20222, mainly due to indirect GHG emissions of 135,200 CO e arising from the construction of three new vessels delivered in 2021, while no new vessels were delivered in 2022. The main source of indirect GHG emissions in 2022 were therefore the well-to-tank (WTT) emissions of fossil fuels consumed onboard the fleet, accounting for 94% of total Scope 3 emissions. The remaining emissions came from purchased goods and services (4%) and steel used in repair work on dry-docked vessels (2%), as well as 0.3% from upstream transportation and distribution and 0.1% from waste generated in operation.

(2021: 0.6)

Upstream transportation and distribution (category 4): Emissions related to the transportation and distribution services purchased by KCC. 204 tons CO ,e (2021: N/A)

Waste generated in operations (category 5):

Emissions related the disposal and treatment of waste generated from KCC's fleet and office. 95 tons CO e (2021:53)

Carbon intensity (EEOI)

Ambition for 2022

Improved carbon intensity (EEOI) of 25% compared to actual 2018 performance, corresponding to approximately 40% reduction relative to tracked performance of competing standard vessels in its trades in 2018.

The underlying ambitions were among others: (a) Achieve 85% of on-hire days for the fleet in combination trades in 2022 and 90% over time (b) Reduce ballast days on total onhire days to below 13.75% in 2022 and 7.5% over time (c) Improve absolute fuel consumption of the vessels.

Performance 2022

The carbon intensity is measured as CO ,-emissions per ton of transported cargo per nautical mile (EEOI) and includes all Scope 1 emissions from KCC's owned fleet, in actual CO2 emissions (not CO, equivalents). This metric reflects the strong efficiency of KCC's combination carriers as the vessels spend significantly less time sailing in ballast compared to standard vessels. However, as the fleet is relatively small, the reported EEOI is sensitive to periods of non-optimal trading, e.g. when trading a vessel as a standard vessel or when positioning one or more vessels to dry-docking.

KCC's carbon intensity (EEOI) for 2022 improved considerably from 2021 as the fleet EEOI decreased by 7 %, from 7.4 in 2021 to 6.9 in 2022. The ambition for 2022 set in early 2020 was an EEOI of 5.8 (25% reduction from 2018). The EEOI performance ended above the target for 2022 mainly due to lower than targeted trading efficiency with longer ballasting, lower cargo intake and more waiting time than the ambitious targets were based on in early 2020. The EEOI trajectory was as well not sufficiently aligned with the trajectory for reduction in CO2 emissions per vessel-year.

The five major parameters for how the vessels score on their annual EEOI are technical performance, cargo weight, speed, time spent sailing at sea, and time sailing in ballast. These parameters are dependent on both commercial and technical operations. The average cargo weight, average speed, and average time spent sailing at sea remained relatively unchanged from 2021 to 2022, with changes in the order of ±2%. The lower time spent sailing in ballast and improved hull performance were hence the main reasons for the Y-o-Y improvement in EEOI for the KCC fleet.

Time spent sailing in ballast decreased from 17% in 2021 to 12% in 2022, where particularly the CLEANBU fleet contributed to the reduction in ballast days (measured in percentage of total on-hire days) as the vessels have become established in efficient combination trades

The technical performance of the fleet improved considerably in 2022 as well and ended about 9.3% below the 2018 fleets baseline. The technical performance is a measure of how much fuel the vessels are consuming compared to a baseline consumption curve established at sea trial, adjusted for draft, weather effects and speed. The improved performance can be attributed to four main factors; delivery of newbuilds, increased drydocking frequency, continuation of fleet-wide installation of energy saving devices, and increased focus on reducing and preventing hull fouling. Please see the section "Improve energy efficiency" on page 15 for more information.

KCC is taking active steps to further improve trading efficiency of its fleet. From May 2022, the entire CABU fleet was employed in trades to/from Australia after terminating KCC's service between Brazil and US Gulf in early 2022. The Australian CABU trades offer the ultimate trading efficiency with ballast limited to average around 10%. The trading efficiency of the CLEANBU fleet as well improved considerably in 2022.

The CABU fleet's EEOI was negatively impacted in the start of 2022 by the Russian invasion in Ukraine, as two vessels enroute for loading grains in the Black Sea were rerouted and the booked cargoes were cancelled due to safety concerns. The CABU fleet as well faced some excessive port delays and logistics challenges, further reducing the days performing transport work, also impacting the EEOI negatively.

The EEOI for the CLEANBU fleet also varied over 2022. A significant difference in the dry market and tanker market rates during the year created some commercial opportunities affecting the combi trading pattern which in turn impacted the EEOI. Despite these large fluctuations in the underlying standard markets, the CLEANBU delivered the lowest annual EEOI since delivery.

Emission performance

2022 Actual	CABU Mark I	CABU Mark II	CABU Total	CLEANBU	KCC fleet
EEOI1	7.4	7.6	7.5	6.4	6.9
Average CO2 emissions per vessel year2	18 100	16 900	17 600	18 300	17 900
% in combination trade3	83 %	75 %	80 %	87 %	83 %
Ballast days in % of on-hire days4	10%	12%	11%	13%	12%

Historical	2022	2021	2020	2019	2018	Benchmark 20225	Change in % from 2021	Ambition 2022
EEOI1	6.9	7.4	7.4	7.9	7.6	9.2	- 6.8 %	<5.8
Average CO2 emis- sions per vessel year2	17 900	18 800	20 700	19 900	20 800	n.a.	- 4.8 %	<17 700
% in combination trade3	83 %	68 %	77%	73%	81%	n.a.	+ 15 % points	>85%
Ballast days in % of on-hire days4	12%	17%	15%	13%	9%	33%	- 5 % points	<13.75%

Average CO2 emissions per vessel year

Ambition for 2022

Reduced average CO emissions per vessel year by 15% in 2022 to 17,700 mt vs actual 2018.

Performance 2022

The actual CO, emissions per vessel year of the KCC fleet is expressed as an average of all the vessels' CO2 emissions divided by vessel-years, excluding only the time the vessel is in dry-dock.

The average CO, emissions per vessel year for the KCC fleet decreased to 17,900 tons CO2 in 2022 from 18,800 tons CO2 in 2021, a reduction of approximately 5%, and a 14% reduction from base year 2018. The main factors influencing this KPI are both related to the activity of the vessels in terms of sailed distance, speed, cargo weight carried and % time in ballast condition, as well as the technical performance of the vessels, but the most important factor is how many days the vessels are sailing at sea. This increased slightly in 2022 compared to 2021, which means that the decrease in absolute CO2 emissions per vessel year is mainly due to the improvements in technical performance as described under Carbon Intensity (EEOI).

Looking at the development over 2022, the fleet had a stable level of between 17,300 and 17,700 mt CO2, per vessel year in Q1 through Q3, but in Q4 this number spiked to 19,100 mt CO2, due to the higher transport work performed by the fleet in November and December which lowered the carbon intensity but increased actual CO, emissions.

On an individual basis, the vessels in KCC's fleet emitted between 14,000 mt and 23,000 mt CO2, closely following the actual activity of each vessel.

Improvements in the vessels' hull performance was as well a major contributor to the reduction in average CO emissions per vessel year. The top performing half of the fleet were either new CLEANBU vessels delivered in 2020-2021 or older CABU vessels drydocked in 2021. The worst performers included vessels being either dry-docked towards the end of 2022, where effects are not yet shown in 2022 figures or vessels to be dry-docked in 2023.

^{&#hrough e-mail, WhatsApp, and chat. KSM has as well entered into agreements with prescription psychiatrists and psychologists in The Philippines and in Romania to support crew and their families in relation to mental health and family issues. All services are provided}

KSM has an agreement with International Seafarers Welfare and directly from the external service provider to the crew and their Assistance Network ("ISWAN") to provide a mental health helpline to families and KCC/KSM do not have access to any information related to the services provided.

Please see page 21 for more information on crew health and wellbeing.

Worker participation, consultation and communication on occupational health and safety

feedback from the crew. The review is to evaluate and __ signing off. crew members are encouraged to resoond to questions improve the Quality Management System ("QMS"). Crew participation is encouraged, and report forms are made available in print to be . psychosocial conditions and safety onboard. The electronic debrigfing submitted in dedicated collection boxes in addition to the digital - is anonymous, and results are used to improve policies, processes and management system. The safety culture assessment carried out procedures. The results are presented during officer conferences and contained an open question regarding how safety could be improved. The EDF is regularly being reviewed and Each of the proposals were distributed to the relevant office updated, adding questions focusing on trends and department for consideration and input to coming safety initiatives.

The Shipboard management review is a structured process to gather An electronic debriefing form ("EDF") was established in 2014. When related to the Maritime Labor Convention ("MLC"), anti-corruption,

Response rate - Electronic debriefing

2018	26%
2019	53%
2020	48%
2021	70%
2022	62%

Working Environment Committee ("WEC") and conducting monthly - responsible for following up actions from WEC.

All vessels are manned with a Safety Officer. The main purpose of the Safety meetings onboard. The WEC works to ensure safe and proper position is to monitor and verify that safety routinented o conditions onboard with regards to occupational health and work and followed up, to maintain records of safety, and engage in activities environment. The composed of crew from different related to the working environment, such as participation in the - vessel departments and meet monthly. The vessel s

Worker training on occupational health and safety

Trainings on occupational health and safety are as follows:

Familiarization when signing on vessel
Weekly familiarizations related to safety
Practical onboard training in monthly emergency drills
Computer based trainings (CBT) on health and safety required by the Company. The requirement is defined for rank and vessel type and is monitored prior to embarkation ensuring compliance
Semiannual conferences and seminars for all ranks and a crisis management seminar. During the pandemic, the KSM management team had organized online "touch base" meetings with crew at home or in quarantine hotels. 98 such one-hour meetings were organized during 2022 with an average of 20 crew participants per session and with the following subjects: KLASS-

Klaveness Always Safe and Secure (QMS, learning from incidents, learnings from audits, whistleblowing), greener and data smart (Power BI and various projects/initiatives), campaign results (mental health, Be a Buddy not a Bully, Re:fresh Wellbeing -Norwegian Hull Club wellbeing), fleet management operations, cyber security and IT

KLASS gamified learning to introduce, play and practice behaviors . fostering a stronger safety culture
。 KLASS workshops with videos and group discussions involving all onboard. Specific action items are agreed and posted as reminders for all on how to behave and interact to strengthen the KLASS culture

Promotion of worker health

All crew members, either onboard or at home, are together with their - Africa, the global COVAX program or through collaboration with other families covered by health insurance.

Priority number one through the COVID-19 pandemic has been to avoid crew and employees from being infected. The crew has been protected through a COVID-19 management plan including testing and quarantine prior to signing on. The ambition is to have all crew vaccinated, either through national programs in Romania. The Philippines, or South

member companies of the Norwegian Shipowners' Association. By year-end 2022, 100% of crew onboard KCC's vessels were fully vaccinated. The office in Oslo was fully opened in 2022 after several years with long periods working from home. The employees in Singapore continued to work partly from home also during 2022, but from 26 April 2022 the Singapore office was in full operation again and open for all emplovees.

Prevention and mitigation of occupational health and safety impacts directly linked by business relationships

KCC's Counterparty Code of Conduct defines the core legal and ethical non-conformance. Unon the standards expected from subcontractors, contractual counterparties combinationcarriers.com and includes, but is not limited to, issues vessels, anti-corruption, human and labor rights, child labor and for example related to beaching, environmental incidents, corruption or harassment

in substantial safety/environmental risk or breach of the Counterparty ... more information.

registration of a non-conformity on a supplier, the details of the and others KCC does business with. The code is available on www. deficiency shall be brought forward to the parties involved. Affer one major non-conformity is registered, or three non-conformities such as safety and working conditions, environment, recycling of registered within a period of six months, the supplier will be liable to be excluded as an approved supplier for a period of 12 months. For 2022 harassment. All companies KCC does business with are subject o Know to there are registered 5 reports from the vessels related to purchase of Your Counterparty procedures ("KYC") including sanctions- and goods and services. None of them has generated quality cost above business ethics checks and the latter is managed by a business ethics USD 5 000 and the reports are related to substandard quality for local committee when needed. Companies can be excluded from doing supplies are revaluated with a full KYC at least on an business with KCC based on non-adequate business ethics in isolation, annual basis, including counterparties with no non-conformities registered.

After a contractual relationship has been KCC and a supplier, those not performing as per agreed terms are recorded in the Quality Management System, Major nor-conformities are classified Conduct and Counterparty Code of Conduct, KYC Procedures and when a supplier does not meet agreed terms and the deficiency - contract clauses with counterparties and suppliers were as well generates quality cost greater than USD 5,000, lack of quality resulting - amended to ensure compliance with the legislation. See page 25 for

Governance

Compliance and Code of Conduct

The Code of Conduct defines the core legal and ethical standards and applies to all KCC's directors, officers and employees, both on shore and on board our vessels. Being part of Torvald Klaveness, the main internal service providers (ship management, commercial and business administration services) are committed by the same Code of Conduct. Core issues addressed in the Code are human and labor rights, equal opportunities, zero tolerance for harassment, safety and environment, anti-corruption and what we expect of our counterparties.

