ANNUAL REPORT  
2025  
PELAGIA HOLDING  
 
Annual Report 2025  
CONTENT  
BOARD OF DIRECTORS REPORT ........................................................................ 3  
MANAGEMENTS REVIEW .........................................................................3  
Annual report for 2025 ....................................................................................3  
Overview 2025 ...............................................................................................3  
Profit, balance sheet and cash flows .............................................................10  
Corporate governance..................................................................................11  
Disposition of results....................................................................................14  
The company’s prospects.............................................................................14  
SUSTAINABILITY STATEMENT ............................................................................ 16  
General information .....................................................................................16  
Environmental information ...........................................................................35  
Social information ........................................................................................62  
Governance information ...............................................................................71  
STATEMENT FROM THE BOARD OF DIRECTORS AND CEO ..................................... 76  
FINANCIAL STATEMENTS PELAGIA HOLDING AS .............................................. 77  
GROUP ACCOUNTS ............................................................................. 77  
PARENT COMPANY .............................................................................117  
INDEPENDENT AUDITORS REPORTS...............................................................131  
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Annual Report 2025  
Research Fund, and more). These initiatives aim to enhance value creation by developing  
new products from pelagic raw materials, focusing on maximizing the use of the entire fish  
and reducing environmental footprints. One such project in 2025 investigated the use of  
high-temperature heat pump and superheated steam for energy-efficient water removal,  
offering improved opportunities for heat recovery and contributing to reduced energy  
consumption and CO2-emissions.  
BOARD OF DIRECTORS REPORT  
This annual report for 2025 is the second report published after EU’s “Corporate  
Sustainability Reporting Directive” was implemented in 2024. This directive requires us to  
include a sustainability statement and disclose information across various areas, resulting  
in significant changes in both the content and structure of the 2024 and 2025 reports  
compared to previous years. An overview of all published reports and presentations  
containing information can be found on pelagia.com/info/investor.  
ANNUAL REPORT FOR 2025  
Pelagia considers its employees an important intangible resource due to their skills,  
competence, and loyalty.  
Pelagia's operations are segmented into three divisions. Pelagia Food acquires pelagic fish  
from the fishing fleet and processes these into consumer products primarily for export.  
Food operates nine production facilities across Norway and additional sites in Lerwick,  
Shetland, and Skagen, Denmark.  
This report is compiled for Pelagia Holding AS (hereby referred to as “Pelagia”) and its  
subsidiaries, including but not limited to Pelagia AS, Epax Norway AS, Pelagia Sjø AS and  
Karmsund Protein AS. A complete list of subsidiaries can be found in note 1 in the financial  
statement. Pelagia AS, Epax Norway AS, Pelagia Sjø AS and Karmsund Protein AS have their  
own annual financial reports.  
Pelagia Feed produces fishmeal, fish oil, protein concentrates and pet food ingredients in  
Norway, the UK and Ireland. Feed operates nine plants dedicated to fishmeal and fish oil  
production, and five facilities producing protein concentrates and oil. In addition, Charlie  
Vial specializes in processing fish by-products for pet food. Pelagia Feed also operates a  
major storage facility in Egersund, which is approved as a border control station for the  
import of proteins and oils from third countries.  
OVERVIEW 2025  
Business model and strategy  
Pelagia is a group specializing in the production of consumer products derived from pelagic  
fish, along with fishmeal, protein concentrates, and fish oil sourced from pelagic fish,  
whitefish, and salmon. Our strategic ambition is to maximize the processing of raw  
materials within our own value chain while continuously strengthening and diversifying our  
production portfolio. The group manufactures dietary supplements and pharmaceutical  
products based on concentrated marine omega-3. This diverse range of activities positions  
Pelagia as a significant player on the international stage, particularly within the pelagic  
sector, housing production facilities throughout the North Atlantic coast. A substantial  
portion of our products are designated for export. Pelagia operates wholly owned  
production facilities across Norway, the United Kingdom, Ireland, and Denmark. The  
company’s headquarters are situated in Bergen, Norway. In 2025, including fully owned  
foreign subsidiaries and associated companies, Pelagia processed approximately 1.3 million  
tons of raw materials through our own operations.  
Pelagia Health, represented by Epax Norway AS, manufactures highly concentrated  
Omega-3 oils for human consumption, sold under the Epax brand, to be included in dietary  
supplements and pharmaceuticals. This division operates a production facility in Ålesund.  
Pelagia is amongst the largest players in the market for high-quality pelagic fish products  
and is committed to sustainability with a focus on 100% fish utilization.  
A key component of Pelagia’s business model is the integrated utilization of raw materials  
across its divisions. Within Pelagia Food, all fish is used in the production of food for human  
consumption, with varying levels of processing. Any residual raw material from this process  
is transferred to Pelagia Feed, where it is used along with other non-human-consumable  
fish for fishmeal and fish oil production, which serves as essential feed ingredients for  
aquaculture and agriculture. Some oil products can be further refined for use in dietary  
supplements and pharmaceutical products within the Pelagia Health division. Many  
leftover products from these processes are again utilized as feed ingredients. Both directly  
3
Innovation stands as a fundamental goal for Pelagia. Throughout 2025, the group  
participated in several R&D projects in collaboration with a range of partners (several  
equipment suppliers, Enova, SINTEF, Innovation Norway, the Fisheries and Aquaculture  
 
Annual Report 2025  
and indirectly, almost everything Pelagia produces ends up as food for human  
consumption.  
exposure to climate‑ and energy‑related risks and strengthened competitiveness in a  
market with rising regulatory and sustainability expectations. For broader stakeholders—  
including suppliers, local communities, and regulators—the initiatives support industry  
development toward more resource‑efficient and environmentally responsible solutions.  
Furthermore, Pelagia possesses eight operational vessels collecting residual raw materials  
from the salmon industry. These residual materials are converted into protein concentrates  
and oil, used as feed ingredients for non-salmon animals. Raw materials unsuitable for feed  
are repurposed for technical oil production or biogas generation, ensuring full utilization of  
resources.  
At Pelagia we have a high focus on anti-discrimination and equality in the workplace.  
Information on how Pelagia works with this topic, and statistics can be found in our annual  
report “Aktivitets- og redegjørelsesplikt for Pelagia 2025.” This report is published on our  
website alongside the annual report.  
Pelagia has a highly diversified and global customer base, due to the global market  
dynamics and Pelagia’s diversification across the three divisions. By 2025 revenue, the EU  
and Asia represented the most significant markets for Pelagia, followed by Norway and the  
UK. The largest customers were aquaculture feed producers in Norway and leading B2C  
distributors of pelagic fish products. There were no significant changes in markets,  
customer groups, services or products in 2025.  
We did not have specific sustainability-related goals in 2025 in terms of significant groups  
of products and services, customer categories, geographical areas or relationships with  
stakeholders. Building a solid foundation is important for creating targets that are relevant  
and achievable. We have not developed a transition plan, as most of our environmental  
footprint arises within our value chain, and we currently lack sufficient data to determine  
how these impacts can be effectively addressed. We maintain a strong internal focus on  
energy efficiency, the transition to renewable energy, process improvements and  
technological upgrades, as well as electrification, heat recovery and the use of low-carbon  
fuels.  
In 2025, Pelagia expanded its capacity to utilise marine raw materials and under‑used  
residual streams, including the development of enhanced capabilities for processing  
aquaculture sludge. We also implemented operational efficiency measures, such as the  
installation of a heat pump at one facility, which reduced reliance on fossil‑fuel‑based heat.  
These initiatives increased our ability to convert raw and residual materials into stable,  
high‑quality products while lowering the environmental footprint of production.  
The above-mentioned efforts strengthen Pelagia’s long‑term ability to operate a more  
circular and climate‑efficient value chain. Customers benefit from more reliable supply and  
improved sustainability performance in delivered products. Investors gain reduced  
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Annual Report 2025  
Our factories in Norway, the UK, and Denmark receive and process the fish before freezing  
it and shipping it to customers. Pelagia Food offers various qualities of pelagic fish for  
export, including fresh, frozen, and marinated options. Fish is packed whole round or  
filleted, typically frozen in 10 or 20kg cartons or marinated. Residual raw material from  
Food is delivered to our Feed factories, where it is used as raw material in production,  
ensuring that nothing goes to waste.  
FOOD  
The Food-segment operates eleven modern production factories and three storage  
facilities located strategically close to key fishing groups along the Norwegian Coast, the  
UK, and Shetland, as well as a refining and marinating facility in Skagen, Denmark.  
Food products are aimed at business customers who process further and sell to end  
consumers. Food has more than 650 customers located in 57 countries, and 96% of the  
products are exported to the global market. Customers are mainly fish processors that  
procure marine raw material that gets processed, packed for wholesale and retail. Asia is  
the key market for mackerel, while Europe is important for herring. Around the world,  
hundreds of thousands of people eat our fish every day.  
FIGURE 1: ILLUSTRATION FOOD PRODUCTION PROCESS  
Food processes pelagic fish for human consumption. Our food production begins with  
acquiring wild-caught pelagic fish from North-Atlantic pelagic fisheries. This mainly consists  
of mackerel and herring, caught in the Norwegian Sea and the North Sea, and bought  
through auctions or directly from fishing vessels and trawlers.  
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Annual Report 2025  
Feed production lines can be separated into two main production lines – the white and the  
red production line. By-products from both lines are used in the production of technical oil,  
carbon neutral fuel oil, or to produce biogas.  
FEED  
The white production line works with both wild caught fish not suitable for human  
consumption and trimmings and discards from fish processing. This production line  
generates fishmeal and fish oil that are suitable as ingredients in feed for farmed fish, such  
as salmon and trout. The main customers are producers of feed for salmon and trout  
farming.  
The red production line is using raw material from farming and processing of farmed fish.  
This production produces fishmeal and fish oil that are suitable as ingredients in feed for  
other animals. The main customers are feed-producers for farmed animals or marine  
animals other than salmon and trout.  
In addition, two of the feed factories have production lines that produce oil for human  
consumption.  
Feed operates 15 production factories and eight storage facilities located in Norway, the  
UK and Ireland, to ensure fresh and quality assured raw materials. Feed has a significant  
storage capacity in Egersund, Norway, which is approved as a border station for  
importation of protein and oils from third countries.  
FIGURE 2: ILLUSTRATION FEED PRODUCTION PROCESS  
Feed has more than 1 000 customers located in 30 countries. Product offering includes two  
different oil types and six different meal types, mainly sold domestically to producers of  
fish- and animal feed. The Norwegian aquaculture industry is a significant customer  
market.  
Pelagia Feed´s core business is production of fishmeal, marine oils and protein  
concentrates suited for various feed and food applications, always ensuring responsible  
use of raw materials and prime quality.  
The products are made from wild caught fish and trimmings from food production of  
pelagic, white fish and salmon. Production utilizes trimmings from filleting units in the Food  
production segment as raw material for production of feed ingredients, and it collects fresh  
and ensiled by-products from third parties. The raw material is collected either from  
aquaculture facilities using Pelagia’s own vessels or from fish processing facilities using  
trucks. Raw material from wild caught fish is delivered to facilities directly by the vessel or  
by transporting the raw material from the vessel using trucks.  
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Annual Report 2025  
Category 2 raw material  
Category 2 raw material is produced at our  
factory in Djupvik into fish protein  
concentrate for energy or for fur animal feed.  
The fish oil is used either in rendering or as a  
certified climate neutral replacement fuel for  
heating oil.  
Feed – services  
Pelagia owns eight ships and three trucks and leases an additional three trucks. Together,  
these assets provide significant capacity for year‑round, 24/7 collection and handling of  
byproducts across the North Sea, supporting both our suppliers and our own production  
facilities.  
The ships offer several services to fish processors and  
fish farmers to contribute to responsible handling of by-  
products. Together with the logistics of trimmings, they  
also supply equipment necessary for keeping the quality  
of the trimmings from production to pick up, and they  
provide emergency service to the aquaculture industry  
along the coast.  
Customers in this segment are primarily  
Norwegian salmon farmers and salmon  
processing facilities, where Feed uses the  
vessels to collect and handle by-products  
from salmon production or dead/sick salmon.  
FIGURE 4: ILLUSTRATION COLLECTING  
CATEGORY 2 RAW MATERIAL  
Sludge from aquaculture  
The by-products are categorized into different  
A more recent area of business for Pelagia is handling and transportation of sludge  
generated in the fish farming industry. After acquiring Blue Ocean Technology in 2024, we  
further strengthened our focus on sustainable sludge solutions in 2025 with the acquisition  
of Fjord Solutions. While Blue Ocean Technology designs and produces compact systems  
for dewatering, processing and storing sludge, Fjord Solutions complements this by  
providing a robust collection system that efficiently captures and transports feed waste  
and sludge from open and semi-closed cages. These were important steps for Pelagia  
towards delivering more complete sludge solutions for the aquaculture industry.  
FIGURE 3: ILLUSTRATION VESSEL  
categories. Category 3 raw material consists of  
trimmings and cutoffs that occur mostly during  
processing. Category 2 raw material often occurs at fish farms if fish dies or gets too sick to  
be processed as food.  
Both categories are grinded up and added formic acid to ensure that the pH-level is low  
enough that the material does not deteriorate. Pelagia offers equipment and competence  
in handling both category 2 and 3 raw materials in a safe and responsible manner.  
Category 3 raw material  
Category 3 raw material is processed at our factory in Salthella into H-Pro (salmon protein  
concentrate) and H-Oil (salmon oil). These products are used as ingredients in feed for  
different farmed animals.  
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Annual Report 2025  
Epax products include omega-3 rich oils for the pharmaceutical and nutrition industries.  
These are sold to more than 100 customers in 32 countries, to some of the most renowned  
retail brands in the world. Epax has a sales and marketing department in Oslo, Norway, and  
sells products through distribution partners across Europe, Asia and the United States. The  
main customers of these products are producers of dietary supplements and  
pharmaceutical intermediates ingredients.  
HEALTH  
There are little to no leftovers from production. Those fractions not used for human  
nutrition are utilized in other applications, including animal feed, biogas or fertilizer at local  
farms.  
FIGURE 5: ILLUSTRATION HEALTH PRODUCTION PROCESS  
Pelagia Health produces high-potency nutritional ingredients from crude fish oil,  
specializing in high-concentrate omega-3. This is carried out under the brand name Epax,  
which is a leading global brand of premium omega-3 ingredients for dietary supplements,  
and a manufacturer of pharmaceutical intermediate ingredients. Epax is at the forefront of  
developing new health supplements from quality North Atlantic pelagic raw materials.  
Currently most of the oil is purchased externally, particularly from omega-3 rich anchoveta  
from third parties in South America. However, the ambition is to increase the internal  
sourcing. The first Pelagia Feed factories have recently been approved to deliver Human  
Grade certified oils to Epax, with about 16% now being sourced internally with oil from  
North Atlantic pelagic species. The raw material is delivered with container ships to Epax’  
factory in Ålesund, Norway, for refinement and concentration. Healthy omega-3 EPA and  
DHA fatty acids are extracted through this process. These high-quality oils are sold around  
the world as health supplements and pharmaceutical ingredients.  
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Annual Report 2025  
Pelagia’s three business areas, Food, Feed and Health, process the raw material we  
procure. The facilities are spread along the coast of Norway, United Kingdom, Ireland  
and Denmark. In addition, Pelagia’s eight vessels collect and distribute the raw  
material.  
Value chain  
4. The Feed factories are constructed to handle different raw material such as  
by-products and cut offs from fish processing and fish farming, as well as  
wild-caught fish not suitable for human consumption  
5. The Food factories receive wild caught fish directly from the vessels and  
process, pack and freeze the fish for storage and shipping to customers.  
6. Epax, our factory in the health division, is procuring crude oil from fish oil  
facilities in South America and other countries and refines the oil.  
7. Our vessels travel along the coast to collect and transport silage from fish  
farming plants and provide different services to the farms.  
Almost everything Pelagia produces ends up as food either directly or through  
several steps of processing.  
FIGURE 6: ILLUSTRATION MAIN ASPECTS OF VALUE CHAIN  
8. Customers process Pelagia's frozen raw materials to provide herring and  
mackerel products worldwide.  
9. Most of our meal, oil, and protein concentrates are utilized as ingredients in  
feed for fish and other animals.  
Almost everything we do at Pelagia starts with marine raw materials. This raw  
material comes from different sources, and different qualities depending on the  
intended use.  
10. The refined oil from Epax is mainly used in dietary supplements.  
1. Wild-caught fish play a crucial role as our raw materials. Depending on the  
species and quality, it is used either for food production or for making  
fishmeal and oil. The fish comes from fisheries in the North Atlantic Ocean.  
2. Raw material from fish farming is collected to be used in production of  
fishmeal, oil, and concentrates, depending on the quality and category of  
raw material.  
3. Residual raw material is also a raw material that Pelagia sources as an input.  
Residual raw material consists of by-products and cutoffs/trimmings from  
fish processing, including by-catch from wild caught fish.  
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Annual Report 2025  
January 2025. Pelagia bought back about 561 MNOK of the total 900 MNOK loan as a  
part of the transaction. The remainder of the 2020 bond was paid down in August  
2025.  
PROFIT, BALANCE SHEET AND CASH FLOWS  
Result  
The group’s sales revenues were NOK 13 444 million in 2025 (14 943 in 2024). EBITDA  
The group performs annual tests to assess the value of the company’s assets.  
Impairment tests carried out at the end of 2025 show that there is no need for  
impairment. It is considered that available raw material in the form of the size of  
global quotas affects the future sales of pelagic fish and thus also the group’s activity.  
was NOK 847 million in 2025 (1 308 in 2024).  
Depreciation of property, plant and equipment and intangible assets was NOK 497  
million in 2025 (431 in 2024).  
The operating profit was NOK 349 million in 2025 (877 in 2024).  
Pelagia Holding AS total balance 8 236 million in 2025 (7 648 in 2024). Total equity  
was NOK 1 491 million (18 %) in 2025 (1 437 in 2024 (19 %). Net interest-bearing debt  
was NOK 6 619 million in 2025 (5 917 in 2024).  
Net financial expenses were NOK 368 million in 2025 (313 in 2024). The tax cost was  
NOK -30 million in 2025 (113 in 2024).  
Cash flow  
Profit after tax was NOK 12 million in 2025 (451 in 2024) and the total result was NOK  
-11 million in 2025 (548 in 2024).  
Net cash flow from operating activities was NOK 188 million in 2025 (739 in 2024).  
The difference in EBITDA and net cash from operating activities is mainly due to  
increased inventories. Net cash flow from investing activities was NOK -396 million in  
2025 (-1 272 in 2024). The investments in 2025 are related to acquisition of subsidiary  
of 28 million, purchase of property, plant and equipment of NOK 479 million and sale  
of property, plant and equipment of NOK 112 million. Net cash flow from financing  
activities was NOK 84 million in 2025 (545 in 2024). The change from 2024 to 2025  
mainly relates to net change in bank overdraft and dividends paid. Holdings of cash  
and cash equivalents were NOK 60 million in 2025 (183 in 2024).  
Pelagia Holding AS EBITDA/operating profit was -11 million in 2025 (-5 in 2024). Profit  
after tax/total result 54 million in 2025 (120 in 2024).  
Balance  
The total balance was NOK 11 924 million in 2025 (11 706 in 2024). Total equity was  
NOK 4 075 million (34 %) in 2025 (4 296 in 2024 (37 %).  
Net interest-bearing debt was NOK 6 845 million in 2025 (5 917 in 2024).  
The group is in compliance with all covenants at the end of the year.  
In Pelagia Holding AS, net cash flow from operating activities was NOK -42 million in  
2025 (-111 in 2024). Net cash flow from investing activities was NOK -26 million in  
2025 (-520 in 2024). The investments in 2025 are related to dividends and group  
contribution, net change in loans to subsidiaries and interest received. Cash and cash  
equivalents were NOK 0 million in 2025 (0 in 2024).  
The group’s interest rate terms are NIBOR plus a margin. The margin may vary  
somewhat depending on the equity ratio and profit-dependent ratios for the group.  
The group established a new 5-year long financing agreement in November 2022. A  
bond loan of NOK 900 million was issued in December 2020 with maturity in  
December 2025. Further, a new 1000 MNOK 5-year bond loan was issued in March  
2024. The loan due in 2025 was refinanced with a new 1000 MNOK 5,5-year bond in  
Going concern  
The financial statements have been prepared using the going concern assumption.  
The board confirms that the prerequisites for going concern are present.  
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Annual Report 2025  
School and a Master of Science in Economics and Finance from Warwick business  
School. He holds and has held several positions in seafood companies.  
CORPORATE GOVERNANCE  
The role of the administrative, management and supervisory bodies  
Board of directors  
Pelagia has a highly competent board of directors consisting of five members: three  
from our owner companies (one woman and two men), and two employee  
representatives (one woman and one man). None of the members are independent.  
The same composition applied in 2024 as in 2025.  
Britt Kathrine Drivenes – Board member  
Britt is the CFO of Austevoll Seafood ASA. She holds a Master of Strategy and  
Management degree from the Norwegian School of Economics (NHH), Master of  
Management Program in Internal audit, Risk Management and Corporate Governance  
and a Bachelor of Business Administration degree from the Norwegian Business  
School (BI). She has experience in finance and accounting, as well as both training and  
experience within ESG and sustainability reporting.  
The responsibilities of Pelagia's board of directors are quite comprehensive and  
crucial for the company's governance and strategic direction. They are responsible for  
overseeing the company's overall management and ensuring that it adheres to all  
relevant laws and regulations. This includes maintaining high standards of corporate  
governance and ethical conduct.  
Karoline Bjoland – Board member  
Karoline is the Production Manager at Pelagia Karmsund Fiskemel. She is the  
employee elected representative for the union Styrke from the feed division. She has  
worked for over 18 years in Pelagia.  
The board has a member with significant experience and competence within ESG  
(Environmental, Social, and Governance). If needed, the board also has access to  
several employees across the group’s companies with extensive competence within  
ESG and different sustainability topics. The board members’ areas of expertise and  
experience within different business areas and industries are well suited to cover  
Pelagia’s material impacts, risks and opportunities (IRO).  
Endre Sekse – Board member  
Endre has worked as warehouse worker and forklift operator at Pelagia Måløy since  
1983. He is a representative for the union Norsk Nærings- og  
Nytelsesmiddelarbeiderforbund (NNN) and a corporate union representative for the  
NNN food division. He has served as an employee representative on the boards of  
both Pelagia AS and Pelagia Holding AS for two terms, and he is also involved in  
Pelagia's working environment and pension committees.  
Helge Singelstad – Chairman of the board  
Helge is CEO of Laco AS, chairman of Austevoll Seafood ASA, and serves in addition on  
numerous boards of directors. He has extensive experience from various types of  
businesses such as oil and gas, and from the seafood sector. He possesses a degree in  
Computer Engineering from Bergen University College (HiB), a degree in Business  
Administration from the Norwegian School of Economics (NHH), and a first degree in  
Law from the University of Bergen (UiB).  
Arne Myklebust and Ragnhild Skaara are elected as observers to the board by the  
employees and participate in the board meetings. Further, Helge Arvid Møgster, Arne  
Møgster and Gustav Witzøe regularly participates in the board meetings as observers.  
CEO Egil Magne Haugstad and CFO Rolf Andersen participate in the board meetings  
from the administration.  
Executive management  
Helge Karstein Moen – Board member  
Pelagia’s executive management group consisted in 2025, as in 2024, of seven  
members – all men – that has a range of responsibilities that are crucial for the  
company's operations and sustainability efforts. They oversee processes to manage  
Helge is the CEO of Sortun Invest and a board member of Kverva AS. He has previous  
experience as CEO in Kverva AS, and manager in Central Klaveness AS, First Securities  
and Midt-Norge Fonds. He holds a Bachelor in Finance from Trondheim Business  
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Annual Report 2025  
material impacts, risks, and opportunities related to sustainability matters. The  
sustainability manager is responsible for ensuring that the management group is  
included in the process of determining material IROs and setting targets and actions.  
The management stays informed of progress towards targets regularly throughout  
the year. Targets we have set related to material IROs are part of day-to-day  
operations and are therefore followed up on and presented by the responsible COO.  
Bjørn Refsum – Chief Operational Officer Health Division  
Bjørn joined the group in 2018. He previously served as CEO of Epax and Nordic  
Pharma. He holds a M.Sc. in Chemical Engineering from the Norwegian University of  
Science and Technology (NTNU).  
Arnt-Ove Blytt-Tøsdal Kolås – Chief Operational Officer Feed Division  
Arnt-Ove joined Pelagia in 2016, with prior experience as a consultant at DNV. He has  
held various roles within the Pelagia group, including Technical Director and Chief  
Technical Officer, before being appointed as COO for the Feed Division in 2021. He  
holds a M.Sc. in Industrial Economics from NTNU.  
The members of the management group are overall responsible for overseeing and  
ensuring that IROs are managed responsibly. Dedicated controls and procedures  
related to the management of IROs have been assessed as unnecessary as this is  
integrated into other procedures and controls.  
Magnus Strand – Chief Operational Officer Food Division  
Egil Magne Haugstad – Chief Executive Officer  
Magnus joined the group in 1993 and has maintained various roles, including CEO at  
EMY Fish, before being appointed COO of the Food division in 2015. He holds a M.Sc.  
in Industrial Economics and Technology Management from NTNU.  
Egil Magne joined the group in 2001 and holds an approximate 13.3% indirect  
shareholding in Pelagia Holding AS. He has previously held management positions at  
Felleskjøpet and Gartnerhallen. He holds a M.Sc. in Agriculture and Life Science from  
Norwegian University of Life Sciences (NMBU) and a M.Sc. in Business from  
Norwegian Business School (BI).  
Rolf Kristian Vaage – Chief Sales Officer  
Rolf Kristian joined the organization in 2007, bringing previous experience from  
salmon sales. He held various sales roles within Pelagia before being appointed Chief  
Sales Officer in 2019. He holds a B.Sc. in International Marketing from NTNU.  
Rolf Andersen – Chief Financial Officer  
Rolf joined the group in 2012. He has previously served as CFO in Egersund Fisk, CFO  
in AKVA Group, and Director in PwC. He holds the title of State Authorized Public  
Accountant and a M.Sc. in Business Administration from NHH.  
Audit Committee  
The audit committee at Pelagia has several important responsibilities. They oversee  
both financial and non-financial reporting, ensuring that all reports are accurate and  
comply with relevant standards. This includes external audits, risk management, and  
internal control related to ESG matters.  
Frode Vatne – Chief Information Officer (until April 2026)  
Frode joined the group in 2017. He has previously held management roles at GMC,  
Aibel, and Proserv. He holds a M.Sc. in Logistics (distinction) from the University of  
Hull, a M.Sc. in Management Accounting from Aalborg University, and was a visiting  
Scholar in Management Accounting at the University of Illinois.  
The audit committee plays a crucial role in maintaining transparency and  
accountability within the organization. They ensure that the company's financial  
practices are sound and that any potential risks are identified and managed according  
to the Audit Committee Policy approved by the Board of Directors. The committee  
consists of two members, both men, and the composition remained the same in 2025  
as in 2024.  
Cecilie Bertelsen assumed the role of CIO in February 2026.  
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Annual Report 2025  
Helge Karstein Moen – Chair of the committee  
See description above.  
the prices of raw materials and eliminate parts of the currency risk. In order to  
manage the currency risk arising from future transactions and recognised assets and  
liabilities, entities in the group use forward exchange contracts. The company has  
some investments in foreign subsidiaries where net assets are exposed to currency  
risk by translation. The entities in the group have different functional currencies, the  
most important being NOK, EUR and GBP.  
Helge Singelstad – Committee member  
See description above.  
CEO Egil Magne Haugstad and CFO Rolf Andersen participate in the Audit Committee  
meetings from the administration.  
2) Price and other operational risk  
The group is operating in a globalized market where a significant part of the products  
is subject to export. The market prices of the group's products will therefore be  
affected by the global offer and demand for seafood.  
TABLE 1: GENDER DISTRIBUTION GOVERNING BODIES 2025  
Management group  
Board of directors  
Male  
60%  
Female  
40%  
Wild-caught fish is a renewable resource, whose quantity, however, will naturally  
fluctuate over time. The total legal catch will be limited to quotas set by the  
authorities in Norway, UK and Ireland (EU) and the availability may geographically  
change over time. Variations in biomass and quotas may therefore also cause  
unexpected variations in production volume and the price of raw materials.  
Audit committee  
100%  
100%  
-
-
Executive management  
The gender distribution remained unchanged in 2025 compared to 2024 for all three  
bodies.  
Also, into 2026 the unstable political situation could affect costs such as trade tariffs,  
international freight and energy costs.  
Risk management and internal control  
The Board complies with the Norwegian Code of Practice for Corporate Governance  
to the extent relevant for companies with a listed unsecured bond loan. The board is  
of the opinion that Pelagia is appropriately organized and that the business is carried  
out in accordance with current legislation and regulations and in accordance with the  
company’s purpose and articles of association. For more information on corporate  
governance, we refer to www.pelagia.com.  
3) Interest rate risk  
Pelagia's bank deposits and debt are subject to floating rate of interest. This involves  
that Pelagia is exposed to liquidity risk as a result of changes in the market interest  
rates. Pelagia uses derivatives to hedge this liquidity risk. Currently about 40% of the  
net interest-bearing debt is covered by a fixed rate until Sept 27. Pelagia's borrowings  
are to a large extent related to operations and vary in line with seasonal fluctuations  
and working capital requirements.  
Financial risk  
Market risk  
1) Currency risk  
The degree of credit risk varies based on the market segment in which Pelagia  
operates. The main part of the sales to Japan and Far East and Africa is based on  
prepayment and other forms of guaranteed settlement, the counterparty risk is  
therefore low. In other markets, such as Eastern Europe and EU, it is necessary to sell  
Over time there is a correlation between market prices translated into the functional  
currency and the prices of raw materials for the individual entity. Changes in market  
prices translated into the functional currency will therefore over time be reflected in  
13  
 
Annual Report 2025  
shares of volume on credit in order to serve the markets. Pelagia utilises credit  
insurance for a large share of the customers but will in periods be exposed without  
credit insurance for some of the customers. To handle risks, Pelagia has routines and  
systems for close follow-up of outstanding receivables. Internal credit limits have  
been established for customers where receivables are not secured through credit  
insurance. The internal limits are assessed based on the customer's financial position,  
history and any other factors. Pelagia's total credit exposure is mainly related to trade  
receivables.  
Allocation of the annual result in Pelagia Holding AS:  
Annual result:  
TNOK  
54 123  
0
54 123  
Provisioned dividend:  
Transferred to other equity:  
TNOK  
TNOK  
The Board is not aware of any events after the closing of the annual accounts that  
have a significant impact on the assessment of the accounts for 2025.  
THE COMPANY’S PROSPECTS  
Credit risk  
Pelagia has significant part of its sales in foreign currency and has an extensive use of  
currency features to hedge its currency positions. Significant changes in the value of  
the Norwegian krone against e.g. USD, Euro and JPY can have significant accounting  
effects in the short term.  
The degree of credit risk will vary depending on the market segment in which the  
group operates. All credit will, as a general rule, be secured through credit insurance  
or other instruments. On a day-to-day basis the group monitors the risk associated  
with each individual customer and outstanding receivable and has recorded  
allowance for doubtful accounts that, at all times, are considered sufficient.  
The group’s ability to utilize its production capacities will depend on raw material  
supply in the North Atlantic, and hence the size of the global quotas that are  
distributed between the countries that have a share in the fishery resources. Overall,  
the outlook for the fisheries on which the group bases its operations is reasonably  
stable. Still, short-term there can be variations in quotas and the available raw  
material. The mackerel quota decreased by 22% in 2025 compared to 2024. There is a  
further reduction of 50% expected in 2026. There will be a reduction in quota also for  
North-Sea Herring and Blue Withing, while there is an increase for the Norwegian  
Spring-spawning Herring. Overall, the quotas are decreasing in 2026. The long-term  
goal of Pelagia is to favor the sustainable management of the main fish stocks. At the  
moment, Pelagia does not see a significant climate risk that should affect the fisheries  
and the related value of its assets. Still, a long-term risk is that the fisheries in the  
North Atlantic are impacted by climate change.  
Liquidity risk  
In the opinion of management and the board, the group has sufficient access to  
financing that safeguards business opportunities and freedom of action.  
Equality and diversity  
In its recruitment policy, Pelagia seeks to attract the best applicants for key positions,  
and we provide women and men equal opportunities for career development. The  
board emphasizes that there is to be no discrimination on the grounds of gender in  
matters such as salary, promotion, continuing education and recruitment.  
DISPOSITION OF RESULTS  
The disposition of results below applies to Pelagia Holding AS which is the holding  
company in the Pelagia Group. Net financial results mainly consist of recognized  
dividends and group contributions from subsidiaries, as well as interest expenses. In  
addition to shares in subsidiaries and the group’s financing, assets and liabilities  
mainly consist of receivables and liabilities to subsidiaries. The equity was 18 % per.  
31.12.2025 (19 % as of 31.12.2024).  
Demand for pelagic fish is relatively good, but the reduction in quota leads to  
increased competition for raw materials and increased prices, thus some markets may  
fall out. The markets have also been periodically affected by currency restrictions in  
some countries that may complicate trade. For fishmeal and fish oil, demand in the  
14  
 
Annual Report 2025  
markets is also good, but prices and margins are affected by varying raw material  
quotas in South America. Due to an increase in production in Peru fish oil prices were  
significantly reduced during 2nd half of 2024 and has been negatively affecting Pelagia  
profitability during 2025. Going into 2026 the fish oil price seems to have increased.  
The group buys all its raw materials at variable prices and sells finished goods on the  
world market. Thus, the company’s finances are not directly linked to the  
The Transparency Act went into effect on July 1, 2022. Pelagia will publish an updated  
account of our due diligence in 2025 by 30.06.2026. This will be made available on the  
company's website.  
development in market prices, but to the margin achieved through production. The  
challenges of achieving good margins are normally high when prices in the market fall,  
as there is normally a long lead time from production to market.  
In October 2024, the group lost a court case in the District Court related to the  
delivery of wastes and by-products from production in the Health division. Due to the  
development of the product portfolio, a smaller volume has been sold under contract  
to the buyer of by-products. Due to the reduction in the delivered volume under the  
contract, the company was sentenced to pay the customer compensation of NOK 53  
million including costs and interest. The appeal trial was scheduled for Q1 26, but the  
parties have now entered into a collaboration business/sales contract and have jointly  
agreed that this new agreement settles all the issues of the ongoing litigation  
regarding the parties' previous business/sales agreement with immediate effect.  
Also, into 2026 the unstable political situation could affect costs such as trade tariffs,  
international freight and energy costs.  
The board emphasizes that there is uncertainty associated with assessments of future  
conditions.  
The company entered into an agreement on board liability insurance in 2025.  
The Board of Directors has adopted a code of conduct setting out standards of  
conduct for the company and its employees, last revised in December 2025. The  
ethical guidelines describe, among other things, what the Group believes constitutes  
proper behavior towards both employees and external parties, more information can  
be found under social information.  
15  
 
Annual Report 2025  
SUSTAINABILITY STATEMENT  
GENERAL INFORMATION  
TABLE 2: CONTENTS SUSTAINABILITY STATEMENT  
TABLE 3: LIST OF DISCLOSURE REQUIREMENTS  
Page reference  
Contents  
General information  
Environmental information  
EU-Taxonomy report  
Social information  
16  
35  
54  
62  
71  
Page  
reference  
16  
17  
17  
11, 18  
19  
List of disclosure requirements  
ESRS 2 General disclosures  
BP – 1  
General basis for preparation of sustainability statements  
Governance information  
BP – 2  
GOV – 1  
GOV – 2  
Disclosures in relation to specific circumstances  
The role of the administrative, management and supervisory bodies  
Information provided to and sustainability matters addressed by the  
undertaking’s administrative, management and supervisory bodies  
Integration of sustainability-related performance in incentive  
schemes  
GOV – 3  
20  
GOV – 4  
GOV – 5  
SBM – 1  
SBM – 2  
SBM – 3  
Statement on due diligence  
Risk management and internal controls over sustainability reporting  
Strategy, business model and value chain  
Interests and views of stakeholders  
Material impacts, risks and opportunities and their interaction with  
strategy and business model  
20  
21  
21, 3  
21  
27  
IRO – 1  
Description of the process to identify and assess material impacts,  
risks and opportunities  
Disclosure requirements in ESRS covered by the undertaking’s  
sustainability statement  
23  
33  
IRO – 2  
A complete table of datapoint that derive from other EU legislations can be found on  
pages 33-34.  
16  
 
Annual Report 2025  
BASIS FOR PREPARATION 1  
Disclosures in relation to specific circumstances3  
The following table lists the information that is incorporated by reference to other  
parts of the management report.  
Our sustainability statement has been prepared in compliance with the Corporate  
Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting  
Standards (ESRS). These statements are in line with the ESRS issued by the European  
Financial Reporting Advisory Group (EFRAG). Every data point included in the report  
within the environmental, social, and governance sections has been evaluated as  
material according to our double materiality assessment (DMA). For detailed  
information on the scope limitations and methodology of our DMA, please refer to  
“Process to identify impacts, risks and opportunities related to specific topics” below.  
TABLE 4: DISCLOSURES INCORPORATED BY REFERENCE  
Disclosure requirement  
ESRS 2 SBM-1, paragraphs  
40(a)i-Ii, 40(e-g), 42(a-c), AR15 chain  
Full name  
Strategy, business model and value  
Page  
3-9  
ESRS 2 GOV-1, paragraphs  
21(a-e), 22(a-d), 23(a-b)  
ESRS E5-2 MDR-A, paragraph  
69(a-c)  
ESRS G1 GOV-1, paragraphs  
5(a-b)  
The role of the administrative,  
11-13  
88-94  
11-13  
management and supervisory bodies  
Actions and resources in relation to  
material sustainability matters  
The role of the administrative,  
management and supervisory bodies  
The sustainability statements are prepared at a consolidated level2, in the same way  
as the financial statement. The sustainability statement covers Pelagia's upstream and  
downstream value chain, as well as own operations. Regarding the material impacts,  
risks and opportunities, it is specified for each IRO whether it is linked to own  
operations, up- and/or downstream value chains. This also applies to metrics and  
targets. If not specified, it is only related to own operations.  
Estimates for value chain data and/or metrics are disclosed in relation to the relevant  
disclosure requirement throughout the statement. This includes information about  
the metrics, basis for preparation and description of the level of accuracy for scope 1,  
2 and 3 emissions, as well as the description of the value chain. There remains  
uncertainty in the emission estimates across the value chain, particularly within  
customer processing, due to limited data availability and varying reporting practices.  
We serve a diverse customer base across multiple segments, where our products are  
used in a wide range of production processes. As a result, we must generalize and  
estimate impacts based on limited and variable information.  
An overview of Pelagia’s value chain can be found above under “Value chain”. For  
each disclosure on a material topic related to the value chain, the specific part of the  
value chain is specified. Pelagia has not omitted information due to it being classified  
and/or sensitive.  
The annual report for 2025 is the second report published by Pelagia in accordance  
with CSRD.  
During the preparation of the sustainability information in E1-5, we discovered that a  
portion of purchased electricity was incorrectly classified as “Renewable sources,  
including biomass” in Table 9. A later technical review confirmed that all purchased  
electricity should instead be reported under “Purchased or acquired electricity” and  
1
3
BP-1 General basis for preparation  
BP-2 Disclosures in relation to specific circumstances  
2
A table of subsidiaries included in this consolidated report can be found in the financial statement, note 1  
17  
 
