Last updated: 26.05.2026

Background to the Transparency Act
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The Transparency Act came into force in Norway on July 1, 2022. The Act aims to promote companies' work with human rights and decent working conditions – within their own operations and among their subcontractors.
Furthermore, it shall ensure companies' transparency and work with fundamental human rights and decent working conditions. The Act requires the publication of a statement, providing the public with access to
information on how negative impacts on human rights and decent working conditions are addressed within the company.

The due diligence assessments cover actual and potential negative impacts (risks) related to human rights and decent working conditions. The Norwegian Consumer Authority is the supervisory body for the Act, and the guidelines provided on the Consumer Authority's website have framed the work at Dive Topco AS.
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Examples of negative impacts to be assessed include: Social dumping, unlivable wages, child labor, forced labor and modern slavery, discrimination and harassment (including of vulnerable and marginalized groups), destruction
or disturbance of indigenous areas, violations of the right to privacy, risk of harm to life and health, and lack of the right to organize and collective bargaining (www.forbrukertilsynet.no).
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Through the Transparency Act, the companies in the Submara group are obliged to conduct due diligence assessments to identify and prevent negative impacts on people, society, and the environment – both internally within their own operations

and in the supply chain. The Act and our work with the Transparency Act are based on OECD guidelines.

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About Submara

The Submara group was established in 2023, building on the experience and expertise of several diving companies. The company offers a wide range of diving services throughout Norway and internationally. Submara consists of the companies

Buskerud Dykkerservice AS, Dykkerkompaniet AS, Dykkerteknikk AS, EB Marine AS, Fagdykk AS, Falck Dykkertjeneste AS, Geomap Norge AS, G Øye AS, IMC Diving AS, Olav Erik Hagen AS, Submara Bidco AS,

Submara Midco AS, Submara Holding AS, and Submara Survey AS.
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Headquarters are in Sætre, Asker, and the company also has locations in Bergen, Stryn, Stavanger, Horten, Kristiansand, Sandnes, Kongsberg, Tromsø, Bodø, Alta, Svolvær, Lillestrøm, and Fredrikstad. Submara has approximately

a total of 200 employees. The Submara Group's areas of expertise include construction diving, ROV services, underwater work on ships and rigs, water and wastewater engineering, and towing services. The company performs everything from foundation securing of bridges, quays, and docks,

laying of cables and pipes, to high-tech underwater inspection using our ROVs and survey tools.
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The board consists of representatives from the largest owners as well as independent board members elected at the general meeting. The main owner of Submara is Longship Fund II with 58%, while the rest of the company is
owned by key employees.
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MC Diving has led the due diligence work on behalf of Submara. IMC Diving is a certified company in accordance with Management System, ISO 9001 and ISO 14001.

Several of the companies in the group are Eco-Lighthouse certified. Work is underway to establish a common management system at a group level. This work will continue over time, and during the transition phase, the companies in the

group will have their own management and quality systems while the group establishes overarching management systems for the group.

Dive Topco AS has its own employees residing in Norway. Purchases are primarily made from Norwegian suppliers for all companies.

Embedding Responsibility and Management System

Submara has an established and implemented common set of values that applies to all companies and employees in the group.

Our values are:

1) Safety first

2) Innovative technical expert

3) Responsible quality provider

4) Commercial value creator
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The group is in the process of establishing an overarching management system with governing documents, procedures, and guidelines. These address and safeguard requirements for HSE, working conditions, and human rights for

Submara's suppliers. The guidelines have been approved by management, and by the board where applicable. Management and the board have been actively involved in the due diligence process. A working group was established in 2023 to conduct due diligence, and a series of meetings were held to perform a

risk assessment of potential negative conditions both internally and within the supply chain. The group's work was reported to management on an ongoing basis.
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In 2024, the group implemented a common risk assessment methodology and updated the group's overall risk assessment. HSE (Health, Safety, and Environment), working conditions, and human rights among its own employees and Submara's suppliers were part of this risk assessment.
Working conditions, human rights, and HSE conditions among our suppliers do not have a particularly high-risk score in this mapping. Submara has conducted several management meetings throughout 2024. In these meetings, managers have reviewed

the group's risk assessments.
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Due Diligence and Measures