Anonymous online compliance surveys with all employees and interviews with selected employees are made annually. No material risks or new issues were revealed by the survey conducted in early 2023, however, the survey indicated that additional training related to Counterparty Code of Conduct and Know Your Counterparty Procedures might be one of the compliance focus areas for 2023. The interviews will be made in March 2023. All employees receive training every year in different compliance areas. New employees must complete all online Compliance training modules.

Know your counterparty

KCC expects those who do business with us to imciples described in KCC's Counterparty Code of Conduct (CoC) in their of Conduct and KYC Procedures were updated in 2022 as part of the business or have at least equivalent standards adopted and conduct - implementation of the Transparency Act from 1 July 2022. See page 25 their business in accordance therewith. All new counterparties are for more information. evaluated, and existing counterparties are re-evaluated on a frequent basis. The procedures are a critical function to assess counterparty risk and a legal requirement to comply with e.g. sanctions. anti-corruption and anti-money laundering laws, and counterparties are also

Risk management and internal control

KCC assesses risks deemed relevant to the different business activities several times every year and the assessment is presented to and discussed by the Audit Committee and the Board of Directors.

KCC does not have an internal audit function, however, an internal RCC, has not identified, any non-compliance, with, laws, and/or audit plan has been outlined for 2023 and internal audits were made regulations in the social and economic area in 2022.

for 2022. Areas currently considered main risk areas are covered as well as review of policies and procedures. Topics covered in 2022 include energy efficiency investments, tax, financial instruments and environmental KPIs, in addition to the recurring controls and items.

Global Reporting Initiative (GRI) content index 2022

Klaveness Combination Carriers ASA (KCC) has reported in accordance with the GRI Standards for the period 1 January 2022 - 31 December 2022.

| GRI
x27; EEOI (Energy Efficiency Operational Index) is defined by IMO and represents CO2 emitted per transported cargo per nautical mile for a period of time (both fuel consumption at sea and in port included). Prior to 2020, end date of a voyage was included. From 2020 and onwards, reporting system provider was chat were able to calculate EEO on a per day basis, allocated to the corresponding quarter. ' Average CO2 emissions per vessel year = total emissions = Days available = off-hire days at vard. When new vessels are delivered to the fleet, the vessel years are calculated from the date the vessel is delivered. Prior to 2020, end date for a voyage was decisive for which period emission was included. From 2020 and onwards, reporting system provider was changed so that we were able to calculate emissions on a per day basis, allocated to the corresponding quarter.

^{3 % an agreement with International Seafarers Welfare and directly from the external service provider to the crew and their Assistance Network ("ISWAN") to provide a mental health helpline to families and KCC/KSM do not have access to any information related to the services provided.}

Please see page 21 for more information on crew health and wellbeing.

Worker participation, consultation and communication on occupational health and safety

Response rate - Electronic debriefing

2018	26%
2019	53%
2020	48%
2021	70%
2022	62%

Working Environment Committee ("WEC") and conducting monthly - responsible for following up actions from WEC.

Worker training on occupational health and safety

Trainings on occupational health and safety are as follows:

Familiarization when signing on vessel
Weekly familiarizations related to safety
Practical onboard training in monthly emergency drills
Computer based trainings (CBT) on health and safety required by the Company. The requirement is defined for rank and vessel type and is monitored prior to embarkation ensuring compliance
Semiannual conferences and seminars for all ranks and a crisis management seminar. During the pandemic, the KSM management team had organized online "touch base" meetings with crew at home or in quarantine hotels. 98 such one-hour meetings were organized during 2022 with an average of 20 crew participants per session and with the following subjects: KLASS-

KLASS gamified learning to introduce, play and practice behaviors . fostering a stronger safety culture
。 KLASS workshops with videos and group discussions involving all onboard. Specific action items are agreed and posted as reminders for all on how to behave and interact to strengthen the KLASS culture

Promotion of worker health

All crew members, either onboard or at home, are together with their - Africa, the global COVAX program or through collaboration with other families covered by health insurance.

Prevention and mitigation of occupational health and safety impacts directly linked by business relationships

in substantial safety/environmental risk or breach of the Counterparty ... more information.

Governance

Compliance and Code of Conduct

Know your counterparty

Risk management and internal control

KCC assesses risks deemed relevant to the different business activities several times every year and the assessment is presented to and discussed by the Audit Committee and the Board of Directors.

Global Reporting Initiative (GRI) content index 2022

Klaveness Combination Carriers ASA (KCC) has reported in accordance with the GRI Standards for the period 1 January 2022 - 31 December 2022.

| GRI
of days in combination trades = number of days in combination trades as a percentage of total on-hire days. A combination trade starts with wet cargo (usually caustic soda or clean products), followed by a dry bulk cargo. A combination trade is one which a standard tarker or dry bulk vessel cannot perform. The KP is a measure of KCC's ability to operate our combination carriers in trades with efficient and consecutive combination of wet and dry cargos versus trading as a standard tanker or dry bulk vessel. There are two exceptions to the trade is considered to be a combination trade: Firstly, in some rare instances a tanker cargo is fixed instead of a dry bulk exporting region where KC usually transports dry bulk commodities. E.g. the vessel transports clean petroleum products to Argentina followed by a grain cargo

on the return leg. Secondly, triangulation tradines two tanker voyages followed by a dry bulk voyage with minimum ballast in between the three voyages (e.g. CPP Middle East + CPP Far East Australia + Dry bulk Australia-Middle East) are also considered combination trade. The KP has been changed with effect from 1 January 2021 and 2020 figures have been adjusted. Previously the definition of a combination trade was based on the main trading patterns and contract of affreightment portfolio (CABU trades Far East/Middle East – Australia and US Gulf-Brazil. CLEANBU trade Middle East/India-South America). KP for 2018 and 2019 is based on old definition. The CLEANBU segment has been established and the CABU business has developed, hence the updated definition better reflects how often KCC succeeds to combine wet and dry cargo. * Ballast in % of on-hire days = Number of days sailing in ballast divided by number of on-hire the vessels off-hire are not included.

Prior to 2020, end date of a voyage was decisive for which period ballast was included. From 2020 and onwards, reporting system provider was changed so that we were able to track ballast on a per day basis, allocated to the corresponding quarter.

^{2ack from the crew. The review is to evaluate and __ signing off. crew members are encouraged to resoond to questions improve the Quality Management System ("QMS"). Crew participation is encouraged, and report forms are made available in print to be . psychosocial conditions and safety onboard. The electronic debrigfing submitted in dedicated collection boxes in addition to the digital - is anonymous, and results are used to improve policies, processes and management system. The safety culture assessment carried out procedures. The results are presented during officer conferences and contained an open question regarding how safety could be improved. The EDF is regularly being reviewed and Each of the proposals were distributed to the relevant office updated, adding questions focusing on trends and department for consideration and input to coming safety initiatives.}

Response rate - Electronic debriefing

2018	26%
2019	53%
2020	48%
2021	70%
2022	62%

Working Environment Committee ("WEC") and conducting monthly - responsible for following up actions from WEC.

Worker training on occupational health and safety

Trainings on occupational health and safety are as follows:

Familiarization when signing on vessel
Weekly familiarizations related to safety
Practical onboard training in monthly emergency drills
Computer based trainings (CBT) on health and safety required by the Company. The requirement is defined for rank and vessel type and is monitored prior to embarkation ensuring compliance
Semiannual conferences and seminars for all ranks and a crisis management seminar. During the pandemic, the KSM management team had organized online "touch base" meetings with crew at home or in quarantine hotels. 98 such one-hour meetings were organized during 2022 with an average of 20 crew participants per session and with the following subjects: KLASS-

KLASS gamified learning to introduce, play and practice behaviors . fostering a stronger safety culture
。 KLASS workshops with videos and group discussions involving all onboard. Specific action items are agreed and posted as reminders for all on how to behave and interact to strengthen the KLASS culture

Promotion of worker health

All crew members, either onboard or at home, are together with their - Africa, the global COVAX program or through collaboration with other families covered by health insurance.

Prevention and mitigation of occupational health and safety impacts directly linked by business relationships

in substantial safety/environmental risk or breach of the Counterparty ... more information.

Governance

Compliance and Code of Conduct

Know your counterparty

Risk management and internal control

KCC assesses risks deemed relevant to the different business activities several times every year and the assessment is presented to and discussed by the Audit Committee and the Board of Directors.

Global Reporting Initiative (GRI) content index 2022

Klaveness Combination Carriers ASA (KCC) has reported in accordance with the GRI Standards for the period 1 January 2022 - 31 December 2022.

| GRI
Benchmark: The EOl and % ballast for "Benchmarkstand vessels" are calculated based on standard vessels (Panamax)Kamsarmax dry, MR-tankers and LR1-tarkers) making the same transportation work in the same trades as performed by KCC's CABU and CLEANBU vessels. The EEO for "Benchmark 17 standard vessels" is calculated as the weighted average of EEOI for the individual trades performed. There is a degree of uncertainty related to the benchmark values as these are estimated using data from Baltic Exchange and AXS Marine.

How KCC is impacted by new regulations

IMO regulations (EEXI and CII)

IMO's MEPC approved in June 2021 its short-term measures consisting of two main measures, the EEXI and the Carbon intensity (CII), which both came into effect from January 2023.

The EEXI regulation sets a minimum requirement to the energy efficiency of the design of both new and existing vessels in line with the Phase 2 EEDI requirements applicable for newbuilds. The current EEXI-scores of the CLEANBU and CABU II vessels' design is considerably below the EEXI requirements for combination carriers (-9% and -6%, respectively). The preliminary EEXI score of the design of the five CABU I vessels built 2001-2007, calculated by DNV, suggests an EEXI score of between +4% to +10% above the set minimum requirements.

KCC is working together with DNV to include the effect of initiated energy efficiency measures into the current EEXI calculations on the CABU I vessels by validating results from ship model tests conducted in 2022. This include effects of the installation of energy saving devices such as propeller boss cap fins and Mewis ducts, both of which will be finalized when the CABU vessel Bantry completes her dry-docking in Q2 2023. The five CABU I vessels will in addition to the energy efficiency measures need to install an engine power limitation software to comply with the new regulation. The operational impact will be limited as the fleet rarely operate at maximum load on the main engine.

KCC has performed additional simulations to include the effect of new energy saving measures into the EEXI calculations on the CLEANBU and CABU II vessels, such as the targeted installations of air lubrication system and shaft generator on two vessels in 2023. If rolled out, this will further improve the EEXI-scores of these eleven vessels built 2016-2021 (three CABU II and eight CLEANBU) and will contribute to futureproof these vessels for potential tightening of the EEXI requirements when MEPC conducts its evaluation of the EEXI regulations in 2026.

The carbon intensity (CII) regulations will set minimum requirements to operational efficiency of the vessels. Vessels will be allocated an annual CII-rating on a scale A-E (where A is best, and E is inferior) based on actual performance reported through IMO's DCS system. The rating thresholds will become increasingly stringent towards 2030 and vessels with rating of D and E will need to present a corrective action plan for reaching a C rating or better to be approved by the flag state.

The IMO approved CII metric fails to include actual cargo work, and only considers registered DWT. As a laden vessel require more energy than a ballasting vessel, highly efficient and well utilized vessels, such as KCC's combination carriers, will actually be penalized.

Despite these serious flaws of IMO's CII regulations, KCC expects the whole fleet to have a CII-score of C or better in 2023 and the subsequent years. Based on calculations of the KCC-fleet's actual 2022 CII performance against the required 2023 CII performance, twelve vessels rated B and four vessels rated C, all of which were within the required CII for 2023. KCC's ongoing initiatives to improve both voyage and energy efficiency will likely secure a margin to the CII minimum requirements.

Fact box

EEDI = Energy Efficiency Design Index

EEXI = Energy Efficiency Existing Ship Index EEDI/EEXI is an energy efficiency calculation (CO2 per nm * DWT) applicable for all vessels by I January 2023. The required score depends on type of vessel and DWT. Measures to improve energy efficiency, reduce installed power or a combination of both will for many vessels be required to comply. This is a one-off calculation typically

based on sea trial or model tank performance

CII = Carbon Intensity Indicator

CII is a dynamic score between A-E, based on the vessels actual CO, emissions and distance sailed over a year. Factors such as speed, hull fouling, vessel utilization, weather exposure etc. will influence this score. The initial CII introduced by IMO, AER, is using the vessels fixed DWT as proxy for transport work, and not actual cargo. An alternative CII, EEOI, is based on actual cargo intake, thus promoting more efficient transport work

EU Emission Trading Scheme (EU ETS)

The EU Commission presented in July 2021 a proposal for a gradual inclusion of shipping into EU's ETS in the period 2023-2025, and in December 2022 EU legislators agreed on a revision on the EU ETS, meaning that EU ETS will include CO_ emissions from ships above 5000 Gross Ton transporting cargo or passengers for commercial purposes from 2024.