Annual Report 2025  
included in “Total fossil energy consumption,” regardless of contractual instruments.  
Consequently, 85ꢀ056 MWh was wrongly reported as renewable energy in the 2024  
sustainability statement. This error has now been corrected to ensure full compliance  
and consistent energy reporting going forward.  
Use of phase-in provisions in accordance with Appendix C of ESRS 1  
Pelagia has chosen to use the following phase-in provisions:  
TABLE 5: PHASE-IN PROVISIONS USED  
Disclosure  
requirements  
Full name of disclosure requirement  
During the preparation of the sustainability information in E1-6, we identified a  
material prior‑period reporting error concerning the metric “% of Scope 1 GHG  
emissions from regulated emissions trading schemes” in Table 11. For the base year  
2024, this metric was omitted due to a misinterpretation that it related to the trading  
of emission allowances, an activity in which Pelagia does not participate. Accordingly,  
emissions from our four EU Emissions Trading System (ETS) regulated facilities should  
have been included for 2024. This prior‑period error has now been corrected, and the  
updated figure for the base year 2024 is 73%.  
ESRS 2 SBM-1  
paragraph 40(b)  
Strategy, business model and value chain  
ESRS 2 SBM-3  
paragraph 48(e) with strategy and business model  
Material impacts, risk and opportunities and their interaction  
Anticipated financial effects from material physical and  
transition risk and potential climate-related risk  
ESRS E1-9  
ESRS E3-5  
ESRS E5-6  
ESRS S1-7  
Anticipated financial effects from water and marine  
resources-related impacts, risks and opportunities  
Anticipated financial effects from resource use and circular  
economy related impacts, risks and opportunities  
Characteristics of non-employee workers in the undertaking’s  
own workforce  
ESRS S1-14  
ESRS S1-15  
Partially health and safety non-employees  
Work-life balance  
The role of the administrative, management and supervisory bodies4  
The composition and diversity of the administrative, management and supervisory  
bodies can be found above under “Corporate governance”.  
Pelagia has integrated sustainability from the top down to ensure that the entire  
group has the same focus on sustainability work. The sustainability governance  
structure includes the board of directors, audit committee, and executive  
4
GOV-1 The role of the administrative, management and supervisory bodies  
18  
 
Annual Report 2025  
management. The board and management have roles and responsibilities in  
overseeing processes to manage material impacts, risks, and opportunities related to  
sustainability matters.  
and the company's existing expertise to manage them, or how this expertise will be  
developed internally or sourced externally.  
Addressing and handling of sustainability matters 5  
The executive management are responsible for approving targets related to the  
material impacts, risks and opportunities and are regularly updated on progress  
towards these.  
The board bears the ultimate responsibility for ensuring that the sustainability  
statement is prepared and published in accordance with regulations. Strategic  
planning and efforts related to ESG and sustainability, including the execution of such  
strategies, are also components of the board's duties. Furthermore, the board is  
tasked with overseeing the process and ensuring that all material impacts, risks, and  
opportunities are appropriately managed. This includes but is not limited to the  
implementation of due diligence, and the results and effectiveness of policies, actions,  
metrics and targets.  
Our double materiality assessment was conducted in 2024 and revisited in 2025,  
identifying ten material impacts, risks and opportunities. Several of our material IROs,  
especially those related to climate change mitigation and energy consumption, are  
closely connected to Pelagia’s vision and overall strategy. Our strategic ambition is to  
maximize the processing of raw materials within our own value chain while  
continuously strengthening and diversifying our production portfolio. By increasing  
the level of local processing, we reduce transportation needs and thereby lower our  
overall environmental footprint. Higher value-added processing also enables more  
efficient resource utilization and supports the application of the cascading principle,  
ensuring that raw materials are used to their fullest potential across multiple product  
streams. This approach reinforces our long-term resilience and contributes to  
responsible growth across our operations.  
FIGURE 7: HOW ESG RESPONSIBILITIES ARE ORGANIZED  
All material IROs have been presented and approved by the relevant governing  
bodies. A list of all material IROs can be found below under “Material impacts, risks  
and opportunities”. Results from the review conducted in 2025 were addressed with  
The administrative, management and supervisory members have access to internal  
sustainability experts, as well as external specialists, including auditors and other third  
parties. All the administrative bodies are informed about new or updated regulations  
5
GOV-2 Information provided to and sustainability matters addressed by the undertaking’s administrative,  
management and supervisory bodies  
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Annual Report 2025  
management representatives as well as representatives for employees and safety in  
BAMPU (joint company, work environment and pension committee).  
corruption standards, where identified concerns require actions and can influence  
commercial engagements.  
Since the double materiality assessment was conducted for the first time in 2024 and  
first revisited in 2025, the frequency and matter of informing the administrative and  
supervisory bodies is still a developing process. This is also the case for  
implementation of due diligence, and the results and effectiveness of policies, actions,  
metrics and targets adopted to address them.  
Trade-offs linked to material IROs, such as higher short-term investment needs versus  
long-term gains in energy performance, resource utilization or supply resilience, are  
acknowledged and form part of broader management deliberations. Although the  
integration of IROs into strategy and financial decisions is still developing, they  
provide an important frame of reference for understanding long-term risks and  
opportunities across Pelagia’s operations.  
The executive management is responsible for defining and following up the  
sustainability strategy and other matters. The responsibility is spread out between the  
different chief officers according to the figure above. The COOs are responsible for  
informing the rest of the management team on impacts, risks and opportunities  
related to their responsible division.  
2024 is set as base year for most sustainability matters. 2024 was the first year we  
reported according to CSRD, where we conducted assessments, gathered information  
and collected data systematically to align with CSRD requirements. For some areas we  
have not yet been able to set targets.  
Integration of sustainability in remuneration6  
Pelagia considers material impacts, risks and opportunities as part of general strategic  
discussions and when evaluating significant operational or investment decisions.  
While these assessments are still being formalized, material IROs, such as energy  
consumption, climate-related risks, access to raw materials and opportunities for  
increased resource utilization, provide relevant context when management considers  
long-term development of the business.  
Pelagia offers potential incentives to members of the administrative and management  
bodies, where bonuses and remuneration are evaluated based on overall company  
performance and achievements. The CEO has authority to evaluate and determine the  
allocation of bonuses. Sustainability matters are considered in this holistic  
assessment, though no specific percentage of the remuneration is linked to climate  
related considerations. No specific target for emissions had been set in 2025 and is  
therefore not taken into consideration.  
The annual report includes information on ongoing initiatives such as investments in  
energy-efficiency and conversion to biofuel, product development to increase  
value-adding processing, and measures to manage fluctuations in raw material  
availability. These activities are examples of areas where sustainability-related risks  
and opportunities may influence management’s considerations, balancing potential  
environmental benefits with operational and financial implications.  
Statement on due diligence7  
The main aspects and steps of our due diligence process can be found in several  
different parts of the sustainability statement. An overview of where the different  
parts are located can be found in appendix to this chapter, in Table 6: Statements on  
due diligence.  
HSE considerations are inherently built into our strategy and financial decisions, as  
maintaining safe working conditions is fundamental to our operations. We also expect  
our customers to comply with our Code of Conduct, including alignment with anti-  
6
7
GOV-3 Integration of sustainability-related performance in incentive schemes  
GOV-4 Statement on due diligence  
20  
 
Annual Report 2025  
Risk management and internal controls over sustainability reporting8  
Pelagia’s Statement of Policy on Corporate Governance outlines the Board’s  
responsibility for internal control and risk management, and the Audit Committee’s  
oversight of both financial and non‑financial reporting.  
Strategy and business model9  
Disclosures related to strategy, business model and value chain can be found under  
“Business model and strategy” in the Board report10. An overview of headcount by  
geographical areas can be found under “Characteristics of Pelagia employees” under  
the social information section.  
In preparing the sustainability report, Pelagia identifies and assesses risks that may  
affect the completeness, accuracy, and reliability of sustainability information. Key  
risks include poor data quality, incomplete or inconsistent data from operational  
units, limited insight into value‑chain activities, and manual processes that increase  
the likelihood of errors. These risks are assessed through our double materiality  
assessment and through regular dialogue with operational departments. More  
information on how risks are assessed and prioritized are described under “Process of  
monitoring impacts, risks and opportunities” (page 25).  
OUR STAKEHOLDERS 11  
In Pelagia we strive to maintain dialogue with our stakeholders to secure alignment  
between our business and strategy, and the views and interests of our stakeholders.  
Stakeholders’ input is used as input in our decision-making, due diligence and  
materiality assessments. Management stays informed of stakeholder views and  
interests by getting updates when there is a significant change to these. The  
sustainability manager is responsible for informing management, primarily done  
through management meetings. Information is made available and distributed so  
management and the board can get relevant input from stakeholders when needed.  
To mitigate these risks, Pelagia has established a set of internal control measures.  
Quantitatively, we rely on systematic and automated data extractions from internal  
systems to secure consistent, traceable, and verifiable data sets over time. We also  
work continuously to improve data collection processes, strengthen system  
integrations, and develop clearer guidance for local data owners. Qualitatively, all  
sustainability‑related statements must be supported by appropriate documentation  
and undergo review by relevant internal stakeholders. The draft report is  
subsequently reviewed by relevant management, and any discrepancies or  
uncertainties are addressed prior to submission to the Board for approval. This  
multi‑step process enhances internal control mechanisms and supports the quality,  
accuracy, and transparency of Pelagia’s sustainability reporting in line with ESRS  
requirements.  
Stakeholder views are considered when shaping our strategies and sustainability  
efforts, and when significant changes are being made. Per 2025, no major changes to  
either strategy or business areas have been conducted or planned based on the  
stakeholder dialogue. This is because the interests and views of stakeholders are  
aligned with both strategies and business areas.  
Information on how the views and interests of the different stakeholder groups was  
included in the double materiality assessment can be found under “Process to identify  
impacts, risks and opportunities related to specific topics.”  
Employees  
Our people are our most valuable resource. As employer, Pelagia is committed to  
creating a meaningful and safe workplace, centered on collaboration and  
transparency. We engage with employees through various channels, including internal  
8
10  
GOV-5 Risk management and internal controls over sustainability reporting  
ESRS 2 SBM-1, paragraph 40(a)i-ii; 40(e-g); 42(a-c); AR 15.  
9
11  
SBM-1 Strategy, business model and value chain  
SBM-2 Interests and view of stakeholders  
21  
 
Annual Report 2025  
communication systems, general meetings, as well as councils at each location with  
employee representatives.  
Owners  
Owners of Pelagia are engaged in sustainability matters on a regular basis to ensure  
alignment with our strategy and performance. This includes regular briefings, annual  
general meetings, and other arenas where we discuss progress and challenges related  
to material topics. By keeping our owners informed and involved, Pelagia fosters a  
shared commitment to achieving our sustainability efforts and driving long-term  
success. Circularity, business conduct and financial stability are particularly important  
to our owners.  
We have established channels where employees can provide feedback or raise  
concerns directly to the company. This includes our whistleblower system and annual  
employee surveys, which are detailed in the governance section. Employees’ views  
and interests are also conveyed by employee representatives in committees on  
various topics, such as HSE and work environment. These committees are detailed in  
the social information section. Engagement with our employees provides valuable  
knowledge and possibilities for improvement in the company. For our employees,  
health and safety, as well as secure employment, is of key importance. More  
information about our engagement with own employees is available in the social  
information section.  
Local communities  
Pelagia has close ties to local communities; most of our facilities are in smaller  
communities along the coasts of Norway, the UK, Ireland, and Denmark. We provide  
employment opportunities within these communities, support local businesses and  
sponsor local initiatives. We engage with communities regularly and value their  
feedback to ensure that we foster strong cooperation with all the communities where  
Pelagia operates. Community perspectives are usually gathered through informal  
channels, as administrative staff at the various factories are themselves part of the  
local communities in which we operate. Feedback and complaints we receive are  
handled locally as they arise. Pelagia engages in local management on the same basis  
as other industries. For local communities, emissions, job opportunities and the use of  
local businesses are of key importance.  
Customers  
Pelagia aspires to deliver premium products and services to build trust in our markets.  
Engaging with our customers is essential, as their needs and preferences play an  
important role in developing our business model and value proposition. We engage  
with customers on an operational basis, in periodic reviews and due diligence  
processes. Their input and feedback are used to improve our products, and to  
optimize transport and logistics downstream. Our customers emphasize emissions  
performance, certifications, circularity and high standards of business conduct.  
Suppliers  
We consider engaging with our suppliers as key to promoting responsible sourcing  
and ethical practices. Marine resources are our main input in production, and  
promoting sustainable sourcing from the ocean is paramount to Pelagia, as described  
in the Environmental information section. We continuously engage with suppliers  
through daily operations, due diligence assessments and audits, which enable  
informed decisions concerning our supply chain and possibilities to streamline  
logistics to reduce emissions where possible. For our suppliers, it is important that  
Pelagia is a dependable customer who pays on time and upholds a strong  
commitment to responsible business conduct.  
22  
 
Annual Report 2025  
In the process of identifying IROs, we also considered complaints, comments and  
other input from affected communities to see whether this provided relevant  
information to the IROs we had identified or if it provided a basis for new IROs.  
Pelagia has most of our facilities near local communities and interact and  
communicate with these regularly either directly, through collaborations or from  
feedback provided from affected communities. This communication has been used as  
input for identifying IROs. More information about how we engage with local  
communities is described above under “Our stakeholders”. We also used internal  
resources who had extended information on the views and interests of different  
stakeholder groups. More information about data sources, estimations, scopes and  
other information can be found alongside the relevant IRO.  
PROCESS TO IDENTIFY IMPACTS, RISKS AND OPPORTUNITIES RELATED TO  
SPECIFIC TOPICS  
Materiality assessment process 12  
2024 was the first time Pelagia conducted a double materiality assessment. The  
assessment was revised in 2025 to ensure continued relevance and to account for any  
changes during the year, while maintaining the process and methodology applied in  
2024 to ensure consistency and comparability. The revision did not identify any  
changes to Pelagia’s material impacts, risks or opportunities.  
Scope of the assessment  
The process to identify material impacts, risks and opportunities (IROs) is an  
important step in preparing our sustainability statement. The process is based on the  
EFRAG guidelines and requirements in ESRS 1.  
We considered dependencies between impacts, risks and opportunities, and related  
actions. When we identified an impact or a dependency, we checked if this impact or  
dependency could pose either a risk or an opportunity. Three of the four material  
opportunities and risks arose either from a dependency or an impact. IROs related to  
specific facilities or divisions were disaggregated accordingly.  
The scope and context of the assessment is defined as Pelagia’s subsidiaries, business  
segments, and geographies that Pelagia or its value chain operates in. Activities in our  
own operations, as well as in the value chain and through business relationships were  
mapped out, involving representatives from the various geographies and COOs.  
Topic-specific considerations  
Process of identifying impacts, risks and opportunities  
When identifying impacts, risks and opportunities, topic-specific considerations were  
considered. We have not conducted topic-specific consultations with stakeholders  
beyond those described in the general methodology section. In addition to the  
approach described above and considering input from affected communities, we also  
screened our assets and activities when identifying water and marine related IROs  
(E3) and resource use and circular economy related IROs (E5). In connection with E3,  
we screened our assets for water consumption, water pollution and emissions, and  
for E5, we screened our assets for waste generated. The screening was carried out  
using company data systems and standardized assessment templates applied across  
all facilities, ensuring consistency and comparability.  
To identify Pelagia’s IROs, we performed desktop research and interviews with  
external stakeholders, customers and internal subject matter experts. Interviewees  
were selected based on background, relevance, or business relationships, to provide  
relevant input. Input from external stakeholders and experts is an important part of  
data collection for the double materiality assessment. Engagement with stakeholders  
happens regularly throughout the year through meetings, participation in forums, and  
other processes. This engagement with regular dialogue and collection of interests  
and views of external sources are used to verify results of the materiality assessment  
and check for potential changes.  
12 ESRS 2 IRO-1 Disclosures on the materiality assessment process  
23  
 
Annual Report 2025  
When assessing IROs related to pollution (E2), biodiversity and ecosystems (E4) and  
business conduct (G1), we applied the same process as described above, which  
included assessment of locations and business activities to identify actual or potential  
IROs in our operations and value chain. For our own operations we have close contact  
with affected communities and use this as a basis for considering potential IROs. In  
relation to E4, we also assessed dependencies, transition risks and physical risks on  
diversity and ecosystems of the Pelagia Group. When doing this assessment for our  
value chain, we grouped together locations and companies in the value chain with  
similarities. For our own operations, we have conducted an overarching analysis at  
site-specific level. This revealed that Pelagia does not have locations that are in or  
near biodiversity-sensitive areas with a significant negative impact or risk to the  
surroundings, which would require necessary mitigating actions.  
above 16, the IRO was determined to be material. When human rights were involved  
in the IRO, severity took precedence over likelihood in the assessment.  
The DMA process identified Pelagia’s relevant topical standards and disclosure  
requirements, including application requirements. For each material matter, the  
corresponding disclosure requirements and data points were carefully evaluated for  
their relevance to the identified impact, risk or opportunity, as well as their usefulness  
for users of the report. This assessment was used to determine the material  
information to be disclosed in relation to the material impacts, risks and  
opportunities.  
Pelagia is a diversified company, consisting of many subsidiaries. It was therefore  
important to involve all divisions and COOs with their respective teams in the  
decision-making process and assessment of IROs. To ensure that we got a complete  
overview and could correctly assess the risk of adverse impacts, the assessment  
process included all significant activities and areas where we or our business partners  
operate. We did not focus on specific activities, business relationships, geography or  
other factors, but strived to include and assess all that could be significant by getting  
all the information needed to make a good assessment available.  
We did not identify any negative impacts regarding E2 or E4.  
Process of assessing impacts, risks and opportunities  
To determine Pelagia’s material topics, we mapped and assessed the identified IROs  
as described in ESRS 1. Negative impacts were scored based on severity and  
likelihood, where severity was based on scale, scope and irremediability. Positive  
impacts were scored on scale, scope and likelihood. Risks and opportunities were  
scored against their likelihood and magnitude. Pelagia’s financial team was involved in  
assessing financial materiality, bringing in key competence, understanding of  
sustainability-related risks relative to other types of risks, and knowledge about the  
effect on the company. In addition to internal resources, Pelagia hired experts from  
third parties to participate in this to ensure that the process was conducted according  
to the regulations.  
Impacts where Pelagia was involved through own operations or because of its  
business relationships are considered according to the impact it has or may have on  
nature, the environment and people. Irremediability and likelihood are also taken into  
consideration.  
Process for verifying assessment  
Following the assessment, IROs were then calibrated with management, who  
discussed and verified the material topics. The double materiality assessment was  
then distributed to management to be considered in overall risk assessments.  
To rate each IRO, we assessed severity, likelihood, scale, scope and irremediability on  
a 1-5 scale. For the impact assessment, the average of the scale, scope and  
irremediability (if negative) was multiplied by its likelihood to get a final score for the  
impact. For risks and opportunities, their likelihood was multiplied by the magnitude  
of the financial effects to provide the risk or opportunity with a score. If the score was  
Uncertainties were verified against the most relevant internal or external  
stakeholders to ensure that the assessment and collected information regarding the  
IRO was accurate, current and pertinent. This internal control process has several  
steps. First, data collected from different stakeholders is checked against relevant  
personnel. Then, the criteria thresholds applied, and the assessment results are  
24  
 
Annual Report 2025  
Climate scenario analysis13  
verified with management. Management is the final decision-maker and responsible  
for deciding whether the results from the double materiality assessment are accepted  
and can be used. If any discrepancies are detected, these are addressed and  
corrected before the final materiality assessment is distributed.  
Pelagia has conducted an analysis to assess transition and physical risks and  
opportunities related to climate change. Different climate scenarios have been used  
to analyze how they impact our activities, as well as the resilience of the business.  
These scenarios align with state-of-the-art science and are compatible with climate-  
related assumptions made in the financial statements. These are compatible with the  
assumption mentioned in note 10, that the main risk for Pelagia is the effect climate  
change can have on fish stocks and lead to an increased cost of marine raw material.  
Process of monitoring impacts, risks and opportunities  
Management and other relevant personnel are informed when a new impact, risk or  
opportunity is assessed as material. IROs that were assessed as material in 2024 and  
2025 are the first ones for Pelagia, after conducting our first double materiality  
assessment in 2024. The process of monitoring these IROs is therefore yet developing,  
and as of now the monitoring process is individually adapted to each IRO, which is  
handled according to how the responsible employee sees fit.  
Scope and methodology  
The analysis was informed by previous climate assessments as well as the double  
materiality assessment. It was conducted by the sustainability team before it was  
discussed and qualified by representatives in the management group. Following the  
double materiality assessment, the scope of the analysis includes Pelagia’s own  
operations as well as the first tier of our value chain, and the time horizons define  
short term as one year ahead, medium term as 2030, and long term as 205014. No  
material physical or transitional risks have been excluded from the analysis. The  
standard time horizons from CSRD were adopted with no link to specific expected  
lifetimes of its assets, strategic planning or capital allocation plans.  
Material impacts, risks and opportunities are monitored and considered whenever  
significant decisions are discussed that could affect these IROs or lead to new material  
IROs, and this process is an integrated part of our annual reporting cycle and DMA  
review. Risks assessed as material are handled in the same manner as other types of  
risks in the company. More about risk management can be found under the chapters  
“Corporate governance” and “Basis for preparation” above. This process has not been  
formalized or made part of a procedure or policy. The prioritization of sustainability-  
related risks and other types of risks follows the same process, where risks are  
prioritized based on their potential financial impact and the likelihood of the risk  
occurring after preventative measures have been implemented.  
When assessing activities, we considered potential and actual sources of emissions,  
which were also included when discussing plans for investments. This included  
screening our activities and plans to identify actual and potential future GHG emission  
sources and, where applicable, drivers for other climate-related impacts (e.g.,  
emissions of black carbon or tropospheric ozone or land-use change) in our own  
operations and along the value chain. Potential effects from GHG emissions on  
climate change include higher risk of climate hazards, higher temperatures affecting  
ecosystems, and rising sea levels, to name a few.  
The material risks have not had any significant impact on the company’s overall risk  
profile as these risks were known beforehand and preventative measures have  
already been implemented to mitigate the risks.  
13  
14  
ESRS 2, IRO-1, E1: Disclosures on the materiality assessment process  
These time horizons are based on recommendation for time horizons found in the ESRS 1  
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Annual Report 2025  
Scenarios  
heavy precipitation, sea level rise, storm surges and flooding are relevant for our  
coastal facilities, which were further assessed against the scenarios. These climate-  
related hazards could lead to significant damage to buildings and production  
equipment near the seaside and result in a need for significant investments to restore  
the facilities affected.  
The analysis includes scenarios from each side of the spectrum, released by the  
Network for Greening the Financial System (NGFS) in 2021. On one side, the “Net Zero  
2050” scenario is consistent with the Paris Agreement which limits climate change to  
1.5°C, assumes that climate policies are introduced early to enable immediate  
emission reduction, and that technology change is fast. This scenario represents a  
medium transition risk and low physical risk.  
Emissions assessment  
Additionally, we have assessed our actual and potential impacts on climate change  
(i.e., our total GHG emissions). This involved calculating GHG emissions in our own  
operations and along the value chain, using methodologies aligned with the  
methodology from CSRD. This process includes defining organizational boundaries,  
selecting appropriate emission factors, and setting a baseline year for comparability  
over time. Emissions are calculated in respective models and reported in line with  
regulatory standards set out by the CSRD.  
On the other side, the “Hot House World” high emission scenario describes warming  
of 3°C or above, with reduction policy at current level corresponding to a higher risk  
of physical climate hazards and lower transition risks. To analyze the impacts on  
facilities, corresponding projection data from the RCP 8.5 scenario by IPCC was used  
where available.  
The key driver for using these scenarios to plan for worst and best case is to see how  
the outer point could affect our business model and activities. This approach helps us  
prepare for both extremes and everything in between. Considering energy usage,  
emissions, and the uncertain political situations, using both outer points offers the  
best approach. We also assessed scenarios on a mainly national and regional level and  
assessed some specific locations. Both scenarios used are from the Network for  
Greening the Financial System (NGFS) in 2021.  
Conclusion  
The transition to a lower-carbon and resilient economy is expected to result in  
increased costs for raw materials and energy, as well as changes in regulations and  
market dynamics. However, Pelagia's focus on high resource efficiency, the use of  
residual raw materials, and the adoption of lower-emission and renewable energy  
sources presents significant opportunities to mitigate these risks and enhance the  
company's resilience and competitiveness.  
The scenarios are used as high-level stress tests and provide directional, not granular,  
results. They are limited by long-term uncertainty, limited data availability in parts of  
the value chain, and the use of broad regional projections rather than detailed  
site-specific modelling. As a result, the level of detail is qualitative and strategic rather  
than technical or asset-level.  
Risk and opportunity assessment  
To identify physical risks at site-level granularity, a climate risk and vulnerability  
assessment was conducted of facilities and activities. Significant risks were assessed  
relative to the scope and expected lifespan of the activity. The overall impact was  
generally considered low. Here, climate related hazards such as extreme weather,  
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Annual Report 2025  
Results of the double materiality assessment  
FIGURE 8: RESULTS OF THE ASSESSMENT  
Material impacts, risks and opportunities15  
Pelagia’s impacts, risks and opportunities resulting from the double materiality assessment are presented on the following pages. There were no changes to Pelagia’s material  
impacts, risks and opportunities compared to the previous reporting period.  
More information on how the specific impacts, risks and opportunities are related and how they are handled in the strategy and business model can be found alongside the  
disclosure requirements for each individual IRO. None of the IROs resulted in entity specific topics to report on.  
15 SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model  
27  
 
Annual Report 2025  
E1 Climate change  
E3 Water and marine resources  
Climate change mitigation  
Extraction and use of marine resources  
Negative impact  
Actual  
Own operations  
GHG emissions own operations  
Negative impact  
Potential, short term  
Upstream  
Overfishing in value chain  
Pelagia operates facilities, vessels, and vehicles that consume  
energy and generate GHG emissions that have a negative impact  
on climate. Emissions are concentrated in factories that produce  
fishmeal and oil in Norway, Denmark, UK and Ireland.  
The primary raw material used in our food production for human  
consumption is wild caught fish sourced from the North Atlantic  
where the risk of overfishing is present in our upstream value  
chain. The extraction of marine resources may impact future stocks  
and contribute to a decrease in the fish population of important  
fish stocks.  
Negative impact  
Actual  
Up- and downstream  
GHG emissions value chain  
Greenhouse gas emissions occur in Pelagia’s upstream and  
downstream value chain, causing a negative impact on climate  
both locally and globally. Emissions are primarily driven by fishing  
vessels, the production of other input factors used in our factories,  
and the transportation of products to customers mainly by road or  
sea.  
Risk  
Access to marine raw materials  
Short term  
Own operations and  
upstream  
Unstable political situations, uncertainties around quotas,  
reduction in fish stocks, and changes in regulations are all factors  
that contribute to a risk of accessing sufficient raw materials. This  
risk is concentrated in Pelagia’s food production where wild caught  
fish is the primary input.  
Risk  
Climate change affecting fish stocks  
Long term  
Own operations and  
upstream  
Variations in ocean acidity and temperatures influence fish  
movement patterns and population of pelagic fish in the North  
Atlantic. This may affect the catch locations of raw materials and  
have a negative impact on Pelagia’s production sourcing.  
E5 Resource use and circular economy  
Risk  
Increased cost on raw materials  
Long term  
Own operations and  
upstream  
Unpredictability in access to wild caught fish used as input in  
production at Pelagia’s factories may lead to increased cost of raw  
materials which will impact profitability where margins are slim.  
Resource inflows  
Positive impact  
Actual  
Own operations  
and upstream  
Using residual raw material  
Pelagia’s use of residual raw material that are discarded from the fish  
farming and fish processing industry, decreases dependency on wild  
caught fish in production of fishmeal and oil. This offers a sustainable  
alternative in raw material sourcing and has a positive impact on the  
environment. Reducing the need for wild-caught fish also decreases  
pressure on fish stocks.  
Energy  
Opportunity  
Long term  
Own operations  
Transition to lower emissions and renewable energy sources  
Increased use of lower emission technologies and renewable  
energy sources can reduce the environmental footprint of our  
products, which can be advantageous compared to other products.  
Some of these energy options are also more cost-effective than  
energy from fossil sources.  
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Annual Report 2025  
G1 Business conduct  
S1 Own workforce  
Corruption and bribery  
Working conditions  
Negative impact  
Potential  
Downstream  
Corruption and bribery in the value chain  
Negative impact  
Potential  
Short-term  
Health and safety  
With customers located in a variety of countries, there's a substantial  
risk of potential financial crimes like corruption, bribery, and money  
laundering in our downstream value chain. A large portion of our  
customers operate in high-risk regions, potentially posing a negative  
impact on people and challenging business relations across our  
facilities and divisions.  
A substantial part of our employees are located at facilities where  
there are chemicals, equipment and machinery that can cause physical  
harm to employees. This poses a potential negative impact that can  
affect employees’ health and safety.  
Own operations  
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Annual Report 2025  
Resilience analysis16  
Introduction  
facility to ensure efficient logistics of locally produced raw material. Pelagia has  
different types of facilities and are dependent on qualified employees. Some factories  
are running throughout the year while others are only running during the high  
seasons when the fish is being landed. This leads to varying needs for employees  
depending on the season.  
The resilience analysis aims to evaluate the physical, transitional, social, and  
governance risks, impacts and opportunities to ensure that Pelagia’s strategy and  
business model are compatible with different future scenarios. This analysis is crucial  
for decision-making related to investments and mitigating identified risks effectively.  
The analysis was performed in 2024 and revisited in 2025. No significant changes  
were identified in 2025, therefore no further adjustments to the analysis were  
deemed necessary.  
When assessing each physical, transitional, social, or governance risk, the most  
relevant time horizon for determining the materiality of the risk was considered. Only  
the most significant transition risks (mentioned below) were assessed on how they  
can affect business activities and assets. The most significant risks have a higher  
potential financial impact and likelihood of occurring.  
When the analysis was performed, we started by collecting data on our  
environmental, social and governance performance. We had already performed a  
climate scenario assessment and a double materiality assessment (DMA) that  
included a mapping of the value chain. These combined were used as a basis for this  
analysis. We looked through the collected data for impacts, risks and opportunities as  
well as strengths, weaknesses and threats linked to our strategy and business model.  
We also looked through the information gathered from stakeholders during the  
stakeholder dialogue to see if any of this information could be useful in this analysis.  
The anticipated financial effects from material physical and transition risks and  
mitigation actions and resources were estimated and considered as an integral part to  
determine materiality. Some uncertainty is linked to the financial effects of raw  
material access going forward. The quotas are determined annually, and we do not  
have a secure overview of how they will be affected moving forward.  
This assessment has been used as an input in the double materiality assessment to  
ensure that no significant risks or opportunities have been excluded. No significant  
uncertainties were found in the analysis. We have not identified any assets or  
activities incompatible with the transition to a climate-neutral economy or with  
significant locked-in emissions.  
Scope and focus  
The analysis focuses on Pelagia's own operations and the first level of the value chain,  
both upstream and downstream. It includes both assets and our different business  
activities. The time horizons align with those used for the climate scenario analysis,  
with short term defined as one year ahead, medium term as 2030, and long term as  
2050.17 The scenarios used in the resilience analysis are the same as for the climate  
scenario analysis. No GHG emissions targets are set per 31.12.2025.  
Key risks, impacts and opportunities  
Changing temperature and acidification of the oceans: This risk affects the availability  
and quality of marine resources, which are critical to Pelagia's operations.  
Pelagia’s strategy and business model depends on using both wild caught fish and  
residual raw material and utilizing all raw material depending on the quality and type.  
The facilities are spread along the coast to ensure that the raw material travel as short  
as possible before being processed. Most Feed facilities are located near a Food  
Increased cost of raw material: Unpredictability in the supply of wild-caught fish may  
lead to increased costs, impacting profitability.  
16  
17  
SBM-3 Material impacts, risks and opportunities and interaction with strategy and business model  
These time horizons are based on recommendation for time horizons found in the ESRS 1  
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Annual Report 2025  
Access to raw material: Unpredictability in the supply of wild-caught fish and quotas  
set for important fish stocks may lead to trouble accessing the quantity of raw  
material needed.  
Employee training and HSE procedures: Investing in training to ensure a skilled  
workforce and take necessary precautions to avoid significant harm.  
Strengthening governance practices: Enhancing governance frameworks to ensure  
compliance with regulatory requirements and support sustainable business practices.  
High use of residual material: Utilizing residual raw materials from the fish farming  
and processing industry reduces dependency on wild-caught fish and offers a  
sustainable alternative.  
More information on how we mitigate these risks and how opportunities are handled  
can be found further in the report. The risks identified are not linked to a specific  
asset or business activity but are risks to Pelagia as a whole. They are taken into  
consideration when discussions on strategy and investments are taking place. Per  
2025 we have no specific current or planned action connected to these risks.  
Use of lower-emission and renewable sources of energy: Transitioning to lower-  
emission technologies and renewable energy sources can reduce the environmental  
footprint and provide cost advantages.  
Health and safety own workforce: Ensuring a safe and healthy workplace for our  
employees.  
Pelagia's strategy and business model are resilient due to various factors such as  
reliance on different marine resources, increased use of renewable energy sources,  
efficient use of raw materials, strategic locations, responsible social practices and  
robust governance structures. This resilience is a crucial part in decision-making  
related to investments to mitigate identified risks effectively.  
Corruption and bribery in the value chain: A significant number of customers in  
countries with high risk of financial crimes, such as corruption and bribery, increases  
the likelihood of this occurring in our value chain.  
Mitigation strategies  
Conclusion  
Diversification of marine resources: Pelagia relies on different marine resources to  
ensure resilience against changes in ocean conditions. Utilizing both wild caught fish,  
residual raw material from fish processing and fish farming.  
The resilience analysis concludes that Pelagia's strategy and business model are well-  
positioned to handle future challenges and opportunities. The company's reliance on  
different marine resources and focus on sustainability enhances its resilience and  
supports informed decision-making related to investments.  
Strategic location of facilities: Facilities are spread along the coast to minimize  
transportation distances and reduce emissions.  
Pelagia's diverse business areas and competencies are being evaluated to prevent  
significant risks related to the necessity of an immediate and substantial shift in our  
product or service portfolio or the need for major workforce reskilling. Due to the  
overall assessment of the risks assessed concluded to be low, Pelagia has no specific  
plans to secure access to capital, shift our product or service portfolio or make other  
significant changes to our assets related to sustainability topics. This is due to no  
significant risks being identified that are not already mitigated.  
Investment in renewable energy: Pelagia has adopted lower-emission and renewable  
energy sources to mitigate transition risks. Investments have been made in  
production facilities, and we’re monitoring the effects continuously.  
Efficient use of residual materials: Pelagia focuses on maximizing the use of residual  
raw materials to reduce waste and improve sustainability.  
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Annual Report 2025  
APPENDIX – SUSTAINABILITY STATEMENT  
STATEMENT ON DUE DILIGENCE18  
TABLE 6: STATEMENTS ON DUE DILIGENCE  
Core elements of due  
POLICIES  
Sections in the sustainability statement and page reference  
Statement of Policy on Corporate Governance  
diligence  
Pelagia’s Statement of Policy on Corporate Governance was adopted in 2025. The  
policy applies to all companies in Pelagia Holding AS to reasonable extent. The policy  
outlines the company’s legal structure, its divisions, departments and owner  
structure, and the national laws and regulations it is subject to, with a commitment to  
adhere to relevant laws and regulations, and recommendations for good corporate  
governance.  
a) Embedding due  
diligence in governance,  
strategy and business  
model  
ESRS 2 GOV-2  
ESRS 2 GOV-3  
ESRS 2 SBM-3  
ESRS 2 SBM-3, E1  
ESRS 2 GOV-2  
ESRS 2 SBM-2  
ESRS 2 SBM-3  
ESRS 2 MDR-P, E1-2  
ESRS 2 MDR-P, E3-1  
ESRS 2 SBM-3  
ESRS 2 SBM-3, E1  
ESRS 2 SBM-3, E3  
ESRS 2 MDR-A, E1-3  
ESRS 2 MDR-A, E3-2  
ESRS 2 MDR-A, E5-2  
ESRS 2 MDR-M, E1-5  
ESRS 2 MDR-M, E1-6  
ESRS 2 MDR-M, E5-4  
19  
20  
27  
36  
19  
21  
30  
38  
47  
ESRS 2 SBM-3, E3  
ESRS 2 SBM-3, E5  
ESRS 2 SBM-3, S1  
ESRS 2 SBM-3, G1  
ESRS 2 MDR-P, E5-1 49  
ESRS 2 MDR-P, S1-1 64  
ESRS 2 MDR-P, G1-1 72  
47  
49  
63  
72  
b) Engaging with affected  
stakeholders in all key  
steps of the due diligence  
S1-2  
65  
The policy further outlines company objectives, values, a commitment to contribute  
to sustainable development and a commitment to ensure that good corporate  
governance is an integral part of decision-making processes. It contains guidelines for  
equality and diversity, underlining our zero tolerance towards discrimination. It also  
outlines the responsibilities, tasks, purpose and composition of the board of directors  
and the audit committee, processes for monitoring and auditing, and strategy for  
information and communication. It provides an overview of the internal controls and  
risk management functions of the group, including roles and responsibilities, activities  
and reviews.  
27, 30 ESRS 2 SBM-3, E5  
49  
63  
72  
c) Identifying and  
assessing adverse impacts  
36  
47  
38  
48  
49  
39  
40  
52  
ESRS 2 SBM-3, S1  
ESRS 2 SBM-3, G1  
ESRS 2 MDR-A, S1-4 66  
G1-1  
G1-3  
ESRS 2 MDR-T, E1-4 39  
ESRS 2 MDR-T, E3-3 48  
ESRS 2 MDR-T, E5-3 50  
ESRS 2 MDR-T, S1-5  
ESRS 2 MDR-T, G1-4 74  
d) Taking actions to  
address those adverse  
impacts  
72  
73  
e) Tracking effectiveness  
of these efforts and  
communicating  
ESRS 2 MDR-M, S1-14 69  
ESRS 2 MDR-M, G1-3 73  
67  
CFO is accountable for implementation of the policy. It is available through our  
intranet, and to externals through Pelagia.com.  
18  
GOV-4 Statement on due diligence  
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Annual Report 2025  
DATA POINTS THAT DERIVE FROM OTHER EU LEGISLATION 19  
TABLE 7: DATA POINTS THAT DERIVE FROM OTHER LEGISLATIONS  
Disclosure Requirement and related datapoint  
SFDR  
Pillar 3  
Benchmark Regulation EU Climate  
Sustainability  
Law reference statement  
Material  
Page reference  
reference reference reference  
X
ESRS 2 GOV-1 Board’s gender diversity ¶ 21 (d)  
x
x
13  
ESRS 2 GOV-1 Percentage of board members who are independent ¶ 21 (e)  
ESRS 2 GOV-4 Statement on due diligence ¶ 30  
Material  
Material  
11  
20, 32  
X
X
X
X
ESRS 2 SBM-1 Involvement in activities related to fossil fuel activities ¶ 40 (d) i  
ESRS 2 SBM-1 Involvement in activities related to chemical production ¶ 40 (d) ii  
ESRS 2 SBM-1 Involvement in activities related to controversial weapons ¶ 40 (d) iii  
ESRS 2 SBM-1 Involvement in activities related to cultivation and production of tobacco ¶ 40 (d) iv  
ESRS E1-1 Transition plan to reach net zero climate neutrality by 2050 ¶ 14  
ESRS E1-1 Undertakings excluded from Paris-aligned Benchmarks ¶ 16 (g)  
ESRS E1-4 GHG emission reduction targets ¶ 34  
x
x
x
x
x
Not material  
Not material  
Not material  
Not material  
-
-
-
-
x
Not relevant  
Not relevant  
Material  
-
x
x
x
x
-
X
X
X
X
X
X
39  
39  
40  
40  
42  
42  
-
ESRS E1-5 Energy consumption from fossil sources disaggregated by sources (only high climate impact sectors) ¶ 38  
ESRS E1-5 Energy consumption and mix ¶ 37  
Material  
Material  
ESRS E1-5 Energy intensity associated with activities in high climate impact sectors ¶ 40 to 43  
ESRS E1-6 Gross scope 1, 2, 3 and Total GHG emissions ¶ 44  
ESRS E1-6 Gross GHG emissions intensity ¶ 53 to 55  
Material  
x
x
x
x
Material  
Material  
ESRS E1-7 GHG removals and carbon credits ¶ 56  
x
Not material  
Not material  
Not material  
ESRS E1-9 Exposure of the benchmark portfolio to climate-related physical risks ¶ 66  
x
-
ESRS E1-9 Disaggregation of monetary amounts by acute and chronic physical risk ¶ 66 (a); Location of significant  
assets at material physical risk ¶ 66 (c)  
ESRS E1-9 Breakdown of the carrying value of its real estate assets by energy-efficiency classes ¶ 67 (c)  
ESRS E1-9 Degree of exposure of the portfolio to climate-related opportunities ¶ 69  
ESRS E2-4 Amount of each pollutant listed in Annex II of the E-PRTR Regulation emitted to air, water and soil, ¶ 28  
ESRS E3-1 Water and marine resources ¶ 9  
x
x
-
Not material  
Not material  
Not material  
Material  
-
-
x
X
X
X
X
X
X
X
X
X
-
47  
-
47  
-
ESRS E3-1 Dedicated policy ¶ 13  
ESRS E3-1 Sustainable oceans and seas ¶ 14  
Not material  
Material  
ESRS E3-4 Total water recycled and reused ¶ 28 (c)  
ESRS E3-4 Total water consumption in m3 per net revenue on own operations ¶ 29  
ESRS 2- SBM 3 - E4 ¶ 16 (a)  
Not material  
Not material  
Not material  
Not material  
Not material  
-
-
-
ESRS 2- SBM 3 - E4 ¶ 16 (b)  
ESRS 2- SBM 3 - E4 ¶ 16 (c)  
-
19  
IRO-2 Disclosure Requirements in ESRS covered by the undertaking’s sustainability statement  
33  
 