Dive Topco AS and its associated companies have an established management system and work systematically with quality, working environment, and HSE. Work on due diligence, measures, and systematic follow-up has been incorporated into the

established quality and HSE system. This also includes processes for supplier approval and evaluation. The due diligence process is systematically structured, focusing on the most relevant risks for one of the

largest companies in the group. Relevant risks are based on the themes covered by the Transparency Act and human rights, such as rights to organize, wage conditions, working hours and rest periods,

discrimination, vulnerable groups, harassment/bullying, and living conditions in projects. A risk matrix has been developed and used in the due diligence process as a tool for our assessments of potential human rights violations.
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The systematic risk assessment addresses the factors: i) Probability of such an issue occurring ii) Severity of such an event iii) Scope – how many of the group's stakeholders would be

affected iv) Remediation capability – to what extent the risk can be influenced by reduced probability or reduced negative effect (a product of the factors severity and scope). Based on the risk assessment, Submara has determined which measures need to be followed up.

This assessment is updated once a year in connection with the Management Review (MR), which is carried out as part of management's overall risk assessment. Going forward, management's risk assessment will be conducted for each individual company in the group and will culminate in a common risk assessment for the group.

Many aspects are already comprehensively covered in line with each company's context or through the HSE system/internal control and ISO certification (9001 and 14001).
Generally, Norwegian conditions are largely covered by legislation and regulations that independently ensure the intention of the Transparency Act. The Working Environment Act is one of the most important in this regard.
Submara's due diligence assessment will be expanded when new circumstances arise or new companies are acquired/established within the group.

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Internal Affairs and Own Operations

Submara has conducted a risk assessment of potential negative conditions within its own operations and for internal affairs. A dedicated mapping tool for risk assessment has been used.

The employee group consists mostly of Norwegian staff, with some having foreign backgrounds. All employees in the group are employed by Norwegian companies. The Working Environment Act and the Internal Control Regulations govern the operations.

The Submara companies monitor HSE, working environment, and working hours. A reporting and deviation system has been established and is available to employees. Safety representatives participate in HSE work, and regular meetings are held with management and employees.
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Conditions that have been assessed include labor rights such as the right to organize, wage conditions, working hours and rest periods, discrimination, vulnerable groups, harassment/bullying, and living conditions in projects.

No reprehensible conditions have been uncovered in these areas. Submara notes that arrangements for more female workers/divers on vessels could be improved.

The internal risk of actual and potential negative impact, related to human rights and decent working conditions, is assessed as low.

Supplier Assessment

Submara has an established system for supplier approval and evaluation. In the due diligence assessment, we have reviewed reports and risk maps from the Global Rights Index.

Submara has conducted a due diligence assessment of its own suppliers based on its experience and knowledge of them. An updated overview of our suppliers has been completed, and where their subcontractors are

located. Subcontractors are risk-assessed as red where products are manufactured in countries where the Global Rights Index assesses the risk as high (red and orange fields).

A number of purchased goods are produced abroad. Our direct suppliers are primarily local and Norwegian, with some from the Nordics and Europe. Subcontractors for product deliveries will be from Europe and Asia.
It is estimated that there is generally a higher risk of human rights violations among suppliers and manufacturers in Asia.

The overview of suppliers is updated annually, and evaluation includes HSE, delivery, experience, and competence. Evaluation criteria have been expanded as part of the work with the Transparency Act and human rights.

Submara is not aware of any instances of human rights violations by our suppliers. It is our assessment that for all our Norwegian suppliers, there is a low risk of human rights violations.

For subcontractors to our suppliers, human rights violations may occur, but we are not aware of any such cases.
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Systematic Evaluation and Monitoring

Submara will continue to follow up on our due diligence assessment regarding potential human rights violations. Our ethical guidelines for suppliers will be updated, and human rights will be included in our systematic

evaluation of the supply chain. Our suppliers will be asked to monitor their own suppliers, and we will assess the work being done. If circumstances warrant it, we will consider conducting supplier audits that include human rights requirements.

Risks of human rights violations will be reported in Submara's established non-conformance system. Procedures for reporting, including anonymous reporting, are in place.

The companies recently integrated into Dive Topco AS are in the process of being incorporated into a common management system. The due diligence assessment will be reviewed annually and will be part of our annual management review.
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This Due Diligence Report was reviewed by the Board of Directors on June 4, 2025.

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