For voyages in and out of EU, shipowners will need to surrender emission allowances for 50% of the reported CO_ emissions, and there will be a three-year gradual phasein where 40% of relevant emissions reported in 2024 will have to be paid for in 2025 and 70% of emissions reported in 2025 will have to be paid for in 2026. In 2026, 100% of

EU Taxonomy assessment

The EU taxonomy is a classification system identifying environmentally sustainable economic activities. The aim of the taxonomy includes directing capital flows to sustainable investment, limit market fragmentation in the classification of sustainable activities and increase transparency. The taxonomy regulation states that an activity must make a substantial contribution to at least one of the six environmental objectives set out by the EU: Climate change mitigation, Climate change adaptation, Water and marine resources, Circular economy, Pollution prevention and Biodiversity, while it does not cause significant harm towards the other five objectives and meets minimum social safeguards. First step is to identify if the activities are eligible in the EU Taxonomy. KCC owns and operates 16 combination carriers that all fall within

emissions reported will have to be paid for, including CO equivalents from other GHG emissions such as methane (CH,) and nitrous oxides (N,O), and the shipping industry will be completely included into the EU ETS.

In contrast to IMO's CII-regulation, EU's MRV-system, and hence its ETS for shipping, takes into account both the quantity of cargo transported . Due to KCC's superior carbon efficiency with minimum ballast and slightly higher tanker cargo transport capacity than competing standard vessels, EU's ETS will give KCC an important competitive advantage in trades to and from EU. This is illustrated in the carbon pricing impact example in the table on page 11 in this report.

the category "Sea and coastal freight water transport. vessels for port operations and auxiliary activities", hence the preliminary assessment is that 100% of KCC's economic activity is identified as eligible based on all three performance indicators: Revenue, operating expenses and capital expenditures.

The Norwegian law implementing the EU Taxonomy entered into force from 1 January 2023, hence Norwegian companies covered by the reporting obligations must comply when reporting for 2023. Next step for KCC is to assess if its activities are taxonomy aligned, i.e. the eligible activities meet the technical screening criteria. KCC will assess alignment with the EU taxonomy during 2023.

Always safe and secure Main Social priority

Klaveness Combination Carriers ASA – ESG Performance Report 2022

Always safe and secure

A strong culture safeguarding our people and minimizing our impact on climate and the environment is at the heart of everying we do

Safety is priority number one for KCC and the ship manager KCC together with KSM, focus on building and developing Klaveness Ship Management AS (KSM), and the goal is - the safety culture both at sea and on shore. To maintain that no one shall be injured doing work for KCC. There are safe and reliable operations and to foster a strong safety inherent safety and security risks related to operations at - culture, focus in 2022 has been on the following actions sea. These must always be managed carefully to safeguard crew, vessels, cargo, and environment.

. Deliver by the safety mantra, "KLASS" (Klaveness Always Safe and Secure), in all parts of our operation
"Always wear Proper Personal Protective Equipment Campaign" to ensure compliance with the Personal Protection Equipment Policy
· "Stop Work for Safety Campaign" based on the "Stop Work Policy" empowering crew with the responsibility and obligation to stop work if perceived unsafe condition or operation. In a "Stop Work" situation, safety barriers will be re-evaluated, and work resumed when conditions are safe
· "Safe Mooring and Unmooring Campaign" to remind crew about risks involved and highlight safety precautions during such operations
High management attention on learnings from SIRE (Ship Inspection Report Program) vetting inspections
· alternatives of safe access were evaluated and discussed during safety meetings onboard the vessels
Enhanced safety awareness and risk understanding through training, experience sharing and seminars .
· "Be a Buddy Policy" introduced to develop a positive and respectful work culture
· KPI monitoring shared with all employees ashore and onshore, management and the Board of Directors to improve safety
· Investment in top safety equipment and where necessary, making physical modifications to enhance safety on the vessels
· Investment in digital tools to avoid high risk operation (e.g. remote inspections of cargo holds using 3D camera)

Safety performance

injuries and 24 minor injuries. The latter down from 42 in 2021, likely partly a result of the safety campaigns during 2022 and several years with increased focus on safety through the KLASS program. A sustainable strong safety performance relies on continuous improvement of the Quality Management System (QMS) and on building and strengthening a sound collaborative safety culture.

In 2022, the fleet experienced no major or medium Lost Time Injury Frequency (LTF) for the KCC fleet in 2022 was 0.3, quite in line with average in Intertanko's 5 benchmarking system (0.44) and within the KCC target of <0.5. KCC had no spills to the environment in 2021 and 2022. We had 3 high potential incidents in 2022, compared to 11 in 2021. This KPI is tracked with the purpose of learning from near accidents to prevent serious accidents to take place in the future.

Health & Safety	2022	2021	2020	2019	2018	Target
Major injuries6	0	1	0	0	0	0
Medium injuries7	0	0	3	5	3	0
Minor injuries	24	42	23	20	18	0
Lost Time Injury (# injuries) 8	1	2	6	7	7	0
Number of hours worked	3.5 mill	3.3 mill	2.4 mill	2.2 mill	1.7 mill
Lost Time Injury Frequency (LTIF)9	0.3	0.6	2.5	3.2	4.0	<0.5
High potential incidents	3	11	8	no data	no data	0
Spills to the environment	0	0	1	0	0	0

Safety Culture Survey

A safety culture survey was conducted in 2022 organized by a professional third-party provider. The survey was divided in the following eight behaviors that characterize a strong safety culture: Trust, Care, Open, Learn, Feedback, Speak-up, Teamwork, and Manage Dilemmas. Main results from the survey:

700 responses (84 % response rate from crew onboard)
Improved score on six out of eight categories compared to the same survey conducted last time in 2019
All categories had higher score than average score in the external provider's database
· Highest score on Speak-up and Feedback
· Main area for improvement is Managing Dilemmas and a focus area for 2023 is training on following procedures and managing dilemmas
Strong overall results, but different scores between teams and vessels will be further assessed, and actions taken by the ship manager (KSM)

Crew health and wellbeing

Attention on crew health and wellbeing has increased during and after the COVID-19 pandemic. During 2022, training was carried out increasing crew awareness related to various offers supporting mental health and wellbeing. The crew benefits from helpdesk services offered through the International Seafarers' Welfare and Assistance Network (ISWAN) which is an international maritime charity working to improve the lives of seafarers and their families

with services, resources, strategies and advocacy. A house insurance scheme has been introduced to the families of the crew in The Philippines. This is an initiative taken as a result of the country experiencing more frequent typhoons and hurricanes, causing major damage to the homes of the seafarers and their families.

Crew retention and diversity40

the period 2018-2022 was 92-99%, above KSM's target of The Philippines and supported by KSM in Oslo. 90%, securing safe, stable and reliable operations.

The crew is from the Philippines, Romania, South Africa, Crewrecruitment, training and development are performed Poland and The Czech Republic and the retention rate in by partially owned KSM manning agencies in Romania and

Crew statistics	2022	2021	2020	2019	2018	Target
Total workforce at sea	680	637	890	773	681	n.a.
% female crew	0.7 %	0.6 %	0.4 % %	0.4 %	0.6 %	n.a
# of nationalities	5	5	5	5	5	n.a
Retention rate crew	95 %	92%	95 %	99 %	98 %	>90 %

91 TIF per 1 million working hour (no statistics available for 2018). Lost Time Injuries (LTls) are the sum of fatalities, permanent total disabilities, permanent partial disabilities and lost workday cases. In line with OCMF (Oil Companies Reporting Guidelines for Uil Companies Interne Forum) 10 For diversity related to onshore employees, see note 7 in the Annual Report 2022

5The International Association of Independent Tanker Owners, a membership driven trade association 6 Major injuries = Fatality or permanent disability preventing return to work 7 Medium iniuries = Medical treatment and repatriation, will return to work 8 LTI=Injury leading to loss of productive work time

Vetting and port state control

The ambition is to establish a higher safety standard than The fleet experienced one port state control detention in pure tanker companies. The average number of highrisk observations from OCIMF11 SIRE vetting inspections decreased from 1.9 in 2021 to 0.7 in 2022, better than the 2022 target of maximum two. The Vetting & HSEQ team in KSM works diligently to learn from every observation received and works closely with the crew in identifying and eliminating potential issues and improving further the vetting performance.

2022 due to insufficient procedures to secure the freefall lifeboat release hook system. Following this incident, tests and checks have been added to the procedure in the Planned Maintenance System. Average number of deficiencies per port state control remain stable at 0.7 in line with last year, slightly higher than the target of

Vetting and port state control	2022	2021	2020	2019	2018	Target
Vetting inspections (SIRE)	41	31	25	14	22	n.a.
Average number of observations per inspection for the Ship Inspection Report Programme (SIRE)	3.7	4.9	4.4	5.5	3.2	n.a.
Average number of high risk12 observations per inspection for the Ship Inspection Report Programme (SIRE)	0.7	1.9	1.9	2.4	No data	<2 <3 for 2019 and 2020)
Port state controls	45	33	28	20	18	n.a.
Average number of deficiencies per port state control	0.7	0.7	1.2	1.0	0.4	<0.5
Port state control detentions	1		1	1		0

¹ The Oil Companies International Marine Forum (OCMF) is a voluntary association of oil companies promoting safe and environmentally responsible transportation of crude oil, oil products, petrochemicals and gas 12 High risk observation is an internal definition of a significant legislative, safety or pollution risk

Trusted and responsible partner Main Governance priority

Klaveness Combination Carriers ASA – ESG Performance Report 2022

Trusted and responsible partner

Anti-corruption

KCC operates in a global environment with many international interactions and port calls and is hence vulnerable to corruption and facilitation payments. KCC prohibits payment of bribes and kickbacks of any kind, whether in dealings with public officials or individuals in the private sector. KCC is opposed to and will contribute to counteract all forms of corruption, and this is clearly stated in the Code of Conduct and the Anti-Corruption and Business Ethics Guidelines. KCC's entire business activities are continuously assessed for corruption risk and the main risk areas are considered to be port calls, purchasing and yard work. KCC is together with other Torvald Klaveness entities and the ship manager (KSM) working systematically to eliminate facilitation payments.

The crew complete on-line anti-corruption training and training is also conducted during the annual officer's conferences. Anti-corruption issues are reported and discussed in weekly KSM management meetings, and statistics and experience related to specific ports and issues are distributed to crew, KSM onshore employees and the ship owner, KCC.

KCC encourages the vessels to report requests for facilitation payments as statistics are used to improve the anti-corruption work. Hence the target was to have more than 16.0 requests for facilitation payment reported for 2022. The reason for the low number of reported requests is not necessarily underreporting but might be a result of the trading pattern. All the reported requests are requests only, and not paid, i.e. avoided facilitation payment. Four out of the nine reported requests for facilitation payments reported in 2022 were in China, two in Egypt while the last three were in Turkey, Ukraine and Indonesia. Five were demands for cigarettes, two for cash, one unjustified fee and the last was a demand for other presents. The requests are down compared to 2021, where 13 incidents were reported in total, mainly in China and Indonesia with in total 10 requests. The reporting per ship-year is as well down from 0.9 requests in 2021 to 0.6 in 2022.

KCC did not experience any confirmed incidents of corruption or any confirmed incidents in which employees were dismissed or disciplined for corruption in 2022. No contracts with business partners were terminated or not renewed due to violations related to corruption, and no public legal cases regarding corruption were brought against the Company, its employees or service providers.

Anti-corruption statistics	2022	2021	2020	2019	2018	Target
# calls in ports that ranked the 20 lowest on the Transparency International Corruption Perception Index	0	0	2	0	0	n.a.
# reported requests and avoided facilitation payments	த	13	20	26	8	>16 (2021>16.3, 2020>12.6) 13
Anti-corruption training for crew	86 %	90 %	92 %	87 %	Not available	>75%

The ship manager, Klaveness Ship Management AS (KSM), was in January 2018 certified by DNV as to comply with the new Anti-Bribery Management system (ISO 37001:2016). The certification was extended in 2022 until early 2023. KSM was the first shipping company to be certified by DNV in relation to this ISO-standard

Torvald Klaveness was one of the founding members of the Maritime Anti-Corruption Network (MACN) in 2011. Since the inception it has grown to include over 180 member companies. MACN is a mission driven not for profit organization established by the maritime industry to tackle corruption in the maritime industry and among the geographical focus areas for MACN in 2022 relevant for KCC were the Suez Canal and India

Whistleblowing

KCC promotes a culture of openness and transparency and encourages whistleblowing regarding blameworthy activities or circumstances within its business. Employees and others who have reason to believe that there are '( 2*-/#4 /\$1\$/\$ . *- \$-0(./) . 2\$/#\$) ҍ. business have the right to and are encouraged to whistleblow and the whistleblower shall be protected against retaliation following such whistleblowing.