Annual Report 2025  
Disclosure Requirement and related datapoint  
SFDR  
Pillar 3  
Benchmark Regulation EU Climate  
Material/  
Law reference Not material  
Not material  
Page reference  
reference reference reference  
X
ESRS E4-2 Sustainable land / agriculture practices or policies ¶ 24 (b)  
ESRS E4-2 Sustainable oceans / seas practices or policies ¶ 24 (c)  
ESRS E4-2 Policies to address deforestation ¶ 24 (d)  
-
-
-
X
X
X
X
X
X
X
x
Not material  
Not material  
Not material  
Not material  
Not material  
Not material  
Material  
ESRS E5-5 Non-recycled waste ¶ 37 (d)  
-
ESRS E5-5 Hazardous waste and radioactive waste ¶ 39  
-
ESRS 2- SBM3 - S1 Risk of incidents of forced labour ¶ 14 (f)  
ESRS 2- SBM3 - S1 Risk of incidents of child labour ¶ 14 (g)  
-
-
ESRS S1-1 Human rights policy commitments ¶ 20  
64  
-
ESRS S1-1 Due diligence policies on issues addressed by the fundamental ILO Conventions 1 to 8, ¶ 21  
ESRS S1-1 Processes and measures for preventing trafficking in human beings ¶ 22  
ESRS S1-1 workplace accident prevention policy or management system ¶ 23  
ESRS S1-3 Grievance/complaints handling mechanisms ¶ 32  
Not material  
Not material  
Material  
X
X
X
-
64  
65  
69  
69  
-
Material  
ESRS S1-14 Number of fatalities and number and rate of work-related accidents ¶ 88 (b) and (c)  
ESRS S1-14 Number of days lost to injuries, accidents, fatalities or illness ¶ 88 (e)  
ESRS S1-16 Unadjusted gender pay gap ¶ 97 (a)  
X
X
X
X
X
X
X
X
X
X
x
x
Material  
Material  
Not material  
Not material  
Not material  
Not material  
Not material  
Not material  
Not material  
Not material  
Not material  
Not material  
Not material  
Not material  
Not material  
Not material  
Not material  
Not material  
Not relevant  
Not relevant  
Material  
ESRS S1-16 Excessive CEO pay ratio ¶ 97 (b)  
-
ESRS S1-17 Incidents of discrimination ¶ 103 (a)  
-
ESRS S1-17 Nonrespect of UNGPs on Business and Human Rights and OECD ¶ 104 (a)  
ESRS 2- SBM3 – S2 Significant risk of child labour or forced labour in the value chain ¶ 11 (b)  
ESRS S2-1 Human rights policy commitments ¶ 17  
x
-
-
-
ESRS S2-1 Policies related to value chain workers ¶ 18  
-
ESRS S2-1 Nonrespect of UNGPs on Business and Human Rights principles and OECD guidelines ¶ 19  
ESRS S2-1 Due diligence policies on issues addressed by the fundamental ILO Conventions 1 to 8, ¶ 19  
ESRS S2-4 Human rights issues and incidents connected to its upstream and downstream value chain ¶ 36  
ESRS S3-1 Human rights policy commitments ¶ 16  
x
x
-
-
X
X
X
X
X
X
X
X
X
X
X
-
-
ESRS S3-1 non-respect of UNGPs on Business and Human Rights, ILO principles or and OECD guidelines ¶ 17  
ESRS S3-4 Human rights issues and incidents ¶ 36  
x
x
-
-
ESRS S4-1 Policies related to consumers and end-users ¶ 1  
-
ESRS S4-1 Non-respect of UNGPs on Business and Human Rights and OECD guidelines ¶ 17  
ESRS S4-4 Human rights issues and incidents ¶ 35  
ESRS G1-1 United Nations Convention against Corruption ¶ 10 (b)  
ESRS G1-1 Protection of whistle-blowers ¶ 10 (d)  
-
-
-
-
ESRS G1-4 Fines for violation of anti-corruption and anti-bribery laws ¶ 24 (a)  
ESRS G1-4 Standards of anti-corruption and anti- bribery ¶ 24 (b)  
x
74  
74  
Material  
34  
 
Annual Report 2025  
ENVIRONMENTAL INFORMATION  
Pelagia is committed to ensuring that 100% of our raw materials are utilized and  
thereby minimizing waste and maximizing value. We pride ourselves on maintaining  
the lowest possible environmental footprint throughout our production, while taking  
care to manage our material impacts, risks and opportunities.  
TABLE 8: LIST OF DISCLOSURE REQUIREMENTS  
Page  
reference  
List of disclosure requirements  
E1 Climate change  
36  
36  
SBM – 3  
Material impacts, risks and opportunities and their interaction with  
strategy and business model  
E1 – 1  
E1 – 2  
E1 – 3  
E1 – 4  
E1 – 5  
E1 – 6  
Transition plan for climate change mitigation  
Policies related to climate change mitigation and adaptation  
Actions and resources in relation to climate change policies  
Targets related to climate change mitigation and adaptation  
Energy consumption and mix  
37  
38  
38  
39  
39  
40  
47  
47  
Gross Scopes 1, 2, 3 and Total GHG emissions  
E3 Water and marine resources  
SBM – 3  
Material impacts, risks and opportunities and their interaction with  
strategy and business model  
E3 – 1  
E3 – 2  
E3 – 3  
Policies related to water and marine resources  
Actions and resources related to water and marine resources policies  
Targets related to water and marine resources  
47  
48  
48  
49  
49  
E5 resource use and circular economy  
SBM – 3  
Material impacts, risks and opportunities and their interaction with  
strategy and business model  
E5 – 1  
E5 – 2  
E5 – 3  
E5 – 4  
EU Taxonomy  
Appendix  
Policies related to resource use and circular economy  
Actions and resources related to resource use and circular economy  
Targets related to resource use and circular economy  
Resource inflows  
49  
49  
50  
52  
54  
59  
35  
 
Annual Report 2025  
ESRS E1 - CLIMATE CHANGE  
GHG emissions  
Materiality assessment in relation to climate change  
Negative actual impact, short term (own operations and value chain)  
We assessed the impact Pelagia’s own operation has in relation to carbon emissions,  
using emissions calculated for 2025. We also screened all significant activities and  
plans by examining how these were linked to emissions and if future planned  
activities would affect the emissions or have any other climate-related impacts.  
In our own operations, scope 1 and 2 emissions amounted to 1 586 710 (location  
based) / 1 657 118 (market based) tCO₂e in 2025 (see Table 11). Emissions are  
concentrated in our factories that produce fishmeal and oil. Efforts to reduce  
emissions at our facilities and improve energy efficiency is a continuous focus.  
In relation to physical risks, we relied on the results from the climate scenario and  
resilience analysis to assess if there are any material climate related physical risks,  
either in our own operations or in tier one of our value chains. This assesses what  
risks are most relevant for our assets and business activities, and how these may be  
sensitive to climate change.  
In our value chain, emissions are particularly significant in the sourcing and  
production of input material used at our factories, and in transportation of  
products to customers mainly on road or by sea. The primary raw material that  
Pelagia sources is pelagic stock, such as herring and mackerel, which have low CO₂  
emissions relative to other seafood products.21  
Material impacts, risks and opportunities and their interaction with  
strategy and business model 20  
Climate changes are affecting every person on the planet as well as the  
environment, for example through shifts in weather patterns, changes to seasonal  
cycles, and increasing pressure on natural environments and communities. Climate  
changes are therefore a critical issue to address. The short- or medium-term  
impact will not directly affect the business model or value chain. However,  
emissions and the following effects from both own operations and the value chain  
contribute to overall climate change. Pelagia is mitigating the impact by using new  
technology and testing how to get energy from low emission sources.  
Increased cost of raw materials  
Risk, long term (own operations and upstream)  
The access to wild caught fish and other important raw materials in Pelagia’s  
production may be subject to a changing market and regulatory landscape in  
response to climate or nature risks such as overfishing. Unpredictability in supply  
and governmental measures are expected to raise prices of raw materials.  
While material, this risk is not expected to have a significant effect on Pelagia’s  
financial position, financial performance or cash flow over short term. Therefore,  
there has not been decided whether there is a need for any material adjustments  
within the next financial reporting period. Pelagia is mitigating this risk by ensuring  
good capital resources and flexibility and having diverse business areas.  
20  
21  
SBM-3 Material impacts, risks and opportunities and interaction with strategy and business model  
SINTEF – Greenhouse gas emissions of Norwegian seafood products in 2017 (dated 2020)  
36  
 
Annual Report 2025  
Transition to lower-emission and renewable sources of energy  
Opportunity, long term (own operations)  
Climate change affecting fish stocks  
Risk, long term (value chain)  
A climate-related opportunity for Pelagia lies in expanding the use of low-emission  
or renewable energy in our operations. In addition to being more cost-efficient, a  
decrease in emissions will keep the footprint of our products low and may bring  
about a competitive advantage. Pelagia’s focus on cost-effective and energy  
efficient solutions contributes to our ability to capture this opportunity.  
Change in ocean acidity and ocean temperatures due to global warming affect  
swimming patterns, population and stocks of Pelagic fish. Under the high emission  
scenario with warming of +3°C, this may pose a significant risk to raw material  
supply in the long term. Pelagia’s variety of business areas and geographies, high  
resource efficiency, and actions to reduce emissions, all demonstrate its resilience  
in this scenario.  
This opportunity may provide Pelagia with the chance to transition from fossil fuels  
energy sources to low-emission and renewable energy sources. Pelagia made  
several investments in technologies to further this transition in 2024 and 2025. We  
anticipate that this transition may strengthen Pelagia’s long-term position and  
contribute to lower emissions and more stable energy costs over time.  
This risk will likely impact both our operations and the fishing fleet by altering  
where fish can be caught. Pelagic species are swimming in schools in the open  
ocean and can move to different areas depending on access to food and other  
circumstances. A change of ocean acidity and ocean temperatures can change how  
the stock swims or in the worst case affect the size and survival of the fish stocks.  
Pelagia is mitigating this risk by working to reduce our own emissions and using  
different species as our raw material as well as residual raw material as an input  
factor in our production. We have not been able to calculate the effect this risk can  
and will have on the financial position, but we do not expect significant changes in  
the short or medium term. Long-term impacts are subject to significant uncertainty  
and have therefore not been quantified financially.  
Transition plan for climate change mitigation22  
We have assessed and quantified our greenhouse gas emissions across all scopes.  
More than 90% of our total emissions occur in the value chain, primarily from  
fisheries and other activities that are not under Pelagia’s operational or financial  
control. As a buyer in auction‑based markets, we do not have the ability to influence  
how these emissions arise, even though we recognize their significance.  
Given the structure of our value chain and the lack of direct leverage over upstream  
emission sources, we do not yet have the necessary basis to develop a credible  
transition plan. Nevertheless, we remain committed to transparency and will continue  
to monitor regulatory developments, data availability and industry practices. We will  
also maintain dialogue within the value chain to support improvements where  
feasible, while acknowledging that our direct influence is inherently limited.  
22  
E1-1 Transition plan for climate change mitigation  
37  
 
Annual Report 2025  
Policies 23  
Total energy consumption per processed raw material  
Our Responsible operations policy aims to enhance sustainability and minimize  
environmental impact by reducing carbon emissions, promoting resource efficiency,  
and ensuring ethical practices. It does not explicitly address climate change  
adaptation but supports energy efficiency and renewable energy deployment through  
its focus on reducing energy use and pursuing low-emission and renewable energy  
sources. The policy relates to all the material risks, opportunities and impacts  
mentioned in this chapter. It considers own operations and value chain, is approved  
by the CEO and applies to all our facilities. The Sustainability Manager is accountable  
for its implementation. The policy aligns with standards like the United Nations  
Sustainable Development Goals (SDGs). The policy is made available on Pelagia’s  
intranet.  
0,70  
0,60  
0,50  
0,40  
0,30  
0,20  
0,10  
-
2023  
2024  
2025  
Liquid fuel oil  
Bio fuel  
Electricity  
Actions and resources 24  
FIGURE 9: ENERGY USE PER PROCESSED RAW MATERIAL  
Pelagia's bond loans aim to provide capital for investments aligned with its strategy.  
These bonds are not green or sustainable, nor linked to any specific sustainability  
objectives or targets. All actions mentioned are financed using two bonds. The bonds  
secure access to capital to ensure that these and future actions can be conducted.  
More information about the bonds can be found in note 4 in the financial statement.  
None of the actions require significant investments. The scope of the mentioned  
actions is own operations and value chain.  
Fuel switching by using certified carbon neutral fish oil  
We produce certified carbon‑neutral fish oil at two of our facilities, as further  
described under “Actions and resources ” in the Resource use and circular economy  
chapter (ESRS E5). This oil replaces conventional fossil heating oil in our operations. By  
switching to climate‑neutral fuel, the four factories using this oil achieved a combined  
26% reduction in emissions per kWh consumed when comparing 2025 to 2023. This  
fuel‑switching initiative is an important decarbonization measure in our climate  
strategy, directly reducing Scope 1 emissions and supporting the transition to  
lower‑carbon operations.  
Energy efficiency technologies and equipment  
In 2024, an industrial-sized heat pump was installed at our feed facility in Måløy. This  
energy-efficient heat pump has contributed considerably to reduce our energy  
consumption and emissions in this factory when comparing 2025 to 2023. The  
experience from this installation is now being used to assess whether similar solutions  
can be expanded to other facilities and operational areas.  
In 2024, the use of carbon‑neutral fuel resulted in a reduction of 4 844 tCO₂e  
compared with the emissions profile of conventional fuels. This reduction increased to  
8 389 tCO₂e in 2025. Over the same period, emissions from conventional liquid fuels  
in the four factories fell by 14%, an improvement from the 11% decrease recorded in  
the previous reporting period.  
23  
24  
E1-2 Policies related to climate change mitigation and adaptation  
E1-3 Actions and resources in relation to climate change policies  
38  
 
Annual Report 2025  
62–67. None of the metrics are subject to external assurance. The effectiveness of  
policies is not tracked, nor is the effectiveness of the action regarding supply chain  
decarbonization. The effectiveness of the two actions related to energy efficiency and  
fuel switching are tracked by calculating progress on a year-to-year basis. We have  
not defined a level of ambition to be achieved. Quantitative indicators used to  
evaluate progress are specified above in relation to each action. Base year for both  
actions is 2023, which was the last full production year before the actions were  
initiated.  
Pelagia has not established quantitative climate targets for scopeꢀ1 and scopeꢀ2  
emissions. Based on our current emissions profile, these scopes represent  
approximately 10ꢀpercent of our total greenhouse gas emissions (market-based  
method), while the remaining 90ꢀpercent originates from scopeꢀ3 categories. Because  
scopeꢀ3 emissions fall largely outside our direct operational control and still lack  
sufficient data quality and completeness, setting meaningful long‑term targets at this  
stage would not provide a robust or decision‑useful basis for climate management.  
FIGURE 10: DIRECT MARKET-BASED CO2 EMISSIONS PER TOTAL ENERGY CONSUMPTION  
We have therefore chosen to postpone the establishment of climate‑related targets  
until we can prepare a more informed and analytically sound target‑setting process  
that reflects the full emissions profile of the company. As part of this approach, we  
will continue improving data coverage and reliability across the value chain to ensure  
that future targets are comprehensive, credible, and aligned with our transition plan  
for climate change mitigation.  
Supply chain decarbonization by focusing on effective logistics and transportation  
Our Food and Feed facilities are typically strategically located in proximity to one  
another, limiting suppliers’ need for transportation. To further reduce emissions, we  
have a continuous focus on effective logistics throughout our value chain, preference  
of sea transport where feasible, and a growing share of electrical vehicles in our fleet.  
Energy consumption 27  
Pelagia operates within the high climate impact sectors manufacture of food products  
and wholesale of grain, unmanufactured tobacco, seeds and animal feeds. The energy  
consumption and mix for Pelagia are as shown in the table below.  
Metrics and targets for climate change25 26  
Pelagia applies climate-related metrics covering scope 1, scope 2 and relevant scope 3  
emissions, as well as metrics for energy consumption and energy mix, as detailed in  
the sections below. These metrics are defined in ESRS E1 (including E1-5 and E1-6),  
and for associates and joint ventures calculated in accordance with ESRS 1 paragraphs  
25  
27  
E1-1 Transition plan for climate change mitigation  
E1-5 Energy consumption and mix  
26  
E1-4 Targets related to climate change mitigation and adaptation  
39  
 
Annual Report 2025  
Greenhouse gas emissions 30  
TABLE 9: ENERGY CONSUMPTION AND MIX  
Pelagia’s scope 1 and 2 emissions account for only 10% (market-based calculation) /  
5% (location-based calculation) of total emissions. We continue to focus on reducing  
emissions and enhancing energy efficiency in our own operations, while working on  
understanding potential reduction within the value chain. The calculation of the  
greenhouse gas emissions has all been used with emissions factors for CO₂e that  
present the emission of other greenhouse gases such as CO₂, CH4, N₂O, HFCs, PFCs,  
SF6, and NF3 converted into CO₂ equivalents.  
Energy consumption and mix (MWh)  
2024  
2025  
Coal and coal products  
Crude oil and petroleum products  
Natural gas  
Other fossil sources  
Purchased or acquired electricity, heat, steam, and cooling from  
fossil sources  
-
162 592  
204 966  
-
-
143 529  
177 354  
-
160 953  
149 670  
Total fossil energy consumption  
528 511  
470 554  
Scope 1 and 2 – emissions from own operations  
Share of fossil sources in total energy consumption (%)  
Consumption from nuclear sources  
96%  
-
92%  
-
To calculate scope 1 and 2 emissions, Pelagia has approached this according to the  
requirements from CSRD. We account for all GHG emissions from companies and  
subsidiaries that are included in the consolidated annual report. A complete overview  
of these subsidiaries can be found in note 1. Pelagia has no activities or companies  
that are included solely based on operational control, all companies included are  
based on financial control. This method aligns with the method described in ESRS E1.  
Share of consumption from nuclear sources in total energy  
consumption (%)  
Renewable sources, including biomass (also comprising  
industrial and municipal waste of biologic origin, biogas,  
renewable hydrogen, etc.)  
0%  
0%  
21 811  
41 062  
Purchased or acquired electricity heat, steam, and cooling from  
renewable energy  
-
-
Self-generated non-fuel renewable consumption  
Total renewable energy consumption  
249  
22 060  
680  
41 742  
Share of renewable sources in total energy consumption (%)  
4%  
8%  
Total energy consumption  
550 571  
512 296  
TABLE 10: ENERGY INTENSITY PER NET REVENUE  
Energy intensity per net revenue (MWh/mNOK)28  
2024  
36,6  
2025  
38,1  
% vs. LY  
Total energy consumption per net revenue29  
4%  
28  
30  
Revenue can be found in note 5  
E1-6 Gross Scopes 1, 2, 3 and Total GHG emissions  
29  
From activities in high climate impact sectors. We only operate in high climate sectors.  
40  
 
Annual Report 2025  
FIGURE 11: EMISSIONS PER PROCESSED VOLUME  
tCO2e Scope 1&2  
0,132  
200 000  
180 000  
160 000  
140 000  
120 000  
100 000  
80 000  
60 000  
40 000  
20 000  
-
0,140  
0,120  
0,100  
0,080  
0,060  
0,040  
0,020  
-
0,120  
0,066  
0,073  
181 884 96 511  
157 236 86 828  
2024  
2025  
tCO2e Scope 1&2 Market based  
tCO2e Scope 1&2 Location based  
tCO2e (Market) / ton RM processed  
tCO2e (Location) / ton RM processed  
41  
 
Annual Report 2025  
TABLE 11: GHG EMISSIONS  
GHG emissions (tCO₂e)  
Retrospective  
Milestones and target years  
Base year  
2024  
Comparative  
2024  
Annual % target /  
2025 2030 2050  
2025  
% vs. LY  
Base year  
Scope 1 GHG emissions  
Gross Scope 1 GHG emission  
% of Scope 1 GHG emissions from regulated emissions trading schemes  
Scope 2 GHG emissions  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
88 040  
73%  
88 040  
80 309  
64%  
-9%  
-12%  
73%  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
Gross location-based Scope 2 GHG emission  
Gross market-based Scope 2 GHG emissions  
Significant Scope 3 GHG emissions  
Total Gross indirect (scope 3 categories)  
1 Purchased goods and services  
8 471  
93 844  
8 471  
93 844  
6 519  
76 926  
-23%  
-18%  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
1 884 872  
1 576 315  
44 517  
19 873  
169 154  
12 264  
1 884 872  
1 576 315  
44 517  
19 873  
169 154  
12 264  
1 499 882  
1 260 583  
28 030  
24 945  
139 905  
13 058  
-20%  
-20%  
-37%  
26%  
-17%  
6%  
2 Capital goods  
3 Fuel and energy-related activities  
4 Upstream transportation and distribution  
9 Downstream transportation and distribution  
10 Processing of products sold (10)  
Total GHG emissions  
62 749  
62 749  
33 361  
-47%  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
n/a  
Total GHG emissions (location-based)  
Total GHG emissions (market-based)  
1 978 898  
2 064 271  
1 978 898  
2 064 271  
1 586 710  
1 657 118  
-20%  
-20%  
Biogenic emissions scope 1  
5 887  
5 887  
11 035  
87%  
GHG intensity per net revenue (tCO₂e/m NOK) 31  
Total GHG emissions (located-based) per net revenue  
Total GHG emissions (market-based) per net revenue  
131,6  
137,3  
131,6  
137,3  
118,0  
123,3  
-10,3%  
-10,2%  
31  
Revenue can be found in note 5  
42  
 
Annual Report 2025  
Scope 3 – emissions from the value chain  
owned or controlled by Pelagia). Information on transport volumes, transport  
methods and estimated distances are analyzed and summarized.  
The most significant emission categories include Category 1 – Purchased goods and  
services and Category 4 – Upstream transportation and distribution. The other  
categories; 10 – Processing of sold products, 2 – Capital goods, 3 – Fuel and energy  
related activities, and 9 – Downstream transportation and distribution each account  
for 1-2% of the scope 3 emissions. For information on data collection, see the “Basis  
for preparation | Accounting policy” section and figure 12 for illustration.  
Category 10 – Processing of sold products: The products we sell are often minimally  
processed. Our food products are mainly canned, cooked or smoked, our feed  
products are used to produce animal and fish feed, and our health products are used  
as ingredients in dietary supplements and pharmaceutical intermediates ingredients.  
Most of the emissions from this category are from the production of food to human  
consumption.  
Category 1 – Purchased goods and services: Upstream emissions of Pelagia’s  
purchased goods and services such as raw materials, packaging materials and  
services. Main part of the emissions in this category is from procurement of marine  
raw materials. Due to the large amount of raw material purchased, even with pelagic  
fish and trimmings having low emissions, this is the largest scope 3 category. 97% of  
the emissions in this category are from purchases of fish and marine products.  
The following categories have been identified as insignificant to Pelagia’s overall  
emissions impact. The size is estimated to be an immaterial contributor to our total  
emissions (<1%), and it does not present as a significant climate-related risk.  
•
•
•
•
•
Category 5 – Waste generated in operations  
Category 6 – Business travel  
Category 7 – Employee commuting  
Category 8 – Upstream leased assets  
Category 13 – Downstream leased assets  
Category 2 – Capital goods: Includes all asset acquisitions activated in the reporting  
year. Most of the emissions are from investing in factories, equipment, vessels and  
other buildings.  
Category 3 – Fuel- and energy-related activities: Covers emissions from fuel and  
energy production used by the company in the reporting year, not included in scope 1  
or scope 2. We have collected data from purchased fuel and energy, and we have  
included transmission and distribution losses.  
Categories 11, 12, 14 and 15 are not included in our report due to it not being  
relevant, more information on why can be found on the pages under “Basis for  
preparation | Accounting policy”.  
Category 4 – Upstream transportation and distribution: Includes estimated emissions  
from transporting and distributing purchased products in the reporting year between  
our suppliers and own operations using third-party vehicles where Pelagia is not main  
cost bearer (in vehicles not owned or controlled by Pelagia). It also covers third-party  
transportation and distribution services bought by Pelagia, such as inbound and  
outbound logistics and movement between our facilities.  
Category 9 – Downstream transportation and distribution: We collect activity data for  
transportation of sold products where Pelagia is not main cost bearer (in vehicles not  
43  
 
Annual Report 2025  
Own Emissions per division  
Scope 3 CO2 emissions in the value chain  
2%  
2%  
1%  
2%  
84%  
9%  
8 %  
24 %  
1 Purchased goods and services  
2 Capital goods  
CO2e  
Food  
Feed  
Health  
Scope 1+2  
(market based)  
3 Fuel and energy-related activities  
4 Upstream transportation  
9 Downstream transportation  
10 Processing of sold products  
68 %  
FIGURE 12: ALL EMISSIONS 2025  
44  
 
Annual Report 2025  
Basis for preparation | Accounting policy  
Pelagia’s scopes 1, 2 and 3 emissions are calculated in  
accordance with the ESRS and are expressed in CO2  
equivalents. 32 They are prepared at a consolidated level  
including subsidiaries, where reporting boundaries and  
operational control are set initially. Calculation tools used are  
Excel and PowerBI.  
methodological choices and by prioritizing future data‑quality  
improvements.  
Scope 3 Category 2 – Capital goods  
Spend method was applied in calculating upstream emissions  
from Pelagia’s fixed assets, using emission factors from DFØ.  
Pelagia works continuously to improve data quality across all  
scopes. Ongoing initiatives include strengthening master data,  
enhancing underlying systems, and developing more  
automated, auditable data flows to support GHG calculations.  
These improvements build on the current methodology, where  
emission factors for scopesꢀ1–3 are selected based on  
geographical availability, methodological consistency and  
reliability, using sources such as DEFRA, AIB, NVE and other  
recognized databases.  
Scope 3 Category 3 – Fuel- and energy-related activities  
Fuel- and energy related activities are calculated based on the  
same data as in scope 1 and 2, with factors capturing the  
upstream emissions and including transmission and  
distribution losses. We have used data from purchased fuel  
and energy as well as calculating transmission and distribution  
losses. This category has been calculated using average-data  
method, based on DEFRA factors.  
GHG Calculation methodology  
Pelagia applies a consistent data‑driven methodology for  
calculating greenhouse gas emissions across scope 1, scope 2  
and scope 3. Activity data is primarily sourced from the ERP  
system, which provides verified purchase information,  
transport information, energy consumption data and other  
operational inputs. For scopes 1 and 2, purchase orders and  
supplier invoices constitute the most accurate and traceable  
basis for fuel and electricity data, with internal controls  
ensuring accuracy and completeness. A limited amount of data  
is handled manually when ERP information is missing or  
inaccurate, supported by clearly defined validation procedures.  
Scope 3 emissions are calculated using Pelagia’s own activity  
data. While certain emission factors are provided by suppliers,  
no supplier‑specific activity or emissions data were used in the  
calculations. Consequently, the share of Scope 3 emissions  
calculated using primary data obtained from suppliers or other  
value‑chain partners is 0ꢀ% for the reporting year.  
Scope 3 Category 4 – Upstream transportation and distribution  
In 2024, Pelagia carried out a comprehensive and highly  
detailed data collection and calculation process for upstream  
transportation and distribution. This included collecting  
information on transported volumes, transportation modes  
and routes, calculating distances, and applying emission  
factors. A distance‑based method was used to ensure accurate  
and transparent quantification, and business rules were  
established and validated by representatives across divisions to  
address any remaining data gaps.  
Scope 3 Category 1 – Purchased goods and services  
Calculated using an average-data method mainly for  
production-related items, and a spend based on services and  
other products. Categorized by purchased products, raw  
materials have been calculated using mostly average-data  
method. Other products have been calculated using spend-  
based method. Obtaining more relevant emission factors and  
primary data for marine raw materials is a focus area, with  
current factors from Sintef (2020). Other sources used are  
Defra (2024) based on volumes and spend, and DFØ (2021)  
based on spend.  
Pelagia conducts a full screening of all Scopeꢀ3 categories to  
identify material emission sources and to prioritize efforts on  
the most relevant areas. Boundaries for Scopeꢀ3 calculations  
cover tier‑one suppliers and tier‑one customers across all  
Pelagia entities. Emission estimates are primarily based on  
ERP‑derived activity data, supplemented by sector averages  
and proxy emission factors where primary data are not yet  
available. Due to limited supplier‑specific information,  
uncertainties are addressed through conservative  
For the 2025 calculations, we applied the activity data  
collected for 2025 and combined it with the emission factors  
derived from the detailed 2024 assessment. As transportation  
patterns and distance mixes are assessed to be largely  
consistent with the previous year, emissions per ton  
transported from 2024 were used to estimate emissions for  
the 2025 volumes. The 2025 calculations include estimated  
32  
Greenhouse Gas Protocol Corporate Standard (GHG Protocol). CO₂e  
include carbon dioxide (CO₂), methane (CH₄) and nitrous oxide (N₂O)  
reflecting their global warming potential.  
45  
 
Annual Report 2025  
emissions from upstream transportation of Pelagia’s purchased  
or sold products between tier‑one suppliers and our own  
operations, as well as between internal facilities.  
transported volume have been applied to the 2025 volumes to  
estimate downstream transportation emissions.  
products are used in finished goods that are ultimately  
consumed.  
Scope 3 Category 10 – Processing of sold products  
Scope 3 Category 13 – Downstream leased assets  
Not calculated due to low relevance to Pelagia (close to 0%  
emissions in base year 2024)  
Downstream processing emissions of Pelagia’s intermediate  
products involves uncertainties. Estimates are based on  
processing profiles identified considering relevance and data  
availability. Estimated with emissions data from major  
customers or representative internal operations, these are  
used as proxies and scaled up to total sold volumes. Emissions  
beyond business customers are not considered.  
Scope 3 Category 5 – Waste generated in operations  
Not calculated due to low relevance to Pelagia (close to 0%  
emissions in base year 2024).  
Scope 3 Category 14 – Franchises  
This category has been excluded from the calculation due to  
Pelagia not having any franchises.  
Scope 3 Category 6 – Business travel  
Not calculated due to low relevance to Pelagia (Less than 1%  
emissions in base year 2024).  
Scope 3 Category 15 – Investments  
Not calculated due to Pelagia not having any investment within  
the scope of this category.  
Categorized based on selected product processing profiles,  
these profiles were estimated based on average-data method  
or on other available data from each case. The processing  
profiles were used as proxies to estimate total emissions. This  
category has high uncertainty but is estimated to only account  
for 1% of total emissions.  
Scope 3 Category 7 – Employee commuting  
Not calculated due to low relevance to Pelagia (Less than 1%  
emissions in base year 2024).  
Biogenic emissions – out of scope emissions  
Pelagia’s biogenic CO₂ emissions from biomass combustion  
totaled 11 035 tCO₂e in own operations, while biogenic  
emissions in the value chain (category 11) are assessed as  
insignificant. In accordance with ESRS E1 and the GHG  
Protocol, biogenic CO₂ is excluded from scope 1 and disclosed  
separately. Other greenhouse gases from biomass combustion,  
including CH₄ and N₂O, are included in scope 1. Scope 1  
emissions of 731 tCO₂e have been calculated using DEFRA’s  
emission factor for ‘Biodiesel ME (from tallow)’, whereas  
biogenic CO₂ emissions from the same fuel are calculated using  
DEFRA’s corresponding “Out of Scope” factor and reported  
under “Biogenic emissions”.  
Scope 3 Category 8 – Upstream leased assets  
Not calculated due to low relevance to Pelagia (close to 0%  
emissions in base year 2024).  
Scope 3 Category 11 – Use of sold products  
Not calculated due to emissions from the use of Pelagia’s  
products are not relevant considering Pelagia’s intermediate  
products are used in finished goods that do not consume  
energy directly and are ultimately consumed.  
Scope 3 Category 9 – Downstream transportation and  
distribution  
Downstream transportation and distribution have been  
calculated using the same methodological framework as  
described for Category 4. Activity data for 2025 has been  
combined with Pelagia’s emission factors derived from the  
detailed 2024 assessment. As distribution patterns are  
considered consistent year‑over‑year, 2024 emissions per  
Scope 3 Category 12 – End-of-life treatment of sold products  
Not calculated due to emissions from the use of Pelagia’s  
products are not relevant considering Pelagia’s intermediate  
46  
 
