The sustainability statements are prepared on the same consolidated basis as the financial statements.

The purpose of Hydro's reporting is to provide stakeholders with a fair and balanced picture of relevant aspects, engagements, practices, and results for 2024. The sustainability statements are prepared on the same consolidated basis as the financial statements. Sustainability information that relates to business relationships in non-consolidated entities, including Hydro’s upstream or downstream value chain, is clearly identified as such. No specific information corresponding to intellectual property, know how or the results of innovation that is considered material for users of the integrated annual report, has been omitted. Quantitative metrics included in the sustainability statements include a description of reporting principles, measurement and calculation methodology, assumptions and basis for presentation, including an evaluation of accuracy if the data is estimated using sector averages or other proxies and planned actions to improve accuracy in the future. Metrics subject to a high level of measurement uncertainty are clearly identified as such. The sustainability statements, including additional notes and disclosures pursuant to the Norwegian Equality Act in the appendix, are approved by the Board of Directors.

No specific information corresponding to intellectual property, know how or the results of innovation that is considered material for users of the integrated annual report, has been omitted. Quantitative metrics included in the sustainability statements include a description of reporting principles, measurement and calculation methodology, assumptions and basis for presentation, including an evaluation of accuracy if the data is estimated using sector averages or other proxies and planned actions to improve accuracy in the future. Metrics subject to a high level of measurement uncertainty are clearly identified as such.

Head of ESG Reporting, Magnus Young magnus.young@hydro.com

Hydro regularly assesses risk and controls over its sustainability reporting process. The risks are reviewed with the Board Audit Committee and discussed with Hydro’s external auditors who provide limited assurance over the sustainability statement. The external assurance process is risk based, and the external auditors provide feedback on their assessment of risks to the Board Audit Committee and Hydro’s management. The auditors also provide feedback to the Board of Directors in relation to the Board’s review and approval of the integrated annual report. Hydro is exposed to risks associated with incomplete or inconsistent reporting on sustainability topics, including risks associated with greenwashing. There are also risks related to the accuracy of data inputs and manual errors in the reporting process from aggregating data from multiple systems into the corporate disclosure management system. Hydro has developed and implemented formalized processes to determine material sustainability disclosures for the integrated annual report 2024. Material sustainability matters are covered by Hydro’s sustainability reporting manual, which formalizes roles, responsibilities and definitions for the information reported in the sustainability statement. Hydro has also implemented controls based on the assessment of risks in the sustainability statements, including review controls for quantitative and qualitative data in the sustainability statements by business area, group functions and Hydro’s disclosure committee, as well as access controls and automated input controls in sustainability reporting systems. Hydro’s external auditors perform testing on Hydro’s sustainability reporting as part of the limited assurance provided over the company’s sustainability statements in the integrated annual report. The assurance activities performed by the external auditor are described in the assurance statement.

Hydro regularly assesses risk and controls over its sustainability reporting process. The risks are reviewed with the Board Audit Committee and discussed with Hydro’s external auditors who provide limited assurance over the sustainability statement.

Hydro’s external auditors perform testing on Hydro’s sustainability reporting as part of the limited assurance provided over the company’s sustainability statements in the integrated annual report. The assurance activities performed by the external auditor are described in the assurance statement.

The sustainability reporting, covering the contents in the Sustainability statements of the annual report, are subject to limited assurance in accordance with the international audit standard ISAE 3000 (revised), issued by the International Auditing and Assurance Standards Board (IAASB)

The sustainability reporting, covering the contents in the Sustainability statements of the annual report, are subject to limited assurance in accordance with the international audit standard ISAE 3000 (revised), issued by the International Auditing and Assurance Standards Board (IAASB)

Hydro regularly assesses risk and controls over its sustainability reporting process. The risks are reviewed with the Board Audit Committee and discussed with Hydro’s external auditors who provide limited assurance over the sustainability statement. The external assurance process is risk based, and the external auditors provide feedback on their assessment of risks to the Board Audit Committee and Hydro’s management. The auditors also provide feedback to the Board of Directors in relation to the Board’s review and approval of the integrated annual report.