KCC has an external whistleblowing channel available on the KCC website for both employees, crew and external parties. The receiver of whistleblowing from employees ) 3/ -)'+-/\$ .\$./# #\$ !*(+'\$) ȥ\$ -Ңң in Torvald Klaveness. The receiver of whistleblowing from crew is the designated person ashore (DPA) in Klaveness #\$+ )" ( )/ ҁ # #\$ ! *(+'\$) ȥ\$ - "(2\$*' '2#\$./ 0/* \$//))* \$/-0 /# . /\$*( /# - 2# !* /( ( + (\$ */ /' - .(*/\$/\$*( whistleblowing is coming from.

The DPA received nine whistleblowing cases related to KCC in 2022. Interviews with the involved parties were performed in all cases, either physical or online. Seven cases were substantiated based on non-compliance with company policies.

Compliance Program and training

The purpose of the compliance program is to ensure /#/ /# *-")\$5/\$*) /. 2\$/#\$) '' - ' 1)/ -0' . ) regulations, and in accordance with Klaveness Code of Conduct and its related policies. Compliance is the *-) -./*) *! ҍ. 0.\$) .. /\$1\$/\$ .҂ ) /# /-\$)\$)" program has been designed to address the importance of compliance and build awareness both to the relevant legal requirements and to internal policies.

During 2022, ten Compliance Program policies and guidelines were updated covering among other things competition regulations, anti-corruption, whistleblowing, *0)/ -+-/4 * *! *)0/ ) &)*2 4*0- *0)/ -+-/\$ .ҁ )/*-4 *)'\$) /-\$)\$)" !*- '' employees were conducted in the relevant themes and all KCC employees participated in dilemma training covering ''*ȥ\$ .)''0.\$) ..!0)/\$*).ҁ

Ship recycling

*((\$/. /* (& - 4'\$)" *! /# 1 .. '. \$) !0'' compliance with the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (Hong Kong convention), the guidelines of the Norwegian #\$+*2) -.ҍ-..*\$/\$*))2# - - ' 1)/҂/# #\$+ Recycling Regulation.

The last recycling of a Klaveness vessel was made in China by Grieg Green recycling in 2014.

Counterparty Code of Conduct and Know Your Counterparty Procedures

2- \$) &-\$) ) /# \$(+' ( )//\$) ! /# Transparency Act in Norway are strong reminders of the importance of Know Your Counterparty Procedures (KYC Procedures) and Counterparty Code of Conduct to avoid compromising our ethical values and avoid entering into /- ..0% //.)/\$).ҁҍ.-* 0- .\$)'0 \$) \$/\$) / - \$/ -\$.& .. ..( )/҂ .)/\$) # & ) 0.\$) .. /#\$. # & !0.\$)" ) )1\$-)( )/'҂ social and governance (ESG) aspects.

The Transparency Act shall promote enterprises' respect !*- !0)( )/' #0() -\$"#/. ) )/ 2*-&\$)"conditions in connection with the production of goods and the provision of services and ensure the general public access to information regarding how enterprises address adverse impacts on fundamental human rights and decent 2*-&\$)"*)\$/\$*)./#-*0"#*0//# \$-1'0 #\$).ҁ

In relation to the Transparency Act which came into force 1 July 2022, KCC evaluated and made some minor adjustments to its Code of Conduct and Counterparty Code of Conduct. KYC Procedures and contract clauses with counterparties and suppliers were as well amended to ensure compliance with the legislation. The KYC Procedures include a heatmap related to certain geographical areas ) /\$1\$/\$ .Ҩ1'0 #\$). 2# - /# -\$.& *! #0()

-\$"#/.1\$*'/\$*). ).0./)-2*-&\$)"*)\$/\$*). - considered high, and hence more comprehensive due \$'\$" ) \$.) ҁ-0.\$) ../#\$.*((\$// '- 4\$) +' .. .. ."- 4Җ5*) . .)- *(( )( .0- . /*./*+҂(\$/\$"/ *-+- 1 )/)41 -. ȥ /ҁ-. +-/ -).+- )4-/- +*-/) !*0)*)ҍ.2 .\$/ ҁ

During 2022, 15 potential counterparties (applicable for KCC and/or other Klaveness companies) were excluded due to business ethics concerns ranging from Russian/ '-0. ȥ\$)\$/4 /* )1\$-*)( )/' \$..0 . ) /\$1\$/\$ . \$) occupied areas. KCC/Klaveness reached out to a doubledigit number of counterparties regarding potential environmental or human rights violations or trying to impact their policies, e.g. related to ship recycling, with .*( +*.\$/\$1 ! &ҁ# *(+)4!0-/# -(*- \$)'0 reference to the Counterparty Code of Conduct in its contracts, and violating the code may constitute a default event, enabling KCC to end a business relationship. KCC #. )* \$- / 3+*.0- /* 0..\$ *- '-0. ) \$ / /# *0/- &*! /# 2-\$)&-\$) /*)*/*)0/)4 business with companies owned or controlled by Russian *- '-0.\$) \$)/ - ./.ҁ 0-/# -҂ #. 3 (+/ '' 0..\$)+*-/.҂\$)\$/\$*)/*/# 2-5*) \$)/# '& ҁ

Key partnerships and coalitions14

Iransparency Act

KCC structure and operations

This report has been developed to comply with the legal requirements as stated in the Norwegian Transparency Act of June 2021. The reporting requirement applies to Klaveness Combination Carriers ASA ("KCC") as the company is resident in Norway with consolidated total assets of more than NOK 35 million, combined with consolidated revenue of more than NOK 70 million.

KCC has offices in Oslo, Norway, and Singapore and in addition purchases services from subsidiaries of Rederiaksjeselskapet Torvald Klaveness located in Manila, Philippines, and Dubai. The crew are from the Philippines, South Africa, Poland, Romania and The Czech Republic and are employed on contracts with the ship manager, Klaveness Ship Management AS ("KSM").

KCC owns and operates 16 combination carriers that are employed globally, currently with main trading areas in the Far East, Middle East, Australia, India and South America. Drydocking of vessels every 2-3 years, are mainly performed in China. Cargo transported are caustic soda solution, alumina and bauxite to the alumina industry (39%), clean petroleum products and coal (25%), iron ore (15%), agricultural products (11%) and other (9%)1 and KCC is part of the value chains in industries such as energy, food, and mining, metals and minerals, whereof risk related to violation of human rights and decent working conditions are present.

Policies, governance and training

As stated in KCC's Code of Conduct available on KCC's web site:

· KCC supports and respects the protection of internationally proclaimed human rights as set out in the fundamental principles of the Universal Declaration of Human Rights and the core international human rights treaties. KCC strives to avoid causing or contributing to adverse human rights impacts through our business activities and address such impacts if and when they occur.
KCC supports and respects internationally recognized labour rights as set out in the fundamental ILO conventions, including the freedom of association and the right to Collective Bargaining Agreements within national laws and regulations, and we support i) the elimination of all forms of forced and compulsory labour; ii) the effective abolition of child labour; iii) the elimination of discrimination in respect of employment and occupation.

We expect those who do business with us (our "Counterparties") to implement the principles described in our Counterparty Code of Conduct ("CoCC") in their businesses or have at least equivalent standards adopted and conduct their business in accordance therewith. The CCoC is as well available on KCC's web site. KCC includes a clause referring to KCC's expectations with a reference to its CCoC in contracts when relevant.

The Code of Conduct and the Counterparty Code of Conduct have been approved by the Board of Directors and were updated in 2022. Other Compliance Program policies and guidelines were updated as well during 2022 and mandatory online training and dilemma training for all KCC employees and employees in the service providers part of the Rederiaksjeselskapet Torvald Klaveness group were conducted.

Risk mapping and due diligence

KCC's Know Your Counterparties Procedures ("KYC Procedures") include sanctions checks, business ethics checks and credit rating of all counterparties. Prior to the implementation of the Transparency Act in 2022, a heatmap identifying high-risk areas for human rights violations and substandard working conditions based on geographical areas and activities/value chains was implemented. Based on the heatmap additional due diligence checks are performed whenever high risks are involved. The due diligence questionnaire used when assessing counterparties was as well expanded requiring information about counterparties' suppliers and sub-contractors. Special concerns related to specific counterparties and/ or their value chains uncovered through the risk mapping and due diligence, will be considered by a Business Ethics Committee ("BEC"). The BEC will recommend measures based on the severity of the findings, such as abstaining from entering new business, start a dialogue with the relevant counterparties or establish other preventive or mitigating measures.

The heatmap was established based on several workshops involving employees in KCC and the wider Torvald Klaveness system covering a wide range of business functions such as bunkering, technical management, procurement, operations, chartering, legal, finance and risk management. The map will be evaluated on an annual basis.

Human rights and working conditions risk map

Geographical area/ Type of activity (value chain)	Europe	North America	South/ Central Central America	Oceania Oceania	Africa	Middle East	Singapore + remaining OECD Asia	Rest of Asia incl. China and India
Mining, metals, minerals
Oil exploration and refining
Power plants
Food industries
Trading companies
Shipping and logistics2
Bunkering
Dry docking and newbuilds
Equipment makers

Main risks and risk management

KCC did not detect severe human rights violations or During 2023, KCC will focus on improving the due diligence substandard working conditions in our own operations in 2022. Crew safety is priority number one for KCC and the ship manager, KSM. Lost Time Injury Frequency ("LTIF") for the KCC fleet in 2022 was 0.3, within KCC's target of <0.5. In addition to safety, securing decent Whistleblowing mechanism crew salaries and securing crew health and wellbeing - KCC promotes a culture of openness and trans-parency are priority areas for KCC. Terms and conditions in the crew's Contract of Employment ("CoE") are regulated by the Collective Bargaining Agreements ("CBA") between the Norwegian Shipowners Association ("NSA") and the International Transport Workers' Federation entities ("ITF") in the respective countries and are as well covered whistleblow and the whistleblower shall be protected by a special agreement with the ITF in Norway on behalf of against retaliation because of such whistleblowing. beforementioned ITF entities. KSM is in addition Maritime Labor Convention ("MLC") certified adding further beneficial conditions for seafarers onboard and their rights as employees. KSM has as well its own beneficial conditions for seafarers giving them additional benefits related to financial matters, competence development and wellbeing for sailors and their families.

Based on issues identified through the KYC Procedures and measures recommended by the BEC, 15 potential counterparties (applicable for KCC and/or other Klaveness companies) were excluded in 2022 due to business ethics concerns ranging from Russian/Belarus affinity to environmental issues, beaching of vessels and activities in occupied areas. KCC/Klaveness reached out to a doubledigit number of counterparties regarding potential environmental or human rights violations, or with an ambition to impact their policies, e.g. related to ship recycling, with some positive feedback.

procedures for high-risk areas with focus on shipyards and procedures to prevent, cease, or mitigate human rights violations and substandard working conditions.

and encourages whistleblowing regarding blameworthy activities or circumstances within its business. Employees and others who have reason to believe that there are blameworthy activities or circumstances within KCC's business have the right to and are encouraged to

KCC has an external whistleblowing channel available on the KCC website for both employees, crew and external parties. The receiver of whistle-blowing from employees and external parties is the Chief Compliance Officer ("CCO") in Torvald Klaveness. The receiver of whistleblowing from crew is the designated person ashore (DPA) in Klaveness Ship Management AS. The CCO notifies the KCC Audit Committee about whistleblowing notifications related to KCC independent of where the whistleblowing is coming from.

Additional ESG topics

Environment

Other air emissions16,11

Other air pollutants, such as NO., SO., PM, CH,, CO and N,O have harmful effects on both local air quality, as well as _ (NO.). All CLEANBUs hence comply with IMO's Tier III regulations having a varying degree of greenhouse warming potential. The emission of these pollutants varies as a function of engine load, except for SO, which depends on the sulfur level in the fuel.

KCC has complied with the IMO 2020 sulfur regulation since it was introduced 1 January 2020 (maximum 0.5 % /0.1 % when sailing in designated sulfur emission control areas (SECA)). (MARPOL Annex VI Reg. 14 (IMO Global Sulphur Cap 2020).