Annual Report 2025  
ESRS E3 – WATER AND MARINE RESOURCES  
Overfishing in value chain  
Potential negative impact, short term (upstream)  
As a major fish processor reliant on wild-caught fish, marine residual raw material and  
other marine materials, Pelagia depends on sustainably managed oceans. Impacts, risks  
and opportunities related to marine resources were identified through our materiality  
assessment.  
Pelagia’s potential negative impact can reduce the availability of key fish stocks and  
directly affect our ability to secure sufficient raw material for our operations.  
Overfishing is an inherent risk with Pelagia’s business model, given its dependence on  
wild fish stocks whose availability naturally fluctuates and may be reduced if  
harvesting exceeds sustainable levels.  
Material impacts, risks and opportunities and their interaction with strategy  
and business model33  
The primary raw material used in our production is sourced from the North Atlantic.  
In Norway, this is purchased at auctions from sales cooperatives such as the  
Norwegian Sales Organization for Pelagic Fish (Norges Sildesalgslag). All landings are  
incorporated into the official Norwegian fisheries statistics, forming the basis for  
scientific stock assessments and the determination of annual fishing quotas. The  
Directorate of Fisheries provides oversight of wild marine resources.  
Access to marine raw materials  
Risk, short term (own operations and upstream)  
Pelagia’s activities rely on the availability of fish resources in the areas where our  
production facilities are located. Several factors contribute to the risk related to  
accessing marine raw materials, such as changes in fish population, unstable political  
situations, and uncertainties around quotas and regulations.  
In the UK and Ireland, all raw materials, both whole fish and by‑products, are certified  
through MarinTrust. All Pelagia products undergo strict quality control to safeguard  
traceability throughout the value chain as well as health, safety, and quality.  
Pelagia operates facilities across several locations along the coasts of Norway, the  
United Kingdom, Ireland, and Denmark. This broad geographic spread helps ensure  
that we maintain proximity to raw materials even when fish stock migration patterns  
vary, so our factories are strategically distributed to enable us to process all species  
wherever they are available. However, this approach can increase our risk: by  
maintaining several factories, we become more exposed to the possibility of over-  
capacity, as individual facilities may experience lower volumes when raw material  
availability fluctuates.  
Policies 34  
Pelagia’s Responsible Operations Policy addresses the use of water and marine  
resources in our own operations. The policy is also linked to the potential impact of  
overfishing by outlining that we only source marine raw materials from regulated  
fisheries. To support this, we ensure that suppliers follow regulations that prevent  
overfishing and require full traceability back to the geographic catch area, enabling us  
to monitor the origin of our raw materials. In addition, the policy highlights the risk  
associated with long‑term access to raw materials and emphasizes efficient resource  
use and sustainable operations that protect marine ecosystems. By complying with  
Tools to mitigate this risk in the short term include temporary workforce reductions,  
and in more challenging situations, a need to consider scaling down or, in rare cases,  
closing individual facilities. In addition, we continuously work to develop new  
processing methods and expand market opportunities, strengthening our ability to  
manage periods of lower raw material availability.  
33  
34  
SBM-3 Material impacts, risks and opportunities and interaction with strategy and business model  
E3-1 Policies related to water and marine resources  
47  
 
Annual Report 2025  
Actions35  
regulations and operating responsibly, we help secure continued access to these  
resources. The policy further guides how Pelagia should manage its own operations.  
Promote transparency and traceability for marine raw material  
Pelagia procures a significant amount of marine raw materials. We only source from  
approved and regulated channels and have traceability of all raw materials procured  
through mass-balance and internal monitoring systems. The result is a comprehensive  
overview of all our raw materials, ensuring they are sourced from approved suppliers  
and can be traced back through our production process to their origin.  
Responsible Sourcing and Procurement Policy cover the extraction of marine resources  
and outlines our commitment to only source marine resources that comply with  
national regulations and have traceability. The policy addresses the potential impact of  
overfishing in the value chain. It does not explicitly mention the preservation of marine  
resources, but it highlights that we are following national regulations and only purchase  
through proper channels, and as such the policy is promoting responsible procurement  
of marine resources. This is monitored by logging every procurement of raw material  
into approved systems, and suppliers of raw material are checked against internal  
procedures. By requiring quality control, traceability and compliance with regulations  
while promoting sustainable practices and responsible resource management, the  
policy is also connected to the risk of accessing raw materials and how to mitigate this.  
The policy is related to how Pelagia procures and sources goods and services.  
This action helps mitigate the risk of overfishing in our value chain and support the long-  
term sustainability of our business model, which depends on access to adequate marine  
raw materials. The scope of this action is our own operations and suppliers in our value  
chain. This work has been ongoing for several years to ensure traceability for our  
marine raw materials, and we remain committed to continuous improvements.  
Targets36  
Pelagia has not yet set targets related to water and marine resources. We want to  
ensure that the targets we define are relevant, meaningful and realistically aligned with  
our specific circumstances and environmental impact.  
These policies are related to sustainable oceans and seas. They cover our own  
operations and formalize demands from our suppliers. Information relevant for our  
suppliers is made available in our Code of Conduct published on our website.  
The effectiveness of policies is not tracked, nor is the effectiveness of the action related  
to policies. For the action concerning transparency and traceability, we ensure  
effectiveness by procuring only marine raw materials with traceability, ensuring that we  
can trace our raw materials back to their origin.  
35  
36  
E3-2 Actions and resources in relation to water and marine resources policies  
E3-3 Targets related to water and marine resources policies  
48  
 
Annual Report 2025  
ESRS E5 – RESOURCE USE AND CIRCULAR ECONOMY  
Policies38  
Pelagia’s business model and strategy are built on a foundation of circular economy and  
optimal resource use. Our double materiality assessment identified the following  
material impact related to resource use and circular economy.  
Our policy on responsible operations contains information about our commitment to  
using all our raw material in the most sustainable and cost-effective manner possible. A  
key aspect of this policy is optimizing raw materials, thereby supporting the positive  
impact of using residual raw material. The policy objective is to ensure that all parts of  
the fish, including discards and trimmings, are used cost-effectively and sustainably.  
Material impacts, risks and opportunities and their interaction with strategy  
and business model37  
Our responsible asset management policy outlines our commitment to efficient asset  
management. A key aspect of the policy is the incorporation of circularity and optimal  
asset utilization, and it details the waste hierarchy Pelagia is guided by. These aspects  
directly relate to the positive impact of using of residual raw materials, for example  
through reducing waste, optimizing usage, and capturing energy generation from items  
or biomass that cannot be reapplied into other production processes.  
Using residual raw material  
Actual positive impact (own operations and upstream)  
Pelagia’s use of residual raw material that is discarded from the fish farming and  
fish processing industry, decreases dependency on wild caught fish in production  
of fishmeal and oil. This offers a sustainable alternative in raw material sourcing  
and has a positive impact on resource use and circular economy. This also reduces  
the need for wild-caught fish to be used, decreasing the pressure on fish stocks.  
Our responsible sourcing and procurement policy affirms Pelagia’s commitment to  
sustainable and ethical sourcing, as well as our aim to reduce the amount of virgin  
materials and increase the amount of recycled or by-products used in our supply chain  
and sourced products. Sustainable sourcing can be complicated due to misinformation  
and lack of information on how to determine if a purchase is sustainable, but when  
feasible and economically responsible, sustainable products should be chosen.  
Following these principles helps decrease the pressure on fish stocks by promoting the  
use of residual raw material. Examples of sustainable products are products that offer  
traceability, are produced with environmentally responsible practices, use fewer virgin  
resources, meet relevant ethical and environmental standards, or designed for  
circularity and long-lasting performance.  
Pelagia uses both category 3 (cutoffs from processing) and category 2 (sick or dead  
fish, not suitable for use in feed) residual raw material in its production.  
This positive impact is located both upstream and in own operations.  
Upstream – we procure residual raw material from external suppliers to use as a  
raw material in our productions. Own operations – we use all the trimmings and  
discards from our own food production as a raw material in our feed production.  
This positive impact is one of the foundations for our business model and strategy.  
Pelagia aims to utilize all raw material in the most value-adding and sustainable  
way possible, focusing especially on the use of residual raw material from both  
internal and external sources. We are continually working on product innovations  
and increasing efficiency in processing of residual raw material.  
Actions and resources 39  
Pelagia works closely with partners across our upstream and downstream value chain to  
increase circularity. The actions mentioned below are designed to strengthen the  
37  
38  
ESRS 2 SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business  
E5-1 Policies related to resource use and circular economy  
39  
model  
E5-2 Actions and resources related to resource use and circular economy  
49  
 
Annual Report 2025  
circular use of marine resources, covering both our own operations and our broader  
value chain.  
Providing equipment and training for improved handling of residual raw materials  
Pelagia manufactures equipment for proper storage and handling of residual raw  
materials and provides suppliers with training in optimal handling procedures. This  
initiative supports suppliers in improving raw‑material quality and contributes to  
higher‑value cascading applications. Pelagia also incentivizes suppliers economically by  
offering higher prices for better‑quality raw materials. Over time, this collaboration has  
improved both the quality and volume of residual raw materials available for  
processing. We do not report on specific quality targets for this action but work  
continuously to ensure the highest possible quality of the raw materials we purchase, as  
this will increase economic value for both Pelagia and our suppliers.  
The first three actions are significant investments that were financed using the bond.  
Pelagia’s bond aims to provide capital for investments aligned with our strategy. This  
bond is not green or sustainable, nor linked to any specific sustainability objectives or  
targets. More information about the bond can be found in note 4 in the financial  
statement.  
Construction of a new filleting factory in Egersund  
A new mackerel filleting factory was completed in late 2025, enabling more efficient  
processing of landed mackerel and ensuring that all residual raw material generated in  
production is stored and processed for higher‑value uses. The investment is expected to  
increase the volume of residual raw material available for feed production. Effects will  
become clearer after a full mackerel season, although reduced quotas in 2026 may  
delay impact recognition.  
Producing climate‑neutral technical oil for heating  
Pelagia operates two ISCC‑certified plants, in Djupvik (certified 2023) and Bressay,  
Shetland (certified 2024), that convert category 2 raw materials—unsuitable for feed or  
food—into climate‑neutral technical fish oil for use as fuel in Pelagia’s own factories.  
These activities involve collaboration with certified partners across the ISCC value chain  
and follow strict traceability and sustainability requirements. By substituting fossil fuel  
oil with technical fish oil, Pelagia reduces emissions and increases circular resource use.  
Currently the oil is used internally, but future external sales are not excluded.  
Investment in fish‑oil utilization capacity at Ålesund  
In 2024 Pelagia invested in a new production line in Ålesund to increase the efficient  
use of crude fish oil from residual raw material sourced in the North Atlantic. The  
upgraded facility enables quality‑based separation of oil fractions, allowing Pelagia to  
direct the highest‑quality fish oil to human‑consumption applications while lower‑grade  
fractions are used for feed or technical purposes.  
Metrics and targets40  
The targets Pelagia has set in relation to circular economy and resource use are linked  
to the material impact. None of the targets are required by legislation, and neither are  
based on conclusive scientific evidence. Both targets below are on an annual basis.  
2024 is set as base year, which is the year these targets were first used. The target value  
is set at zero recorded cases each year. The methodology used for measurement  
remained the same in 2025 as in 2024. None of the targets are related to sustainable  
sourcing, as the raw materials used in production consist primarily of internally  
generated residual materials. Since these materials are not externally sourced, the  
targets are not related to procurement practices or supplier sustainability but instead  
focus on internal resource efficiency and circular use of residual materials. By-products  
Procurement of companies that utilize residual raw material  
C‑Fish and Ideal Foods in the United Kingdom and Ireland were acquired in 2024. These  
companies utilize residual raw material from salmon processing to produce ingredients  
for human consumption and pet food. Their close cooperation with regional fish  
processors supports Pelagia’s upstream engagement and expands available volumes of  
circular raw materials. Early increases in residual‑material procurement have been  
observed, although the full causal effects will require longer tracking.  
40  
E5-3 Targets related to resource use and circular economy  
50  
 
Annual Report 2025  
from production are applied according to the cascading principle, where edible and  
high-quality fractions are used for food and feed purposes first, followed by industrial  
uses and, lastly, energy production.  
and suitable for use in feed. Downgrading to category 2 occurs when the material can  
no longer be used for higher‑value purposes—such as feed production—because its  
quality or handling does not meet the required standards, limiting its use to lower‑value  
applications such as energy production. This target supports the cascading principle,  
ensuring that resources are used in a way that maximizes economic and environmental  
value across our operations and supply chain.  
In setting the targets, we used input from the double materiality assessment where  
stakeholder input was collected. None of the metrics are assured by other parties than  
auditors. These targets are monitored through our non-conformance system, where  
incidents are reported. The purpose of these targets is to ensure maximal value  
retention of residual raw material and prevent loss of circular potential.  
The increase in recorded incidents from 1 in 2024 to 6 in 2025 reflects the higher  
overall volume of raw material handled as our operations continue to scale. However,  
the volume downgraded per incident has decreased, demonstrating that our control  
routines are steadily improving and are effective at limiting the extent of each event. In  
2025, only 0.1% of the total volume of byproducts received was downgraded due to  
mishandling.  
Recorded cases of residual raw material being discarded in our own food factories  
The white production line (see page 6 for details on the business model) works with  
both wild caught fish not suitable for human consumption and trimmings and discards  
from fish processing. When handling residual raw material, situations can occur where  
the material must be discarded due to low quality or contamination. Such cases are  
logged, and we have a target of zero incidents caused by our own handling. The target  
is linked to increasing the use of circular raw materials by ensuring that all residual raw  
material maintains high enough quality to be used in our feed factories. This reduces  
the risk of the material ending up as waste or biogas due to mishandling or other issues.  
It also ensures that the material is used according to cascading principles. This target  
applies to operations at all our food facilities.  
We continuously update, document, and report all incidents in accordance with  
regulatory requirements for the use of animal byproducts. This ensures appropriate  
follow‑up and implementation of corrective actions aimed at preventing future events.  
The overarching goal is to ensure that residual raw materials remain suitable for use as  
feed ingredients rather than being diverted to energy production, in line with the  
cascading principle and our broader sustainability commitments.  
TABLE 12: TARGETS FOR E5 2025  
Downgrading residual raw material due to mishandling from Pelagia  
Description  
Target  
0
2024  
0
2025  
1
The red production line (see page 6 for details on the business model) handles animal  
byproducts intended for feed production and is therefore particularly sensitive to  
correct handling and temperature control throughout the process. Pelagia strives for  
zero incidents where this raw material must be downgraded from category 3 to  
category 2 due to mishandling. Category 3 consists of animal byproducts that are safe  
Recorded cases of residual raw material being  
discarded in our own food factories  
Incidents of downgrading category 3 residual  
raw material to category 2 due to mishandling  
from Pelagia  
0
1
6
51  
 
Annual Report 2025  
TABLE 13: SUSTAINABLY SOURCED RAW MATERIAL PER DIVISION  
Food  
Feed  
Health  
Total  
2024  
2025  
2024  
2025  
2024  
2025  
2024  
2025  
Total procured in ton  
405 000  
324 000  
862 000  
860 000  
11 000  
10 000  
1 278 000  
1 193 000  
Percentage that is sustainably  
sourced42  
29 %  
33 %  
97 %  
98 %  
100 %  
100 %  
75 %  
80 %  
Resource inflows 4142  
material procured can be found in table 13. We have avoided double counting by only  
using raw material procured from external sources and not internally transferred raw  
material. Internal transfers of residual raw material between Pelagia’s divisions are  
excluded from the inflow metrics to ensure that inflows reflect only new material  
entering the system.  
Resource inflows consist of both procured raw materials (whole fish and by-products)  
and residual raw materials generated through internal processes. Both types are used  
to manufacture finished products. Processing residual raw materials is a central part of  
Pelagia’s business model and an important driver of circular economy. Because the  
share of internally produced residual raw material can be influenced by Pelagia’s own  
operations, this represents a concrete way for us to strengthen circular resource use.  
For this reason, we include internally generated residual raw materials alongside the  
volumes sourced from external suppliers. None of the metrics are assured by other  
parties.  
Pelagia define “sustainably sourced” as raw materials from fisheries that are certified by  
MarinTrust (https://www.marin-trust.com/), Friend of the sea  
(https://friendofthesea.org/) or the Marine Stewardship Council (MSC)  
(https://www.msc.org/), or from fisheries that are part of the fishery in progress (FIP)  
program under either of the certification schemes. Residual raw material is defined as  
sustainable if it is being used according to the cascading principle.  
Procured raw material  
We can distinguish between procured residual raw material and procured whole fish.  
Residual raw material is a by-product from production of other products.  
Processed raw material  
Pelagia processes a significant amount of residual raw material. We have therefore  
chosen to present an entity specific metric of the percentage of residual raw material,  
as seen in Table 14 below. Both our food and feed factories are using residual raw  
material in their production. In 2025 we processed approximately 1.3 mill tons of raw  
material, 43% of this was residual raw material. The residual raw material is either  
Pelagia’s divisions use different raw materials as described under the “Annual report for  
2025”-section where we presented the divisions Food, Feed and Health. Based on the  
double materiality assessment, only raw material categories identified as material are  
included in the inflow metrics. Other procured items did not exceed the materiality  
threshold and therefore fell outside the scope. For 2025, the overall weight of raw  
41  
E5-4 Resource inflows  
42  
Baseline year is updated due to improved data quality; the change is not material and does not reflect a  
modification of methodology  
52  
 
Annual Report 2025  
sourced from external sources or from our own factories. All residual raw material is  
classified as sustainable due to its use according to the cascading principle.  
The table below shows the percentage of residual raw materials used in our factories  
per division compared to other raw materials. Note that this is an overview of the total  
amount processed at all our factories; the proportion of residual versus other raw  
materials varies by factory.  
Division Food purchases whole fish from fishing vessels, and a portion of this volume is  
filleted in our production facilities. The parts of the fish that are not used for human  
consumption are transferred to the Feed division for use as residual raw material.  
When whole fish are sold to external customers, the assessment of how the residual  
raw material is utilized is transferred to the next stage of the value chain. By increasing  
our own level of processing, we can ensure that the entire fish is utilized and that  
residual raw material is handled in accordance with recognized cascading principles.  
The total volume of processed raw material therefore includes both purchased goods  
and materials originating from internal processing. As a result, aggregated data for  
Pelagia would not provide meaningful performance indicators, and we have therefore  
chosen to report figures at the divisional level.  
TABLE 14: PROCESSED RESIDUAL RAW MATERIAL  
Food  
Feed  
2024  
Health  
2024  
2025  
2025  
57%  
2024  
2025  
Percentage of processed raw  
material that is residual raw  
material  
6%  
7%  
53%  
0%  
0%  
53  
 
Annual Report 2025  
The EU Taxonomy is still under development and may expand to cover additional  
activities in future delegated acts. This means that the number of economic activities  
relevant to Pelagia may increase over time.  
EU TAXONOMY REPORT  
Introduction  
As part of the EU’s sustainable finance framework, the EU Taxonomy establishes a  
classification system for environmentally sustainable economic activities to promote  
transparency, comparability and prevent greenwashing. In line with Article 8 of the  
Taxonomy Regulation and the 2026 simplification measures (Omnibus-package), Pelagia  
has applied the materiality principle introduced through Article 2(1a). Under this  
principle, undertakings may omit eligibility and alignment assessments for economic  
activities representing less than 10% of the denominator for turnover, capital  
expenditure (CapEx) or operating expenditure (OpEx).  
This report is prepared in accordance with the EU Taxonomy Regulation (2020/852) and  
its complementary delegated acts, at a consolidated level for Pelagia Holding AS and  
subsidiaries. The underlying financial information is prepared in accordance with IFRS®  
Accounting Standards. Pelagia has reviewed its economic activities against the activities  
defined in the EU Taxonomy to determine which have the potential to be classified as  
taxonomy‑eligible and which additionally meet the technical screening criteria for  
taxonomy alignment.  
For the reporting year, economic activities falling below the 10% threshold for CapEx  
and OpEx were therefore treated as non‑material and are not subject to further  
screening or technical criteria assessment. These activities are included only in the  
denominators of the KPIs and disclosed as non-assessed. The absence of materiality is  
explained by their very limited financial significance relative to Pelagia’s overall  
operations, with the cumulative value of non‑material activities remaining well below  
the 10% limit for each KPI.  
Taxonomy‑eligible and ‑aligned activities are presented as shares of Pelagia’s turnover,  
CapEx and OpEx. Formal definitions of these KPIs follow the regulation and are  
described in the Accompanying Information chapter.  
To be considered environmentally sustainable, an economic activity must (i) make a  
substantial contribution to at least one of the six environmental objectives, (ii) not  
cause significant harm (DNSH) to the remaining objectives, and (iii) comply with the  
Minimum Social Safeguards. The six environmental objectives are:  
1. Reducing and preventing greenhouse gas emissions  
2. Climate change adaptation  
3. Sustainable use and protection of water and marine resources  
4. Transition to circular economy, waste prevention and recycling  
5. Pollution prevention and control  
FIGURE 13: TAXONOMY KPI FOR TURNOVER, CAPEX AND OPEX  
Results of the materiality assessment  
Pelagia’s core activities are currently not covered by the EU Taxonomy, and therefore  
no part of the company’s turnover is taxonomy‑eligible or aligned. All turnover-related  
activities fall below the 10% materiality threshold and are classified as non‑material in  
accordance with Article 2(1a).  
6. Protect and restore biodiversity and ecosystems  
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Annual Report 2025  
For OpEx, one economic activity—acquisition and ownership of buildings—was  
identified as material, contributing more than 10% of taxonomy-relevant OpEx. This  
activity is taxonomy‑eligible but not aligned following assessment against the technical  
screening criteria and DNSH requirements. All other OpEx‑related activities individually  
and collectively remained below 10%, and are therefore treated as non‑material, with  
no further eligibility or alignment assessment required.  
7.7 Acquisition and ownership of buildings  
E L I G I B L E  
Pelagia has economic activities related to the ownership or acquisition of buildings,  
including factories, residential and office buildings.  
While newly commissioned buildings could in principle fall under activity 7.1  
‘Construction of new buildings’, Pelagia reports all building-related CapEx under activity  
7.7 in line with official guidance43, which clarifies that buildings constructed for own use  
shall be reported under 7.7. The substantial contribution criteria of activity 7.1 are  
nevertheless applied to eligible buildings constructed after 30.12.2020.  
For CapEx, the same activity—acquisition and ownership of buildings—was the only one  
exceeding the materiality threshold. While a broader group of potential activities was  
initially considered during the screening, each of these represented less than 10% of  
total CapEx, and their aggregate share also remained below 10%. These activities are  
therefore assessed as non‑material and have not undergone detailed technical review.  
In terms of assessing the substantial contribution criteria, most buildings built before  
30.12.2020 lack an energy performance certificate (EPD) or estimated primary energy  
demand (PED) primarily due to their construction age or the nature of the building, such  
as unheated process buildings. Generally, our buildings lack available documentation to  
assess substantial contribution or DNSH criteria. Therefore, Pelagia’s building activities  
are eligible but not aligned with the requirements.  
Assessment process  
To identify taxonomy‑eligible activities, Pelagia screened its economic activities against  
the list of activities included in the EU Taxonomy for each of the six environmental  
objectives. The materiality principle applied has been for turnover, OpEx and CapEx KPIs  
to determine which activities required eligibility and alignment assessments.  
Climate Risk and Vulnerability Assessment  
For activities identified as eligible and material, further assessments were conducted to  
determine whether they made a substantial contribution to the relevant environmental  
objective and met the DNSH criteria for the remaining objectives. The assessment  
concluded that only one activity contributed to the objective of climate change  
mitigation (CCM). No activities related to climate change adaptation (CCA) were carried  
out during the reporting period, and the objective was therefore not considered  
relevant.  
In line with the do no significant harm (DNSH) requirements for climate change  
adaptation, Pelagia has conducted a high‑level climate risk and vulnerability assessment  
for relevant activities, in accordance with Appendix A to the EU Taxonomy Regulation.  
The assessment identified physical climate risks relevant to coastal facilities. Overall  
vulnerability was assessed as low, and where moderate risks were identified,  
appropriate adaptation measures have been considered.  
Minimum social safeguards  
In accordance with Articles 3 and 18 of the EU Taxonomy Regulation, Pelagia is  
committed to complying with the minimum social safeguards relating to human rights,  
anti‑corruption, taxation and fair competition. These commitments are aligned with the  
43  
FAQ 107 of Commission Notice C/2023/267  
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Annual Report 2025  
OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on  
Business and Human Rights and are embedded in Pelagia’s Code of Conduct and  
relevant governing policies.  
equipment45, and right-of-use assets46 as consolidated in the financial statements for  
Pelagia Holding AS.  
The numerator is identified by reviewing investment transactions related to the  
Taxonomy-eligible or aligned activities and extracting the related investment  
transactions within the reporting period. Specific CapEx initiatives related to Taxonomy  
activities have not been mapped and determined, and as such we do not have a CapEx  
plan specifically related to the EU Taxonomy.  
The commitments apply across Pelagia’s operations and value chain and are supported  
by due diligence procedures for suppliers and customers, including risk assessments  
and whistleblowing arrangements. Based on these commitments and procedures,  
Pelagia is in compliance with the minimum social safeguards for the reporting period.  
OpEx  
Accompanying information  
In the Taxonomy regulation the OpEx KPI is defined as the proportion linked to  
Taxonomy-eligible or aligned activities (numerator) of total operating expenditure  
(denominator) related to:  
Double counting  
Our approach to calculating the KPIs involves assigning each financial transaction to only  
one relevant activity, thereby mitigating the risk of double counting. This approach  
ensures that the financial data accurately reflects the contribution of each activity  
without duplication or overlapping. Moreover, as explained before, the activities do not  
contribute to multiple environmental objectives.  
•
•
•
•
•
Maintenance and repairs (including cleaning) of buildings and vessels  
Building renovation  
IT cost related to maintenance  
Short-term lease47  
Turnover  
Research and development excluding management cost  
No economic activities under turnover covered by the taxonomy were identified;  
therefore, no data has been collected for the numerator. The denominator is the  
amount in note 5 and 21 of the financial statements for Pelagia Holding AS.  
The activities relevant to Pelagia are categorized as building, transport or energy  
related. We have selected operational costs for maintenance, cleaning, research &  
development (R&D) and short-term leasing to calculate the numerator. To determine  
the amounts used for eligible activities, we have collected cost data for maintenance  
and cleaning of buildings, vehicle and vessels, R&D cost for energy projects and short-  
term lease related to buildings and vehicles.  
Turnover related to Pelagia’s internal consumption was considered as part of the  
activity assessment. However, no internal turnover was identified in connection with  
the relevant activities for this reporting period.  
CapEx  
The CapEx KPI is defined as the proportion of total capital expenditure that is associated  
with Taxonomy-eligible, or Taxonomy aligned activities. The denominator comprises  
investment expenditures including additions to intangible assets44, property, plant and  
44  
46  
IAS 38 Intangible assets, note 10 in the financial statement  
IFRS 16 Leases, note 19 in the financial statement  
45  
47  
IAS 16 Property, plant and equipment, IFRS 16 Leases, note 19 in the financial statement  
As defined in IFRS 16  
56  
 
Annual Report 2025  
TABLE 15: SUMMARY KPIS  
2025  
Financial year (N)  
Taxonomy  
aligned  
activities  
in  
Environmental objective of Taxonomy aligned activities  
Proportion  
of Taxonomy  
aligned  
activities in  
previous  
financial  
Not  
assessed  
activities  
Taxonomy Proportion  
Proportion  
of  
Taxonomy  
eligible  
aligned  
KPI  
of  
Proportion Proportion  
previous  
Taxonomy  
of  
of  
considered financial  
(monetary aligned  
enabling  
activities  
(12)  
transitional  
activities  
(13)  
non-  
material  
(14)  
year  
(2024)  
(15)  
Total  
(2)  
value of  
activities (3) CapEx) (4)  
activities  
(5)  
year (2024)  
(16)  
KPI (1)  
mNOK  
%
mNOK  
%
%
%
%
%
%
%
%
%
%
mNOK  
%
Turnover  
CapEx  
OpEx  
13 443  
589  
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10,7  
12,1  
-
-
6,9  
7,7  
33  
2
2,9  
0,3  
585  
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Annual Report 2025  
TABLE 16: TEMPLATE CAPEX AND OPEX  
CapEx  
2025  
Reported KPI  
Financial year (N)  
Environmental objective of Taxonomy aligned activities  
Taxonomy  
eligible KPI  
(Proportion  
of  
Taxonomy  
eligible  
Taxonomy  
Taxonomy aligned KPI  
(Proportion  
of  
(monetary Taxonomy  
Proportion  
of  
Taxonomy  
aligned in  
Taxonomy  
aligned  
KPI  
Enabling  
activity  
(12)  
Code  
(2)  
value of  
CapEx) (4)  
aligned  
CapEx) (5)  
Transitional eligible  
activity (13) (14)  
Economic Activities (1)  
CapEx) (3)  
(E)  
(T)  
%
mNOK  
%
%
%
%
%
%
%
%
Acquisition and ownership of  
buildings  
Sum of alignment per objective  
Total KPI (CapEx)  
7.7  
10,7  
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10,7  
-
-
-
OpEx  
2025  
Reported KPI  
Financial year (N)  
Environmental objective of Taxonomy aligned activities  
Taxonomy  
Taxonomy  
Taxonomy aligned KPI  
(Proportion  
of  
(monetary Taxonomy  
Proportion  
of  
Taxonomy  
aligned in  
Taxonomy  
eligible KPI  
(Proportion  
of  
Taxonomy  
eligible  
aligned  
KPI  
Enabling  
activity  
(12)  
Code  
(2)  
value of  
OpEx) (4)  
aligned  
OpEx) (5)  
Transitional eligible  
activity (13) (14)  
Economic Activities (1)  
OpEx) (3)  
(E)  
(T)  
%
mNOK  
%
%
%
%
%
%
%
%
Acquisition and ownership of  
buildings  
Sum of alignment per objective  
Total KPI (OpEx)  
7.7  
12,1  
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
12,1  
-
-
-
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Annual Report 2025  
APPENDIX – ENVIRONMENTAL INFORMATION  
Compliance is monitored through our whistleblowing  
channels, employee interviews, and well-being surveys.  
Suspected violations and incidents shall be reported to  
management or through our whistleblowing channels.  
Reports will be handled according to our whistleblowing  
routines. Violations provide a basis for disciplinary  
measures, and necessary disciplinary or preventive  
actions must be taken in cases of breach. Reprehensible  
matters must be terminated, and measures be  
implemented.  
the OECD Guidelines. This policy stipulates our  
expectation that business partners conduct due  
diligence in line with the OECD Guidelines and UN  
Guiding Principles. It details expectations we have for  
our business partners related to business conduct,  
including anti-corruption, compliance with laws and  
regulations, fair competition, taxation and no money  
laundering, and related to labor standards, including  
HSE, freedom of association and collective bargaining, no  
forced or child labor, and decent pay and working hours.  
The policy also outlines expectations related to human  
rights, discrimination and equality, privacy and data  
security, whistleblowing, avoiding conflict of interests,  
and climate and environment.  
POLICIES  
Ethical Guidelines  
Our Ethical Guidelines applies to all board members,  
employees and everyone who acts on behalf of Pelagia,  
who shall practice the guidelines in all their activities.  
The purpose of the guidelines is to ensure that our  
behavior is in line with Pelagia’s values.  
The guidelines outline acceptable personal behavior,  
company values, and the obligation to comply with laws  
and regulations. They detail our policy of no  
All employees have easy access to the guidelines  
through our internal systems, and all new employees  
receive the guidelines together with their employment  
agreement. The guidelines are also available for external  
stakeholders at Pelagia.com.  
discrimination and anti-corruption, our focus on a safe  
work environment, and our commitment to respect and  
protect human rights, including our commitment to  
follow the UN Guiding Principles on Business and Human  
Rights and the OECD Guidelines for Multinational  
Enterprises on Responsible Business Conduct. The  
guidelines affirm our commitment to take care of the  
environment and contribute to sustainable  
The sustainability manager and CEO are overall  
responsible for the policy. Suspected violations or  
incidents of the Code by a party in our value chain  
should be reported using the form available on our  
website. Incidents reported either from internal or  
external sources will be handled according to our  
whistleblowing procedure. Violations may result in  
termination of agreements and contracts and/or other  
forms of cooperation. Repeated breaches or lack of  
follow-up are considered breach of contract. Our Code  
of Conduct is distributed to business partners and is  
available at Pelagia.com. Employees also have access  
through our intranet.  
Code of Conduct  
Our Code of Conduct outlines the expectations and  
principles we have for our business partners, including  
but not limited to suppliers, agents, and customers. This  
policy extends our corporate culture expectations to  
these parties to conduct business in an ethical and  
responsible manner. Pelagia requires business partners  
to operate in accordance with these guidelines and  
applicable laws and regulations. In selecting and  
evaluating business partners, acceptance of and  
adherence to our Code of Conduct is a criterion.  
development.  
CAO (Chief Administrative Officer) is responsible for  
implementation, while CEO is overall responsible for the  
policy. Managers are responsible for ensuring that  
activities within their area of responsibility are carried  
out in accordance with the guidelines. When setting the  
policy, consideration was given to the owners,  
represented through the board of directors, as key  
stakeholders’ interests. Owners’ ethical guidelines  
served as a model for our policy.  
The Code is based on UN Global Compact’s ten  
principles, the International Labour Organization, and  
When setting this policy, consideration was given to our  
external stakeholders. In preparing the policy, we went  
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Annual Report 2025  
through various external stakeholders’ own Code of  
Conducts, and we verified our policy content against the  
results from our double materiality assessment and the  
input we got from external stakeholders, to ensure that  
our Code of Conduct was aligned with expectations from  
our stakeholders.  
Human Rights, and the OECD Guidelines for  
Multinational Enterprises on Responsible Business  
Conduct.  
The policy affirms our commitment to comply with  
applicable laws and regulations governing sourcing and  
procurement activities. It further underlines our  
expectations that suppliers and partners adhere to  
ethical conduct, including respect for human rights,  
labor standards and anti-corruption practices, and that  
they confirm this by signing our Code of Conduct. It  
outlines requirements for selecting suppliers, including  
ability to deliver in compliance with our HSE and quality  
requirements, ability to provide information about origin  
of materials and ensure traceability throughout  
production processes, and emphasizes supplier  
inclusion. It details our dedication to minimizing the  
environmental impact of our operations and include  
actions and goals to cover various aspects of our  
resources and operations, and a commitment to  
continuous improvement in our sourcing practices. Our  
suppliers are expected to share this dedication.  
The CFO is responsible for implementing the policy.  
Suspected violations of the policy should be reported  
immediately. Reporting is done to supervisors or through  
our whistleblower channels, and Pelagia does not  
tolerate retaliation against anyone who reports  
misconduct.  
Corporate Due Diligence Policy  
This policy was implemented in 2024 with the purpose of  
affirming our commitment to conduct due diligence to  
identify, prevent, mitigate and account for actual and  
potential adverse impacts related to workers’ and  
human rights, corruption and bribery, taxation, and fair  
competition. The policy applies to all employees, board  
members and everyone who acts on behalf of Pelagia, as  
well as business partners, suppliers and customers, who  
are expected to respect the social safeguards, ethical  
business practices and responsibility to conduct due  
diligence as outlined in the policy.  
The policy is available to all employees through our  
intranet. It is communicated to third parties and shared  
externally as needed. When setting the policy, its  
content was verified against the results from our double  
materiality analysis and the input we got from that  
process to ensure that the policy is aligned with  
stakeholder expectations.  
Responsible Sourcing and Procurement Policy  
The purpose of this policy is to describe how all our  
procurement activities shall be conducted in a  
transparent, fair, and efficient manner. All our  
procurement activities are within the scope of the policy.  
It considers the extraction of resources and outlines our  
commitment to only source resources that comply with  
national regulations and have traceability. The policy  
applies to all employees, contractors, and agents  
engaged in procurement activities on behalf of the  
organization, encompassing acquisition of goods,  
services, and works.  
Sustainability manager is accountable for  
implementation. The policy is available for our  
employees through our intranet and shared externally as  
needed.  
The policy details our commitment to comply with laws  
and regulations and conduct due diligence, our zero  
tolerance towards corruption or bribery, and our  
commitment to comply with tax and competition laws  
and regulations. A reference is made to national and  
European legislation and instruments Pelagia is subject  
to and follows, including Norwegian human rights and  
environmental due diligence legislation, the  
Transparency Act, the European Taxonomy Regulation,  
the Corporate Sustainability Reporting Directive, the  
upcoming Corporate Sustainability Due Diligence  
Directive, the UN Guiding Principles on Business and  
In setting the policy, consideration was given to key  
stakeholders by verifying its content against our double  
materiality assessment and the responses we got during  
the process, to ensure that the policy is aligned with  
stakeholder expectations.  
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Annual Report 2025  
Sustainability manager is accountable for  
operations that benefit the environment, individuals,  
and company alike. The policy also details how we shall  
responsibly, cost-efficiently and sustainably source and  
use resources, water and energy, limit our impact on  
climate and environment, and focus on HSE.  
Responsible Asset Management Policy  
implementation. Policy is monitored through the data  
collected on waste generated and handled on an annual  
basis, reported by each location. Reprehensible  
conditions shall also be reported through our  
whistleblowing system. We used the DMA and responses  
from that process to ensure that the policy was aligned  
with the expectations of stakeholders. The policy is  
available for employees through our intranet and will be  
shared externally as needed.  
Through our Responsible Asset Management Policy, we  
affirm our aim to reduce risks and costs while ensuring  
responsible use, maintenance, and end-of-life  
management of our assets, through incorporating  
circularity and optimal asset utilization. The policy  
applies to the whole organization and outlines principles  
for efficient asset management, to maximize value, align  
with strategic objectives, and support sustainable, cost-  
effective performance.  
The policy applies to all our divisions and facilities,  
considering both our own operations and our value  
chain. Consideration was given to key stakeholders by  
verifying policy content against the DMA process and  
responses we got from stakeholders through this, thus  
ensuring policy alignment with stakeholders’  
expectations. It is approved by the CEO, while the  
sustainability manager is accountable for its  
implementation. The policy is made available to  
employees through our intranet and shared externally as  
needed. Reprehensible conditions shall be reported  
through our whistleblowing system, and we use  
reported cases and employees’ feedback to monitor the  
policy.  
Responsible Operations Policy  
The policy recognizes the importance of identifying  
climate-related hazards and implement adaptation  
measures, before it sets out how we shall use and  
maintain our assets and their end-of-life management. It  
also outlines our waste management principles with five  
step waste hierarchy to help secure that minimum  
amounts of waste are generated and that waste is  
handled correctly. The policy further asserts that all sites  
shall comply with waste management laws and  
regulations and make use of certified contractors for  
waste management services who also provide an annual  
report on the volume collected.  
Our Responsible Operations Policy aims to enhance  
sustainability and minimize environmental impact by  
reducing carbon emissions, promoting resource  
efficiency, and ensuring ethical practices. Across the  
Pelagia group, we are committed to supporting the  
Sustainable Development Goals, and this policy is  
particularly aligned with SDG 5, 8, 12 and 14.  
The policy affirms our commitment to managing our  
facilities and vessels with a focus on responsibility, cost-  
efficiency, and sustainability, and our goal to administer  
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Annual Report 2025  
SOCIAL INFORMATION  
Our employees are our most important resource, along with our raw material.  
Through collaboration, we create results, ensure growth, and increase  
competitiveness. It is important to manage the social impacts, risks and opportunities  
on our own workforce.  
TABLE 17: LIST OF DISCLOSURE REQUIREMENTS  
Page reference  
List of disclosure requirements  
S1 Own workforce  
63  
63  
SBM – 3  
Material impacts, risks and opportunities and their interaction with  
strategy and business model  
S1 – 1  
S1 – 2  
Policies related to own workforce  
Processes for engaging with own workforce and workers’  
representatives about impacts  
64  
65  
S1 – 3  
Processes to remediate negative impacts and channels for own  
workforce to raise concerns  
Taking action on material impacts on own workforce, and  
approaches to managing material risks and pursuing material  
opportunities related to own workforce, and effectiveness of those  
actions  
65, 66  
66  
S1 – 4  
S1 – 5  
Targets related to managing material negative impacts, advancing  
positive impacts, and managing material risks and opportunities  
Characteristics of the undertaking’s employees  
Health and safety metrics  
67  
S1 – 6  
S1 – 14  
Appendix  
68  
69  
70  
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Annual Report 2025  
Employees that need special consideration will be handled individually, and we will  
adapt and facilitate as much as possible to the individual situation.  
ESRS S1 – OWN WORKFORCE  
Our approach  
Human rights and a safe, secure work environment are fundamental to ensure  
dignity, freedom, and respect throughout our operations, partnerships, and  
communities we interact with.  
Health and safety  
Potential negative impact, short term (own operations)  
Our business depends on our dedicated employees, enabling us to meet customer  
demands and maintain operational efficiency. We are committed to providing all  
employees with safe and healthy working conditions, aiming for zero workplace  
accidents.  
Health and safety pose a potential negative impact on own workforce due to a lot  
of Pelagia’s operations being conducted in facilities where there are chemicals,  
equipment and machinery that can cause harm to employees. It is particularly  
employees working in production facilities that may be at greater risk of harm due  
to the type of activities they take part in.  
Pelagia consists of companies and facilities in multiple countries. We continually strive  
to ensure that every employee has a safe place to work. Our operations involve  
processing raw materials upon arrival at our facilities, leading to variable workloads—  
intense during peak periods and lighter at other times.  
The understanding that certain segments of our workforce may be at greater risk  
of harm due to the nature of their work is based on reported cases throughout the  
years.  
Our facilities are in countries with regulated work environments that protect  
employees’ rights. Pelagia ensures a safe workplace, where employee representatives  
are included in the board of directors and participates in decision-making regarding  
strategy and business model and how potential changes can affect employees.  
This potential impact is caused by the need for manufacturing goods using  
machinery and human labor. The potential of employees getting harmed while at  
work is unfortunately a part of the business model of industrial production, and  
Pelagia is working systematically to reduce the potential of this negative impact.  
Material impacts, risks and opportunities and their interactions with  
strategy and business model48  
Our materiality assessment identified one potential negative impact related to own  
workforce – namely health and safety.  
Description of types of employees and non-employees  
We categorize our employees into six different groups, consisting of all those  
employed by companies in Pelagia Holding AS. These are all parts of the material  
topics in this section.  
Other than those employees who may be at greater risk of negative impacts relating  
to health and safety due to the nature of their work and work environment, we have  
not identified particularly vulnerable groups of employees in our workforce.  
48  
SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model  
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TABLE 18: CATEGORIES OF EMPLOYEES  
These policies inform everyone about acceptable behavior and provide guidelines on  
how to act safely and ethically at work. Detailed information about the Ethical  
Guidelines can be found in “Appendix – environmental information”, and for the HSE-  
policy in “Appendix – social information”. All employees are covered by a  
management system that ensures that governing documentation is made available,  
and workplace accidents are recorded.  
Category Description  
A
B
C
D
E
Senior management  
Professionals and managers  
Administrative workers  
Production workers  
Human rights  
Our commitment to respect and safeguard human rights and labor rights for own  
workforce is detailed in our Ethical Guidelines. Pelagia follows the UN Guiding  
Principles on Business and Human Rights and the OECD Guidelines for Multinational  
Enterprises on Responsible Business Conduct, and we carry out due diligence  
assessments according to these instruments to map and assess the risk of violations  
of human rights and labor rights. By following these instruments, our human rights  
commitment is aligned with these and other international instruments, including the  
International Bill of Human Rights and the ILO Declaration on Fundamental Principles  
and Rights at Work.  
Seasonal and on-call workers  
Workers at sea  
S
It occurs that we have non-employees for shorter or longer assignments. We divide  
non-employees into two groups: those who are physically present at our locations,  
and those who are located at their employers’ site of work. The former group of non-  
employees are subject to material impacts by Pelagia’s operations, while the latter  
group is not.  
Policies related to own workforce49  
Pelagia’s Ethical Guidelines and HSE policies address and are related to the potential  
negative impact regarding health and safety of own workforce.  
Compliance is monitored through reported cases, employee interviews, and well-  
being surveys. Employees are encouraged to report suspected violations through our  
whistleblowing channel. This system is described in the governance section under  
“Whistleblower system”, which details the process to identify and investigate  
potential violations, as well as actions in case of breach. Remedy will depend on and  
be tailored to the specific case. As we have had no identified cases of human rights  
abuse, we have not tested these routines particularly for human rights violations.  
To ensure workplace safety and to manage the potential negative impact, we have  
strict HSE-policies in place. Our Ethical Guidelines also details behavior that is in  
accordance with Pelagia’s values, including how we shall have a continuous focus on  
ensuring a safe and injury-free workplace. Both policies cover the entire group, with  
additional specific HSE procedures for each division and department. Pelagia  
prioritizes a safe environment for everyone, and these policies are crucial to achieve  
that.  
Pelagia engages with own employees on an ongoing basis through various channels,  
as further elaborated below.  
49  
S1-1 Policies related to own workforce  
64  
 