Hydro is exposed to risks associated with incomplete or inconsistent reporting on sustainability topics, including risks associated with greenwashing. There are also risks related to the accuracy of data inputs and manual errors in the reporting process from aggregating data from multiple systems into the corporate disclosure management system.

The sustainability reporting is subject to independent assurance by the company's auditors.

140+ locations

42 countries

Europe -Austria Belgium Bosnia and Herzegovina Croatia Czech Republic Denmark Estonia Finland France Germany Hungary Ireland Italy Lithuania Luxembourg Netherlands Norway Poland Portugal Romania Serbia Slovakia Spain Sweden Switzerland Turkey United Kingdom

Asia and Oceania - Australia Bahrain China India Japan Qatar Singapore South Korea Turkey United Arab Emirates

Americas - Argentina Brazil Canada Mexico USA

Hydro’s downstream operations have a strong local presence in both Europe and North America. Demand in downstream segments increased throughout 2024 in most sectors, except building and construction. Upstream business areas and Energy delivered returns above their cost of capital during 2024, while downstream segments delivered below in challenging markets. Hydro’s downstream segments have a clearer currency profile with a net long exposure to USD and EUR reflecting the main currencies in the markets in which they operate.

Note 9.1 Related party information As of December 31, 2024, The Norwegian state had ownership interests of 34.8 percent of total shares outstanding (2023: 34.8 percent) in Hydro through the Ministry of Trade, Industry and Fisheries. In addition, Folketrygdfondet, which manages the Government Pension Fund – Norway1) held 7.0 percent (2023: 6.3 percent). There are no preferential voting rights associated with the shares held by the Norwegian State. Hydro has concluded that the Norwegian state's shareholding represents a significant interest in Hydro, and that the State thus is a related party. Hydro’s share buyback program authorized at the extraordinary general meeting in September 2023 had as a prerequisite for buybacks and subsequent cancellation of shares that these transactions would not result in a change to the ownership interest of 34.26 percent of issued shares of the Ministry of Trade, Industry and Fisheries. Share redemptions from the Norwegian state was carried out at the same price terms as for the buybacks via the stock exchange. The share buyback program authorized at the ordinary general meeting in May 2024 has the same prerequisite for buybacks and subsequent cancellation of shares that these transactions do not result in a change to the ownership interest of 34.26 percent of issued shares of the Ministry of Trade, Industry and Fisheries. Share redemptions from the Norwegian state will be carried out at the same price terms as for the buybacks via the stock exchange. The Norwegian state has ownership interests in a substantial number of companies. The ownership interests in 69 companies are managed by the ministries and covered by public information from the Ministry of Trade, Industry and Fisheries2) . We have not assessed which of these companies that are controlled by the State. Hydro has business transactions with a number of these companies, including purchase of power from Statkraft and bank services from DNB. Generally, transactions are agreed independently of the possible control exercised by the State. A significant share of Hydro's defined benefit post-employment plans is managed by the independent pension trust, Norsk Hydros Pensjonskasse. Employees managing and operating the pension trust are employees of Norsk Hydro ASA. Their salaries and other benefits are reimbursed by the pension trust on a monthly basis, in total NOK 12 million for 2024 and NOK 12 million for 2023. Further, the pension trust is located in Hydro's head office. Office costs, including heating and administrative services, are charged with a total of NOK 1 million for both 2024 and 2023. The pension trust provides services to Hydro for administration of unfunded pension plans with NOK 6 million for 2024 and NOK 5 million for 2023.