None of KCC's vessels have installed scrubbers. This is based on an evaluation of potential savings from installation of SO, scrubbers by burning less expensive High Sulfur Fuel Oil (HSFO), risk of future non-availability of HSFO, technical risks of the SO, scrubber system and possible negative environmental effects of the release of wash water from the scrubber system to sea in ports and confined waters. Fuel used on KCC vessels is Low Sulfur Fuel Oil (LSHFO) and Ultra-Low Sulfur Marine Gas Oil (ULSMGO).

The CLEANBU vessels (50 % of the KCC fleet of 16 vessels) were among the first tankers/dry bulk vessels to have installed selective catalytic

reduction (SCR) systems for reducing the emissions of nitrous oxides applicable for all newbuilds with keel laid after 1 January 2016. Operation of the SCR systems are mandatory whenever the vessels are In nitrogen emission control areas (NECA) currently only applicable in North American waters, the Baltic Sea as well as the southern parts of the North Sea.

In line with its Environmental Policy, KCC shall go beyond compliance of environmental regulations and has therefore decided to increase the use of the SCR system outside the NECA zones to reduce NO, air pollution in especially densely populated areas. Starting 2023, KCC will target the use of SCR systems for NO2 reduction whenever feasible in all ports at all times while the vessels are being alongside during loading and discharge operation irrespective of region and regulations.

Reductions in other air emissions follows the reduction in fue consumption. In addition to the reduced pollution to air, the reduction in emission of sulfur and nitrogen compounds will also lower the contribution to ocean acidification and eutrophication.

Other air emissions in mt	2021	2022	GMb18
NO , (nitrogen oxides)	6 755	6111
SO , (sulfur oxides)	784	દર્ભદ
PM, (particulate matter < 10 µm)	379	350
CH2 (methane)	5	4.6	28 CO "e
CO (carbon monoxide)	266	242
N,O (nitrous oxide)	16	15	265 CO, e

Calculation methodology:

emission factor dependine on the engine speed and Tier as stated in monoxide (N.O) emitted is calculated by means the EIAPP certificate, while the the mass of Sulfur oxides (SQ.) emitted is calculated by means fuel-based emission factor. SO emissions vary with the sulphur content in the fuel or with the use of exhaust gas cleaning systems.

The mass of Nitrogen oxides (NO ) emitted is calculated by means of particulate matter (PM , ), methane (CH,), carbon of a energy-based emission factor depending on engine type and Tier as well as on consumed fuel type.

Source: Fourth IMO GHG Study – July 2020

Ozone-Depleting Substances (ODS)

The use of ODS onboard ships is regulated by MARPOL Annex VI have air conditioning in accommodation and refrigeration plant in Regulation 12, and KCC follows this regulation when applicable. The engine room using the refrigerant R-22 (Chlorodifluoromethane), use of all ODS'which are not hydrochlorocarbons (HCFC's) were prohibited on ships constructed on or after 19 May 2005, and the use of HCFCs is prohibited for vessels constructed on or after 1 January 2020.

CLEANBU and CABU II, have no systems or equipment installed and import, of any ozone-depleting substances. containing ODS, however the oldest vessels constructed in 2001-2002

KCC's vesels delivered after 2002. including the newest fleets KCC's fleet does not have own production. nor is involved in the export

Energy

Energy Consumption

The energy use of KCC closely follows the enission of renewable energy sources is limited to the renewable part of electricity consumed in office, which is negligible. Conversion to energy using energy conversion factors from the Third and Fourth MO Greenhouse study from 2014 and 2020, respectively, Marine MGO/MDO is calculated to contain 11.35 MWh of energy per ton fuel, and Marine HFO is calculated to contain 12.579 MWh per ton fuel. The total energy consumption of KCC in 2022 amounted to approx. 3.7 Petajoules9.

	Category	Unit	2021	2022
Scope 1 Energy use
Stationary combustion (KCC Oslo Office)
	Subtotal	MWh	0.40	0.16
Transportation (KCC Fleet)
	Marine diesel/gas oil	MWh	71,942	53,699
	Marine fuel oil	MWh	1,017,741	962,867
	Biodiesel, ME	MWh	3,290	0
	Subtotal	MWh	1,092,972	1,016,567
Scope 1		MWh	1,092,973	1,016,567
Scope 2 Energy use
Electricity (KCC Oslo Office)	Electricity Nordic mix	MWh	19.0	30.5
Scope 2		MWh	19.0	30.5
TOTAL		MWh	1,092,992	1,016,597
		GJ	3,934,771	3,659,750

18 Global warming potential (GWP) as defined by Source IPCC, 2006 19 W = J/s. 1 kWh = 3.6MJ

45 Sources: SO, and NO, emissions gathered from Storn while emissions for VOC and PM calculated using emission factors from EPA: "Emission estimate methodology for maritime navigation I There are also other harmful air pollutants associated with the operation of diesel engines pollutants (POP) and hazardous

air pollutants (HAP), but conversion factors for these emissions types could not be found and are probably not relevant to ship engines

Energy intensity

When calculating energy intensity in KCC, only energy from fuel used - The energy use from KCC fleet in 2022 was approx. 3.93 PJ, compared for ship propulsion is evaluated. The metric used to present the energy intensity is MJ/ton-mile and describes how much energy KCC uses to the transport work of KCC fleet. In 2022, the total transport work was an approx. 5% higher energy content compared to HFO. 40 351 135 753 ton-miles, which gives an energy intensity of 0.0907 MJ/ ton-mile. This results in a reduction in energy intensity of about 8% compared to 0.0988 MJ/ton-mile in 2021.

Reduction in energy consumption

to 3.66 PJ in 2021, which indicates a decrease in energy consumption of 7%. This reduction is mainly due to higher energy efficiency of the fleet t ransport one metric ton of cargo one nautical mile, which represents

All KCC vessels have a Garbage Management Plan onboard in accordance with the IMO guidelines published in resolution MEPC.201(62). Onboard waste is sorted into 11 different garbage categories and recorded in an onboard garbage record book before being disposed at a waste reception facility in port or incinerated onboard, except for minor food waste which may be disposed at open sea. Ash from incineration is also delivered to the appropriate reception facility. Both ANNEX I and ANNEX II slops, including wash water, are discharged in accordance with relevant MARPOL regulations

The total volume of waste generated per ship was approx. 40 m³ in 2022, with the three largest contributors being plastic waste sent to recvcline (35%) and domestic waste (40%). of which half was presents the share of waste recycled, incinerated and directed to incinerated onboard the vessels and the other half disposed at port reception facility, as well as organic waste (15%). Organic waste is

either disposed overboard on open seas according to MARPOL ANNEX V regulation or recycled in port to produce biofuel (cooking oil).

All waste from the office headquarters in Oslo20 is collected, sorted into 13 different waste categories, and sent to Norsk Gjenvinning AS, which either recycles the recyclable waste, incinerates it for energy or produces biogas/fertilizer from the organic waste. In 2022, 64.6%21 of the waste was recycled, a small decrease from 68.9%in 2021.

The table below gives an overview of the main categories of waste from KCC in 2022, split into waste from KCC office and from KCC's fleet, converted into metric tons using conversion factors from CEMAsys. It landfill, as well as the share of hazardous waste recycled.

Waste category	Dispoasal Method	Haz.	Unit	KCC Office	KCC Fleet	KCC TOTAL
Hazardous	Recycled	Yes	mt	0.0023		0.0023
Organic	Recycled		mt	0.1581	8.4400	8.5981
Organic	Disposed at sea		mt		84.8910	84.8910
Residual	Incinerated		mt	0.2435	130.7901	131.0336
Residual	Landfill		mt		136.0200	136.0200
Industrial	Landfill		mt		28.0600	28.0600
Wood	Recycled		mt	0.0004		0.0004
Paper	Recycled		mt	0.1803		0.1803
Glass	Recycled		mt	0.0476		0.0476
Metal	Recycled		mt	0.0072		0.0072
EE waste	Recycled	Yes	mt	0.0421	6.8020	6.8441
Plastic	Recycled		mt	0.0064	223.8500	223.8564
Mineral oil	Incinerated	Yes	mt		24.5210	24.5210
TOTAL			MT	0,69	643.374	644.062

Noise Pollution

Underwater noise is a category of pollution that has received more focus over the last decade, as it mav have adverse impacts on marine life, such as interfering with the ability of marine mammals to communicate, navigate and hunt. Although no global regulations have been introduced to address this issue yet, the IMO has released non-mandatory guidelines for the reduction of underwater noise from commercial shipping.

KCC is evaluating various measures from this guideline to be implemented to help reduce noise pollution, and already the CLEANBU fleet has modified the air ejector outlet from the original design where all the vessels have been equipped with silencers, and some have also been moved into the ballast water treatment room inside deck. Also, the spacing for the engine room fan housing has been equipped with noise dampening plates. Furthermore, specific operational procedures are in place to reduce the noise further in certain specific sensitive ports.

Biodiversity and marine pollution

KCC has modern and compliant ballast water treatment systems (BWTS) installed on all vessels with MV Bakkedal installing this in 2022. This treatment system is operated whenever the vessels perform ballast water exchange operations to prevent the spread of harmful aquatic organisms from one region to another in accordance with the Ballast Water Management Convention, which will enter into force in 2024. Important details of the operation of the BWTS are recorded in the onboard Ballast Water Record Book

Invasive aquatic species may also be transferred from one region to another through biofouling of the ship's hull. Biofouling is the growth of marine organisms on the hull and propeller, and ranges from the creation of thin lavers of biofilm consisting of single celled organisms and algae to the growth of e.g. barnacles, seaweed, and mussels.

The hydrodynamic resistance of the vessel increases with increased growth of biofouling, and thus increases the required fuel needed to propel the vessel through the water. To reduce the risk of transfer of invasive aquatic species all KCC vessels have a Biofouling Management Plan (BFMP) onboard. This plan serves as a practical guidance to both ship manager (KSM) and the Master and crew of the ship on different measures that can be used such as anti-fouling paint. frequent hull and propeller cleaning operations, speed-cleaning instructions, avoidance of long idle periods and other operational measures.

The implementation of an effective biofouling management plan is also one of three compliance options for vessels arriving in Australian territorial seas after Australia introduced new requirements on 15 June 2022 for managing biofouling on international vessels arriving in Australia. This requirement specifies that all vessels need to provide information on how biofouling is managed prior to arrival in order to mitigate the risk of spread of invasive species to Australian marine - better understanding cleaning performance and paint condition, as habitats and fisheries. Alternatively, the vessels may submit proof that all biofouling has been cleaned within 30 days prior to arrival, or that an alternative biofouling management method pre-approved by the Australian government has been implemented.

KCC applied in 2022 high quality silicone anti-fouling coating on additional two more vessels undergoing dry-docking to reduce the risk of biofouling during operation. A high-pressure hull cleaning and touch-up of a third vessel undergoing repairs in dry dock was also performed, reactivating the vessel's relative newly applied anti-fouling system together with a touch- up on damaged spots.

KCC has also a policy of conducting 2.5-vear dry-docking intervals in order to safeguard a high-quality anti-fouling system on all ship hulls.

Cleaning operations are always performed in accordance with applicable national and local laws and regulations so that viable biofouling or chemical and physical pollutants are not released into the local aquatic environment where they may cause harm. Care is also taken to prevent the erosion of the anti-fouling paint so that harmful biocides are not released into the port water. All anti-fouling paints also comply with the International Convention on the Control of Harmful Antifouling Systems on Ships and do not contain organotin compounds acting as biocides.

KCC has tested semi-autonomous cleaning robots designed to be used intransit at sea on four of its vessels and has purchased additional five systems to equip the full CLEANBU fleet. This semi-autonomous robot is gentle to the anti-fouling system and prevents biofouling by removing the initial layer of biofilm while the vessel is sailing, thus preventing the growth of macrofouling. The organic residue sinks to the bottom of the sea floor where it will cease to live.

In 2023, KCC will collaborate with the maker of these robots on a pilot project to evaluate the cleaning performance, hull roughness and fouling coverage while performing in-transit cleaning, with the goal of well as optimizing the type of brushes used for cleaning. KCC are also performing hull cleaning operations in ports, and testing robots that filter and collect the removed biofouling

KCC does not currently have data related to shipping duration in marine protected areas and areas of protected conservation status. 22

Social

Occupational health and safety management system

Klaveness Ship Management AS ("KSM") as ship manager issued with The QMS is applicable for all KSM employees ashore and for all vessel occupational health and safety system (the "Quality Management are subject to the QMS when visiting the responsibilities related to safety, security. IT- & cybersecurity, environmental standards, ethical standards, Corporate Social Responsibility ("CSR"), and compliance with quality policies and objectives. The OMS also serves as the tool to formally implement the Company's values and aspirations and how the Company intends to achieve the objectives of its policies. The DOC holder's Quality Management System is certified to comply with:

Document of compliance ("DOC") has established a formalized crew. All visitors on board the vessels (e.g. service engineers, System" or "QMS") that documents procedures, and vessels. The system is subject to continuous improvement with periodical updates.