Annual Report 2025  
Engagement with own workforce and employees’ representatives50  
Employees are represented by the Pelagia Board of Directors, both as board members  
and observers. Employee representatives have two seats on the group’s board, and  
board meetings are held three times a year. All employees in Norway have the  
possibility to be elected.  
We carry out annual individual employee interviews as well as an annual well-being  
survey. Both non-employees and others have the same opportunity to whistleblow as  
employees, an important positive measure for both employees and non-employees.  
The whistleblower system is described in detail under the governance information  
chapter.  
Engagement related to materiality assessment and topics  
Pelagia has a joint company, work environment and pension committee, known as  
BAMPU. The committee consists of management representatives, employee  
representatives, safety representatives, and a representative from the occupational  
health service. The committee’s primary role is to fulfill Pelagia’s HSE objectives and  
statutory tasks, ensuring a safe and healthy work environment for all employees.  
BAMPU has quarterly meetings where health and safety issues and other company  
matters are discussed. The committee handles matters that concern the whole  
organization, and outcomes apply to and should be implemented at all departments  
and facilities in the group.  
The assessment of material impacts, risks and opportunities were discussed with  
workers’ representatives as well as representatives within divisions and departments.  
These representatives were involved with input during the process, after the  
preliminary results were ready, and before the materiality assessment was finalized.  
The engagement was facilitated with meetings and dialogue directly with workers’  
representatives, as part of the meetings with BAMPU. BAMPU meetings occur every  
quarter and sustainability and HSE matters are always part of the agenda.  
CEO holds the operational responsibility for ensuring that engagement with own  
workforce takes place and that the insights gathered inform the company’s decisions  
and overall approach to managing the potential negative health and safety impact on  
employees. It has not been identified particularly vulnerable groups within the  
company, and therefore no extra effort to communicate with such groups has been  
implemented.  
Each of Pelagia’s departments also have their own working environment committee,  
known as AMU. These committees consist of management representatives, elected  
representatives and safety delegates. AMU committees have regular meetings to  
discuss topics that concern the working environment in each department, including  
HSE matters. In addition, each facility has an HSE committee that handles cases as  
they happen and takes care of the needs the individual facility and its employees have  
in terms of training and similar. Cases arising at the facility-level can be lifted to  
BAMPU for organization-wide handling.  
Channels for own workforce to raise concerns51  
Pelagia has a whistleblowing channel where all employees and non-employees can  
register complaints or raise concerns. The channel is made available for all employees  
through our intranet, our webpage and distributed at our facilities. It has been  
implemented by Pelagia, and responses are stored and handled internally. It is  
intended to be used both for employee matters and other grievances. Our  
commitment to protect against retaliation for individuals that use the whistleblowing  
Employees can provide input before decisions are made, and this feedback is  
discussed prior to finalizing any decision. How employees are informed about the way  
in which their feedback has influenced decisions will be tailored to each specific case,  
depending on the matter. This may include town hall meetings, through employee  
representatives, information screens, or digitally via Teams, Intranet or e-mail.  
50  
51  
S1-2 Processes for engaging with own workforce and workers' representatives about impacts  
S1-3 Processes to remediate negative impacts and channels for own workers to raise concerns  
65  
 
Annual Report 2025  
system is outlined in our whistleblowing routines. This commitment is explained in the  
governance section, along with a detailed description of the whistleblowing system.  
how to handle a specific negative impact will be identified, formalized and  
implemented across the company for each specific case as they arise.  
Effectiveness and trust in these channels are evaluated e.g., through our annual  
employee well-being survey and based on cases reported.  
Health and safety  
Due to the nature of our operations, health and safety poses a potential negative  
impact on own workforce. We have implemented strict HSE policies and procedures  
that shall help prevent negative impacts from occurring and mitigate the risk of such  
impacts. The scope of health and safety actions is the whole group, all activities and  
locations, and all employees, including non-employees who are physically present at  
our locations. Additionally, we have specific procedures for each division, adapted to  
each division’s specific operations.  
Actions52  
Pelagia has action plans on HSE and for the various departments. We do not have  
resources specifically allocated to managing material impacts. If resources are  
needed, this is discussed and allocated for each individual case, adjusted to the nature  
and needs of the case in question.  
Based on information from employees and the double materiality assessment, as well  
as general dialogue with workers’ representatives, any negative impacts will be  
identified and handled.  
Our focus on health and safety is a continuous and ongoing commitment, to ensure a  
safe work environment for our workforce and to achieve our goal of zero accidents,  
losses or injuries to people, materials and the environment. Since Pelagia has  
production facilities where dangerous situations occur due to machinery, equipment  
and people, there will always be a need for further improvement and facilitation.  
Health and safety work will therefore never be completed and there are no end dates  
to these actions, but we do set targets on a year-to-year basis.  
Processes to remediate negative impacts and channels for own workforce to raise  
concerns  
We have several channels where our own workforce can raise concerns. All our  
employees have access to our whistleblower system and are encouraged and  
regularly reminded to report reprehensible conditions. Whistleblower routines,  
including processes for handling, are described in detail under the governance  
information chapter.  
Key health and safety actions in 2025 included:  
•
•
Production managers conducted HSE training  
Training courses for managers regarding follow-up of employees on sick  
leave  
We also conduct well-being surveys amongst all our employees and strive to offer  
individual employee interviews at least once a year. During this, there is an  
opportunity for dialogue between the employee and its immediate manager.  
•
•
Worked on establishing one common system for occupational health service  
to ensure aligned focus across divisions and departments. The  
implementation process continues in 2026  
An HSE information campaign regarding personal protective equipment was  
carried out  
Health and safety were identified as a potential negative impact, and how we handle  
this impact is described below. As no other actual negative impacts were identified,  
we have not yet tested how we can remediate impacts. If additional negative impacts  
are identified, we have routines for reporting and handling of reports. The process for  
52  
S1-4 Taking action on material impacts on own workforce  
66  
 
Annual Report 2025  
For 2025, we had a target for sick leave to be less than 3,5%, and HSE to have zero  
incidents but many recorded safety observations, deviations and risks. Sick leave is  
calculated based on total working hours, including vacation days. Incidents are  
measured by number of first aid injuries, medical treatment injuries, lost-time injuries,  
regulatory violations from authorities, environmental spills/impacts, fire incidents,  
and complaints. The base year for these targets is 2024, and none of the metrics are  
assured by other parties.  
•
Worked on establishing a learning platform that provides employees with  
access to various courses. The implementation process continues in 2026.  
On the organizational level, BAMPU identifies actions and tracks and assesses  
effectiveness of these in delivering outcomes. When a negative impact occurs, we  
have routines that we follow. First, it is to help the employee(s), then report to  
government authorities. The appropriate authority to report to depends on the  
severity of the impact. A deviation report is filed, and the incident is discussed both  
locally in AMU and centrally in BAMPU to identify appropriate actions. Other potential  
negative impacts will also be discussed here, and potential changes will be  
implemented in other relevant parts of the organization. Where an incident repeats  
itself, specific actions are implemented with the expected outcome to hinder the  
incident from occurring. The effect of implemented actions is monitored by the  
decrease in the occurrence of the incident.  
These targets relate to our approach to HSE and reducing sick leave: we work  
systematically to be ahead of risks by addressing root causes through monitoring,  
observation and reporting. We want employees to report deviations and  
observations, and we systematically record the HSE-related work we do, which is  
reviewed in departments and divisions.  
In an industry company like Pelagia with many processing facilities relying on people,  
machinery and heavy equipment, it is difficult to achieve the target of zero incidents.  
Nevertheless, we still strive to achieve this target and continuously improve health  
and safety. The targets are a constant reminder that we need to strive to ensure every  
employee is safe at work and that Pelagia as a company do what we can to prevent  
both injuries and sick leave as far as we can possibly do.  
In all countries where we have facilities, there are strict national routines for handling  
HSE-related negative impacts. We act according to national laws and regulations to  
provide or enable remedy for negative impacts.  
Targets53  
We identified health and safety as our only potential negative impact on own  
workforce. Targets for HSE are set in BAMPU and apply to the entire company.  
Through BAMPU, HSE-targets are set in collaboration between management and  
representatives for safety and employees. BAMPU also tracks HSE-performance and  
implement actions. HSE targets are set on a yearly basis, and progress is measured  
from year to year. The scope of targets is the whole group, including own employees,  
non-employees physically present at our locations, own activities and locations.  
Additionally, each division and each facility have their own targets specific to their  
operations and workforce, with their own procedures for handling the targets.  
TABLE 19: TARGET FOR S1 2025  
Description  
Sick leave  
Target  
<3,5%  
0
2024  
3,7%  
129  
2025  
4,22%  
129  
HSE incidents  
53 S1-5 Targets related to managing impacts, advancing positive impacts, as well as to risks and  
opportunities  
67  
 
Annual Report 2025  
Characteristics of Pelagia employees54  
TABLE 20: EMPLOYEES PER GENDER  
TABLE 22: FTE PER REPORTING PERIOD  
55  
Reporting period (FTE)  
Gender  
Number of employees (head count)  
Female  
Male  
Total  
2024  
1266  
557  
0
2025  
1245  
523  
0
2024  
292  
106  
8
2025  
283  
162  
5
2024  
Number of employees  
868 869  
Number of permanent employees  
652 664  
Number of temporary employees  
46 34  
2025  
2024  
1160  
758  
54  
2025  
1152  
826  
39  
Male  
Female  
Not reported  
Total employees  
1822  
1768  
55  
TABLE 21: EMPLOYEES PER COUNTRY  
Country  
Number of employees (head count)  
Number of non-guaranteed hours employees  
116 169 171 346  
2024  
1524  
216  
57  
2025  
1482  
209  
56  
178  
287  
Norway  
United Kingdom  
Ireland  
The data was collected by counting all employees throughout the reporting period  
from January to December. Some employees were then subtracted for reasons such  
as too few hours, getting a more realistic number of employees. FTE differs between  
the countries. To ensure consistency, we have based FTE calculations on 1750 annual  
working hours. Non-guaranteed hours employees include seasonal employees. No  
employees registered as “other”. None of the metrics regarding employees or health  
and safety are assured by other parties.  
Denmark  
Ukraine  
21  
18  
2
2
Iceland  
1
1
Pelagia’s Food division is highly seasonal and relies on seasonal workers due to  
seasonal fluctuations in the access of raw materials. For example, best access to raw  
materials from pelagic fish is during the autumn and winter months. The prime catch  
period for mackerel is between September and November, while blue whiting is  
mainly caught between February and April. Geographical catch areas also fluctuate  
54  
55  
S1-6 Characteristics of the Undertaking’s Employees  
For the most representative numbers in the financial statements, see note 6  
68  
 
Annual Report 2025  
for each raw material, resulting in peak periods at different times of the year for each  
of our facilities. By contrast, the Feed and Health divisions are highly automated, with  
production running 24/7 year-round. These divisions therefore require employees to  
work shifts throughout the year.  
During the reporting period, 65 employees left Pelagia, which constitutes a 6,63%  
turnover rate. The rate is calculated by dividing employees that left Pelagia in 2025 on  
the total number of employees, measured by head count. Seasonal workers are  
excluded from employee turnover.  
Health and safety metrics56  
TABLE 23: HEALTH AND SAFETY METRICS  
Health and safety metrics  
Percentage of people in own workforce covered by HSE  
management system  
2024  
100%  
2025  
100%  
Number of fatalities in own workforce as a result of work-  
related injuries and work-related ill-health  
0
0
0
0
Number of fatalities for other workers working on our sites as  
a result of work-related injuries and work-related ill-health  
Recordable work-related accidents  
51  
25  
0
42  
21  
0
Rate of work-related accidents per one million hours worked  
Recordable work-related ill-health  
Days lost to work-related injuries from work-related  
accidents, work-related ill-health and fatalities from ill-health  
369  
860  
56  
S1-14 Health and safety metrics  
69  
 
Annual Report 2025  
APPENDIX – SOCIAL INFORMATION  
Our operations shall be in accordance with applicable  
safety regulatory requirements, with a goal of zero  
accidents, losses or injuries to people, materials, and  
the environment. The policy outlines how we, through  
our awareness of HSE, shall ensure the best possible  
protection of people’s lives and health, as well as  
facilities and environment.  
available for all employees through our intranet and  
quality management system.  
POLICIES  
HSE Policy  
Health, safety and the environment is an integrated  
mindset for us working in Pelagia, and we are  
committed to ensuring that our workplace and  
operations are safe and create safe products, with the  
least possible impact on the environment. We have a  
general HSE policy, and each division and department  
have additional specific procedures in place. The  
scope of the HSE policy is the entire company,  
including all our own employees, activities and  
locations, and non-employees physically present at  
our locations.  
Compliance is monitored through whistleblowing  
channels, employee well-being surveys, and employee  
interviews. Suspected violations and incidents shall be  
reported to management or through our  
whistleblowing channels and will be handled  
according to our whistleblowing routines.  
When setting the policy, consideration was given to  
employees and affected communities as key  
stakeholders. The team of HSEQ managers are  
responsible for implementing the HSE policy, while  
the CEO is overall responsible for it. The policies are  
70  
 
Annual Report 2025  
GOVERNANCE INFORMATION  
At Pelagia, we are committed to conduct business with integrity across all our  
operations, ensuring compliance with laws and regulations in every country where we  
operate.  
TABLE 24: LIST OF DISCLOSURE REQUIREMENTS  
Page reference  
List of disclosure requirements  
G1 Business conduct  
SBM – 3  
Material impacts, risks and opportunities and their interactions  
with strategy and business model  
72  
G1 – 1  
G1 – 3  
G1 – 4  
Business conduct policies and corporate culture  
Prevention and detection of corruption and bribery  
Incidents of corruption or bribery  
72  
73  
74  
71  
 
Annual Report 2025  
Our ethical guidelines provide guidance to all employees on acceptable behavior in  
line with our values, which includes never accepting any bribes or other illegal or  
inappropriate gifts, allowances or benefits. Our policy on corporate due diligence  
underlines our commitment to human rights, anti-corruption, taxation, fair  
competition and conducting due diligence assessments. Our Code of Conduct extends  
our corporate culture expectations to third parties. The Code of Conduct and  
Corporate Due Diligence Policy are related to the potential impact of corruption and  
bribery in the value chain. See “Appendix – environmental information” for detailed  
descriptions of all three policies.  
ESRS G1 – BUSINESS CONDUCT  
Material impacts, risks and opportunities and their interactions with  
strategy and business model 57  
Our materiality assessment identified one potential negative impact related to  
business conduct, namely corruption and bribery in the value chain.  
Corruption and bribery in the value chain  
Potential negative impact (downstream)  
New employees are required to confirm their acknowledgment of the ethical  
guidelines, and Pelagia continuously promotes corporate culture through internal  
communication systems such as publishing stories on the intranet, townhall meetings,  
teams’ channels and frequent stories and reminders on information screens at the  
various facilities.  
Pelagia has numerous customers across various countries. A large portion of these  
operate in high-risk regions, referring to countries where there is a higher risk of  
corruption or bribery occurring. It is therefore a substantial risk of challenging  
business relations and potential negative impacts occurring in our downstream  
value chain, including financial crimes like corruption, bribery and money  
laundering, that can negatively affect people and communities.  
To evaluate corporate culture, Pelagia conducts an annual employee survey, which  
addresses topics such as job satisfaction and motivation, well-being, cooperation and  
communication, discrimination and harassment, and whistleblowing. There is also an  
opportunity for dialogue during each employee’s annual interviews. In addition,  
confidential exit interviews with HR are encouraged for both permanent and seasonal  
employees, to enable feedback. These measures offer valuable insights to help  
improve the workplace and corporate culture.  
As part of our due diligence process, we conduct risk assessments for all our  
suppliers and customers. This risk assessment covers several topics, one of these  
being corruption and bribery. We have included internationally recognized  
corruption indexes, such as Transparency International’s Corruption Perceptions  
Index, to assess the risk of corruption in relation to our customers and suppliers.  
According to this index, many of our customers operate in countries across the  
world where there is a higher risk of corruption and bribery. It is primarily our  
Food-division that sell to such markets.  
If a business conduct incident were to occur, Pelagia has routines to investigate and  
follow up cases depending on their nature and whether they involve employees or  
external stakeholders. External cases are typically managed with the involvement of  
relevant business partners to ensure objective and independent handling.  
Business conduct policies and corporate culture 58  
In Pelagia we have three main policies that provide guidelines to ensure that behavior  
is in accordance with our values, both across the organization and in our value chain.  
Pelagia does not have a specific policy for training in business conduct matters, but  
employees are required to complete annual training in our ethical guidelines that  
57  
58  
SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model  
G1-1 Business conduct policies and corporate culture  
72  
 
Annual Report 2025  
covers various matters related to ethical behavior and business conduct. Functions  
that handle financial transactions and maintain direct customer or supplier  
interactions – such as procurement, sales and logistics – are considered the functions  
most at risk of corruption and bribery.  
relevant immediate manager then follows up and is responsible for investigating the  
notification. If the immediate manager is disqualified, the senior manager or HR will  
follow up and investigate. HR supports during the process.  
The investigation will vary depending on the matter and seriousness of the case, but it  
could include individual conversations with parties and witnesses, and technical  
investigations such as review of documents. HR and finance will assist in serious  
matters. An external party may also be involved in the investigation. Allegations  
involving employees will first be assessed whether they are real, and if so, the person  
who has received a notice against him/herself will have the opportunity to defend  
him/herself.  
Whistleblower system  
At Pelagia, employees are encouraged and reminded to report reprehensible  
conditions, including misconduct regarding company rules and guidelines. In the  
annual training covering our ethical guidelines, employees are trained in what  
constitutes reprehensible conditions, that unethical conduct shall be reported and  
how it should be reported. Employees have easy access to our whistleblowing system  
and access codes are made accessible at our facilities and through our intranet.  
External parties can alert Pelagia using the contact form on Pelagia.com.  
If a reprehensible condition is found, the condition must be terminated, measures be  
taken to restore a fully safe working environment, and the effect of measures  
followed up to ensure lasting improvement. We do not have a defined threshold for  
when matters are reported upwards, but serious matters will be reported to company  
management.  
Pelagia is committed to ensure confidentiality and avoid any retaliation. The identity  
of the whistleblower shall not be known to more than what is necessary for  
appropriate processing of the case, and whistleblowers shall be protected against  
retaliation in accordance with the Norwegian Working Environment Act §2 A-4. The  
manager has the main responsibility to ensure that the whistleblower does not  
experience any retaliation. The whistleblower system also offers the option to report  
anonymously.  
Prevention and detection of corruption and bribery 59  
Pelagia’s commitment to respect social safeguards and ethical business practices is  
underlined in our Ethical Guidelines, Corporate Due Diligence Policy, and Code of  
Conduct. Together, these policies cover and emphasize a zero tolerance for  
corruption and bribery in our own operations and in our value chain.  
Notifications are taken seriously and examined thoroughly regardless of the form it  
was submitted. In compliance with national whistleblowing laws, such as the  
Norwegian Working Environment Act §2 A-6, we have established internal procedures  
to ensure that allegations are properly investigated.  
With a significant number of customers in countries where there is an increased risk  
of financial crimes such as corruption and bribery, it is important for Pelagia to  
recognize and mitigate the potential negative impact that incidents of corruption and  
bribery can have. To prevent corruption and bribery in our value chain, training and  
systematic work against corruption is carried out.  
Cases and allegations are collected and handled using the same process. First HR is  
alerted that a complaint, case or allegation have been submitted and conduct  
preliminary investigations. We have two resources from HR that receive reports, who  
both have formal human resources training, including training in confidentiality. The  
59  
G1-3 Prevention and detection of corruption and bribery  
73  
 
Annual Report 2025  
To comply with our commitment and ensure that we identify, prevent and address  
potential matters of corruption and bribery, Pelagia has procedures for conducting  
due diligence on third parties including customers, suppliers and business partners.  
These procedures support employees to adequately perform due diligence  
assessments proportionate to the related risk, which include geographical  
considerations related to sanctions, anti-corruption, anti-money laundering, and  
human rights conditions.  
Corruption and bribery should be alerted using the whistleblowing system. Reports  
are followed up and handled according to the whistleblowing procedure described  
above. The whistleblowing system handles allegations and cases both in Pelagia and  
the value chain.  
The Transparency Act in Norway formalizes the need to report on the work Pelagia is  
doing in accordance with the OECD Guidelines. Pelagia has implemented the same  
measures in relation to our customers, to ensure that we are actively handling  
potential negative impacts. Annual reports in accordance with the Transparency Act  
are published on Pelagia.com.  
Certain functions in Pelagia such as procurement, sales and logistics, face higher risks  
of corruption and bribery due to handling financial transactions and interacting with  
external stakeholders. Training and onboarding are managed by relevant managers,  
as specific issues vary by role.  
Metrics and targets 60  
For 2025, we have set no other targets than having zero incidents of corruption and  
bribery. None of the metrics are assured by other parties.  
We conduct annual training in our ethical guidelines for employees, which also cover  
corruption and bribery. In 2025, this training process was further developed and  
formalized, and it is now required that employees complete this training. The training  
covers 100% of our functions at risk. Company management is part of setting and  
revising our ethical guidelines and are also covered by this training program.  
Incidents of corruption or bribery  
There were no identified incidents of corruption or bribery in 2025, nor were there  
any convictions or fines for violations of anti-corruption or anti-bribery laws. No  
actions have therefore been taken to address breaches of standards or procedures.  
60  
G1-4 Incidents of corruption or bribery  
74  
 
Annual Report 2025  
Karoline Bjoland  
Board member  
Endre Sekse  
Board member  
Mꢀꢁꢂ  
·
Britt Kathrine Drivenes  
Board member  
Board member  
76  
 
Annual Report 2025  
STATEMENT FROM THE BOARD OF  
DIRECTORS AND CEO  
We declare, to the best of our knowledge, that the annual accounts for the period from January 1 to December  
31, 2025, have been prepared in accordance with applicable accounting standards, and that the information in  
the accounts provides a true and fair view of the assets, liabilities, financial position, and overall results of the  
company and the group. We also declare that the annual report provides a true and fair overview of the  
development, results, and position of the company and the group, along with a description of the most  
significant risks and uncertainties facing the company and the group.  
We confirm that to the best of our knowledge that the 2025 sustainability statement has been prepared in  
accordance to and meets the information requirements of the Norwegian Accounting Act, the European  
Sustainability Reporting Standard (ESRS) and the EU Taxonomy (Article 8 of EU Regulation 2020/852).  
Bergen, 29 April, 2026  
Endre Sekse  
Board member  
Karoline Bjoland  
Board member  
Britt Kathrine Drivenes  
Board member  
77  
 
PELAGIA HOLDING AS  
FINANCIAL STATEMENTS 2025  
GROUP ACCOUNTS  
 
Pelagia Holding AS  
CONSOLIDATED INCOME STATEMENT  
Amounts in NOK 1.000 (period 01.01. - 31.12.)  
Sales revenue  
Note  
2025  
2024  
2, 5, 21  
13 443 849
14 943 346
Change in inventories of finished goods  
Raw materials and consumables used  
Salaries and personell expenses  
Depreciation and amortisation  
Other operating expenses  
12  
21  
6
8, 9  
6, 7  
757 262
9 832 071
1 107 225
497 354
302 660
11 295 863
1 086 453
430 643
900 742
950 406
Operating profit  
349 194
877 321
Finance income  
Finance costs  
Net finance  
18  
18  
2
-
367 854
-367 854
-
313 218
-313 218
Profit before taxes  
Income tax expense  
Net profit  
-18 660
-30 299
11 639
564 104
113 017
451 087
17  
Profit is attributable to:  
Owners of Pelagia Holding AS  
Non-controlling interests  
Total  
-4 571
16 210
11 639
424 632
26 456
451 087
CONSOLIDATED STATEMENT OF COMPREHENSIVE INCOME  
Amounts in NOK 1.000 (period 01.01. - 31.12.)  
Profit for the period  
Note  
2025  
2024  
11 639
451 087
Other comprehensive income to be reclassified to profit or loss in subsequent periods  
Currency translation differences  
Hedging reserves, cash flow hedges  
Tax expense/(revenue)  
-22 278
93 239
4 082
898
4
4
-
-
Total other comprehensive income for the period, net of tax  
-22 278
96 422
Total comprehensive income for the period  
-10 639
547 509
Total comprehensive income for the period is attributable to  
Owners of Pelagia Holding AS  
Non-controlling interests  
Total  
-23 219
12 580
-10 639
522 514
24 996
547 509
 
Pelagia Holding AS  
CONSOLIDATED BALANCE SHEET PER 31.12  
Amounts in NOK 1.000  
Note  
2025  
2024  
Assets  
Non-current assets  
Other intangible assets  
Goodwill  
8, 10  
8, 10  
88 164
1 303 176
1 391 339
98 361
1 317 039
1 415 399
Total intangible assets  
Land, buildings and other real property  
Plant and equipment  
Ships  
Right-of-use leased assets  
Total property, plant and equipment  
9, 10, 20  
9, 10, 20  
9, 10, 20  
9, 19  
1 568 688
2 311 702
544 105
143 761
4 568 256
1 428 900
2 475 335
557 907
105 499
4 567 642
Investments in other shares  
Other receivables  
26 805
1 500
24 669
1 500
13  
Total financial assets  
28 305
26 169
Total non-current assets  
5 987 901
6 009 210
Current assets  
Inventories  
12, 20  
4 661 385
3 904 123
Trade receivables  
Derivatives  
Other current receivables  
Cash and cash equivalents  
4, 13, 20, 21  
1 107 068
25 883
1 485 273
31 897
92 717
183 039
4
13, 20  
14  
81 896
59 959
Total current assets  
Total assets  
5 936 192
5 697 049
11 924 092
11 706 259
 
Pelagia Holding AS  
CONSOLIDATED BALANCE SHEET PER 31.12  
Amounts in NOK 1.000  
Note  
2025  
2024  
Equity and liabilities  
Share capital  
Share premium  
Other equity  
Non-controlling interests  
Total equity  
15  
15  
149 836
1 347 615
2 356 219
221 351
149 836
1 347 615
2 579 438
218 766
16  
4 075 020
4 295 654
Liabilities  
Deferred tax liabilities  
Employee benefit obligations  
Derivatives  
17  
4
108 789
1 831
-
197 615
1 584
2 268
Total non-current liabilities  
110 620
201 467
Liabilities to financial institutions  
Other long-term non interest bearing loan  
Bond loan  
Lease liabilities  
Total other non-current liabilities  
4, 18  
4, 18  
4, 18  
4, 19  
2 648 004
810
1 982 265
111 860
4 742 939
2 553 444
1 120
989 584
92 546
3 636 693
First year's instalment non-current liabilities  
Current portion of provisions for lease liabilities  
Current debt to financial institutions  
Derivatives  
4, 18, 19  
4, 19  
18  
225 245
36 195
2 049 844
-
1 139 862
16 129
1 417 590
68 922
4
Trade payables  
Tax payable  
Public duties owing  
Other current liabilities  
392 038
-
72 062
220 128
2 995 512
489 469
35 063
69 855
335 555
3 572 445
17  
7
Total current liabilities  
Total liabilities  
7 849 072
7 410 605
Total equity and liabilities  
11 924 092
11 706 259
Bergen, April 29, 2026  
__________________  
Helge Singelstad  
Chairman of the board  
__________________  
Endre Sekse  
Board member  
_________________  
Karoline Bjoland  
Board member  
__________________  
Egil Magne Haugstad  
CEO  
__________________  
Britt Kathrine Drivenes  
Board member  
_________________  
Helge Karstein Moen  
Board member  
 
Pelagia Holding AS  
CONSOLIDATED STATEMENT OF CASH FLOWS  
Amounts in NOK 1.000  
Note  
2025  
2024  
Cash flows form operating activities  
Result before tax expense  
Adjusted for:  
-18 660
564 104
- Depreciation and amortisation  
- Taxes paid  
- Taxes received - previous year adjustment  
- Fair value adjustment derivatives  
- (Gain) and loss on sale of fixed assets  
- Interest expenses net  
8, 9, 19  
497 354
-122 044
27 910
4 970
-30 180
468 709
430 643
-247 807
-
39 219
-
17  
17  
4
18  
476 386
Change working capital:  
- Change trade receivables  
- Change inventories  
- Change trade payables  
- Change other accruals  
Net cash flow from operating activities  
378 205
-757 262
-100 363
-160 267
188 372
-479 386
-255 858
66 363
144 918
738 581
Cash flows from investing activities  
Acquisition of subsidiary  
Purchase of property, plant and equipment  
Purchase of other intangible assets  
Sale of property, plant and equipment  
Net cash flows from investing activities  
22  
9
8
-28 183
-479 069
-
111 533
-395 719
-166 173
-1 097 170
-13 920
5 601
-1 271 661
9
Cash flows from financing activities  
Raising of non-current liabilities  
Repayment of non-current liabilities  
Net change bank overdraft  
Repayment lease liabilities  
Interest paid  
Dividends paid to parent company's shareholders  
Dividends paid to non-controlling interests  
Net cash flows from financing activities  
18  
18  
18  
2 463 400
-2 312 150
632 255
-33 755
-455 487
-200 000
-9 995
1 186 500
-90 030
343 739
-16 554
-475 179
-400 000
-3 427
18, 19  
18  
84 267
545 050
Change in cash and cash equivalents net  
-123 080
183 039
59 959
11 970
171 069
183 039
Net cash and cash equivalents as at 1st of January  
Net cash and cash equivalents per 31st of December  
 
Pelagia Holding AS  
CONSOLIDATED STATEMENT OF CHANGES IN EQUITY  
Equity to owners of Pelagia Holding AS  
Currency  
translation  
differences  
Non-  
controlling  
interests  
Share  
capital  
Share  
Hedge  
reserve  
Retained  
earnings  
Total  
equity  
premium accumulated  
Amounts in NOK 1.000  
Equity 01.01.2024  
Total  
149 836
1 347 615
247 893
-3 183
2 204 662
3 946 822
198 610
4 145 432
Result for the period  
-
-
-
-
-
-
424 632
-
424 632
97 881
26 456
-1 460
451 088  
96 421  
Other comprehensive income  
Total comprehensive income  
for the period  
94 698
3 183
-
-
94 698
3 183
424 632
522 513
24 996
547 509
Non-controlling interests on aquisition of  
subsidiary  
Dividends paid  
Non-controlling interests buyout  
Total transactions with owners and  
non-controlling interests  
Equity 31.12.2024  
-
-
-
-
-
-
-
-
-
-
-
-
-
-400 000
7 552
-
-400 000
7 552
20 662
-3 427
-22 075
20 662
-403 427
-14 523
-
-
-
-
-
-392 448
2 236 847
-392 448
4 076 887
-4 840
218 766
-397 288
4 295 654
149 836
1 347 615
342 591
Equity to owners of Pelagia Holding AS  
Currency  
translation  
differences  
premium accumulated  
Non-  
controlling  
interests  
Share  
Share  
Hedge  
reserve  
Retained  
earnings  
Total  
capital  
equity  
Amounts in NOK 1.000  
Equity 01.01.2025  
Total  
149 836
1 347 615
342 591
-
2 236 847
4 076 888
218 766
4 295 654
Result for the period  
-
-
-
-
-
-
-
-4 571
-
-4 571
-18 648
16 210
-3 630
11 639
-22 278
Other comprehensive income  
Total comprehensive income  
for the period  
-18 648
-
-
-
-
-
-
-18 648
-
-
-
-4 571
-23 219
12 580
-10 639
Dividends paid  
-200 000
-200 000
-9 995
-209 995
Total transactions with owners and  
non-controlling interests  
Equity 31.12.2025  
-
-
-
-200 000
2 032 276
-200 000
3 853 669
-9 995
221 351
-209 995
4 075 020
149 836
1 347 615
323 942
No dividend has been proposed for 2025. Divident payments to Pelagia's shareholders are classified as liability from  
the date the dividend has beed approved by the General Meeting.  
 