The pension trust owns some of the office space rented by Hydro. The current rental arrangement was entered into in 2015 representing a partial continuation of a rental agreement from 2006, and priced based on market price benchmarks at the time of the agreement in 2006. Hydro has paid a rental of NOK 94 million and NOK 86 million for 2024 and 2023, respectively. The current term of the rental contract expires in February 2027. A new contract for premises in the same office complex covering a ten-year period with options for two additional five-year periods from 2026 was entered into during 2023. Hydro also sold electricity to the pension trust for its operational needs at the same office site for a total amount of NOK 5 million in 2024 and NOK 8 million in 2023. As of the end of 2024, Hydro’s outstanding receivables on Norsk Hydros Pensjonskasse were NOK 2 million, while Hydro’s payable to Norsk Hydros Pensjonskasse amounted to NOK 34 million, all settled in early 2025. Hydro's significant joint arrangements and associates; and transactions with those entities are described in note 3.1 Investments in joint arrangements and associates. Hydro’s relationship with partners in joint arrangements are generally limited to a combined effort within a limited area. Hydro considers the joint venture partners as competitors in other business transactions, and do not see these relationships as related party relationships. Entities that are associates or joint ventures of Hydro’s joint venture Hydro Rein are also considered related parties of Hydro. Hydro has transactions with some of those entities. The main transaction type is purchase of electrical power under long-term power purchase agreements, for the majority of the agreements at fixed prices subject to inflation adjustment. Such purchases will, for the wind project Stor-Skälsjön in Northern Sweden, and the solar and wind projects in Brazil start during 2025. In 2024, some power volumes have been purchased on spot terms at prevailing prices in the relevant markets. Hydro Rein also provided construction services to the Stor-Skälsjön project with a revenue of NOK 101 million in the period prior to Hydro’s sale of the controlling interest in Hydro Rein in June 2024. Some of the board members or their close members of family serve as board members or executive directors in other companies. In addition, some members of Hydro's executive leadership team or their close members of family serve as board members in other companies. Hydro has transactions with some of those companies; however, have not identified any transactions where the relationship is known to have influenced the transaction. Some close family members of members of Hydro’s management are employed in non-executive positions in Hydro. Transactions with related parties are at arm’s length principles. Executive management remuneration is disclosed in the table below. The members of Hydro’s executive leadership team and the members of Hydro's board of directors during 2024 and 2023 and their individual remuneration is reported in Norsk Hydro ASA Report on executive remuneration 2024.

Significant subsidiaries and changes to the group Significant accounting policies Consolidation The consolidated financial statements include Norsk Hydro ASA and subsidiaries, which are entities in which Hydro has the power to govern the financial and operating policies of the entity (control). Control is normally achieved through ownership, directly or indirectly, of more than 50 percent of the voting power. Currently, Hydro has more than 50 percent of the voting power in close to all subsidiaries. Subsidiaries are included from the date control commences until the date control ceases. Intercompany transactions and balances have been eliminated. Profit and loss resulting from intercompany transactions have been eliminated. Non-controlling interests Non-controlling interests represent equity interests in subsidiaries held by other owners than Hydro. Noncontrolling interests are reported as a separate section of the Group's equity in accordance with IFRS 10 Consolidated Financial Statements. Results attributed to non-controlling interests are based on ownership interest, or other method of allocation if required by contract. Transactions between non-controlling shareholders and the group Sales and purchases of equity interests and equity contributions not resulting in Hydro gaining or losing control of a subsidiary are reported as equity transactions in accordance with IFRS 10. No gain, loss or remeasurement of values of recognized assets, liabilities or goodwill are recognized as a result of such transactions. Foreign currency translation For consolidation purposes, the financial statements of subsidiaries with a functional currency other than Norwegian kroner (NOK) are translated into NOK. Assets and liabilities, including investment in associates, joint ventures and goodwill, are translated using the rate of exchange as of the balance sheet date. Income, expenses and cash flows are translated using the average exchange rate on a monthly basis. Goodwill is recognized in the predominant functional currencies in the acquired businesses. Translation adjustments are recognized in Other comprehensive income and accumulated in Currency translation differences in Other components of equity. On disposal of such subsidiary, joint venture or associate, the cumulative translation adjustment of the disposed entity is recognized in the income statement as part of the gain or loss on disposal. Business combinations Business combinations are accounted for using the acquisition method in accordance with IFRS 3 Business Combinations. Consideration is the sum of the fair values, as of the date of exchange, of the assets transferred, liabilities incurred or assumed, and equity instruments issued in exchange for control of the acquiree. The fair value of Hydro's pre-existing ownership interest in an acquiree is included in the consideration, with any gain or loss recognized in Other income, net. The acquiree's identifiable assets, liabilities and contingent liabilities are recognized separately at the acquisition date at their fair value irrespective of any non-controlling interest, and goodwill recognized to the extent the consideration exceeds identified net assets. The interest of non-controlling shareholders in the acquiree is initially measured as the non-controlling interests' proportion of the fair value of the net assets recognized (partial goodwill method, see note 2.3Goodwill). Non-controlling interests are subsequently adjusted for changes in equity of the subsidiary after the acquisition date. Assets held for sale and Income from discontinued operations Assets held for sale are reported separately in accordance with IFRS 5 Non-current Assets Held for Sale and Discontinued Operations, provided that the sale is highly probable, which includes the criteria that management is committed to the sale, and that the sale will be completed within one year. Assets held for sale are not depreciated but are measured at the lower of carrying value and the fair value less costs to sell for the asset group. Assets are not reclassified in prior period balance sheets. Immaterial disposal groups are not reclassified. A discontinued operation is a component of Hydro that is held for sale or has been disposed of. A discontinued operation is a separate major line of business or geographical area of operations. Related cash flows, results of operations and gain or loss from disposal are reported separately as Income (loss) from discontinued operations. Assets held for sale, liabilities in disposal groups and income and expense from discontinued operations are excluded from specifications presented in the notes unless otherwise stated.

