Transparency Statement

The Norwegian Transparency Act (Lov om virksomheters åpenhet og arbeid med grunnleggende menneskerettigheter og anstendige arbeidsforhold) entered into force on 1 July 2022. The Act is intended to promote respect for fundamental human rights and decent working conditions, and to ensure public access to information about how businesses address these issues. It requires larger businesses to carry out due diligence assessments and to report on them publicly.

About Bower

Bower Offshore AS (formerly Zosco Norway AS), org. no. 937 096 275, is an offshore shipping company based in Fosnavåg, owned by Zamil Offshore Services Company. We provide maritime services to the offshore energy market — oil and gas and renewable energy. Our supply chain includes shipyards, equipment and operations suppliers, and crewing and manning services, both in Norway and internationally.

Bower Offshore AS comprises the following wholly owned subsidiaries:

• Bower Shipping AS (operating company)
• Bower Crewing AS (crew)
• Bower Eir AS (ship-owning company, BOWER EIR)

Policies and governance

Our work on human rights and decent working conditions is anchored in management and the board of directors, and is built on our internal policy framework. The following policies are particularly relevant to this work:

• Code of Business Conduct
• Supplier Code of Conduct
• Health and Safety Policy
• Equal Opportunities Policy
• Anti-Harassment Policy
• Drug and Alcohol Policy
• Stop Work Policy
• Environmental Policy

The policies are available on our website.

Due diligence assessments

Bower Offshore has established a due diligence process covering our own operations, suppliers and partners, based on the OECD Guidelines for Responsible Business Conduct. We map and prioritise risk according to geography, industry-specific factors and the workforces involved, with particular attention to the most exposed suppliers.

For prioritised suppliers, we carry out assessments and follow-up activities, which may include document reviews, dialogue and audits. We expect suppliers, subcontractors and partners to comply with the standards set out in our ethical guidelines and Supplier Code of Conduct. This work is ongoing, and assessments are updated on a regular basis.

We work to raise awareness of human rights and decent working conditions among our own employees and among suppliers, including through training and dialogue.

Whistleblowing

Bower Offshore has established a whistleblowing channel through which employees, suppliers and others can report concerns, including violations of human rights and indecent working conditions, in our own operations and in the supply chain. Reports are followed up, and those who report can be assured that there will be no negative consequences for doing so. Enquiries can be directed to varsling@bower.no.

Identified risks

Through our assessments, we have identified potential risks related to human rights and decent working conditions in the industry and supply chain, including:

• discrimination on the basis of nationality, ethnicity, gender, religion or similar grounds
• exploitation through low wages, excessive working hours or poor working conditions
• working environment and safety, particularly at shipyards and among subcontractors
• freedom of association and the right to collective bargaining
• the particular vulnerability of migrant workers, for example passport confiscation or contract abuse
• forced labour and modern slavery in the lower tiers of the supply chain
• lack of transparency in the supply chain

Findings and measures

Based on the due diligence assessment, Bower Offshore has implemented the following measures:

• Introduced a requirement for new suppliers and shipyards to confirm that fundamental human rights and working conditions are being upheld
• Asked existing suppliers to confirm that fundamental human rights and working conditions are being upheld
• Initiated training and awareness-raising for personnel with procurement responsibilities on responsible business conduct

Right to information

Under Section 6 of the Transparency Act, anyone has the right to request information about how Bower Offshore addresses actual and potential adverse impacts on fundamental human rights and decent working conditions. This applies to both general information and information relating to a specific product or service.

Enquiries should be directed to personvern@bower.no. We will respond within three weeks. If a request requires a disproportionate amount of work, the response deadline may be extended to two months, in which case we will notify the enquirer within three weeks with information about the new deadline.

We may refuse or limit a request if it does not provide sufficient basis for identifying what it concerns, if it is manifestly unreasonable, if it relates to information about an individual's personal circumstances, or if it concerns technical devices, procedures, or operational and business matters that are commercially sensitive. Any refusal will be given in writing with reasons stated.

This statement has been reviewed and approved by the board of directors of Bower Offshore AS on 24.06.2026.