Pelagia Holding AS  
NOTE 1  
Accounting policies  
General information  
All amounts are in NOK 1,000 unless otherwise stated.  
Pelagia Holding Group ("Pelagia") is a group within production, sale and distribution of fish meal/fish oil and  
pelagic fish for consumption. Pelagia is an important party within pelagic sector in the North Atlantic. The main  
office is in Bergen
, Norway.
 
Group structure  
The consolidated financial statements comprise the parent company Pelagia Holding AS and the following  
subsidiaries and associated companies:  
Subsidiary  
Registered office  
Parent Company  
Owner share  
Pelagia AS  
Bergen  
Pelagia Holding AS  
100 %  
Mat Miljølaboratoriet AS  
Måløy  
Pelagia AS  
100 %  
Pelagia Technologies AS  
Bergen  
Pelagia AS  
100 %  
Pelagia Innovation AS  
Bergen  
Pelagia AS  
100 %  
Norsildmel Innovation AS  
Bergen  
Pelagia AS  
100 %  
Epax Norway AS  
Ålesund  
Pelagia AS  
100 %  
Epax Pharma Holding UK Unlimited  
UK  
Pelagia AS  
83 %  
Epax Pharma Holding UK Unlimited  
UK  
Epax Norway AS  
17 %  
Pelagia Danmark A/S  
Denmark  
Pelagia AS  
100 %  
Pelagia Ukraine LLC  
Ukraine  
Pelagia AS  
100 %  
Pelagia Feed (Ireland) Ltd. *)  
Ireland  
Pelagia AS  
100 %  
Charlie Vial Ltd  
UK  
Pelagia Feed (Ireland) Ltd.  
100 %  
Pelagia (UK) Ltd.  
UK  
Pelagia Feed (Ireland) Ltd.  
100 %  
Ideal Foods Ltd.  
UK  
Pelagia (UK) Ltd.  
100 %  
Ideal Nutritional Foods Ltd.  
UK  
Ideal Foods Ltd.  
100 %  
Ideal Pet Foods Ltd.  
UK  
Ideal Foods Ltd.  
100 %  
Pelagia (Greenock) Ltd.  
UK  
Pelagia (UK) Ltd.  
100 %  
Pelagia Shetland Ltd.  
UK  
Pelagia AS  
77 %  
Pelagia Bressay Ltd.  
UK  
Pelagia AS  
100 %  
Pelagia Sjø AS  
Austevoll  
Pelagia AS  
100 %  
Arctic Protein EHF  
Iceland  
Pelagia AS  
100 %  
Karmsund Protein AS  
Avaldsnes  
Pelagia AS  
51 %  
Kalvøya Utvikling AS  
Kalvåg  
Pelagia AS  
100 %  
Associated companies and joint venture  
Registered office  
Financial interest  
TD Moreproduct  
Ukraine  
50 %  
*) Pelagia Feed (Ireland) Limited, included in the consolidated financial statements of Pelagia Holding AS, has made use of the  
right to omit publication of the company accounts to «Registrar of Companies» in accordance with Section 357 i «the  
Companies Act 2014». The company meets the requirements in section 357(a) to 357(h).  
 
Pelagia Holding AS  
NOTE 1 CONTINUES  
Basis for preparation  
Below are stated the principal accounting policies used in the preparation of the consolidated financial  
statements.  
Framework for the preparation of the financial statements  
The consolidated financial statements of Pelagia Holding AS have been prepared in accordance with  
IFRS® Accounting Standards as adopted by the EU. For the presented consolidated financial statements there are  
no differences between IFRS® Accounting Standards as adopted by EU and IASB.  
Assets and liabilities are measured at cost to the extent that other measurement bases are not required by  
accounting standards.  
The preparation of financial statements in conformity with IFRS requires the use of certain accounting  
estimates. Management also needs to exercise judgement in applying the Group’s accounting policies. Areas  
involving a high degree of judgement or complexity, or areas where assumptions and estimates are significant to  
the consolidated financial statements, are disclosed in note 3 to the financial statements.  
The consolidated financial statements have been prepared under the going concern assumption.  
Revenue recognition  
Revenue is measured at fair value of the consideration, net after deduction of discounts and value added tax.  
Revenue is recognised when it can be reliably measured, it is probable that the transactions will generate future  
economic benefits that will accrue to the company and the criteria described below have been fulfilled. Revenues  
from the sale of goods are recognised in the income statement when control have been transferred to the buyer.  
No special discounts are granted, the prices vary and are agreed for each individual delivery. Standard payment  
terms are used to the largest extent possible but may vary based on delivery terms and instrument of payment.  
Pelagia uses different Incoterms delivery terms to various customers. Recognition of revenue takes place at the  
time of delivery as defined in Incoterms for the actual delivery terms.  
Sales orders for both pelagic fish for consumption and meal and oil are mainly transported by sea and by truck.  
Delivery terms most used are CIF (Cost Insurance Freight) and FOB (Free On Board). For both cases, transfer of risk  
and control ordinarily takes place as soon as the goods have been loaded on board the ship.  
Consolidation and investment in associated companies  
Subsidiaries  
Subsidiaries are all entities over which Pelagia has control. Subsidiaries are fully consolidated from  
the date on which control is transferred to the Group. They are deconsolidated from the date that control ceases.  
Associates  
Associates are all entities over which Pelagia has significant influence but not control, generally accompanying a  
shareholding of between 20% and 50% of the voting rights. Investments in associates are accounted for using the  
equity method of accounting. The investment is recognised at acquisition cost on the date of acquisition. The  
carrying amount includes any implicit goodwill identified on acquisition. When necessary, amounts reported by  
subsidiaries have been adjusted to conform with the Group's accounting policies.  
 
Pelagia Holding AS  
NOTE 1 CONTINUES  
Foreign currency translation  
The consolidated financial statements are presented in NOK, which is the functional currency of the parent  
company and the Group’s presentation currency. All subsidiaries use local currency as their functional currency.  
Foreign currency transactions are translated into the functional currency using the exchange rates prevailing at the  
dates of the transactions. Foreign exchange gains and losses resulting from the settlement of such transactions  
and from the translation at year-end exchange rates of monetary assets and liabilities denominated in foreign  
currencies are recognised in the income statement.  
Share of result from associates are translated at average rate of exchange. Share of equity (including goodwill and  
excess values) are translated at the exchange rate prevailing on the balance sheet date. Translation differences are  
recognised in other comprehensive income.  
In 2025 there is a change in accounting policy regarding presentation of currency translation differences, currency  
translation differences from bank balances or overdrafts are presented as a part of revenue, see note 2.  
Derivatives and hedging  
Pelagia uses derivatives for hedging purposes. Forward exchange contracts, interest swaps and financial power  
contracts are used for such purposes.  
Derivatives are measured at fair value with value changes through profit or loss. The group does not apply hedge  
accounting for derivatives.  
New and amended standards implemented in 2025  
The accounting policies adopted are consistent with those of the previous financial year, except for the  
amendments to IFRS which have been implemented by the Group during the current financial year. Below we  
have listed the amendments in IFRS which have been applicable for the Group's 2025 financial statements:  
- Amendments to IAS 21 - Lack of Exchangeability  
These amendments have not had a material impact on the Group's consolidated financial statements in the  
current reporting period.  
New standards and interpretations not yet adopted  
The Group has not early adopted any accounting standard, interpretation or amendment that has been issued but  
is not yet effective. The Group will adopt new amendments and interpretations, if relevant, when they become  
effective. Below is a list of new amendments not yet effective:  
- Amendments to IFRS 7 and IFRS 9 - Classification and measurement of financial instruments. These amendments  
are not expected to have a material impact on the Group's consolidated financial statements.  
- IFRS 18 - Presentation and Disclosure in Financial Statements, effective for accounting periods beginning on or  
after 1 January 2027. IFRS 18 introduces three defined categories to provide a consistent structure of the  
statement of profit og loss and new mandatory subtotals in the income statement. In addition, the standard  
introduces requirements for disclosures related to management-defined performance measures (MPMs).  
Implementation of IFRS 18 will require changes in the presentation of the Group's consolidated income statement,  
mainly related to reallocation of foreign exchange gains and losses.  
 
Pelagia Holding AS  
NOTE 2  
Change in accounting policy  
In 2025 Pelagia has changed the accounting policy related to presentation of currency translation differences from  
the multi-currency corporate account arrangement. Currency translation differences from the group account have  
in previous financial statements been presented net as finance income or finance cost. As the bank balances or  
overdrafts in foreign currencies are included in the calculation of hedging requirements the related translation  
differences will be presented as part of revenues, in the same manner as the effect from other hedging  
instruments related to operating activities. Comparative figures have been changed accordingly for 2024.  
Effect from change of presentation of currency translation gain and loss from  
group accounts  
2025  
2024  
Increase / (decrease) in sales revenue  
73 199  
-94 188  
Increase / (decrease) in operating profit  
73 199  
-94 188  
Increase / (decrease) in net finance  
-73 199  
94 188  
Effect on net profit  
-
-
 
Pelagia Holding AS  
NOTE 3  
Critical accounting estimates and judgements  
Estimates and judgements are continually evaluated and are based on historical experience and other factors,  
including expectations of future events that are believed to be reasonable under the circumstances.  
Accounting estimates will, by definition, seldom equal the related actual results. The estimates and assumptions  
that have a significant risk of causing a material adjustment to the carrying amounts of assets and liabilities within  
the next financial year are addressed below.  
Inventories  
Inventories are stated at the lower of acquisition cost and net realisable value. The prices of the Group’s products  
are sensitive due to currency conditions, changes in purchase price, quotas and catch volume and other market  
related circumstances.  
An estimate of net realisable value on the balance sheet date is performed by the sales department and is to a  
large extent based on realised prices in the market close to the balance sheet date. Factors like age and product  
quality are also emphasized in the assessment of net realisable value. A potential provision is also adjusted for  
uncertainty in expected sales prices, related to both market risk and turnover rates. See note 12 for information  
about impairment made at the balance sheet date.  
Trade receivables  
Trade receivables require use of judgements in the assessment of provision for bad debts. Provision is made when  
there are objective indicators that the Group will not receive settlement in accordance with original terms. See  
note 13 for further information about trade receivables.  
Intangible assets and goodwill  
Pelagia performs impairment tests for goodwill annually. Recoverable amounts from cash generating units have  
been determined based on calculations of assumed value in use. These calculations require the use of estimates  
and are further described in note 10.  
Cash generating units  
Pelagia has several production facilities in the consumption activity. Due to variations in quotas and seasonal  
production there may be excess capacity in production plants compared to the supply of raw materials. As number  
of plants and sites are of strategic importance for the supply and pricing of raw materials, the value of the plants  
has to be considered as a whole (and as part of a portfolio). Impairment tests of pelagic consumption plants at  
value in use are therefore made based on a portfolio mind of thinking. The plants are assessed as part of groups  
based on given criteria. The groups are considered separate cash generating units.  
Goodwill is monitored at segment level, involving a group of cash generating units. Pelagia has identified three  
segments: FOOD, FEED and HEALTH for which annual impairment tests for goodwill is performed, see note 10.  
 
Pelagia Holding AS  
NOTE 4  
Financial instruments and risk management  
Financial risk management  
The group’s activities expose it to a variety of financial risks: market risk (including currency risk, price risk, cash flow  
interest rate risk), credit risk
and liquidity risk. The group’s overall risk management programme focuses on the  
unpredictability of financial markets and seeks to minimise potential adverse effects on the group’s financial performance.  
To some extent, the group uses derivative financial instruments to hedge certain risk exposures.
The risk management is  
carried out by a central treasury department under policies approved by the board of directors.  
a) Market risk  
i) Currency risk  
Currency risk arises when future commercial transactions or carrying assets and liabilities are denominated in a currency  
which is not the entity's
functional currency.  
The group is exposed to currency risk through cash flows in foreign currency. A substantial part of the turnover will  
normally be in foreign currency, while the expenses are mainly in Norwegian Kroner.  
The current political situation and the impact on the global economy, including international freight costs, trade tariffs and  
inflation, may increase volatility and risk associated with currency sales.  
Over time there is a correlation between market prices translated into Norwegian Kroner and the price of raw materials.  
Changes in market
prices translated into Norwegian Kroner will therefore over time be reflected in the prices of raw  
materials and eliminate parts of the currency risk. In order to manage the currency risk arising from future transactions  
and recognised assets and liabilities, entities in the group use forward exchangecontracts. Pelagia Group aims for all  
currency exposure arising from receivables and liabilities in foreign currency to be hedged 100%. For inventories, an  
assessment is made of the currencies in which future sales will be made, and around 50% of the estimated exposure is  
hedged from the time the goods are in stock. No direct cash flow hedges are made, other than for committed sales  
orders. The company has some investments in foreign subsidiaries where net assets are exposed to currency risk by  
translation.  
The entities in the group have different functional currencies, the most important being
NOK, GBP and  
EUR. Changes in foreign exchange rates that
affect trade receivables, other receivables, and liabilities in currencies other  
than the entity's functional currency will have direct impact on the income statement at year end.  
Currency position 31.12.  
GBP 1000  
DKK 1000  
USD 1000  
EUR 1000  
JPY 1000  
Trade receivables  
11 268  
23 060  
38 448  
25 516  
540 977  
Prepayments  
-
-
-1 875  
-
-
Forward exchange contracts / derivates  
-
-42 750  
-97 241  
-55 574  
-2 324 000  
Net withdrawal overdraft facility  
-43 105  
-221 667  
-30 971  
-44 822  
1 135 617  
Total  
-31 838  
-241 357  
-91 639  
-74 880  
-647 406  
 
Pelagia Holding AS  
NOTE 4 CONTINUES  
Trade receivables per currency ( NOK 1.000)  
2025  
2024  
GBP  
152 925  
132 932  
DKK  
36 564  
56 872  
USD  
387 517  
681 439  
EUR  
302 184  
310 582  
JPY  
34 803  
70 453  
NOK  
193 076  
232 996  
Total  
1 107 068
1 485 273  
Carrying value of derivatives are all mainly connected to different currency derivatives, interest swaps and financial  
electricity derivatives.
Principally it concerns currency derivatives where the company sells currency. The group  
recognises currency derivatives at fair value with value change through profit or loss.  
Currency derivatives (fair value in TNOK)  
2025  
2024  
USD  
3 722  
-60 529  
JPY  
2 841  
-3 424  
EUR  
2 295  
-168  
Others  
143  
-
Total currency derivatives  
9 000  
-64 121  
If NOK in relation to the following foreign currency was 10% higher as of 31 December 2025 and all other variables were  
constant, it would lead to the following effects on profit before tax:  
10 % increase in NOK equals:  
GBP  
DKK  
USD  
EUR  
JPY  
Net impact on result before tax  
-43 210  
-38 270  
-92 364  
-88 681  
-4 165  
The impact is calculated based on Pelagia's exposure to foreign currency on working capital and derivatives.  
10 % weakening in NOK against the same currencies will give the opposite impact on the pre-tax result.  
Corresponding changes in foreign currency rates at year-end on other currencies have been estimated not to have  
material impact on the result.  
 
Pelagia Holding AS  
NOTE 4 CONTINUES  
ii) Price risk  
Pelagia Group is exposed to price changes for its sold products. Pelagia Group is also exposed to risk related to prices of  
pelagic raw materials. The group does not apply raw material derivatives to reduce the price risk. Financial electricity  
derivatives are applied to reduce the price risk related to power, see seperate section on cash flow hedges of forecast  
power purchase transactions.  
iii) Interest rate risk  
Pelagia's bank deposits and debt are subject to floating rate of interest. This involves that Pelagia is exposed to liquidity  
risk as a result of changes
in the market interest rates. Pelagia applies interest swaps to hedge from this liquidity risk.  
Pelagia's borrowings are to a large extent related
to operations and vary in line with seasonal fluctiations and are  
differently drawn during the year. In order to maintain this flexibility Pelagia's debt is mainly based on floating rate of  
interest. Pelagia also has acquisition financing.  
Maturity  
Nominal  
Change in  
Interest rate swaps  
Start date  
date  
amount Fair
value  
fair value  
DNB  
29.08.2024 29.08.2027
1 200 000  
8 539  
-7 990  
Nordea  
29.11.2024 29.08.2027
1 200 000  
7 802  
-7 567  
DNB  
30.09.2024 30.09.2027  
100 000  
-
-
Total interest rate swaps  
16 340  
-15 557  
If the interest rates had been 1% higher (lower) during the year, with all other vairables held constant, the pre-tax result  
would have been reduced (increased) by approx. MNOK 45,5 in 2025 as a result of floating interest rate on borrowings  
and deposits. Equity would have been reduced (increased) by approx MNOK 35,5 in 2025. Sensitivity analysis is based on  
net interest bearing debt and interest swaps at year-end.  
The simulation is only carried out for
debt items that represent the main part of Pelagia's interest positions.  
 
Pelagia Holding AS  
NOTE 4 CONTINUES  
b) Credit risk  
The degree of credit risk varies based on the market segment in which Pelagia Group operates. The main part  
of the sales to Japan and Far East and Africa is based on prepayment and other forms of guranteed settlement, the  
counterparty risk is therefore low. In other markets, as Eastern Europe and EU it is necessary to sell shares of volume on  
credit in order to serve the markets. Pelagia has credit insurance with own risk for a large share of the customers, but will  
in periods be exposed without credit insurance for some of the customers. To handle risk, Pelagia has routines and  
systems for close follow-up of outstanding receivables. Internal credit limits have been established for customers  
where receivables are not secured through credit insurance. The internal limits are assessed based on the customer's  
financial position, history and any other factors. Pelagia's total credit exposure is mainly related to trade receivables. For  
further information, see note 13.  
The group's credit risk at the balance sheet date can be summarized as follows:  
Credit risk  
2025  
2024  
Trade receivables at nominal value  
1 126 160
1 508 389  
Covered by credit insurance and other documentary collection instruments  
-757 889  
-890 898  
Credit exposure trade receivables  
368 271  
617 491  
Counterparty risk related to credit insurance company and banks that have provided Letter of Credit is considered to be  
low. There is a minimal credit risk associated to cash and cash equivalents of 7,7 MNOK as of 31.12.2025.  
c) Liquidity risk  
Pelagic industry is capital demanding due to natural seasonal fluctuations. Pelagia is therefore focusing on having sufficient  
access to financing that ensures business opportunities and flexibility.  
The table below specifies Pelagia's financial liabilities that are not derivatives classified pursuant to the maturity structure.  
The amounts in the table are non-discounted contractual cash flows (including interests based on the current interest rate  
level).  
Maturity profile financial  
liabilities  
2026  
2027  
2028  
2029  
2030  
Later  
Total  
Bank loan  
226 876  
2 614 681  
7 142  
7 142  
7 142  
14 285  
2 877 268  
Bond loan  
-
-
-
1 000 000  
1 000 000  
-
2 000 000  
Bank overdraft  
2 049 844  
-
-
-
-
2 049 844  
Interest payments related to  
above loans  
407 267  
290 932  
140 850  
140 440  
70 630  
820  
1 050 939  
Leasing payments  
36 195  
32 309  
11 357  
11 357  
11 357  
45 480  
148 055  
Long-term not interest bearing  
loan  
155  
155  
155  
155  
155  
35  
810  
Trade payables and other  
liabilities  
684 228  
-
-
-
-
-
684 228  
Total  
3 404 565  
2 938 078  
159 504  
1 159 094  
1 089 284  
60 620  
8 811 145  
 
Pelagia Holding AS  
NOTE 4 CONTINUES  
Capital management  
Pelagia's objectives when managing capital is to safeguard the group's ability to continue as a going concern in order to  
provide returns for shareholders and other stakeholders and to maintain an optimal capital structure to reduce the capital  
costs. The group's current capital structure and key figures are considered to be at an acceptable level in relation to  
Pelagia's goals.  
In order to improve the capital structure, Pelagia may adjust the level of dividends to shareholders, return capital to  
shareholders, issue new shares or sell assets to repay borrowing.  
The financing consists of rolling credit facility (RCF) of MNOK 2 800, as of 31.12.2025 the RCF is drawn by MNOK 2 700. In  
addition a current multi-currency credit facility of MNOK 2 000 has been established, this has been drawn by MNOK 1 941,  
the credit facility was temporarily increased to 2 400 until 27 April 2026.  
The covenants consist of demands to equity ratio above 30% and interest cover ratio (EBITDA / net finance charges) no  
less than 2.5x in the consolidated financial statements of Pelagia Holding AS. The multi-currency agreement is short term  
by nature, otherwise committed until 2027 as part of the same financing agreement as the RCF, renewed in November  
2022 with maturity in 2027.  
Pelagia Holding AS issued a bond loan in 2024 of MNOK 1 000 with maturity in 2029. In January 2025 the entity issued a  
new 1 000 MNOK bond loan with maturity in 2030. Both bond loans bears an interest of 3m NIBOR + 2.75% p.a. Pelagia  
Holding AS had a bond loan from 2020 of MNOK 900, this loan was settled in 2025.  
The same covenants as for the RCF apply to the new bond loan, equity ratio above 30% and interest cover ratio no less  
than 2.5x.  
The covenants are met.  
Booked equity ratio and interest cover ratio are shown in the table below:  
Equity ratio  
2025  
2024  
Booked equity  
4 075 020  
4 295 654  
Total assets  
11 924 092  
11 706 259  
Equity %  
34,2 %  
36,7 %  
Interest cover ratio  
2025  
2024  
EBITDA  
846 548  
1 307 964  
Net interest expenses  
320 569  
338 785  
Interest cover ratio  
2,64  
3,86  
 
Pelagia Holding AS  
NOTE 4 CONTINUES  
Financial instruments  
Fair value  
Fair value  
through over
compre-  
Amortised  
profit and  
hensive  
31.12.2025  
cost  
loss  
income  
Total  
Assets  
Other investments  
-
26 805  
-
26 805  
Other receivables  
1 500  
-
-
1 500  
Trade receivables and other current receivables*  
1 144 537  
-
-
1 144 537  
Interest swaps  
-
16 340  
-
16 340  
Currency derivatives and financial power contracts  
-
9 543  
-
9 543  
Cash and cash equivalents  
59 959  
-
-
59 959  
Total  
1 205 997  
52 689  
-
1 258 685  
Liabilities  
Bond loan  
1 982 265  
-
-
1 982 265  
Other long-term not interest bearing debt  
810  
-
-
810  
Leasing liabilities  
148 056  
-
-
148 056  
Currency derivatives and financial power contracts  
-
-
-
-
Trade payables and other current liabilities  
612 166  
-
-
612 166  
Total  
7 666 390  
-
-
7 666 390  
*Trade receivables and other current receivables excl. of prepayments and public duties owing, cf. note 13.  
Fair value  
Fair value  
through over
compre-  
Amortised  
profit and  
hensive  
31.12.2024  
cost  
loss  
income  
Total  
Assets  
Other investments  
-
24 669  
-
24 669  
Other receivables  
1 500  
-
-
1 500  
Trade receivables and other current receivables*  
1 552 488  
-
-
1 552 488  
Currency derivatives  
-
31 897  
-
31 897  
Cash and cash equivalents  
183 039  
-
-
183 039  
Total  
1 737 027  
56 566  
-
1 793 593  
Liabilities  
Debt to credit institutions  
4 210 895  
-
-
4 210 895  
Bond loan  
1 889 584  
-
-
1 889 584  
Other long-term not interest bearing debt  
1 120  
-
-
1 120  
Leasing liabilities  
108 675  
-
-
108 675  
Currency derivatives and financial power contracts  
-
71 189  
-
71 189  
Trade payables and other current liabilities  
825 024  
-
-
825 024  
Total  
7 035 298  
71 189  
-
7 106 488  
*Trade receivables and other current receivables excl. of prepayments and public duties owing, cf. Note 13.  
 
Pelagia Holding AS  
NOTE 4 CONTINUES  
Assessment of fair value  
The table below shows financial instruments at fair value according to valuation method. The various levels have been  
defined as follows:  
- Level 1: Listed price in an active market for an identical asset or liability.  
- Level 2: Valuation based on onther observable factors than noted priced (used in level 1), either directly (price) or  
indirectly (derived from prices) for
the asset or the liability.  
- Level 3: Valuation based on factors not provided from observable markets (non-observable prerequisites).  
31.12.2025  
Assets / (liabilities)  
Level 1  
Level 2  
Level 3  
Total  
- Currency derivatives  
-
9 000  
-
9 000  
- Interest rate swaps  
-
16 341  
-
16 341  
- Financial power contracts  
-
543  
-
543  
- Other investments  
-
-
26 805  
26 805  
Total  
-
25 883  
26 805  
52 689  
31.12.2024  
Assets / (liabilities)  
Level 1  
Level 2  
Level 3  
Total  
- Currency derivatives  
-
-64 121  
-
-64 121  
- Interest rate swaps  
-
31 897  
-
31 897  
- Financial power contracts  
-
-7 068  
-
-7 068  
- Other investments  
-
-
24 669  
24 669  
Sum  
-
-39 292  
24 669  
-14 623  
There were no transfers from level 1 to level 2 during the year.  
The fair value of financial instruments traded in active markets is based on market prices at the balance sheet date. A  
market is regarded as active if the market prices are readily and regularly available from an exchange, dealer, broker,  
industry group, pricing service, or regulatory agency, and those prices represent actual and regularly occuring market  
transactions on an arm’s length basis. The market price used for financial assets held
by the group is the current bid price,  
for financial liabilities the current selling price is used. These instruments are included in Level 1.  
The fair value of financial instruments that are not traded in an active market (for example, forward exchange contracts) is  
determined by using valuation techniques. These valuation techniques maximise the use of observable market data where  
available and rely as little as possible on entity specific estimates. If all significant inputs required to determine the fair  
value of an instrument are obervable, then the instrument is included in Level 2.  
If one or more of the significant inputs is not based on observable market data, the instrument is included in Level 3.  
For amortized cost assets and liabilities, the book value is considered to be approximately equal to the fair value.  
 
Pelagia Holding AS  
NOTE 5  
Sales revenues/segment information  
Operating segments  
Pelagia's activities are divided into three segments;
meal/oil (Feed), consumption (Food) and omega-3 (Health). The  
segment reporting is followed up by the Board of Directors as the top decision-maker.  
Meal/oil (Feed)  
The meal- and oil activity comprises production of fish meal, fish oil and concentrate of fish protein. The products  
are mainly sold to the aquaculture industry nationally.  
Consumption (Food)  
The consumption activity consists of receipt and processing of pelagic fish for consumption. Pelagic fish for human consu  
mption is mainly frozen mackerel,
herring and capelin catched with closing net or trawl in the Norwegian Sea and the  
North Sea.
The company has production plants spread along the Norwegian coast. The fish is mainly subject to global  
export.  
Epax (Health)  
The activity consists of production of high-concentrate omega-3 ingredients. The product is used as ingredient for leading  
brands within food supplements and pharmaceutical products. Production plant for the activity is located in Ålesund. The  
product is mainly subject to global export.  
Change in accounting policy  
From 2025 currency translation differences from the corporate account arrangement is presented as part of revenue, in  
the same manner as the effect from other hedging instruments related to operating activities. Previously it was presented  
as other financial items. Comparative figures have beed changed accordingly for 2024. See note 2.  
Segment allocation  
Raw material is either from external suppliers or internal transactions of cut-off from the FOOD segment. Internal  
transactions are reallocation of cost of goods and does not generate revenue, these internal transactions are valued based  
on minimum price from Norges Sildesalgslag.  
Intersegment revenue and related costs are eliminated in the table below. Intersegment revenue is MNOK 45,9 in 2025  
(2024: MNOK 36,7) in the FOOD segment and MNOK 1,1 (2024: 0,5) in the FEED segment, there is no intersegment  
revenue in the HEALTH segment.  
Group cost is allocated to the different segments by share of budgeted revenue, based on the assessment that revenue  
reflects the size of the segments and therefore is a fair indication of use of resources from the administration.  
Major customers  
No individual customer accounts for revenue that exceeds ten percent of consolidated sales.  
 
Pelagia Holding AS  
NOTE 5 CONTINUES  
2025  
2024  
Segment information  
Food  
Feed  
Health  
Total  
Food  
Feed  
Health  
Total  
External operating  
income  
6 962 869  
5 444 563  
1 036 417  
13 443 849  
7 060 387  
7 086 477  
796 483  
14 943 346  
Other gains  
-
-
-
-
-
-
-
-
Total operating  
income  
6 962 869  
5 444 563  
1 036 417  
13 443 849  
7 060 387  
7 086 477  
796 483  
14 943 346  
Cost of goods  
6 120 048  
4 161 821  
706 088  
10 987 958  
6 087 804  
5 369 123  
533 053  
11 989 980  
Contribution margin  
842 821  
1 282 742  
330 329  
2 455 891  
972 583  
1 717 354  
263 430  
2 953 366  
Indirect wages  
260 263  
358 789  
89 549  
708 601  
284 118  
324 126  
86 751  
694 995  
Indirect operating  
expenses ex.  
depreciation  
202 459  
627 968  
70 315  
900 742  
256 920  
620 430  
73 056  
950 406  
Operating result  
before depreciation  
EBITDA  
380 099  
295 985  
170 465  
846 548  
441 047  
794 122  
166 984  
1 307 965  
Income recognition  
from aquisition  
-
-
-
-
-
-
-
-
Impairment  
-
-
-
-
-
-
-
-
Depreciation  
152 047  
314 457  
30 850  
497 354  
137 926  
262 613  
30 103  
430 643  
Operating result EBIT  
228 052  
-18 472  
139 615  
349 194  
303 121  
531 509  
136 881  
877 321  
Net interest  
-80 321  
-210 468  
-44 602  
-335 391  
408  
-261 118  
-48 668  
-309 378  
Result from associated  
company  
-
-
-
-
-
-
-
-
Other financial items  
-7 242  
-20 548  
-4 672  
-32 462  
11 062  
-18 205  
3 302  
-3 840  
Result before taxes  
140 489  
-249 488  
90 340  
-18 659  
314 591  
252 186  
91 515  
564 102  
Sales revenues  
distributed on  
geographical markets  
Food  
Feed  
Health  
Total  
Food  
Feed  
Health  
Total  
Norway  
89 702  
2 499 458  
375 021  
2 964 182  
76 672  
3 822 245  
138 183  
4 037 100  
Europe for the rest  
727 066  
1 733 377  
54 397  
2 514 840  
498 608  
2 005 192  
81 583  
2 585 382  
Europe EU  
2 477 375  
934 200  
244 890  
3 656 464  
2 485 824  
827 478  
217 502  
3 530 804  
Asia  
2 885 621  
256 600  
85 659  
3 227 880  
3 107 643  
392 671  
113 567  
3 613 881  
Africa  
393 195  
2 206  
224  
395 624  
538 545  
4 450  
-
542 994  
North-Amerika  
387 961  
18 722  
241 104  
647 787  
353 096  
34 442  
215 092  
602 629  
Other  
1 950  
-
35 123  
37 073  
-
-
30 556  
30 556  
Total  
6 962 869  
5 444 563  
1 036 417  
13 443 849  
7 060 387  
7 086 477  
796 483  
14 943 346  
2025  
2024  
Other  
Property,  
Other  
Other  
Property,  
Other  
Non-current assets by  
intangible  
plant and  
financial  
intangible  
plant and  
financial  
geographical area  
assets  
Goodwill  
equipment  
assets  
assets  
Goodwill  
equipment  
assets  
Home country  
85 805  
849 304  
3 575 006  
7 214  
94 586  
849 304  
3 454 370  
7 612  
(Norway)  
Other countries*  
2 359  
453 872  
993 250  
21 091  
3 775  
467 735  
1 113 272  
18 557  
Total  
88 164  
1 303 175  
4 568 256  
28 305  
98 361  
1 317 038  
4 567 642  
26 169  
*Other countries mainly applies to the UK and Ireland  
 
Pelagia Holding AS  
NOTE 6  
Wage costs, full-time equivalents, remunerations etc.  
Specification of wage costs  
2025  
2024  
Wages  
848 207  
852 252  
Payroll tax  
118 270  
116 209  
Pension costs  
100 080  
98 628  
Other benefits  
40 668  
19 365  
Total  
1 107 225  
1 086 453  
Average number of full-time equivalents  
1 152  
1 159  
Pension obligations  
The pension schemes are generally financed through payments to an insurance company or pension funds determined by  
periodic actuary estimates. The Group has defined contribution plans. Per 31.12.2025 the Group has a defined benefit  
pension scheme of immaterial size. This scheme relates to entities entering the Group in 2019.  
Other  
Remunerations for executive employees:  
Wages  
Bonus  
benefits  
Total  
CEO -
Egil Magne Haugstad  
3 832  
1 925  
716  
6 473  
The CEO has a profit-based bonus scheme calculated from the group's pre-tax result. Bonus is 0.5 % of pre-tax result  
reduced by MNOK 100. The bonus is limited upward to 50% of ordinary annual salary including holiday pay. In case  
of notice the CEO is entitled to a severance pay corresponding to 6 months fixed salary. Mutual notice period for the CEO  
is 6 months.  
No loan or other security has been granted to the board, the CEO or other related parties. There are no other profit  
sharing or options for the board or other related parties.  
The other members of the executive management received a total of TNOK 11 762 in total salary and TNOK 5 100 in  
bonuses.  
Shares owned by Board members and executive employees  
The Board:  
The Chairman of the Board, Helge Singelstad, owns shares indirectly through his ownership in Austevoll Seafood ASA.  
Board member Britt Kathrine Drivenes own shares indirectly through her owner interests in Lerkehaug AS. Lerkehaug AS  
has owner interests in Austevoll Seafood ASA.  
Executive employees:  
CEO Egil Magne Haugstad owns shares indirectly through his ownership in Egersund Fiskeri Investering AS. Egersund  
Fiskeri Investering AS owns 26,63% of the shares in Kvefi AS.  
Remuneration paid to the members of the Board of Directors  
No Board of Directors' fee has been paid in 2025 or 2024. Chairman of the board has no bonus scheme or severance pay  
agreement.  
Auditor:  
Auditor's fees exclusive of vat.  
2025  
2024  
Statutory audit  
8 036  
7 907  
Other certification services  
3 375  
984  
Tax consultancy  
251  
562  
Services other than audit  
460  
1 123  
Total  
12 122  
10 576  
 
Pelagia Holding AS  
NOTE 7  
Specifications  
Other operating expenses  
2025  
2024  
Variable lease, short-term leasing agreements and lease of assets of
minor value  
25 284  
40 663  
Repair and maintenance  
207 677  
244 712  
IT-expenses  
50 838  
49 053  
Bad debts  
-1 616  
1 256  
Other expenses  
618 560  
614 722  
Total other operating expenses  
900 742  
950 406  
Specification of other current liabilities  
2025  
2024  
Wages and public duties owing  
78 952  
89 089  
Prepayments received*  
14 109  
110 643  
Incurred costs  
121 411  
85 241  
Other current liabilities  
5 656  
50 583  
Total other current liabilities  
220 128  
335 555  
*Concerns received prepayments from customers in the consumption segment (Food).  
 
Pelagia Holding AS  
NOTE 8  
Intangible assets and goodwill  
Intangible assets are recognised in the balance sheet if it can be demonstrated that probable future economic benefits  
may be generated that can be assigned to the asset that is owned by the Group and the cost price of the asset can be  
reliably estimated. Intangible assets are recognised in accordance with the cost method of IAS 38. Intangible assets  
whose useful life is indefinite are not subject to depreciation but can be written down if recoverable amount is lower  
than cost price. Intangible assets with limited useful life are depreciated using the straight-line method over their  
estimated useful lives. The depreciation estimate and depreciation method are subject to an annual review based on the  
economic realities.  
Goodwill arises on the acquisition of an entity and constitutes consideration transferred less Pelagia's share of fair value  
of net identifiable assets and liabilities in the acquired entity. In addition goodwill may arise on acquisition if non-  
controlling interests are measured at fair value at the date of acquisition.  
Other  
intangible  
Customer  
Intangible assets 2025  
assets  
Goodwill  
portfolio  
Total  
Acquisition cost 01.01.2025  
125 996  
1 347 938  
165 700  
1 639 635  
Translation differences  
-164  
-13 863  
-
-14 027  
Additions  
-
-
-
-
Acquisition business combination  
37 029  
-
-
37 029  
Disposal  
-24 055  
-
-
-24 055  
Acquisition cost 31.12.2025  
138 806  
1 334 075  
165 700  
1 638 582  
Accumulated amortisation and impairment 01.01.2025  
59 972  
30 900  
133 363  
224 235  
Amortisation  
12 091  
-
10 916  
23 007  
Impairment  
-
-
-
-
Accumulated amortisation and impairment 31.12.2025  
72 063  
30 900  
144 279  
247 242  
Book values 31.12.2025  
66 743  
1 303 176  
21 421  
1 391 339  
Straight-line amortisation periods  
5 years  
Other  
intangible  
Customer  
Intangible assets 2024  
assets  
Goodwill  
portfolio  
Total  
Acquisition cost 01.01.2024  
90 847  
1 232 625  
165 700  
1 489 172  
Translation differences  
-
31 018  
-
31 018  
Additions  
35 150  
84 295  
-
119 445  
Acquisition cost 31.12.2024  
125 996  
1 347 938  
165 700  
1 639 635  
Accumulated amortisation and impairment 01.01.2024  
45 973  
30 900  
119 552  
196 425  
Amortisation  
13 999  
-
13 811  
27 810  
Impairment  
-
-
-
-
Accumulated amortisation and impairment 31.12.2024  
59 972  
30 900  
133 363  
224 235  
Book values 31.12.2024  
66 024  
1 317 039  
32 337  
1 415 399  
Straight-line amortisation periods  
5 years  
Value of customer portfolio identified in the acquisition analysis in 2021 is based on expected earnings and  
estimated customer exit. This is reflected in the depreciation profile, which is degressive over a 10 year period.  
 