International Safety Management (ISM) Code
International Ship and Port Facility Security (ISPS) Code
Maritime Labour Convention (MLC)
ISO 9001 Quality Management System
ISO 14001 Environmental Management System
ISO 37001 Anti-Bribery Management System
ISO 45001 Occupational Health and Safety Management System

Hazard identification, risk assessment and incident investigation

The KSM Risk Matrix is the framework used to assess the likelihood and The authority to stop unsafe work was strengthened in 2021 with a impact of operational risks and hazards during risk assessments as part of toolbox meetings (performed prior to operational procedures and situations implying risk for people, environment, and assets), issuance of work permits and management of change (MOC) processes. The framework is part of the QMS and includes a Hazard Identification and Risk Assessment Library (HIRA) which acts as a register of relevant operational risks.

The QMS as well includes a reporting system of accidents, near-misses, hazardous situations, and suggestions for improvement. The reports are reviewed on a weekly basis and are an important source for cross organizational improvement initiatives.

Employees, crew and others who have reason to believe that there are blameworthy activities or circumstances within KCC's business have the right to and are encouraged to whistleblow. Please see page 25 for more information on the Company's whistleblowing channel.

Stop Work Policy ("SWP"). The policy states that every employee is empowered with a Stop Work Authority ("SWA"). Employees and crew have a right and duty to call for a Stop Work Order ("SWO") if there is reason to believe that personnel health, safety, security, the environment, or property may be endangered. The SWA is independent of position, seniority, or discipline. The SWA is based on a no-blame culture. There shall be no retaliation of any kind against any person(s) for invoking a SWO even if it later turns out that it might have been unnecessary. Stop Work events shall be recorded and will be used to learn and improve.

All incidents shall be reported. It is the responsibility of the HSE&Q Department in KSM to investigate and to oversee that appropriate corrective and preventive actions are implemented, and that experience is shared with other vessels or related departments when relevant. The purpose of carrying out systematic registration of incidents is to continuously improve safety.

Occupational health services

crew through e-mail, WhatsApp, and chat. KSM has as well entered into agreements with prescription psychiatrists and psychologists in The Philippines and in Romania to support crew and their families in relation to mental health and family issues. All services are provided

Please see page 21 for more information on crew health and wellbeing.

Worker participation, consultation and communication on occupational health and safety

Response rate - Electronic debriefing

2018	26%
2019	53%
2020	48%
2021	70%
2022	62%

Working Environment Committee ("WEC") and conducting monthly - responsible for following up actions from WEC.

Worker training on occupational health and safety

Trainings on occupational health and safety are as follows:

Familiarization when signing on vessel
Weekly familiarizations related to safety
Practical onboard training in monthly emergency drills
Computer based trainings (CBT) on health and safety required by the Company. The requirement is defined for rank and vessel type and is monitored prior to embarkation ensuring compliance
Semiannual conferences and seminars for all ranks and a crisis management seminar. During the pandemic, the KSM management team had organized online "touch base" meetings with crew at home or in quarantine hotels. 98 such one-hour meetings were organized during 2022 with an average of 20 crew participants per session and with the following subjects: KLASS-

KLASS gamified learning to introduce, play and practice behaviors . fostering a stronger safety culture
。 KLASS workshops with videos and group discussions involving all onboard. Specific action items are agreed and posted as reminders for all on how to behave and interact to strengthen the KLASS culture

Promotion of worker health

All crew members, either onboard or at home, are together with their - Africa, the global COVAX program or through collaboration with other families covered by health insurance.

Prevention and mitigation of occupational health and safety impacts directly linked by business relationships

in substantial safety/environmental risk or breach of the Counterparty ... more information.

Governance

Compliance and Code of Conduct

Know your counterparty

Risk management and internal control

KCC assesses risks deemed relevant to the different business activities several times every year and the assessment is presented to and discussed by the Audit Committee and the Board of Directors.

Global Reporting Initiative (GRI) content index 2022

Klaveness Combination Carriers ASA (KCC) has reported in accordance with the GRI Standards for the period 1 January 2022 - 31 December 2022.

GRI nda rd/ sta oth er s our ce	Disc losu re	mbe link Pag e nu r or	( \$\$* ).	Rea for son omi ssio n
eral dis clos Gen ures
GRI 2-1	)\$5/ \$*) ' -" deta ils	Klav mbin ation riers is a pub lic li mite d co ny li sted s Co Car ASA enes mpa ) .' /& 3 #)" 2\$ /# /\$& - ҂# ,0 -\$) .' ҂ -/ -24 ҁ Glob al sh of o desc ribed ippin tivit ies: Regi tion in n ote 3 to g ac ons pera ' )' /# -2\$. /# ! /# + -/ эыээ .// -/ ))0 ҂ .+ - + ҁ inclu des t he co ny K lave Com bina tion Carr iers A SA in clud ing a ll mpa ness .0. \$\$- \$ .҄ '' ( +'4 ҂ȥ\$ ) /\$) .҂ - 2 .҂ + - .ҁ
GRI 2-2	Entit ies in clud ed in /# \$5/\$ )ҍ. -") aina bility sust rting repo	Klav mbin (pa ), KC C Sh s Co ation Car riers ASA rent ipow enes com pany n ing A S (d irect ly/in direc tly 1 00% ed s ubsi diary ), KC C Ch ring AS arte own (100 y) an % ow ned subs idiar d Kla ss C omb inati on C arrie rs As ia Pt vene e / Ңьыы .0\$ \$-4 ңҁ \$./ ! +)\$ \$)'0 \$) ޲ \$' ۞ 2) *( . (( rting alig ned with ESG form ortin g. C lidat ion of Per repo ance rep onso infor mati n 10 0% b asis since all s ubsi diari ned 100% on o es ar e ow
GRI 2-3	Repo rting peri od, freq d uenc y an oint cont act p	s fro 22 fo Repo rting iod i m 1 Janu ary 2 022 to 31 Dec emb er 20 r bot h per the Perfo d fo r the ual ll ESG ce R t an Ann Repo rt. K CC a rman epor s we \$/0(0 ).'\$))޲ 4'- -/,0 ҂.\$. "(\$0'(\$ --!- + -/.+ - safe lated nviro ntal KPIs and e he alth and ty K PIs. to e man ce re nme som Publ icati on d ate f or th nual nd th rfroa e An Rep ort a e ES G Pe e Re port mcn \$.ђ -# эыэ юҁ \$./# ҂ \$ 1 " )/ /+ - .*) 4-) .ҁ
GRI 2-4	of infor Rest atem ents mati on	)/./ - ҁ)/\$ ( '/( )(1\$-( /#!(\$/\$(޲ #эыээ (۞\$! \$) /- .# )" 2\$/# ȥ /!- !- /\$) (ь -4эы эьҁ ( 2 )0 1\$-.+- )0( '2#\$҂)\$/\$)޲ 2 ( //# ޳ -/ /./ .-2эыэы !-э ыьѓ ) эыьє ) /# ' ޲(\$ /\$( ҁ- \$)! /\$) - (- -( ҂ see f in th rform ort f he ootn ote t o KP I pag e 17 e ES G Pe Rep or 20 22. T ance -(\$)'/0/ ޳ -- // ./2(\$/\$(޲ /#"(/\$-0+!(*. - tion trad ing.	ҁ\$\$ҁ # ȥ /! the c hang ed K PI (\$/\$(޲	alcu latio No c n has b mad een e for 2 021 and bas ed 2022 on th e old (*\$/\$(޲
GRI 2-5	Exte rnal assu ranc e	Scop e of rnal e dis ed w ith th e Au dit C ittee . Wit hin exte assu ranc cuss omm the C biliti he sc of th bas ed o n wh FO's onsi es. T ce is at resp ope e ass uran (\$ -/#!/(1 ' ./-).(޲(/\$)-!(\$ - &./'(- 3/ (0./-4 hold Gree nhou se G as E miss ion r ting for 2 022 and Envi ers. epor ronm en- /' ) ) #( -& #1 ) ''4 - 4 3/ -) ҂ . 0 . Perfo -37 ( limit ed a ent) e Re port 202 2 pa ge 36 . EY rman ssur ance eng agem ) +) \$/.\$( -޲(.# ҁ! \$//((\$/ 0 /#/ )
GRI 2-6	, val Activ ities ue chai d oth n an er busi rela tion ness ship s	)!- \$ . //\$ -4 0'& ҂# (\$ ') ' /-' /-) +-1 .+- )+ 0( prod lient rform 3 for des f uct c e ES G Pe Rep ort p cript ion o s, se ance age the Com 's va lue c hain and The ly ch ain c onsi tom sts pany cus ers. supp ! ҁ ȥ\$ "ҁ.# \$+4 -.҂ /.҂ 0)& ++'\$ - 2\$ .҂\$) " ) -..0 -.҂ )" .0- ) +)\$ ) \$ȥ 1 ) ! ,0\$+ ) \$ . /# - )/ / / ( . -. ( ) . -1 '.ҁ /# - '1 0.\$ - '/ \$). #\$+. )& ) \$)1 )/ ./-. 1 - ) - . Ң. !./ ңҁ \$")\$޲ -\$+/\$ & # ' - ) Ҋ.2 .\$ . (/ ) "-0 +.* chan from last r for the tivit ies, valu e ch ain a nd Com 's ac ges yea pany othe r bus iness rela tions hips
GRI 2-7	loye Emp es	Infor mati f em ploy is pr ovid ed i in th nual te 7 e An Rep ort on o ees n no full-t 2022 . All t he G 's em ploy ime loye ent, roup ees a re pe rman emp es.
GRI 2-8	& -. 2# - - mplo not e yees	# (+' 4 2\$/# '1 #\$+ \$. )/ -/. ) - 2 ) ) . . " - thro ugh ially ed m anni ies i ia an d t AS part n Ro men own ng a genc man # #\$'\$ ++\$) . \$)" - \$/\$( )1 )/\$ - \$/ ҂ 0- ) . -! !- \$)!- &!- + -/ эыээ эь (/\$ - -() +" (- )ҁ rted is n umb f cre emb he e nd o f th ing at t port repo er o w m ers e re perio d an d the l for is q uite stab le in ber o f sea farer 2022 crew poo num s d to 2021 com pare