Significant judgment in determining whether an entity is a controlled subsidiary or not Control is derived from rights. The majority of Hydro’s subsidiaries are clearly controlled through ownership of all, or a significant majority of, the voting shares. For some companies, control is analyzed through understanding the rights derived from the combination of voting shares held by Hydro and other shareholders, and agreements influencing how business decisions are made, mainly in the form of shareholder agreements. Hydro has no significant subsidiaries where Hydro does not hold the majority of voting shares. In some subsidiaries, non-controlling interests holds significant decision rights through the combination of significant, though not majority, of ownership interests, and requirements for affirmative vote set out in shareholder agreements. For all of these subsidiaries, Hydro has carefully analyzed the decision-making process and concluded that the rights allocated to Hydro are sufficient to direct the activities most important for the entities’ return, and thus supports the conclusion that those entities are subsidiaries. Assessment related to the more significant such subsidiaries are discussed below. Significant judgment in accounting for business combinations In a business combination, consideration, assets and liabilities are recognized at estimated fair value, and any excess purchase price included in goodwill. Where Hydro had an existing ownership interest in the acquiree, that interest is also reassessed to determine its acquisition date estimated fair value, resulting in an acquisition date gain or loss. In the businesses Hydro operates, fair values of individual assets and liabilities are normally not readily observable in active markets. Estimation of fair values requires the use of valuation models for acquired assets and liabilities as well as ownership interests. Such valuations are subject to numerous assumptions and are thus uncertain. The quality of fair value estimates may impact periodic depreciation and amortization of fixed assets, and assessment of possible impairment of assets and/or goodwill in future periods.

Data on employees are retrieved from Hydro’s human resources SAP system. Gender data are based on the employees’ self-reporting in Hydro’s SAP system. Head count per country is based on which country the employees perform their work. Temporary employees include apprentices but exclude contractor employees. Employee turnover covers permanent employees only and includes resignations, retirements and manning reductions, but excludes closures and divestments. Hydro also engages a small number of non-employee workers and consultants that are not included in Hydro's employee data. Data presented represents head count at year end, December 31. See also note 9.2 to the financial statements on the reporting entity.

Data on employees are retrieved from Hydro’s human resources SAP system. Gender data are based on the employees’ self-reporting in Hydro’s SAP system. Head count per country is based on which country the employees perform their work. Temporary employees include apprentices but exclude contractor employees. Employee turnover covers permanent employees only and includes resignations, retirements and manning reductions, but excludes closures and divestments. Hydro also engages a small number of non-employee workers and consultants that are not included in Hydro's employee data. Data presented represents head coun

No significant fluctuations

No significant fluctuations

Workers who are not employed consists mainly of contractors, apprentices and agency workers. Apprentices and agency workers are reported as temporary employees in the Own workforce chapter of the Sustainability statements in the annual report and the Country-byCountry report in Appendix to the annual report).