Pelagia Holding AS  
NOTE 9  
Property, plant and equipment  
Property, plant and equipment are recognised in accordance with the cost method of IAS 16. When assets are sold or  
disposed of any loss or profit resulting from the realisation are recognised in the income statement.  
The carrying amount of replaced parts is recognised in the income statement. All other repairs and maintenance  
expenses are charged to the income statement during the financial period in which they are incurred.  
Plant in progress is classified as property, plant and equipment and recognised at incurred costs related to the asset. The  
plants are not depreciated before they are ready for use.  
Depreciation period and depreciation method are reviewed annually to ensure that the method and period used are in  
accordance with the economic realities related to the asset. The same applies for scrap value. An asset’s carrying amount  
is written down immediately to its recoverable amount if the asset’s carrying amount is higher than its estimated  
recoverable amount.  
Land, buildings  
and other real  
Plant and  
Right-of-use  
Property, plant and equipment 2025  
property  
equipment leased
assets  
Ships  
Total  
Acquisition cost 01.01.2025  
2 216 733  
4 385 730  
191 885  
649 769  
7 444 117  
Translation differences  
-4 537  
-16 606  
-
-
-21 143  
Reclassification  
-
-
-
-
-
Additions  
277 859  
174 595  
67 207  
32 214  
551 875  
Acquisition business combination  
-
330  
-
-
330  
Disposal  
-48 428  
-43 015  
-4 927  
-
-96 370  
Acquisition cost 31.12.2025  
2 441 628  
4 501 034  
254 165  
681 983  
7 878 809  
Acc. depreciation and write down
01.01.2025  
787 834  
1 910 394  
86 387  
91 861  
2 876 476  
Depreciation  
115 649  
288 665  
24 017  
46 017  
474 347  
Depreciation on disposals  
-30 542  
-9 727  
-
-
-40 269  
Acc. depreciation and write down
31.12.2025  
872 940  
2 189 331  
110 404  
137 878  
3 310 554  
Book values 31.12.2025  
1 568 688  
2 311 702  
143 761  
544 104  
4 568 256  
Straight-line depreciation periods:  
10 - 50 years  
2 - 20 years  
4 - 8 years  
20 years  
Land, buildings  
and other real  
Plant and  
Right-of-use  
Property, plant and equipment 2024  
property  
equipment leased
assets  
Ships  
Total  
Acquisition cost 01.01.2024  
2 447 664  
3 229 249  
178 098  
288 452  
6 143 462  
Translation differences  
21 876  
145 334  
-
-
167 210  
Reclassification  
(377 600)  
377 600  
-
-
-
Additions  
124 794  
639 683  
15 035  
361 317  
1 140 829  
Disposal  
-
-6 135  
-1 248  
-
-7 383  
Acquisition cost 31.12.2024  
2 216 733  
4 385 730  
191 885  
649 769  
7 444 117  
Acc. depreciation and write down
01.01.2024  
671 533  
1 550 975  
76 025  
66 038  
2 364 572  
Translation differences  
10 092  
100 846  
-
-
110 938  
Depreciation  
106 209  
260 439  
10 362  
25 823  
402 833  
Depreciation on disposals  
-
-1 866  
-
-
-1 866  
Acc. depreciation and write down
31.12.2024  
787 834  
1 910 394  
86 387  
91 861  
2 876 476  
-
Book values 31.12.2024  
1 428 900  
2 475 336  
105 498  
557 907  
4 567 642  
Straight-line depreciation periods:  
10 - 50 years  
2 - 20 years  
4 - 8 years  
20 years  
 
Pelagia Holding AS  
NOTE 10  
Impairment of non-financial assets  
The recoverable amount is the higher of an asset’s net selling price and value in use. The value in use is calculated by  
discounting expected future cashflows to present value by using pre-tax discount rate, reflecting the market's price  
setting of the time value of money and the risk related to the specific asset.  
Recoverable amount at the balance sheet date is calculated annually for goodwill and assets whose useful life is  
indefinite. An impairment loss is recognised when carrying value of an asset or cash generating unit exceeds its  
recoverable amount. Impairment loss is recognised in the income statement.  
For assets that are not mainly generating independent cash flows the recoverable amount is determined for the cash  
generating unit to which the asset belongs. Impairment calculated for cash generating units is divided so that  
carrying value of any goodwill in cash generating units is reduced first. Subsequently, the remaining  
impairment is distributed on the other assets in the unit proportionally based on carrying values.  
The management assesses profitability within the segments consume (food) and meal/oil (feed) and omega-3 (health).  
The following is a statement of allocation of book value of intangible assets.  
Other  
intangible  
Customer  
Segment  
assets  
Goodwill  
portfolio  
Total  
Feed  
59 443  
1 208 996  
21 421  
1 289 859  
Food  
6 487  
94 180  
-
100 667  
Health  
813  
-
-
813  
Total intangible assets  
66 743  
1 303 176  
21 421  
1 391 339  
Goodwill is monitored at segment level, involving a group of cash generating units. Recoverable amount is calculated  
based on value in use, i.e. on budgeted future cash flows based on the budget for 2026 and prognoses to and inclusive  
2030. After 2030 the terminal value is
calculated based on prognosis for 2030.  
 
Pelagia Holding AS  
NOTE 10 CONTINUES  
Climate risk  
‑
Pelagia is exposed to several material climate related risks, primarily linked to the availability of marine resources. These  
risks are consistent with those described in Pelagia’s CSRD reporting and in the risk assessments presented elsewhere in  
this annual report.  
‑
‑
- Climate change affecting fish stocks (long term risk): Changes in ocean temperature and acidity may influence migration  
‑
patterns, distribution and population levels of pelagic species in the North Atlantic. Under high emission scenarios, these  
developments could affect the location and volume of catches, posing a long term risk to Pelagia’s sourcing of raw  
materials. Pelagic species swim in schools in the open ocean and may move between areas depending on access to food  
and environmental conditions. While this makes them adaptable, it also underscores the importance of responsibly  
managed stocks and sustainable fishing quotas.  
Pelagia’s access to raw materials depends on sustainably regulated fisheries and effective cooperation between coastal  
states. Almost all pelagic raw material used in Norway is purchased through Norges Sildesalgslag, where quotas and  
landings are monitored to ensure sustainable harvest. The impairment tests incorporate expected volume fluctuations  
linked to sustainable quota management. Although reductions in quotas may increase raw material costs, Pelagia expects  
long term catch volumes to remain available near its production facilities, and this assumption is included in the  
‑
assessment of facilities’ useful lives.  
‑
Pelagia mitigates long term risk through high resource efficiency, utilization of multiple species, and use of residual raw  
materials in production. While the potential long term financial impacts of climate change are highly uncertain, we do  
not expect significant effects in the short or medium term.  
‑
‑
- Access to marine raw materials (short term risk): Pelagia’s operations depend on access to fish resources in the areas  
where the Group operates. Short term risks are influenced by variations in fish populations, quota uncertainty and  
political or regulatory developments. Pelagia operates facilities across several coastal regions in Norway, Denmark, the  
United Kingdom and Ireland. This geographic spread strengthens resilience when migration patterns shift, although it  
‑
may increase exposure to periods of lower raw material availability at individual factories.  
Short term mitigation measures include temporary workforce adjustments and, in rare cases, consideration of scaling  
down or closing facilities. Continuous development of processing methods and new market opportunities further  
supports the Group’s ability to handle periods of low availability.  
‑
- Risk of overfishing in the value chain (short term potential negative impact): Overfishing in the upstream value chain  
may reduce the availability of key fish stocks. As Pelagia is dependent on wild-caught species, unsustainable harvesting  
practices pose an inherent risk. All raw materials in Norway are landed through regulated sales cooperatives and are  
subject to scientific assessment and quota determination. In the UK and Ireland, all raw materials are certified through  
MarinTrust. Strict quality and traceability systems apply across Pelagia’s value chain.  
- Extreme weather events: In recent years, more frequent and severe extreme weather has been observed. Pelagia  
‑
monitors this risk closely. Current assessments indicate a low probability of material damage to facilities, and no  
significant climate related investments are expected as a result of extreme weather.  
‑
- Climate related investments and regulatory developments: Pelagia does not have specific climate targets that are  
‑
‑
expected to trigger material investments at present. However, the Group is implementing several measures to reduce its  
‑
climate impact, including investments in energy efficient technologies, equipment enabling the use of carbon neutral  
fuels, and upgrades that increase processing efficiency and utilization of by products and locally sourced fish oil. These  
initiatives will give a better foundation to assess climate targets going forward.  
‑
The Group’s broader sustainability efforts are described in the Sustainability Statement, and there are currently no  
regulatory requirements or climate related risks expected to materially affect the Group’s financial position in the near  
term.  
 
Pelagia Holding AS  
NOTE 10 CONTINUES  
Key assumptions used in the calculation of value in use:  
Feed  
Food  
Health  
Budget period (year)  
5
5
5
Growth rate terminal calculation  
2,0 %  
2,0 %  
2,0 %  
Required rate of return after tax (WACC)  
8,2 %  
8,2 %  
8,2 %  
Asset Beta  
0,79  
0,79  
0,79  
EBITDA-margin in budget period (average)  
11,7 %  
4,9 %  
27,2 %  
EBITDA-margin in terminal  
13,1 %  
5,9 %  
28,6 %  
In total Pelagia Group purchased approx. 1,2 mill tons of raw materials for its activities in 2025 compared to 1.3 million  
tons in 2024. The volume expectations in the budget period is for Feed and Food reduced compared to 2025. Overall the  
volume in the budget period 2026 is reduced with 14% compared to 2025. Calculation of terminal value is based on a  
total volume of 1.3 million tons.  
EBITDA-margin in the terminal value is slightly higher than in the budget period for all three segments,
yet, for the Food  
segment, the margin used in the terminal is below the actual margin achieved in the period 2021-2025.  
Sensitivity analysis:  
Estimated value in use is sensitive to changes in the assumptions, of which required rate of return and
EBITDA-margin  
are the most important. The sensitivity analysis is carried out based on an isolated change of assumptions by:  
a) increase in required rate of return by 1% - point or  
b) reduced EBITDA-margin by 10%*  
These are considered reasonably possible changes in key assumptions.  
Health  
The conclusion of the sensitivity analysis is that no impairment is needed in Health based on an isolated change of  
assumptions.  
Feed  
Calculated carrying amount exceeds book values by 1 285 MNOK.  
Reduction of EBITDA-margin by 1,24%-point would result in carrying value equal to book value.  
Increase in the required rate of return by 1%-point would not reduce the carrying amount below carrying value.  
Food  
Calculated carrying amount exceeds book values by 416 MNOK.  
Reduction of EBITDA-margin by 0,32%-point would result in carrying value equal to book value.  
Increase in the required rate of return by 0,64%-point would result in carrying value equal to book value.  
*The reduction in EBITDA-margin is applied using the same reduction in EBITDA-margin for all years in the budget period  
and terminal. The size of the reduction is calcuated based on 10 % of the EBITDA-margin in the terminal  
 
Pelagia Holding AS  
NOTE 11  
Shares in associated companies - the equity method  
Pelagia’s share of profit or loss in associates is recognised in the income statement and is added to the carrying value of the  
investment. Pelagia's share of other comprehensive income in the associate is recognised in other comprehensive income with a  
corresponding adjustment to the carrying amount of the investment. When the Group’s share of losses in an associate equals or  
exceeds its interest in the associate (including any other unsecured receivables) Pelagia does not recognise further losses, unless  
Pelagia has incurred legal or constructive obligations or made payments on behalf of the associate.  
Pelagia determines at each reporting date whether there is any objective evidence that the investment in the associate is impaired. If  
this is the case, the Group calculates the amount of impairment as the difference between the recoverable amount of the investment  
and its carrying value and recognises the amount adjacent to "Income from investment in associate" in the income statement.  
Dilution gains and losses arising from investments in associates are recognised in the income statement.  
Owner- / voting  
Company  
Classification  
Business address  
share  
TD Moreproduct  
Associated  
Nikolajev, Ukraina  
50 %  
Overview of profit share and book value  
31.12.2024  
Profit share  
Disposal  
31.12.2025  
TD Moreproduct  
-
-
-
-
Total  
-
-
-
-
NOTE 12  
Inventories  
According to IAS 2, Inventories are stated at the lower of acquisition cost and net realisable value. Acquisition cost is determined using  
specific assignment. Pelagia does not consider the various production batches of fish or fish meal and fish oil to be directly  
interchangeable, because of the production date being an important characteristic for the product. Due to significant fluctuations in  
the market for raw materials this accounting principle involves that acquisition cost for different consignments has corresponding  
variability.  
For finished goods and goods in progress acquisition cost consists of expenses for purchase of raw material,  
direct wage costs, other direct costs and indirect production costs (based on normal capacity). Borrowing costs are not included. Net  
realisation value is estimated selling price less variable costs for completion and sale.  
Inventories  
2025  
2024  
Raw materials  
568 239  
769 603  
Goods in progress  
577 173  
306 185  
Packing and supplements  
263 197  
297 310  
Finished goods  
3 315 435  
2 610 406  
Impairment of finished goods to net realisable value  
-62 659  
-79 381  
Total  
4 661 385  
3 904 123  
Book value of inventory impaired to net realisable value  
239 299  
396 333  
Write-downs of inventories to net realisable value amounted to MNOK -16,7 (2024: MNOK 19,0). These were recognised  
as an expense during the year ended 31 December 2025 and included in cost of sales in the statement of profit and loss.  
 
Pelagia Holding AS  
NOTE 13  
Trade receivables and other receivables  
Trade receivables  
2025  
2024  
Trade receivables at nominal value  
1 126 160  
1 508 389  
Provision for bad debts on trade receivables  
-19 092  
-23 116  
Trade receivables, net  
1 107 068  
1 485 273  
Other current receivables  
2025  
2024  
VAT receivable  
-3 117  
-4 936  
Prepaid expenses  
47 544  
30 438  
Other receivables, loans etc.  
37 469  
67 215  
Other current receivables  
81 896  
92 717  
Total current receivables  
1 188 964  
1 577 990  
Non-current receivables  
2025  
2024  
Other loans  
1 500  
1 500  
Total non-current receivables  
1 500  
1 500  
Long‐term loan is interest‐bearing.  
Age distribution trade receivables  
2025  
2024  
Not due  
885 420  
1 302 164  
< 30 days  
192 783  
171 953  
30-60 days  
33 343  
28 754  
> 60 days  
14 615  
5 518  
Total  
1 126 160  
1 508 389  
Age distribution of provision for bad debts  
2025  
2024  
Not due  
2 125  
13 400  
< 30 days  
3 693  
1 167  
30-60 days  
9 356  
3 732  
> 60 days  
3 918  
4 817  
Total  
19 092  
23 116  
Expected credit loss  
2025  
2024  
Not due  
0,24 %  
1,03 %  
< 30 days  
1,92 %  
0,68 %  
30-60 days  
28,06 %  
12,98 %  
> 60 days  
26,81 %  
87,29 %  
Total  
1,70 %  
1,53 %  
Change in provision for losses on trade receivables  
2025  
2024  
Opening balance provision  
23 116  
26 154  
Reduction due to losses finally recorded  
101  
4 551  
Reduction due to reversal of previous provisions  
-19 299  
-25 887  
Increase due to new provisions  
15 173  
18 299  
Per 31.12  
19 092  
23 116  
Expensed losses on accounts receivable  
Established losses  
-101  
-4 551  
Received on previously lost claims  
2 509  
5 931  
Change in provision loss receivables  
-4 024  
-3 038  
Total  
-1 616  
-1 658  
 
Pelagia Holding AS  
NOTE 13 CONTINUES  
Trade receivables are partly secured through credit insurance and other types of insurance (letter of credit, goods against documents  
etc.) The management assesses monthly the risk in outstanding receivables and makes provision for any receivables exposed to loss.  
The provision for losses on trade receivables mainly comprises receivables that have become due and have not been secured through  
credit insurance or in any other way. Separate assessments are made of the risk related to each individual customer. In addition a  
general provision is made for risk in the accounts receivable.  
See note 4 for specification and distribution of trade receivables in different currencies and further about credit risk.  
NOTE 14  
Restricted funds  
2025  
2024  
Restricted tax deductions  
37 742  
36 795  
Total restricted funds  
37 742  
36 795  
NOTE 15  
Share capital, premium and shareholders' information  
Share capital and premium  
2025  
2024  
Number of shares  
149 835 600  
149 835 600  
Nominal value (NOK)  
1
1
Share capital  
149 836  
149 836  
Premium  
1 347 615  
1 347 615  
Total paid-in equity  
1 497 451  
1 497 451  
Shareholder structure 31.12  
Holdings  
Holdings  
Austevoll Seafood ASA  
74 917 800  
74 917 800  
Kvefi AS  
74 917 800  
74 917 800  
Total  
149 835 600  
149 835 600  
 
Pelagia Holding AS  
NOTE 16  
Non-controlling interests  
Equity - non-controlling interests  
Subsidiary  
Minority share  
2025  
2024  
Karmsund Protein AS  
49 %  
129 286  
138 845  
Pelagia Shetland Ltd.  
23 %  
92 064  
77 040  
Sirevåg Fryselager AS  
liquidated in 2025  
-
2 882  
Total  
221 351  
218 766  
Total comprehensive income for the year attributable to non-controlling interests  
Subsidiary  
Profit/(loss)  
OCI  
2025  
Karmsund Protein AS  
-5 153  
-
-5 153  
Pelagia Shetland Ltd.  
18 710  
-3 630  
15 080  
Sirevåg Fryselager AS  
2 653  
-
2 653  
Total  
16 210  
-3 630  
12 580  
Financial information realted to the Group's subsidiaries with material non-controlling interests  
TNOK excluding any consolidation entries  
Pelagia Shetland Ltd.  
Karmsund Protein AS  
2025  
2024  
2025  
2024  
Total revenue  
1 184 457  
1 123 771  
441 588  
596 903  
Profit/(loss) for the year  
81 347  
45 329  
-10 526  
32 431  
Total assets  
639 872  
410 129  
600 339  
534 427  
Total liabilities  
239 592  
75 174  
336 220  
250 782  
Net assets/(liabilities)  
400 280  
334 955  
264 119  
283 646  
 
Pelagia Holding AS  
NOTE 17  
Current and deferred income tax  
The tax expense comprises current and deferred tax. Tax is recognised in the income statement, unless it relates to items  
recognised in other comprehensive income or directly in equity. In this case, tax is also recognised in other comprehensive  
income or directly in equity.  
Deferred income tax is recognised on temporary differences arising between the tax bases of assets and liabilities and  
their carrying amounts in the consolidated financial statements. Deferred tax liabilities are not recognised if they arise  
from the initial recognition of goodwill. Deferred income tax is not accounted for if it arises from initial recognition of an  
asset or liability in a transaction other than a business combination that at the time of the transaction affects neither  
accounting nor taxable profit or loss. Deferred income tax is determined using tax rates and laws that have been enacted  
or substantively enacted by the balance sheet date and are expected to apply when the related deferred income tax asset  
is realised or the deferred income tax liability is settled.  
Deferred income tax assets are recognised only to the extent that it is probable that future taxable profit will be available  
against which the temporary differences can be utilised. Deferred income tax liabilities are provided on taxable temporary  
differences arising from investments in subsidiaries and associates, except for deferred income tax liability where the  
timing of the reversal of the temporary difference is controlled by Pelagia and it is probable that they will not be reversed  
in the foreseeable future.  
Deferred income tax assets and liabilities are offset when there is a legally enforcable right to offset current tax assets  
against current tax liabilities and the deferred income tax assets and liabilities relate to income taxes levied by the same  
taxation authority on either the same taxable entity or different taxable entities where there is an intention to settle the  
balances on a net basis.  
OECD Pillar Two model rules  
Pelagia Group is within the scope of the OECD Pillar Two Model Rules. Pillar Two legislation came into effect from January  
1, 2024. The group applies the exception to recognising and disclosing information about deferred tax assets and liabilities  
related to Pillar Two income taxes, as provided in the amendments to IAS 12 issued in May 2023.  
Under the legislation, the group is liable to pay a top-up tax for the difference between their effective tax rate per  
jurisdiction and the 15% minimum rate. Based on an internal review last year Pelagia concluded that all entities within the  
group had an effective tax rate that equalled or exceeded 15%, except for Pelagia Feed (Ireland) Ltd where the nominal  
tax rate at the time was 12,5%. Still, based on the new OECD regulation Ireland has implemented a top-up tax for entities  
in-scope, to reach the 15% effective rate. Based on this change Pelagia Feed (Ireland) Ltd has for 2025 provided for a tax  
expense based on an effective tax rate of 15% according to the new legislation in Ireland. The tax expense calculated for  
Pelagia Feed (Ireland) Ltd for 2025 was about 19,5 MNOK.  
As all group entities therefore have calculated an effective tax rate of at least 15% there has been no provision for  
additional top-up taxes at group level as per the end of 2025. Due to the preliminary nature of the calculation’s  
differences may occur when preparing the Pillar Two filing, however any such differences are not assumed to be material.  
 
Pelagia Holding AS  
NOTE 17 CONTINUES  
Tax expense of the year  
2025  
2024  
Tax payable  
-
34 165  
Change in deferred tax  
-89 370  
-11 862  
Previous year adjustment *)  
-27 910  
-
Too much, too little accrued last year/ currency effect tax payable last year  
86 981  
90 714  
Tax expense in P&L  
-30 299  
113 017  
Tax expense in OCI  
-
898  
Tax expense total  
-30 299  
113 915  
*) Previous year adjustment relates to Epax Pharma. Pelagia has been successful in an older tax case as the Tax Appeals  
Committee has awarded the company a deduction for losses on interest receivables that were capped by the Tax  
Admninistration. This concerns a loss deduction from 2016 of 126 MNOK. The related tax on the deduction of  
approximately 27 MNOK has already been paid and reduce tax cost in 2025.  
Reconciliation of statutory tax rate to effective tax rate  
2025  
2024  
Profit before tax  
-18 660  
564 104  
Income tax at statutory tax rate 22%  
-4 105  
124 103  
Impact of lower effective tax rate abroad  
-3 157  
-2 810  
Previous year adjustment *)  
-27 910  
-
Other differences  
4 873  
-8 276  
Tax expense  
-30 299  
113 017  
Tax expense in OCI  
-
898  
Tax expense total  
-30 299  
113 915  
Effective tax rate  
162 %  
20 %  
Weighted nominal tax rate  
39 %  
22 %  
Nominal tax rate for 2025 is 22% in Norway and Denmark, in UK and Ireland 19% and 12.5% respectively.  
Specification of tax impact from temporary differences/losses carried forward:  
2025  
2024  
Property, plant and equipment  
201 023  
192 264  
Inventory  
45 567  
21 792  
Receivables  
-4 171  
-4 971  
Right-of-use leased assets  
99 641  
95 067  
Lease liability  
-100 423  
-95 222  
Pension liability  
-244  
-211  
Other temporary differences  
-8 197  
4 096  
Losses carried forward  
-124 408  
-15 199  
Total  
108 789  
197 615  
Book value deferred tax  
108 789  
197 615  
Losses carried forward relates mainly to tax loss in 2025. The entity had taxable income in 2024 and 2023, losses carried  
forward is expected to be applied against future taxable income.  
 
Pelagia Holding AS  
NOTE 17 CONTINUES  
Specification of changes in deferred tax in the income statement:  
2025  
2024  
Property, plant and equipment  
8 760  
-24 185  
Inventory  
23 776  
9 557  
Receivables  
800  
4 564  
Right-of-use leased assets  
4 575  
12 480  
Lease liability  
-5 201  
-12 811  
Pension liability  
-33  
-22  
Other temporary differences  
-12 837  
-10 472  
Losses carried forward  
-109 210  
9 026  
Total  
-89 370  
-11 862  
Change in book value deferred tax  
2025  
2024  
Opening balance 01.01.  
197 615  
209 478  
Recognised in the income statement in the period  
-89 370  
-11 862  
Deferred tax asset from acquisition  
544  
119  
Other changes  
-
-120  
Closing balance 31.12.  
108 789  
197 615  
Tax payable in the balance sheet  
2025  
2024  
Tax payable in the balance sheet 01.01.  
35 063  
157 093  
Tax payable current year  
-
34 165  
Paid tax current year  
-35 063  
-156 195  
Tax payable in the balance sheet 31.12.  
-
35 063  
Tax payable in the balance sheet 01.01.  
35 063  
157 093  
Payment/ repayment of tax on advance  
86 981  
90 714  
Total taxes paid in the cash flow statement  
122 044  
247 807  
NOTE 18  
Borrowings  
Non-current  
2025  
2024  
Bank loan  
2 648 004  
2 553 444  
Bond loan  
1 982 265  
989 584  
Lease liability  
111 860  
92 546  
Total  
4 742 129  
3 635 573  
Current  
First year's instalment non-current liabilities  
225 245  
1 139 862  
First year's instalment lease  
36 195  
16 129  
Bank loan and current overdraft facilities  
2 049 844  
1 417 590  
Total  
2 311 285  
2 573 580  
*Bank loan and bond loan are recognised at amortised cost. Transaction costs are accrued according to the effective interest rate-method.  
See note 4 for further information about financial risk management.  
 
Pelagia Holding AS  
NOTE 18 CONTINUES  
Carrying value and fair value of non-current borrowings:  
Carrying value of Pelagia's borrowings is approximately equal to fair value, as the interest level reflects market conditions.  
Interest terms:  
Pelagia's interest terms are NIBOR plus margin. Margin is calculated based on equity ratio and the ratio between EBITDA  
divided on net interest expenses
(interest coverage ratio).  
Currency:  
Pelagia's long-term debt is in NOK.  
Corporate account arrangement:  
Most companies in the group participate in a multi-currency corporate account arrangement where the parent company  
Pelagia Holding AS is the main account holder. All participants are
jointly and severally liable for the outstanding at the  
corporate account arrangement at any time. The corporate account arrangement is a multi-currency drawing facility. Net  
deposits are presented as cash and cash equivalents. Any bank overdrafts at the balance sheet date are classified as  
current liabilities to credit institutions.  
The group had the following currency exposure connected to the corporate account arrangement per 31.12.2025  
(amount in 1000):  
Exchange  
Currency  
Currency amount  
rate 31.12  
NOK 31.12  
NOK  
-230 859  
1,0000  
-230 859  
DKK  
-221 667  
1,5811  
-350 478  
EUR  
-44 822  
11,8159  
-529 614  
GBP  
-43 105  
13,5383  
-583 572  
JPY  
1 135 617  
0,0642  
72 917  
SEK  
-7 096  
1,0916  
-7 746  
USD  
-30 971  
10,0605  
-311 584  
Total deposit on corporate account  
-1 940 936  
The balance on the group account is presented net in the balance sheet as a result of the net deduction on the group  
account scheme being considered to be a single financial instrument originating in a contract.  
In addition to the corporate account arrangement, one of the subsidiaries has a bank overdraft of MNOK 109, total  
current debt to financial institutions is MNOK 2.050.  
 
Pelagia Holding AS  
NOTE 18 CONTINUES  
Repayment profile interest bearing debt  
Overdraft  
Bank loan  
Bond loan  
Lease liability  
facility  
Total  
2026  
225 245  
-4 682  
36 195  
2 049 844  
2 306 603  
2027  
2 612 293  
-4 682  
32 309  
-
2 639 920  
2028  
7 142  
-4 682  
11 357  
-
13 817  
2029  
7 142  
997 402  
11 357  
-
1 015 901  
2030  
7 142  
998 909  
11 357  
-
1 017 408  
Later  
14 285  
-
45 480  
-
59 765  
Total  
2 873 249  
1 982 265  
148 055  
2 049 844  
7 053 414  
For further description of the group's financing, see note 4.  
For summary of assets pledged as security and guarantees, see note 20.  
Change in liabilities related to financing  
Overdraft  
Bank loan  
Bond loan  
Lease liability  
facility  
Total  
31.12.2023  
2 684 607  
895 860  
101 275  
1 073 851  
4 755 593  
Cash flow changes  
Instalment leasing debt  
-
-
-16 554  
-
-16 554  
Downpayment of debt  
-90 030  
-
-
-
-90 030  
Raising of new debt  
200 000  
1 000 000  
-
-
1 200 000  
Transaction cost  
-1 000  
-12 500  
-
-
-13 500  
Net change bank overdraft  
-
-
-
343 739  
343 739  
Non cash changes  
Raising of new leasing debt  
-
-
23 954  
-
23 954  
Amortising of transaction costs  
1 708  
4 243  
-
-
5 951  
31.12.2024  
2 795 285  
1 887 603  
108 675  
1 417 590  
6 209 154  
Cash flow changes  
Instalment leasing debt  
-
-
-33 755  
-
-33 755  
Downpayment of debt  
-1 973 750  
-338 400  
-
-
-2 312 150  
Raising of new debt  
2 050 000  
438 400  
-
-
2 488 400  
Transaction cost  
-400  
-24 600  
-
-
-25 000  
Net change bank overdraft  
-
-
-
632 255  
632 255  
Non cash changes  
Raising of new leasing debt  
-
-
73 136  
-
73 136  
Amortising of transaction costs  
2 113  
19 261  
-
-
21 374  
31.12.2025  
2 873 249  
1 982 265  
148 055  
2 049 844  
7 053 414  
Specification of financial income and financial expenses  
2025  
2024  
Total financial income  
-
-
Interest expenses borrowings  
315 682  
340 077  
Change in fair value of interest rate swap  
15 557  
-31 897  
Interest expenses financial lease  
4 153  
1 199  
Other financial expenses  
32 462  
3 840  
Total financial expenses  
367 854  
313 218  
Total net financial items  
-367 854  
-313 218  
 
Pelagia Holding AS  
NOTE 19  
Leases  
Leases where the company has control of an identified asset when determining the use and receiving the financial  
benefits, are recognised in the balance sheet from the time the company gains control of the asset in accordance with  
IFRS 16. The lease liability is measured at the present value of future fixed lease payments corresponding to the associated  
right of use of the asset. The discount rate used is equal to the company’s marginal borrowing rate. As basis for  
determining the lease term is used the irrevocable lease term adjusted for extension options that are reasonably certain  
that the company will exercise. Judgement is applied in assessing the discount rate and the probability of exercise of  
extension options. Each lease payment is allocated between interest expense and liability instalment. See note 3 for  
information about undiscounted lease payments.  
Depreciation period for the right of use of assets is determined based on estimated useful life of the asset and the lease  
term and in accordance with Pelagia’s other depreciation policies. Pelagia has chosen to make use of the recognition  
exceptions for short-term leases and leases where the underlying asset has low value. Leases with lease term twelve  
months or less have not been recognised in the balance sheet but recognised as expense directly in the income statement.  
The same applies for leases where the underlying asset has value lower than NOK 50 000. See note 7 for cost of short-  
term and low value leases. Pelagia’s right of use assets are related to long term rental of offices and production facilities.  
Carrying amount  
The following amounts have been recognised in the company's balance sheet:  
Right of use leased assets  
2025  
2024  
Property, including production facilities  
143 761  
105 499  
Total  
143 761  
105 499  
Lease liabilities  
2025  
2024  
Current  
36 195  
16 129  
Non-current  
111 860  
92 546  
Total  
148 056  
108 675  
Maturity structure lease liability  
Property, incl.  
Production  
Total lease  
Discounted cash flows  
facilities  
liability  
Less than 1 year (next year)  
36 195  
36 195  
1-5 years  
66 380  
66 380  
Over 5 years  
45 480  
45 480  
Total lease liability  
148 055  
148 055  
Items in the income statement
- Depreciation and interest expenses  
The income statement presents the following amounts related to the lease liabilities:  
Depreciation related to right of use assets  
2025  
2024  
Property, including production facilities  
24 017  
10 362  
Total depreciation  
24 017  
10 362  
Interest expenses  
Interest expense on lease liability  
4 153  
1 199  
 
Pelagia Holding AS  
NOTE 20  
Mortgage- and guarantees  
2025  
2024  
Book value of secured debt  
4 923 094  
4 210 895  
Book value of mortgaged assets  
2025  
2024  
Land, buildings and other real property  
1 568 688  
1 428 900  
Plant and equipment  
2 311 702  
2 475 335  
Ships  
544 105  
557 907  
Receivables and other financial instruments  
1 190 464  
1 579 490  
Inventory  
4 661 385  
3 904 123  
Total  
10 276 344  
9 945 755  
NOTE 21  
Transactions with related parties  
Pelagia is owned 50% by Austevoll Seafood ASA and 50% by Kvefi AS (Pelagia is considered a joint venture between  
the two owners). The majority of transactions between Pelagia and its owners relate to purchase and sale of fish.  
The following transactions were accomplished between related parties:  
a) Sale of goods and services  
2025  
2024  
- Austevoll Seafood ASA and its related parties  
35 117  
34 085  
- Kvefi AS and its related parties  
38 520  
76 090  
Total  
73 637  
110 175  
b) Purchase of goods and services  
2025  
2024  
- Austevoll Seafood ASA and its related parties  
230 608  
306 002  
- Kvefi AS and its related parties  
4 064  
15 593  
Total  
234 672  
321 594  
c) Trade receivable and trade payable balances  
2025  
2024  
Trade receivables related parties  
- Austevoll Seafood ASA and its related parties  
-
-
- Kvefi AS and its related parties  
-
-
Total  
-
-
Trade payables to related parties  
- Austevoll Seafood ASA and its related parties  
-
-
- Kvefi AS and its related parties  
-
-
Total  
-
-
There have been no material transactions with related parties other than those stated in the table above.  
 
Pelagia Holding AS  
NOTE 22  
The acquisition method of accounting is used to account for business combinations by the Group. The  
consideration transferred for the acquisition of a subsidiary is the fair values of the assets transferred, the  
liabilities incurred to the former owners of the acquiree and the equity instruments issued by the Group. The  
consideration transferred also includes the fair value of any asset or liability resulting from a contingent  
consideration arrangement. Identifiable assets, liabilities and contingent liabilities are recognised at their fair  
values at the acquisition date. Non-controlling interests in the acquiree are measured either at their fair values  
or their share of the acquiree’s net assets.  
Acquisition-related costs are expensed as incurred.  
If the acquisition is achieved in stages, the acquisition date carrying value of the acquirer’s previously held  
equity interests in the acquiree is re-measured to fair value at the acquisition date, any gains or losses arising  
from such re-measurement are recognised in profit or loss.  
Any contingent consideration is recognised at fair value at the acquisition date. Contingent consideration that is  
classified as equity is not re-measured, and its subsequent settlement is accounted for within equity. Other  
contingent consideration is measured continuously at fair value in profit or loss.  
If the consideration (including any non-controlling interests and fair value of previously held equity) exceeds fair  
value of identifiable assets and liabilities acquired, it is recognised as goodwill. If the consideration(including any  
non-controlling interests and fair value of previously held equity) amounts to less than fair value of net assets in  
the subsidiary as a consequence of an acquisition on favorable terms, the difference is accounted for as gain in  
the income statement.  
Aquisition Fjord Solutions AS  
Pelagia signed a Share Purchase Agreement to purchase 100% of the shares in Fjord Solutions AS 28 May 2025.  
The acquisition was made with an accounting effective date for the Group of 01.06.2025. The acquisition is  
made at fair value. The table below shows the contribution divided on acquired assets and liabilities.  
NOK (1000)  
Contribution  
01.06.2025  
Cash contribution  
28 251  
Total contribution for new owner share (100%)  
28 251  
Carrying value of identifiable assets and liabilities as a result of the acquisition  
Identified intangible assets  
1 804  
Tangible fixed assets  
418  
Other current receivables  
171  
Cash, bank and marketable securities  
68  
Other interest bearing liabilities  
-6 258  
Accounts payable  
-2 933  
Other current liabilities  
-151  
Total identifiable net assets  
-6 881  
 
Pelagia Holding AS  
NOTE 22 CONTINUES  
Calculation of excess value  
Contribution for shares (100%)  
28 251  
Transaction value  
28 251  
Net interest bearing liabilities  
-6 190  
Fair value of the operations  
34 441  
Book value of the equity at the acquisition  
-6 881  
Identified Goodwill  
-
Identified intangible assets  
35 677  
Deferred tax  
-544  
Total  
28 251  
No material contingent contributions or contingent liabilities are connected to the acquisition.  
Aquisition Kalvøya Utvikling AS  
Pelagia AS has in 2025 acquired the remaining 85,71% of the company Kalvøya Utvikling AS from the other  
shareholders and as of 31.12.25 owns 100% of the company. The acquisition has been made at fair value,  
MNOK 2,4.  
NOTE 23  
Subsequent events  
There are no subsequent events that could have a material impact on the financial statements presented.  
NOTE 24  
Other matters  
In October 2024, the group lost a court case in the District Court related to the delivery of wastes and by-  
products from production in the HEALTH division. Due to the development of the product portfolio, a smaller  
volume has been sold under contract to the buyer of by-products. Due to the reduction in the delivered volume  
under the contract, the company was sentenced to pay the customer compensation of NOK 53 million including  
costs and interest. The appeal trial was scheduled for Q1 26, but the parties have now entered into a  
collaboration business/sales contract and have jointly agreed that this new agreement settles all the issues of  
the ongoing litigation regarding the parties' previous business/sales agreement with immediate effect.  
 