nda rd/ GRI sta oth er s our ce	Disc losu re	link Pag mbe e nu r or
Gen eral dis clos ures
GRI 2-9	Gove rnan ce and struc ture posi tion com	The is de scrib ed i n th e Co Gove truct ate gove rnan ce s ure rpor rnan ce rt in the Ann ual Repo rt 20 22 p 10-1 2 an d in the Gov repo age erna nce and rting tion in th rform Repo e ES G Pe Rep ort 2 022, e 6. sec ance pag ( +.\$ /\$) !/# \$. \$)'0 \$)) / '- + -/э ыээ ) / ђ ))0 !' ' -. ! 0) .\$/ )/ /\$) ) )4Ҋ +- . ( ( ) (+ .2 ҁ
GRI 2-10	inati nd Nom on a sele ction of th e high est g over nanc e body	The inati ss is des cribe d in the Co Gove ate nom on p roce rpor rnan ce rt 20 22, s ee A l Rep ort 2 022 11. Crite ria u sed is de scrib ed repo nnua page \$)) \$)/# ' + # \$-! /# - ) \$/\$) / ђ -/э ыээҁ ))0 ) - al bo ard m emb ntati f the maj or sh areh olde r (Re deri- er ar e rep rese ves o &.% . '.& ' '1 ңҁ + / *-1 )
GRI 2-11	Chai r of t he h ighe st ce b ody gove rnan	#\$ -!/ # # ҂ -). / ҁ 4 -\$. )/ )\$- 0/\$1 \$)/ \$- . 3 -") 5/\$ \$./# ! /# (% -\$/4. #- #*' - \$&.% . '. &+ )ҁ -҂ / Torv ald K lave ness
GRI 2-12	Role of th e hig hest ce b ody gove rnan in ov eing the erse f ent o man agem impa cts	' .! ) ) )/\$ . .-\$ \$) -! + -/ " ( -( ) he K cedu res ( edur es) 2022 e 6. T You r Cou nter party Pro KYC , pag now proc #1 4/# \$)э ) /# 0- '- ыэы )+ +-1 +- .2 . 1 d an d up date d in 202 2 in relat ion t o th e im plem tion of th uate enta e n the Perf The Tran Act, 25 i ESG Rep ort 2 022. spar ency see page orm ance edur es in clud eeni ng fo r vio latio lated to h n rig hts a nd proc e scr ns re uma )1\$ '\$0 .ҁ # #\$- !/# \$. - !/# 0. \$) )/ -)( ( ( Ethic that disc l iss and s rel ated s Co mmi ttee issue to usse s ge nera ues \$޲ -/\$ .ҁ \$(\$/ \$)/ /\$) /2 /# / -+ юыѓ Җьҁ .+ 0( - ) ) ./& #' -. - ' / / #\$. .0 .0 . ҁ
GRI 2-13	Dele gatio n of bility for onsi resp agin g im pact man s	nsib ilitie the Perfo For r e 6 in ESG ce Re port 2022 espo s see pag rman
GRI 2-14	Role of th e hig hest ce b ody gove rnan abili in su stain ty rting repo	# -! \$. 1 4 /# ! \$- + -/ - /-.ҁ -() ++- -\$ 1' -\$' /+\$ -\$.& ) /# / (/ )/ )/ )/ - ++- .҂ ( - ҂ #1 \$ 2 ) \$. 2 \$/#/# 0\$/ (\$// ) \$) ( )- 1 0 tings thro ugh the y mee ear.
2-15 GRI	./ - /(\$!/.\$޳(	KCC hase vices from pani ned by th lling sha ntro purc s ser com es ow e co re- \$)!- #' -\$&. % . '.&+ / -1 ' '1 - (/\$ -҂ ) . .ҁ (- ) 9 in t he A l Rep ote 1 ort 2 022. see n nnua
GRI 2-16	f critic Com icati mun on o al co ncer ns	Infor mati bout whi stleb lowi ng is vide d in the Perfo ESG on a pro rman ce + эыээ эѐ҂ \$)'0 \$)" \$/\$ /# ! -\$/\$ ' -/ / +" ( (0) ) conc erns
GRI 2-17	'' /\$1 &) 2'- of th edge e hig hest ce b ody gove rnan	# ! \$- "\$1 /# - )\$5/ \$) - /-. / 2. ) *0-. . by K lave Aca dem y sin ce 20 21. ness
GRI 2-18	Eval n of the uatio perfo ce of the rman high est g over nanc e body	1'0 -\$ . /\$) \$) -+ -/ 1 + -/ +-* -)) ion 9 ual R 1. Th alua tion is no 2022 sect Ann t 202 2 pa ge 1 t , see epor e ev inde pend No actio idere d n y in 202 2 in ent. ns w ere cons ecce ssar he ev alua to t tions resp onse
GRI 2-19	ation Rem uner polic ies	delin es fo ailab le o n th Rem ation Gui r Se nior Exec utive uner s ar e av e ( Ҋ. 2 .\$/ 0) ) -' \$)". /\$) \$)!- / ( +)4 - 0) - (- ҁ !0) /\$) - '/ / )/# ) \$) /# )/ -/ () " ( -+ and ual Gove ce R t 20 22 s ectio n 11 12, Ann Repo rt 20 22 rnan epor see ьэҁ )!- (/\$ - '/ .' ) /# /.! - ььҖ / +" ) -4 -+4 ( ) and Seni or Ex ives is pr ovid ed in e 7 t o th e An nual Rep ort 2 022 ecut not and in th ation , the latte ilabl the e Sta teme nt on Rem Com uner r ava e on - Ҋ.2 .\$/ 0) - ' /\$) ".ҁ /\$) !/# * +)4 ) - (0 ) - . elate he C any' s im the iron t and not r to t pact omp s on econ omy , env men le. peop
GRI 2-20	Proc ess t o dete rmin e tion remu nera	ation Guid eline s and ation for S enio Rem Stat nt on Rem r Ex- uner eme uner \$1 \$' ' ) /# ( Ҋ.2 .\$/ 0) - ' /\$)". 0/ - 1 +)4 ) - ҁ The Guid eline d the Stat ved by th e An nual Gen nt w s an eme ere a ppro er- ' /\$) "\$) +-\$'э ) 1/\$) ) !0 )\$) /# (\$)0 /# ыээ / . / " ) -' /\$) /# 2 . \$/ ҁ +/ " 0\$ '\$) . ) / / ( )/ ") on fo for a erati r 202 2 ha ve b ared val b y the Com on re mun een prep ppro - Ҋ. ' ) -' \$)"\$ +-\$'э /\$) .0'/ / ) ыэюҁ ( )/. +)4 ))0 0) - ) have bee n inv olve d fo eval uatio n of the tion for r an remu nera prog ram the m nt. anag eme

GRI standard/ other source	Disclosure	Page number or link	Omissions	Reason for omission
General disclosures
GRI 2-21	Annual total compensation ratio		2-21 Annual total compensation ratio	Calculations not made. Will be partly reported to the Annual General Meeting in April 2023
GRI 2-22	Statement on sustainable devel- opment strategy	CEO letter in ESG Performance Report 2022 page 4. Environmental strategy for 2020-2050 have been approved by BoD. Published on the Company's website.
GRI 2-23	Policy commitments	KCC has the following policies, codes and procedures which include commitments related to responsible business conduct and/or respect of human rights: - Code of Conduct - Counterparty Code of Conduct - Know Your Counterparty Procedures - Business Ethics Guidelines - Competition Law Compliance Manual - Guidelines for Whistleblowing All policies, codes and procedures are available for all employees on a shared website and all employees receive training.	2-23 Policy commitments	Not fully answered in line with GRI requirements
GRI 2-24	Embedding policy commitments	KCC performs a due diligence on all its counterparties in line with the Know Your Counterparty Procedures. The procedures include screening related to business ethics through adverse media report screening. Base case is that all contracts should include a reference to the Counterpar- ty Code of Conduct stating what KCC expects of its counterparties. All employees receive compliance training in different topics every year.
GRI 2-25	Processes to remediate negative impacts	KCC has a whistleblowing channel, see description in ESG Performance Report 2022 page 25 and on the Company's website. The Chief Compli- ance Officer (CCO) in Torvald Klaveness receives and handles notifica- tions for KCC and notifies the Audit Committee of KCC. The CCO handles each case on a case-by-case basis and the content level related to how the cases have been handled are reviewed throught the annual compli- ance survey.
GRI 2-26	Mechanisms for seeking advice and raising concerns	The legal department and the KYC/risk team are supporting the organ- ization in how to implement policies and pratices for responsible busi- ness conduct. The Company has guidelines for whistleblowing and a whistleblowing channel, see page 25 in the ESG Performance Report 2022 and the Code of Conduct available one the Company's website.
GRI 2-27	Compliance with laws and regulations	KCC has not identified any non-compliance with environmental laws in 2022. KCC has not identified any non-compliance with laws and/or regu- lations in the social and economic area in 2022.
GRI 2-28	Membership associations	Memberships in associations where KCC/Klaveness plays an active role: - Norwegian Shipowners Association (NR): Board member in NR's Deepsea Group and member of NR's Recycling Reference Group - Sea Cargo Charter (SCC): Member of SCC Steering Commitee and SCC Technical Committee - BIMCO: Vice Chair of BIMCO's documentary Committee - Smart Maritime: Active industry partner - Climate Change Mitigation In the Maritime Sector (CLIMMS): Industry partner
		Other memberships: - Maritime Anti-Corruption Network (MACN): Klaveness was one of seven founding members in 2011 - Getting to zero 2030 coalition - Intertanko
GRI 2-29	Approach to stake- holder engagement	Stakeholder engagement described in ESG Performance Report 2022 page 6 with further description of stakeholder groups, their concerns and how we engage on Company website.
GRI 2-30	Collective bargain- ing agreements	No KCC employees are covered by collective bargaining agreements. From Klaveness Counterpaty Code of Conduct: Klaveness expects its Counterparties to support and respect internationally recognized labour rights, including the freedom of association and the right to collective bargaining within national laws and regulations.	b. Working condi- tions and terms of employment based on collec- tive bargaining agreements for other employees	n.a.

GRI standard/ other source	Disclosure	Page number or link	Omissions	Reason for omission
Material topics
GRI 3: Material Topics 2022	3-1 Process to determine material topics	ESG Performance Report 2022, page 6.
	3-2 List of material topics	ESG Performance Report 2022, page 6, Company website: https://www.combinationcarriers.com/sustainability
Low Carbon Future	1 6
Energy
GRI 3: Material Topics 2022	3-3 Management of material topics	ESG Performance Report 2022, page 7.
	302-1 Energy con- sumption within the organization	ESG Performance Report 2022, section Additional ESG topics, page 27- 28.	d.	d. n.a. as KCC does not sell electricity etc.
GRI 302: Energy 2016	302-2 Energy con- sumption outside of the organization		KCC does not have data for energy consump- tion outside the organization	Information unavailable/ incomplete
Biodiversity
GRI 3: Material Topics 2022	3-3 Management of material topics	ESG Performance Report 2022, page 7.
GRI 304: Biodiversity 2016	304-1 Operation- al sites owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas		No operational sites owned adjecent to protected areas	n.a.
	304-2 Signifi- cant impacts of activities, products and services on biodiversity	ESG Performance Report 2022, section Additional ESG topics, page 28.
	304-3 Habitats pro- tected or restored		Biodiversity	KCC does not work on protecting or restoring a specific habitat or named area
	304-4 IUCN Red List species and national conser- vation list species with habitats in areas affected by operations	Sustainability Report 2021, section Additional ESG topics, page 21.	Biodiversity	KCC does not have data for IUCN Red list species and their habitats near the standard shipping lanes we operate in
Guidelines of the Norwegian Shipowners' Association	Shipping duration in marine protected areas and ares of protected conser- vation status	ESG Performance Report 2022, Other ESG topics, page 28.	KCC does not currently have data related to shipping duration in marine pro- tected areas and areas of protect- ed conservation status	Information unavailable/ incomplete

GRI standard/ other source	Disclosure	Page number or link	Omissions	Reason for omission
Emissions
GRI 3: Material Topics 2022	3-3 Management of material topics	ESG Performance Report 2022, page 7.
	305-1 Direct (Scope 1) GHG emis- sions, Poseidon Principles, IMO MEPC.304(72)	ESG Performance Report 2022, page 16. The full GHG accounts have been made available on www.combinationcarriers.com.
	305-2 Energy indi- rect (Scope 2) GHG emissions	ESG Performance Report 2022, page 16.
	305-3 Other indi- rect (Scope 3) GHG emissions	ESG Performance Report 2022, page 16.
GRI 305: Emissions 2016	305-4 GHG emis- sions intensity	ESG Performance Report 2022, page 17.
	305-5 Reduction of GHG emissions	ESG Performance Report 2022, page 16-17.
	305-6 Emissions of ozone-depleting substances (ODS)	ESG Performance Report 2022, Additional ESG topics, page 27.	KCC does not have produc- tion, imports, or exports of ODS	n.a.
	305-7 Nitrogen oxides (NO ), sulfur oxides (SO ), and other significant air emissions, MARPOL Annex VI Reg. 13 and 14	ESG Performance Report 2022, Additional ESG topics, page 27.	No reporting of POP, VOC, HAP, as they are not avail- able, however emissions of CH , BC, N¸O and CO reported instead.	Information unavailable/ incomplete
KCC KPIs	KCC defined KPIs for % in combina- tion trade and % in hallact	ESG Performance Report 2022, page 13. Independent assurance report from EY; ESG Performance Report page 36-37.

GRI standard/ other source	Disclosure	Page number or link
Waste
GRI 3: Material Topics 2022	3-3 Management of material topics	ESG Performance Report 2022, page 7.
GRI 306: Waste 2020	306-1 Waste generation and significant waste-related impacts	ESG Performance Report 2022, Other ESG topics, page 28.
	306-2 Management of significant waste- related impacts	ESG Performance Report 2022, Other ESG topics, page 28.
	306-3 Waste generated	ESG Performance Report 2022, Other ESG topics, page 28.
	306-4 Waste diverted from disposal	ESG Performance Report 2022, Other ESG topics, page 28.
	306-5 Waste directed to disposal	ESG Performance Report 2022, Other ESG topics, page 28.
Guidelines of the Norwegian Shipowners' Association	Number and ag- gregate volume of spills and releases to the environment	ESG Performance Report 2022, page 21.
Always safe and secure	ন ক -100 inî
Occupational health and safety
GRI 3: Material Topics 2021	3-3 Management of material topics	Safety is priority number one for KCC. Description on how we work with safety culture and implement systems and routines are described in ESG Performance Report 2022 page 20-22 and page 29-30 (section "Other ESG topics"). KPIs for health and safety is reported to the BoD on a quar- terly basis.
GRI 403: Occupational Health and Safety 2018	403-1 Occupational health and safety management system	ESG Performance Report 2022, page 29 (Section Occupational health and safety management system).
	403-2 Hazard identi- fication, risk assess- ment, and incident investigation	ESG Performance Report 2022, page 29 (Section Hazard identification, risk assessment and incident investigation) and page 18 for information regarding the Company's whistleblowing channel.
	403-3 Occupational health services	ESG Performance Report 2022, page 29 (Section Occupatonal health services).
	403-4 Worker participation, consultation, and communication on occupational health and safety	ESG Performance Report 2022, page 29 (Section Worker participaction, consultation and communication on occupational health and safety).
	403-5 Worker train- ing on occupational health and safety	ESG Performance Report 2022, page 30 (Section Worker training on occupational health and safety).
	403-6 Promotion of worker health	ESG Performance Report 2022, page 30 (Section Promotion of worker health).
	403-7 Prevention and mitigation of occupational health and safety impacts directly linked by business relationships	ESG Performance Report 2022, page 30 (Section Prevention and mit- igation of occupational health and safety impacts directly linked by business relationships).