Contractors are typically hired to assist in operations and handle maintenance of equipment that requires specialized competences. Apprentices and agency workers are mostly employed in production processes, including to handle temporary production peaks.

Data on employees are retrieved from Hydro’s human resources SAP system. Gender data are based on the employees’ self-reporting in Hydro’s SAP system. Head count per country is based on which country the employees perform their work. Temporary employees include apprentices but exclude contractor employees. Employee turnover covers permanent employees only and includes resignations, retirements and manning reductions, but excludes closures and divestments. Hydro also engages a small number of non-employee workers and consultants that are not included in Hydro's employee data. Data presented represents head count at year end, December 31. See also note 9.2 to the financial statements on the reporting entity

No significant fluctuations

No significant fluctuations

The guidelines for the Nomination Committee are adopted by the general meeting of shareholders and include Hydro’s requirements for independence, shareholder interests, competence, capacity, and diversity.

All shareholder elected members were in 2024, deemed to be independent according to the Norwegian standards. None of the company’s non-employee board members had any other service contractual agreements with the company

The Board Audit committee consists of four of the Board members and meets the Norwegian requirements for independence and competence.

Nomination Committee The Nomination Committee consists of three to four members who shall be shareholders or shareholder’s representatives. The members and its chairperson are elected by the general meeting of shareholders for periods of up to two years at a time

The Board held 11 members as of December 31, 2024. Seven are elected by the general meeting of shareholders, four are elected by and among the company’s employees in Norway. All shareholder elected board members are elected for a period of up to two years.

Gender balance Hydro targets 25 percent women employees in permanent and temporary positions combined, and 25 percent women in leadership positions by 2025. Hydro’s overall gender balance improved one percentage point from 2023, with 24 percent of the Hydro workforce comprising women at the end of 2024. The share of women in management has also increased by one percentage point in the same period, with 21 percent of leadership positions in Hydro comprising women at the end of 2024

Hydro also monitors gender distribution across additional staffing categories. In women leadership positions, with at least one person is reporting directly to them, we have a target of 25 percent by 2025. We also monitor women in white-collar staff positions. For this group the data include level 0, 1, 2, 3, 4 and 5 managers. We have set a target of 35% by 2025 in this category.

The guidelines for the Nomination Committee are adopted by the general meeting of shareholders and include Hydro’s requirements for independence, shareholder interests, competence, capacity, and diversity.

Diversity in management

Diversity data for the Board of Directors and Executive Leadership Team (ELT) for Hydro are counted per year end. Diversity in management is reported for levels 0, 1, 2 and 3. Level 0 refers to the CEO, level 1 refers to Corporate Management Board (CMB), level 2 refers to persons reporting to CMB, and level 3 refers to persons that report to level 2.

Stakeholder representation: Employees have 4 representatives while shareholders elect 7 representatives. See Our governance in the annual report.

All shareholder elected members were in 2024, deemed to be independent according to the Norwegian standards. None of the company’s non-employee board members had any other service contractual agreements with the company. No members elected by and among the employees, are part of the company’s executive management. Employee elected directors have no other service contractual agreements with the company outside of their employee contracts, though they are subject to their duties as board members

Shareholders may propose candidates for the nomination committee at any time. In order to be considered at the next ordinary election, proposals must be submitted by the end of November in the year before the election year.

According to its mandate, the nomination committee shall be receptive to external views and shall ensure that any deadlines for proposals regarding members of the nomination committee and the Board are published well in advance on the company’s website. In carrying out its duties the nomination committee actively maintains contact with the shareholder community and strives to ensure that its recommendations are anchored with major shareholders. Shareholders may contact the nomination committee via an electronic form available at the company’s website. The nomination committee regularly has discussions with members of the Board

The nomination committee aims to achieve a board composition that protects the interests of the shareholder community and the company’s need for expertise capacity and diversity. Emphasis is placed on the members complementing each other professionally and the Board’s ability to function as a collegiate body.