PELAGIA HOLDING AS  
FINANCIAL STATEMENTS 2025  
 
Pelagia Holding AS  
INCOME STATEMENT  
Amounts in NOK 1.000  
Note  
2025  
2024  
Other operating expenses  
2
11 064  
4 543  
Operating profit  
-11 064  
-4 543  
Profit from investment in subsidiaries  
Finance income  
Finance costs  
3
4
4, 5  
200 000  
336 885  
512 931  
23 953  
244 000  
372 552  
471 001  
145 551  
Net finance  
Profit before taxes  
Income tax expense  
Net profit  
12 889  
-41 233  
54 123  
141 008  
21 488  
6
119 519  
STATEMENT OF COMPREHENSIVE INCOME  
Profit for the period  
Other comprehensive income  
Total comprehensive income  
54 123  
-
54 123  
119 519  
-
119 519  
Transfers:  
Allocated dividend  
Transferred other equity  
Total transfers  
-
54 123  
54 123  
200 000  
-80 481  
119 519  
7
 
Pelagia Holding AS  
BALANCE SHEET PER 31.12  
Amounts in NOK 1.000  
Assets  
Note  
2025  
2024  
Non-current assets  
Deferred tax asset  
Total intangible assets  
6
33 609  
-
33 609  
-
Investment in subsidiaries  
Loans to group companies  
Total financial assets  
3, 8 3 103 887  
2 394 012  
682 572  
3 076 584  
8, 9  
-
3 103 887  
Total non-current assets  
3 137 496  
3 076 584  
Current assets  
Other current receivables  
Derivatives  
Cash and cash equivalents  
Total current assets  
8, 9 5 089 895  
4 554 413  
16 529  
-
5
8 539  
-
5 098 433  
4 570 942  
Total assets  
8 235 929  
7 647 526  
 
Pelagia Holding AS  
BALANCE SHEET PER 31.12  
Amounts in NOK 1.000  
Equity and liabilities  
Note  
2025  
2024  
Share capital  
Share premium  
Other equity  
Total equity  
7, 10  
149 836  
1 222 878  
118 779  
149 836  
1 222 878  
64 656  
7
7
1 491 493  
1 437 370  
Liabilities  
Deferred tax liabilities  
Total non-current liabilities  
6
-
-
7 625  
7 625  
Bond loan  
Liabilities to financial institutions  
Total other non-current liabilities  
8
8
1 982 265  
2 595 981  
4 578 246  
987 603  
2 494 268  
3 481 871  
First year's instalment non-current liabilities  
Current debt to financial institutions  
Trade payables  
8
100 000  
1 000 000  
1 417 589  
349  
8, 9 1 940 936  
156  
Tax payable  
Dividend  
Other current liabilities  
Total current liabilities  
6
7
-
-
16 191  
200 000  
86 530  
8, 9, 11  
125 097  
2 166 190  
2 720 660  
Total liabilities  
6 744 436  
8 235 929  
6 210 156  
7 647 526  
Total equity and liabilities  
Bergen, April 29, 2026  
___________________  
Helge Singelstad  
Chairman of the board  
___________________  
Endre Sekse  
Board member  
___________________  
Karoline Bjoland  
Board member  
___________________  
Egil Magne Haugstad  
CEO  
___________________  
Britt Kathrine Drivenes  
Board member  
___________________  
Helge Karstein Moen  
Board member  
 
Pelagia Holding AS  
STATEMENT OF CASH FLOWS  
Amounts in NOK 1.000  
Note  
2025  
2024  
Cash flows form operating activities  
Result before tax expense  
Adjusted for:  
12 889  
141 008  
- Taxes paid  
- Dividends and group contribution recognised  
- Interest expenses net  
- Fair value adjustment derivatives  
- Change trade payables  
6
3
4
5
-16 191  
-200 000  
131 832  
7 990  
-98 261  
-244 000  
107 278  
-16 529  
-455  
-193  
- Change other accruals  
Net cash flow from operating activities  
21 493  
-42 180  
12  
-110 947  
Cash flows from investing activities  
Dividends and group contribution received  
Net change loans to subsidiaries  
Interest received  
3
244 000  
-579 600 -1 585 635  
309 575  
735 000  
330 472  
Net cash flows from investing activities  
-26 025  
-520 163  
Cash flows from financing activities  
Raising of non-current liabilities  
Repayment of non-current liabilities  
Net change bank overdraft  
Net change loans from subsidiaries  
Interest paid  
8
8
8
8
4
2 463 400  
-2 288 400  
523 347  
25 346  
-455 487  
-200 000  
68 205  
1 200 000  
-57 549  
343 986  
22 267  
-477 593  
-400 000  
631 111  
Dividends paid to shareholders  
Net cash flows from financing activities  
Change in cash and cash equivalents net  
-
-
-
-
-
-
Net cash and cash equivalents as at 1st of January  
Net cash and cash equivalents per 31st of December  
 
Pelagia Holding AS  
NOTE 1  
Note 1 Accounting policies  
General information  
All amounts are in NOK 1,000 unless otherwise stated.  
Pelagia Holding
AS
is the parent company in Pelagia Group.
Pelagia is a group within production, sale and
 
distribution of fish meal/fish oil and pelagic fish for consumption.
Pelagia is an important party within pelagic  
sector in the North Atlantic. The main office is in
Bergen
.  
Framework for the preparation of the financial statements  
The financial statements of
Pelagia Holding AS
have been prepared in accordance with Regulation of January 21st  
2008 on simplified application of International Financial Reporting Standards (simplified IFRS), hereunder the  
latest amendments to this regulation, Regulation of December 16th. 2024 with effect from January 1st 2022.  
In accordance with the exception in §3-1 no 3 of the regulations, dividends and group contributions from  
subsidiaries are recognized in the same year in which the subsidiary allocates the amount. Statement of changes  
in equity is not included, note information of changes in equity is provided in accordance with the rules of the  
Norwegian Accounting Act.  
The financial statements have been prepared under the going concern assumption.  
Revenue recognition  
Services are recognised as they are earned.  
Classification of balance sheet items  
Assets intended for permanent ownership or use are classified as non-current assets. Assets related to the supply  
chain are classified as current assets. Other receivables are classified as current assets if they are repayable  
within one year. Similar criteria are applied to liabilities.  
Derivatives  
Derivatives are measured at fair value with value changes through profit or loss.  
Cash flow statement  
The cash flow statement is prepared using the indirect method. Cash and cash equivalents include bank deposits  
and other short-term liquid investments that are readily convertible to known amounts of cash at an insignificant  
risk and have a remaining maturity of less than three months from the date of acquisition.  
New and amended standards implemented in 2025  
The accounting policies adopted are consistent with those of the previous financial year, except for the  
amendments to IFRS which have been implemented by the entity during the current financial year. Below we  
have listed the amendments in IFRS which have been applicable for the 2025 financial statements:  
- Amendments to IAS 21 - Lack of Exchangeability  
These amendments have not had a material impact on the entity's financial statements in the current reporting  
 
Pelagia Holding AS  
NOTE 1 CONTINUES  
New standards and interpretations not yet adopted  
The entity has not early adopted any accounting standard, interpretation or amendment that has been issued  
but is not yet effective. The entity will adopt new amendments and interpretations, if relevant, when they  
become effective. Below is a list of new amendments not yet effective:  
- Amendments to IFRS 7 and IFRS 9 - Classification and measurement of financial instruments. These  
amendments are not expected to have a material impact on the entity's financial statements.  
- IFRS 18 - Presentation and Disclosure in Financial Statements, effective for accounting periods beginning on or  
after 1 January 2027. IFRS 18 introduces three defined categories to provide a consistent structure of the  
statement of profit og loss and new mandatory subtotals in the income statement. In addition, the standard  
introduces requirements for disclosures related to management-defined performance measures (MPMs).  
Implementation of IFRS 18 will require changes in the presentation of the entity's income statement, mainly  
 
Pelagia Holding AS  
NOTE 2  
Remuneration and other benefits  
The company has no employees. The CEO is employed by the subsidiary Pelagia AS and receives a salary from  
there. No loans/guarantees have been granted to the CEO or Chairman of the Board. No Board of Directors' fee  
has been paid.  
Auditor:  
Auditor's fees exclusive of vat.  
Statutory audit  
Other certification services  
Tax consultancy  
2025  
1 194  
2 929  
115  
2024  
1 233  
607  
105  
Services other than audit  
Total  
-
711  
2 655  
4 238  
NOTE 3  
Investment in subsidiaries  
The cost method is used for investments in subsidiaries. The cost price is increased when funds are added  
through a capital increase or when a group contribution is made to a subsidiary. Distributions received are  
initially recognized as income. Distributions that exceed the share of retained earnings after the acquisition are  
recognized as a reduction of the acquisition cost. Dividends/group contributions from subsidiaries are recognized  
in the same year in which the subsidiary allocates the amount.  
Registered  
office  
Bergen  
Owner  
share  
100 % 3 884 711  
Equity  
(100%)  
Net profit  
(100 %) Book value  
Subsidiary  
Pelagia AS  
Total  
54 899  
3 103 887  
3 103 887  
Profit from investment in subsidiaries  
Dividend  
Group contribution  
2025  
200 000  
-
2024  
44 000  
200 000  
244 000  
Total profit from investment in subsidiaries  
200 000  
NOTE 4  
Specification of financial income and financial expenses  
Financial income  
2025  
309 261  
27 303  
321  
2024  
330 472  
38 636  
3 444  
Interest income corporate account arrangement  
Interest from group companies on long term receivables  
Other financial income  
Total  
336 885  
372 552  
Financial expenses  
Interest expenses borrowings and corporate account arrangement  
Change in fair value of interest rate swap  
Other financial expenses  
Total  
2025  
318 415  
7 990  
186 525  
512 931  
2024  
486 863  
-16 529  
667  
471 001  
 
Pelagia Holding AS  
NOTE 5  
Financial instruments  
Pelagia's debt is subject to floating rate of interest. This involves that Pelagia is exposed to liquidity risk as a result  
of changes in the market interest rates. In order to manage the interest rate risk Pelage use interest rate swap  
agreements. As of 31.12.2025 Pelagia has entered into the following interest rate swap, where the company pays  
a fixed interest rate of 3,53 % and receives a floating interest rate of 3-month NIBOR:  
Maturity  
date  
Nominal  
amount Fair value  
Change in  
fair value  
-7 990  
Instrument  
Interest rate swap  
Start date  
29.08.2024 29.08.2027 1 200 000  
8 539  
NOTE 6  
Tax  
The tax expense in the income statement includes both the tax payable for the period and the change in  
deferred tax. Deferred tax is calculated at the current tax rate on the basis of the temporary differences that  
exist between accounting and tax values, as well as any tax losses carried forward at the end of the financial year.  
Tax-increasing and tax-reducing temporary differences that reverse or may reverse in the same period are offset.  
The recognition of deferred tax assets on net tax-reducing differences that have not been settled and losses  
carried forward is justified on the basis of expected future earnings. Deferred tax and tax assets that can be  
capitalised are recorded net in the balance sheet.  
Tax on any group contribution received that is recognized as a reduction of cost or directly against equity is  
recognized directly against tax in the balance sheet (against tax payable if the group contribution effects tax  
payable and against deferred tax if the group contribution effects deferred tax).  
The recognition of deferred tax assets on net unrecognized tax losses and tax losses carried forward is justified  
on the basis of expected future earnings. Deferred tax and tax assets that can be capitalized are recognized net  
in the balance sheet.  
Deferred tax  
Temporary differences  
2025  
30 292  
30 292  
-183 059  
-152 767  
2024  
34 658  
34 658  
-
Other temporary differences  
Net temporary differences  
Losses carried forward  
Basis for deferred tax / (tax asset)  
34 658  
Deferred tax / (tax asset) 22 % in the balance sheet  
-33 609  
7 625  
Basis for tax expense, change in deferred tax and tax payable  
Profit before taxes  
Dividend received  
Other permanent differences  
Basis for this years tax expense  
Change in temporary differences  
Change in losses carried forward  
2025  
12 889  
-200 000  
7 677  
-179 434  
-3 625  
-
2024  
141 008  
-44 000  
17 196  
114 203  
-40 607  
-
Basis for tax expense in the financial statement  
÷ Group contribution  
-183 059  
-
73 597  
-
Taxable income (basis for tax payable in the balance sheet)  
-183 059  
73 597  
 
Pelagia Holding AS  
NOTE 6 CONTINUES  
Specification of the tax expense  
Tax payable from this years profit  
Too much, too little accrued last year  
Tax payable total  
Change in deferred tax / (tax asset)  
Tax expense  
2025  
2024  
16 191  
-
16 191  
5 297  
21 488  
-
-
-
-41 233  
-41 233  
Reconciliation of this years tax expense  
Profit before tax  
Income tax at statutory tax rate 22 %  
Tax expense in the financial statement  
Difference  
12 889  
2 836  
-41 233  
-44 069  
141 008  
31 022  
21 488  
-9 533  
The difference consists of the following:  
22 % of non taxable dividend  
22 % of other permanent differences  
Other differences  
-44 000  
1 689  
-1 758  
-44 069  
-9 680  
3 783  
-3 636  
-9 533  
Total explained difference  
NOTE 7  
Equity  
Share  
capital  
149 836  
-
Share  
premium  
1 222 878  
-
Other  
equity  
64 656  
54 123  
118 779  
Movement in equity  
Equity 01.01.  
Result for the period  
Equity 31.12.  
Total  
1 437 370  
54 123  
149 836  
1 222 878  
1 491 493  
 
Pelagia Holding AS  
NOTE 8  
Receivables and liabilities  
Receivables  
Other receivables, both current and non-current, are stated at the lower of nominal value and fair value. Fair  
value is the present value of expected future cash flows. No discounting is applied when the effect of discounting  
is immaterial to the financial statements.  
Receivables due in later than one year  
Loan Pelagia AS  
2025  
2024  
682 572  
-
The loan was interest-bearing and instalment-free until 31.12.2028.  
In 2025 the loan was converted to equity in Pelagia AS.  
Liabilities  
Liabilities, except of certain provisions for liabilities, are capitalized at the nominal amount of the liability.  
Non-current liabilities  
Bond loan  
Liabilities to financial institutions  
Total  
2025  
1 982 265  
2 595 981  
4 578 246  
2024  
987 603  
2 494 268  
3 481 871  
Current liabilities  
First year's instalment non-current liabilities  
Current debt to financial institutions  
Total  
100 000  
1 940 936  
2 040 936  
1 000 000  
1 417 589  
2 417 589  
Liabilities to financial institutions and bond loan are accounted for at amortized cost.  
Transaction costs are accrued using the effective interest method.  
Book value and fair value of non-current liabilities:  
Book value of non-current liabilities is approximately equal to fair value, as interest rates reflect market conditions  
Interest rate:  
Pelagia Holdings interest rate terms are NIBOR plus margin. Margin is calculated based on equity ratio and the  
ratio of EBITDA over net interest cost (interest coverage ratio).  
Currency  
Pelagia Holdings non-current liabilities are nominated in NOK.  
 
Pelagia Holding AS  
NOTE 8 CONTINUES  
Corporate account arrangement:  
Most companies in the group participate in a multi-currency corporate account arrangement where the parent  
company Pelagia Holding AS is the main account holder. All participants are jointly and severally liable for the  
outstanding at the corporate account arrangement at any time.  
The group had the following currency exposure connected to the corporate account arrangement per 31.12.2025:  
Exchange  
Currency  
Currency amount rate 31.12 NOK 31.12  
NOK  
DKK  
EUR  
GBP  
-230 859  
-221 667  
-44 822  
-43 105  
-7 096  
1,0000  
1,5811  
11,8159  
13,5383  
1,0916  
-230 859  
-350 478  
-529 614  
-583 572  
-7 746  
SEK  
USD  
JPY  
-30 971  
1 135 617  
10,0605  
0,0642  
-311 584  
72 917  
Total deposit on corporate account  
-1 940 936  
The balance on the group account is presented net in the balance sheet as a result of the net deduction on the  
group account scheme being considered to be a single financial instrument originating in a contract.  
Repayment profile interest bearing debt  
Overdraft  
Bank loan Bond loan  
facility  
1 940 936  
Total  
2 040 936  
2 600 000  
-
2026  
2027  
2028  
100 000  
2 600 000  
-
-
-
-
-
-
2029  
2030  
Later  
Total  
-
-
-
1 000 000  
1 000 000  
-
2 000 000  
-17 735  
1 982 265  
-
-
1 000 000  
1 000 000  
-
6 640 936  
-21 754  
6 619 183  
-
1 940 936  
-
2 700 000  
-4 019  
2 695 981  
Amortised transaction costs  
Total book value  
1 940 936  
Change in liabilities related to financing  
Overdraft  
facility  
Bank loan Bond loan  
Total  
2 443 560  
895 860  
1 073 603  
4 413 023  
31.12.2023  
Repayment of debt  
Raising of new loan  
Transaction costs  
Amortising of transaction costs  
Net payment to corporate account  
31.12.2024  
-50 000  
200 000  
-1 000  
1 708  
-
-
-
-
-
-50 000  
1 200 000  
-13 500  
5 951  
343 986  
5 899 461  
1 000 000  
-12 500  
4 243  
-
-
343 986  
1 417 589  
2 594 267  
1 887 603  
Repayment of debt  
Raising of new loan  
Transaction costs  
Amortising of transaction costs  
Net payment to corporate account  
31.12.2025  
-1 950 000  
2 050 000  
-400  
-338 400  
438 400  
-24 600  
19 261  
-
-
-
-
-
-2 288 400  
2 488 400  
-25 000  
21 374  
523 347  
6 619 183  
2 113  
-
523 347  
1 940 936  
2 695 981  
1 982 264  
 
Pelagia Holding AS  
NOTE 8 CONTINUES  
The financing consists of rolling credit facility (RCF) of MNOK 2 800, as of 31.12.2025 the RCF is drawn by MNOK  
2 700. In addition a current multi-currency credit facility of MNOK 2 000 has been established, this is drawn by  
MNOK 1 941, the credit facility was temporarily increased to 2 400 until 27 April 2026.  
The covenants consist of demands to equity ratio above 30% and interest cover ratio (EBITDA / net finance  
charges) no less than 2.5x in the consolidated financial statements of Pelagia Holding AS. The multi-currency  
agreement is short term by nature, otherwise committed until 2027 as part of the same financing agreement as  
the RCF, renewed in November 2022 with maturity in 2027.  
Pelagia Holding AS issued a bond loan in 2024 of MNOK 1 000 with maturity in 2029. In January 2025 the entity  
issued a new 1 000 MNOK bond loan with maturity in 2030. Both bond loans bears an interest of 3m NIBOR +  
2.75% p.a. Pelagia Holding AS had a bond loan from 2020 of MNOK 900, this loan was settled in 2025.  
The same covenants as for the RCF apply to the new bond loans, equity ratio above 30% and interest cover ratio  
no less than 2.5x.  
The covenants are met.  
2025  
2024  
Book value of secured debt  
4 636 917  
4 911 857  
Book value of mortgaged assets  
Investment in subsidiaries  
Loans to group companies  
Other receivables  
2025  
3 103 887  
0
5 089 895  
8 193 782  
2024  
2 394 012  
682 572  
4 554 413  
7 630 997  
Total  
NOTE 9  
Intercompany balances  
Receivables from group companies  
Non-current loans  
2025  
-
2024  
682 572  
Dividends and group contribution  
Receivables from corporate account arrangement  
Total  
200 000  
4 889 837  
5 089 837  
244 000  
4 310 238  
5 236 810  
Liabilities to group companies  
Liabilities from corporate account arrangement  
Total  
2025  
86 079  
86 079  
2024  
60 733  
60 733  
*Pelagia Holding AS is the main account holder for the corporate account arrangement. Group companies bank  
overdraft and deposits included in the corporate account arrangement are presented accordingly as current  
receivables and other current liabilities.  
 
Pelagia Holding AS  
NOTE 10  
Share capital  
The share capital of NOK 149 835 600 is composed of 149 835 600 shares of NOK 1.  
Owner/  
Shareholder structure 31.12  
Austevoll Seafood ASA  
Kvefi AS  
Holdings voting share  
74 917 800  
74 917 800  
149 835 600  
50 %  
50 %  
100 %  
Total  
NOTE 11  
Specification of current liabilities  
Other current liabilities  
Incurred interest  
Corporate account arrangement overdraft  
Total  
2025  
39 018  
86 079  
125 097  
2024  
25 796  
60 733  
86 530  
NOTE 12  
Subsequent events  
There are no subsequent events that could have a material impact on the financial statements presented.  
 
To the General Meeting of Pelagia Holding AS  
Independent Auditor’s Report  
Report on the Audit of the Financial Statements  
Opinion  
We have audited the financial statements of Pelagia Holding AS, which comprise:  
•
the financial statements of the parent company Pelagia Holding AS (the Company), which comprise the balance  
sheet as at 31 December 2025, the income statement, statement of comprehensive income and statement of  
cash flows for the year then ended, and notes to the financial statements, including a summary of significant  
accounting policies, and  
•
the consolidated financial statements of Pelagia Holding AS and its subsidiaries (the Group), which comprise the  
balance sheet as at 31 December 2025, the income statement, statement of comprehensive income, statement  
of changes in equity and statement of cash flows for the year then ended, and notes to the financial statements,  
including material accounting policy information.  
In our opinion  
•
•
the financial statements comply with applicable statutory requirements,  
the financial statements give a true and fair view of the financial position of the Company as at 31 December  
2025, and its financial performance and its cash flows for the year then ended in accordance with simplified  
application of international accounting standards according to section 3-9 of the Norwegian Accounting Act, and  
the consolidated financial statements give a true and fair view of the financial position of the Group as at 31  
December 2025, and its financial performance and its cash flows for the year then ended in accordance with  
IFRS Accounting Standards as adopted by the EU.  
•
Our opinion is consistent with our additional report to the Audit Committee.  
Basis for Opinion  
We conducted our audit in accordance with International Standards on Auditing (ISAs). Our responsibilities under those  
standards are further described in the Auditor’s Responsibilities for the Audit of the Financial Statements section of our  
report. We are independent of the Company and the Group as required by relevant laws and regulations in Norway and  
the International Ethics Standards Board for Accountants’ International Code of Ethics for Professional Accountants  
(including International Independence Standards) (IESBA Code) as applicable to audits of financial statements of public  
interest entities, and we have fulfilled our other ethical responsibilities in accordance with these requirements. We believe  
that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.  
To the best of our knowledge and belief, no prohibited non-audit services referred to in the Audit Regulation (537/2014)  
Article 5.1 have been provided.  
We have been the auditor of Pelagia Holding AS for 13 years from the election by the general meeting of the  
shareholders on 31 May 2013 for the accounting year 2013.  
Key Audit Matters  
Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the  
financial statements of the current period. These matters were addressed in the context of our audit of the financial  
statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters.  
Valuation of inventory has the same characteristics and risks as last year and continues to be a focus area this year.  
PricewaterhouseCoopers AS, org.no.: 987 009 713 MVA, Statsautoriserte revisorer, medlemmer av Den norske Revisorforening og autorisert regnskapsførerselskap  
Advokatfirmaet PricewaterhouseCoopers AS, Org.no.: 988 371 084 MVA, Medlemmer av Advokatforeningen. advokatfirmaet@pwc.com  
PwC Tax Services AS, Org.no.: 962 066 321 MVA, Autorisert regnskapsførerselskap, Medlem av Regnskap Norge  
Torgallmenningen 14, 5014 Bergen, P.O, Box 3984 - Sandviken, NO-5835 Bergen, T: 02316 (+47 952 60 000) www.pwc.no  
 
Key Audit Matters  
How our audit addressed the Key Audit Matter  
Valuation of inventory  
The Group's inventory comprises mainly products  
for consumption, fish meal and concentrated oils  
produced from pelagic fish. The inventories are  
distributed throughout multiple locations and  
countries, of which some are administered by  
independent third parties. At the balance sheet  
date, the book value of the Group's inventories was  
TNOK 4 661 385, equivalent to 39% of the Group's  
total assets.  
We obtained an understanding of the Group’s  
policies and internal controls related to determining  
net realisable value of inventories, including  
assessing the need for provisions. We also  
examined whether the principles for calculating the  
provisions were applied consistently year-on-year.  
We obtained and reviewed management’s  
documentation of recognised provision. We tested  
the mathematical accuracy of the model. The  
reasonableness of key assumptions for net  
realisable value was evaluated by comparison to  
actual sales prices in the market close to the  
balance sheet date. Through discussions with  
management, we challenged their use of  
judgement relating to uncertainty of expected sale  
prices, because of market risk and turnover rates.  
Consistent use of principles year-on-year was also  
an important part of our discussions with  
management.  
The Group measures its inventories according to  
IAS 2 Inventories. Measurement according to IAS 2  
implies valuation of inventories at the lower of  
acquisition cost and net realisable value. The  
Group’s assessment of net realisable value is  
mainly based on realised prices in the market close  
to the balance sheet date. Factors like age and  
product quality are also emphasized in the  
assessment. A potential provision is also adjusted  
for uncertainty in expected sales prices, related to  
both market risk and turnover rates. A provision of  
TNOK 62 659 was recognised at the balance-sheet  
date.  
Out audit procedures did not uncover material  
misstatements relating to valuation of inventories.  
We read the notes to the financial statements and  
found that the disclosures given were sufficient and  
appropriate.  
We focused on valuation of inventory because  
inventory is a substantial item in the balance sheet,  
and due to management’s use of judgement in  
measuring its net realisable value.  
See notes 3 and 12 to the consolidated financial  
statements for further information on  
management’s valuation of inventory.  
Other Information  
The Board of Directors and the Managing Director (management) are responsible for the information in the Board of  
Directors’ report and the other information accompanying the financial statements. The other information comprises  
information in the annual report, but does not include the financial statements and our auditor’s report thereon. Our  
opinion on the financial statements does not cover the information in the Board of Directors’ report nor the other  
information accompanying the financial statements.  
In connection with our audit of the financial statements, our responsibility is to read the Board of Directors’ report and the  
other information accompanying the financial statements. The purpose is to consider if there is material inconsistency  
between the Board of Directors’ report and the other information accompanying the financial statements and the financial  
statements or our knowledge obtained in the audit, or whether the Board of Directors’ report and the other information  
accompanying the financial statements otherwise appears to be materially misstated. We are required to report if there is  
a material misstatement in the Board of Directors’ report or the other information accompanying the financial statements.  
We have nothing to report in this regard.  
Based on our knowledge obtained in the audit, it is our opinion that the Board of Directors’ report  
•
•
is consistent with the financial statements and  
contains the information required by applicable statutory requirements.  
Our opinion on the Board of Directors' report applies correspondingly to the statement on Corporate Governance.  
Our opinion on whether the Board of Directors’ report contains the information required by applicable statutory  
requirements, does not cover the Sustainability Statement, on which a separate assurance report is issued.  
2 / 4  
 
Responsibilities of Management for the Financial Statements  
Management is responsible for the preparation of financial statements of the Company that give a true and fair view in  
accordance with simplified application of international accounting standards according to the Norwegian Accounting Act  
section 3-9, and for the preparation of the consolidated financial statements of the Group that give a true and fair view in  
accordance with IFRS Accounting Standards as adopted by the EU. Management is responsible for such internal control  
as management determines is necessary to enable the preparation of financial statements that are free from material  
misstatement, whether due to fraud or error.  
In preparing the financial statements, management is responsible for assessing the Company’s and the Group’s ability to  
continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern  
basis of accounting unless management either intends to liquidate the Group or to cease operations, or has no realistic  
alternative but to do so.  
Auditor’s Responsibilities for the Audit of the Financial Statements  
Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from  
material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion.  
Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with  
ISAs will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are  
considered material if, individually or in aggregate, they could reasonably be expected to influence the economic  
decisions of users taken on the basis of these financial statements.  
As part of an audit in accordance with ISAs, we exercise professional judgment and maintain professional scepticism  
throughout the audit. We also:  
•
identify and assess the risks of material misstatement of the financial statements, whether due to fraud or error.  
We design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient  
and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement resulting  
from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional  
omissions, misrepresentations, or the override of internal control.  
•
obtain an understanding of internal control relevant to the audit in order to design audit procedures that are  
appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the  
Company's and the Group's internal control.  
•
•
evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and  
related disclosures made by management.  
conclude on the appropriateness of management’s use of the going concern basis of accounting and, based on  
the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast  
significant doubt on the Company's and the Group's ability to continue as a going concern. If we conclude that a  
material uncertainty exists, we are required to draw attention in our auditor’s report to the related disclosures in  
the financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based  
on the audit evidence obtained up to the date of our auditor's report. However, future events or conditions may  
cause the Company and the Group to cease to continue as a going concern.  
•
•
evaluate the overall presentation, structure and content of the financial statements, including the disclosures, and  
whether the financial statements represent the underlying transactions and events in a manner that achieves a  
true and fair view.  
obtain sufficient appropriate audit evidence regarding the financial information of the entities or business  
activities within the Group to express an opinion on the consolidated financial statements. We are responsible for  
the direction, supervision and performance of the group audit. We remain solely responsible for our audit opinion.  
We communicate with the Board of Directors regarding, among other matters, the planned scope and timing of the audit  
and significant audit findings, including any significant deficiencies in internal control that we identify during our audit.  
We also provide the Audit Committee with a statement that we have complied with relevant ethical requirements  
regarding independence, and to communicate with them all relationships and other matters that may reasonably be  
thought to bear on our independence, and where applicable, actions taken to eliminate threats or safeguards applied.  
3 / 4  
 
From the matters communicated with the Board of Directors, we determine those matters that were of most significance  
in the audit of the financial statements of the current period and are therefore the key audit matters. We describe these  
matters in our auditor’s report unless law or regulation precludes public disclosure about the matter or when, in extremely  
rare circumstances, we determine that a matter should not be communicated in our report because the adverse  
consequences of doing so would reasonably be expected to outweigh the public interest benefits of such communication.  
Report on Other Legal and Regulatory Requirements  
Report on Compliance with Requirement on European Single Electronic Format (ESEF)  
Opinion  
As part of the audit of the financial statements of Pelagia Holding AS, we have performed an assurance engagement to  
obtain reasonable assurance about whether the financial statements included in the annual report, with the file name pel-  
2025-12-31-en.zip, have been prepared, in all material respects, in compliance with the requirements of the Commission  
Delegated Regulation (EU) 2019/815 on the European Single Electronic Format (ESEF Regulation) and regulation  
pursuant to Section 5-5 of the Norwegian Securities Trading Act, which includes requirements related to the preparation  
of the annual report in XHTML format, and iXBRL tagging of the consolidated financial statements.  
In our opinion, the financial statements, included in the annual report, have been prepared, in all material respects, in  
compliance with the ESEF regulation.  
Management’s Responsibilities  
Management is responsible for the preparation of the annual report in compliance with the ESEF regulation. This  
responsibility comprises an adequate process and such internal control as management determines is necessary.  
Auditor’s Responsibilities  
For a description of the auditor’s responsibilities when performing an assurance engagement of the ESEF reporting, see:  
https://revisorforeningen.no/revisjonsberetninger  
Bergen, 29 April 2026  
PricewaterhouseCoopers AS  
Ole Martin Waage  
State Authorised Public Accountant  
4 / 4  
 
To the General Meeting of Pelagia Holding AS  
Independent Sustainability Auditor’s Limited Assurance Report  
Limited Assurance Conclusion  
We have conducted a limited assurance engagement on the consolidated sustainability statement of Pelagia Holding AS  
(the «Company») included in Sustainability statement of the Board of Directors’ report (the «Sustainability  
Statement»), as at 31 December 2025 and for the year then ended.  
Based on the procedures we have performed and the evidence we have obtained, nothing has come to our attention that  
causes us to believe that the Sustainability Statement is not prepared, in all material respects, in accordance with the  
Norwegian Accounting Act section 2-3, including:  
•
compliance with the European Sustainability Reporting Standards (ESRS), including that the process carried out  
by the Company to identify the information reported in the Sustainability Statement (the «Process») is in  
accordance with the description set out in subsections "Materiality assessment process" and "Climate scenario  
analysis"; and  
•
compliance of the disclosures in "EU Taxonomy Report" of the Sustainability Statement with Article 8 of EU  
Regulation 2020/852 (the «Taxonomy Regulation»).  
Basis for Conclusion  
We conducted our limited assurance engagement in accordance with International Standard on Assurance Engagements  
(ISAE) 3000 (Revised), Assurance engagements other than audits or reviews of historical financial information («ISAE  
3000 (Revised)»), issued by the International Auditing and Assurance Standards Board.  
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our conclusion. Our  
responsibilities under this standard are further described in the Sustainability Auditor’s Responsibilities section of our  
report.  
Our Independence and Quality Management  
We have complied with the independence and other ethical requirements as required by relevant laws and regulations in  
Norway and the International Code of Ethics for Professional Accountants (including International Independence  
Standards) issued by the International Ethics Standards Board for Accountants (IESBA Code), which is founded on  
fundamental principles of integrity, objectivity, professional competence and due care, confidentiality and professional  
behaviour.  
The firm applies International Standard on Quality Management 1, which requires the firm to design, implement and  
operate a system of quality management including policies or procedures regarding compliance with ethical  
requirements, professional standards and applicable legal and regulatory requirements.  
Responsibilities for the Sustainability Statement  
The Board of Directors and the Managing Director (Management) are responsible for designing and implementing a  
process to identify the information reported in the Sustainability Statement in accordance with the ESRS and for  
disclosing this Process in subsections "Materiality assessment process" and "Climate scenario analysis" of the  
Sustainability Statement. This responsibility includes:  
PricewaterhouseCoopers AS, org.no.: 987 009 713 MVA, Statsautoriserte revisorer, medlemmer av Den norske Revisorforening og autorisert regnskapsførerselskap  
Advokatfirmaet PricewaterhouseCoopers AS, Org.no.: 988 371 084 MVA, Medlemmer av Advokatforeningen. advokatfirmaet@pwc.com  
PwC Tax Services AS, Org.no.: 962 066 321 MVA, Autorisert regnskapsførerselskap, Medlem av Regnskap Norge  
Torgallmenningen 14, 5014 Bergen, P.O, Box 3984 - Sandviken, NO-5835 Bergen, T: 02316 (+47 952 60 000) www.pwc.no  
 
•
•
understanding the context in which the Group's activities and business relationships take place and developing  
an understanding of its affected stakeholders;  
the identification of the actual and potential impacts (both negative and positive) related to sustainability matters,  
as well as risks and opportunities that affect, or could reasonably be expected to affect, the Group’s financial  
position, financial performance, cash flows, access to finance or cost of capital over the short-, medium-, or long-  
term;  
•
•
the assessment of the materiality of the identified impacts, risks and opportunities related to sustainability  
matters by selecting and applying appropriate thresholds; and  
making assumptions that are reasonable in the circumstances.  
Management is further responsible for the preparation of the Sustainability Statement, in accordance with the Norwegian  
Accounting Act section 2-3, including:  
•
•
compliance with the ESRS;  
preparing the disclosures in "EU Taxonomy Report" of the Sustainability Statement, in compliance with the  
Taxonomy Regulation;  
•
•
designing, implementing and maintaining such internal control that Management determines is necessary to  
enable the preparation of the Sustainability Statement that is free from material misstatement, whether due to  
fraud or error; and  
the selection and application of appropriate sustainability reporting methods and making assumptions and  
estimates that are reasonable in the circumstances.  
Inherent limitations in preparing the Sustainability Statement  
In reporting forward-looking information in accordance with ESRS, Management is required to prepare the forward-  
looking information on the basis of disclosed assumptions about events that may occur in the future and possible future  
actions by the Group. Actual outcomes are likely to be different since anticipated events frequently do not occur as  
expected.  
Sustainability Auditor’s Responsibilities  
Our responsibility is to plan and perform the assurance engagement to obtain limited assurance about whether the  
Sustainability Statement is free from material misstatement, whether due to fraud or error, and to issue a limited  
assurance report that includes our conclusion. Misstatements can arise from fraud or error and are considered material if,  
individually or in the aggregate, they could reasonably be expected to influence decisions of users taken on the basis of  
the Sustainability Statement as a whole.  
As part of a limited assurance engagement in accordance with ISAE 3000 (Revised) we exercise professional judgement  
and maintain professional scepticism throughout the engagement.  
Our responsibilities in respect of the Sustainability Statement, in relation to the Process, include:  
•
•
•
Obtaining an understanding of the Process, but not for the purpose of providing a conclusion on the  
effectiveness of the Process, including the outcome of the Process;  
Considering whether the information identified addresses the applicable disclosure requirements of the ESRS;  
and  
Designing and performing procedures to evaluate whether the Process is consistent with the Company’s  
description of its Process set out in subsections "Materiality assessment process" and "Climate scenario  
analysis".  
Our other responsibilities in respect of the Sustainability Statement include:  
Identifying where material misstatements are likely to arise, whether due to fraud or error; and  
•
2 / 4  
 
•
Designing and performing procedures responsive to where material misstatements are likely to arise in the  
Sustainability Statement. The risk of not detecting a material misstatement resulting from fraud is higher than for  
one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the  
override of internal control.  
Summary of the Work Performed  
A limited assurance engagement involves performing procedures to obtain evidence about the Sustainability Statement.  
The procedures in a limited assurance engagement vary in nature and timing from, and are less in extent than for, a  
reasonable assurance engagement. Consequently, the level of assurance obtained in a limited assurance engagement is  
substantially lower than the assurance that would have been obtained had a reasonable assurance engagement been  
performed.  
The nature, timing and extent of procedures selected depend on professional judgement, including the identification of  
disclosures where material misstatements are likely to arise in the Sustainability Statement, whether due to fraud or error.  
In conducting our limited assurance engagement, with respect to the Process, we:  
•
Obtained an understanding of the Process by:  
o
o
performing inquiries to understand the sources of the information used by management (e.g.,  
stakeholder engagement, business plans and strategy documents); and  
reviewing the Company’s internal documentation of its Process; and  
•
Evaluated whether the evidence obtained from our procedures with respect to the Process implemented by the  
Company was consistent with the description of the Process set out in subsections "Materiality assessment  
process" and "Climate scenario analysis".  
In conducting our limited assurance engagement, with respect to the Sustainability Statement, we:  
•
Obtained an understanding of the Group’s reporting processes relevant to the preparation of its Sustainability  
Statement by:  
o
o
Obtaining an understanding of the Group’s control environment, processes, control activities and  
information system relevant to the preparation of the Sustainability Statement, but not for the purpose of  
providing a conclusion on the effectiveness of the Group’s internal control; and  
Obtaining an understanding of the Group’s risk assessment process;  
•
•
Evaluated whether the information identified by the Process is included in the Sustainability Statement;  
Evaluated whether the structure and the presentation of the Sustainability Statement is in accordance with the  
ESRS;  
•
Performed inquiries of relevant personnel and analytical procedures on selected information in the Sustainability  
Statement;  
•
•
Performed substantive assurance procedures on selected information in the Sustainability Statement;  
Where applicable, compared disclosures in the Sustainability Statement with the corresponding disclosures in  
the financial statements and other sections of the Board of Directors’ report;  
•
•
Evaluated the methods, assumptions and data for developing estimates and forward-looking information;  
Obtained an understanding of the Company’s process to identify taxonomy-eligible and taxonomy-aligned  
economic activities and the corresponding disclosures in the Sustainability Statement;  
•
Evaluated whether information about the identified taxonomy-eligible and taxonomy-aligned economic activities  
is included in the Sustainability Statement; and  
3 / 4  
 
•
Performed inquiries of relevant personnel and substantive procedures on selected taxonomy disclosures  
included in the Sustainability Statement.  
Bergen, 29 April 2026  
PricewaterhouseCoopers AS  
Hanne Sælemyr Johansen  
State Authorised Public Accountant – Sustainability Auditor  
4 / 4