GRI standard/ other source	Disclosure	Page number or link	Omissions	Reason for omission
GRI 403: Occupational Health and Safety 2018	403-8 Workers covered by an occu- pational health and safety management system	The scope of workers is defined as all employees in the ship manager company (Klaveness Ship Management AS, 100%) and all vessel crew (100%). All visitors on board the vessels (e.g. service people, authorities, pilot or agents) are subject to the QMS when visiting the vessels.
	403-9 Work-related injuries, IMO ISM code	ESG Performance Report 2022, page 21 (Section Safety performance, statistics presented for KCC crew)	403-9 Work-relat- ed injuries, IMO ISM code	Not fully answered in line with GRI requirements
Vetting and port state control
Guidelines of the Norwegian Shipowners' Association	Port state control: Number of deficiencies and detentions received from regional port state control (PSC) organisations.	ESG Performance Report 2022, page 22.
Employment
GRI 3: Material Topics 2022	3-3 Management of material topics	KCC follows established HR policy and guidelines in Torvald Klaveness Group for employees onshore. The Employment Manual complies with the mandatory provisions of the Norwegian Working Environment Act and the local rules in Singapore and has been designed to provide a comprehensive picture of the current HR policy and guidelines and aims to contribute to good HR policy, explain rights and obligations attached to employment, provide consistency and security, contribute to equal treatment of employees and explain current welfare benefits. The Em- ployee Manual is updated regularly by the HR Department. In case of ma- terial changes the Joint Working Environment Committee (SAMU/AMU) will be informed and invited to comment.
GRI 401: Employment 2016	401-1 New em- ployee hires and employee turnover	Two new employee hires in 2022. No employees left the Company in 2022.	Age group and rate of new em- ployees/turnover not provided	KCC does not provide such information
	401-2 Benefits pro- vided to full-time employees that are not provided to temporary or part- time employees	Benefits to full-time employees: KCC employees in Norway are covered by life insurance and defined contribution pension by Gjensidige, travel insurance by Gauda/Gjensidige and health insurance by Vertikal. Other benefits include access to training facilities, holiday resorts and subsi- dised canteen. Employees in parental leave receives full pay with an up- per limit of 12G as a basis for yearly pay. KCC employees in Singapore are covered by medical insurance and employees in parental leave receives pay in line with current internal policy which give 4 weeks axtra pay in addition to pay regulated by local rules. KCC has employees in Norway and Singapore (se note 7 to Annual Report 2022).
	401-3 Parental leave	No KCC employees have been in parental leave during 2022.
Training and education for employees onshore
GRI 3: Material Topics 2022	3-3 Management of material topics	Klaveness Academy provides traning within several topic to the employ- ees, see Sustainability Report 2021, page 16 for more information related to 2021.
	404-1 Average hours of training per year per employee	An estimated 15 hours of training were offered to every employee in 2022 (2021: 20 hours) (Compliance program, Decarbonization program and IT webinars).
	404-2 Programs tor upgrading employee skills and	Compliance program, Decarbonization program, IT webinars.	b. KCC has no retirement or termination of	n.a.

of chipves-s
receiving regular

GRI 404: Training and

Education 2016

transition assis-

tance programs

404-3 Percentage
of employees

career development reviews

employment in

2021 and 2022

GRI standard/ other source	Disclosure	Page number or link	Omissions	Reason for omission
Diversity and equal opportunity - employees onshore
GRI 3: Material Topics 2021	3-3 Management of material topics	KCC is reliant upon talented and dedicated employees. All employment related decisions shall be based upon relevant qualifications, merit, per- formance and other job-related factors. We shall ensure equal rights for all, irrespective of gender identification, ethnicity, religion, sexu- al orientation, disability or social status. When seeking new employees, both genders are required to be included in the process.
GRI 405: Diversity and Equal Opportunity 2016	405-1 Diversity of governance bodies and employees	Information provided in salary note 7 in Annual Report for 2022	a. ii and b. ii age group	KCC does not provide such information
Trusted and responsible partner		្លួន Jul
Anti-corruption
GRI 3: Material Topics 2021	3-3 Management of material topics	Description on how KCC manages anti-corruption and relevant guide- lines are described in ESG Performance Report 2022, page 24 and on the Company's website.
	205-1 Operations assessed for risks related to corrup- tion	ESG Performance Report 2022, page 24.
GRI 205: Anti-corruption 2016	205-2 Communica- tion and training about anti-corrup- tion policies and procedures	Policies, procedured and reporting on KPIs are discussed and reviewed in BoD meetings on a regularly basis. Training for onshore employees (incl Management of KCC) is managed by the Klaveness Compliance Program of which anti-corruption is part of the mandatory program (Sustainability report 2022 page 24). Crew training is described in ESG Performance Report 2022, page 24. KCC's anti-corruption policies and procedures are communicated to business partners through the Coun- terparty Code of Conduct (published on the Company's website).
	205-3 Confirmed incidents of corrup- tion and actions taken	ESG Performance Report 2022, page 24. No incidents of corruption in which employees were dismissed or disci- plined for corruption. No termination or not renewed contracts with business partners No public legal cases regarding corruption
Responsible ship recycling
Hong Kong Convention, Flag state rules, Guide- lines of the Norwegian Shipowners' Association	Policy for recycling of ships. Number of ships recycled during the report- ing period with measures taken to ensure responsible recycling.	Policy described in ESG Performance Report 2022, page 25. No vessels have been recycled during the year.
Supplier environmental assessment
GRI 3: Material Topics 2021	3-3 Management of material topics	The day-to-day work related to the Know Your Counterparty Procedures is performed by a specialist department in Torvald Klaveness. The pro- cecedures are evaluated by a Compliance Committee from time to time and changes are approved by the CEO of Torvald Klaveness/Chair of KCC.
GRI 308: Supplier Envi- ronmental Assessment 2016	308-1 New sup- pliers that were screened using environmental criteria	The following assessment is made for all suppliers and counterparties as part of the Know Your Counterparty Procedures: - Business screening (identifying company structure, ultimate beneficial ownership, assessment of operation and consequential risks to people and environment): - Sanction screening (US, UN, EU and UK sanctions); - Adverse media report screening (illegal activities or risk thereof, reports from NGOs of human rights violations and harming environment); - Inclusion on selected Asset Managers non-tradable list
	308-2 Negative envi- ronmental impacts in the supply chain and actions taken	All suppliers and other counterparties are being assessed as per 308-1 above.	b.-e. Numbers	Aggegated statistics not availabe

Cautionary statement

This report contains certain forward-looking statements - you that our future results, level of activity, performance that involve risks and uncertainties. The forward-looking or achievements will meet these expectations. Moreover, statements reflect current views about future events new other person assumes responsibility and are, by their nature, subject to significant risks and for the accuracy and completeness of the forward-looking uncertainties because they relate to events and depend statements. Unless we are required by law to update these on circumstances that will occur in the future. There are statements, we will not necessarily update any of these a number of factors that could cause actual results and - statements after the date of this report, either to make them developments to differ materially from those expressed conform to actual results or changes in our expectations. or implied by these forward-looking statements. Although You should therefore not place undue reliance on forward we believe that the expectations reflected in the forward looking statements are reasonable, we cannot assure

looking statements.

The CEO and Board of Directors of Klaveness Combination Carriers ASA

Admincontrol

List of Signatures Page 1/1

FINAL ESG Performance Report 2022.pdf

Name	Method	Signed at
Johansen, Winifred P Loum	BANKID MOBILE	2023-03-06 18:03 GMT+01
Øvreas, Magne	BANKID MOBILE	2023-03-06 17:02 GMT+01
Andreassen, Gøran	BANKID MOBILE	2023-03-06 16:58 GMT+01
Dahm, Engebret	BANKID	2023-03-06 16:47 GMT+01
MEYER, ERNST ANDRE	BANKID MOBILE	2023-03-06 16:40 GMT+01
Eilertsen, Brita	BANKID	2023-03-06 19:46 GMT+01

Penneo document key: M4NCL-ELHLU-TQA61-VO0VF-P4VIX-POX2F

Independent assurance report from EY

Penneo document key: M4NCL-ELHLU-TQA61-VO0VF-P4VIX-POX2F

Foretaksregisteret: NO 976 389 387 MVA

Medlemmer av Den norske Revisorforening

Statsautoriserte revisorer Ernst & Young AS Postboks 1156 Sentrum, 0107 Oslo

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Scope

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Criteria applied by Klaveness Combination Carriers ASA

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Klaveness Combination Carriers ASA¶V responsibilities

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Description of procedures performed

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x Conducted interviews with personnel to understand the business and reporting process
x Conducted interviews with key personnel to understand the process for collecting, collating and reporting the Subject Matter during the reporting period
x Checked that the calculation Criteria have been correctly applied in accordance with the methodologies outlined in the Criteria
x Undertook analytical review procedures to support the reasonableness of the data
x Identified and testing assumptions supporting calculations
x Tested, on a sample basis, underlying source information to check the accuracy of the data
x Checked that the presentation requirements outlined in the Criteria have been correctly applied

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,QGHSHQGHQWDFFRXQWDQW¶VDVVXUDQFHUHSRUW ± Klaveness Combination Carriers ASA, 2022

Conclusion

Based on our procedures and the evidence obtained, we are not aware of any material modifications that should be made to the Subject Matter as of 31 December 2022 and for the period from 1 January 2022 to 31 December 2022 in order for it to be in accordance with the Criteria.

Oslo, 6 March 2023 ERNST & YOUNG AS

The assurance report is signed electronically

Johan Lid Nordby State Authorised Public Accountant

of the bearing of the country of the country of the country of the country of the country of the country of the country of the country of the country of the country of the co

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Klaveness Combination Carriers ASA – ESG Performance Report 2022

AI Terminal

Klaveness Combination Carriers

3644_10-k_2023-03-07_b0546aee-f004-437b-a924-7cd274010a31.pdf

ESG Performance Report 2022

Table of Contents

What we do and how we create value

Split of Cargo transported

l etter from our CFO

2022 ESG performance in brief

Governance and reporting

Management approach

Reporting standards

Third party verification

Sustainability priorities

Stakeholder engagement

Materiality assessments

Delivering cost-effective decarbonization

KCC is well positioned to deliver cost-effective decarbonization

Area of focus

Always safe and secure

Safety is priority number one

Area of focus

Trusted and responsible partner

We set high standards on how we conduct our business

Area of focus

Relevant sustainability development goals

Cost-effective decarbonization

Climate-related risks

Strategy and climate-related opportunities

KCC's Decarbonization Efforts

How to reach the ambitions

1. Optimize trading efficiency

KCC works actively to:

During 2022:

Focus 2023 and onwards:

2. Perfecting voyage efficiency

KCC invests in:

KCC has:

During 2022:

Focus 2023 and onwards:

3. Maximize energy efficiency

KCC invests in:

Improve propeller and hull efficiency:

Other emission reduction initiatives are under evaluation, such as:

Total greenhouse gas emissions

Carbon intensity (EEOI)

Ambition for 2022

Performance 2022

Average CO2 emissions per vessel year

Ambition for 2022

Performance 2022

Worker participation, consultation and communication on occupational health and safety

Response rate - Electronic debriefing

Worker training on occupational health and safety

Trainings on occupational health and safety are as follows:

Promotion of worker health

Prevention and mitigation of occupational health and safety impacts directly linked by business relationships

Governance

Compliance and Code of Conduct

Know your counterparty

Risk management and internal control

Global Reporting Initiative (GRI) content index 2022

Worker participation, consultation and communication on occupational health and safety

Response rate - Electronic debriefing

Worker training on occupational health and safety

Trainings on occupational health and safety are as follows:

Promotion of worker health

Prevention and mitigation of occupational health and safety impacts directly linked by business relationships

Governance

Compliance and Code of Conduct

Know your counterparty

Risk management and internal control

Global Reporting Initiative (GRI) content index 2022

Response rate - Electronic debriefing

Worker training on occupational health and safety

Trainings on occupational health and safety are as follows:

Promotion of worker health

Prevention and mitigation of occupational health and safety impacts directly linked by business relationships

Governance

Compliance and Code of Conduct