The nomination committee ensures that due attention is paid to the interests of the shareholder community and the company’s requirements for competence, capacity and diversity

The nomination committee aims to achieve a board composition that protects the interests of the shareholder community and the company’s need for expertise capacity and diversity. Emphasis is placed on the members complementing each other professionally and the Board’s ability to function as a collegiate body.

The nomination committee also takes account of relevant statutory requirements regarding the composition of the company’s governing bodies

The nomination committee aims to achieve a board composition that protects the interests of the shareholder community and the company’s need for expertise capacity and diversity. Emphasis is placed on the members complementing each other professionally and the Board’s ability to function as a collegiate body.

In accordance with Norwegian corporate law, the Corporate Management Board (Hydro's executive board) is responsible for the company's due diligence processes, with the overall oversight by the board of directors. Our process to identify our material impacts is described in the General information chapter in the annual report. See also the section on Human rights of the annual report

The stakeholder engagement process in Hydro is generally managed at an administrative level in the organization and is a line responsibility at all levels. Under special circumstances the board, represented by the chairperson, may conduct dialogue with investors. The board of directors communicates indirectly - and in certain cases directly - with shareholders through the corporate assembly and directly through the general meeting of shareholders. Through the employee representatives, the board also communicates directly with the employee organizations. See General information chapter in the annual report.

All elements of Hydro's sustainability performance are integrated in Hydro's overall group strategy. Hydro’s human rights due diligence is integrated in relevant business processes including the enterprise risk management process. Mitigating actions or activity plans are developed and included in business plans in the business areas where relevant. Business plans are monitored, followed up and evaluated through the year in regular internal board meetings.

Hydro’s governance system is based on the delegation of responsibility from the board of directors to the President and CEO and from the President and CEO to the executive vice presidents (EVPs) of the business areas and to EVPs of corporate functions. Hydro’s governance system is the system by which Hydro is directed and controlled. At the core of the governance system is Hydro’s constituting documents and global directives, including Hydro’s Code of Conduct. These documents include governance of economic, environmental and social topics and describe how legal entities and employees are expected to carry out activities and operations, including the management of impacts.

The annual report 2024, including the Sustainability statements, has been reviewed and approved by the Board of Directors.

Hydro follows the most recent Norwegian Code of Practice for Corporate Governance (NUES) dated October 14, 2021. The Board of Directors’ report in relation to the Code can be found in the appendix.

All new board members take part in an onboarding process focusing on Hydro’s industries, operating model, risk management and sustainability approach, including its Code of Conduct. Regular orientations and discussions are performed in the board on the same topics. The Board conducts an annual self-assessment of its work, competence, skills and expertise, and cooperation with management. This assessment also includes an assessment of the chairperson.

Disclosure of conflicts of interests is a requirement in Hydro's Code of Conduct which is valid even to the board of directors. All board meetings are started by evaluating any possible conflict of interest related to the agenda items. See also Code of Conduct at https://www.hydro.com/governance

The status of Hydro's AlertLine, as well as significant non-compliance issues, are reported annually to the Board of Directors and every quarter to the Board Audit Committee. The President and CEO reports about critical concerns to the board of directors at a running basis when relevant. See Our Governance chapter and section on Norwegian Code of Practice for Corporate Governance in the appendicies, as well as section on Business conduct in the Sustainability chapter of the annual report.

All concerns reported through the AlertLine are also reported to the Board of Directors at an aggregated level and when relevant also on a case by case level. See the Business conduct section in the Sustainability chapter of the annual report.

Management and Board remuneration Please refer to the Remuneration report for information concerning remuneration and remuneration policies, share ownership, loans outstanding and loan policy relating to Hydro’s Board of Directors and Executive Leadership Team.

See Remuneration report at Hydro.com

See the Remuneration report at Hydro.com

See Remuneration report at Hydro.com

Hydro analyzed global pay statistics in 2024 and found an unadjusted gender pay gap of six percent. Hydro analyzes equal pay by accounting for factors such as job type, job level and complexity, experience, education, tenure, performance and work location, in addition to gender. The analysis shows an adjusted pay gap of seven percent, due to gender and other potentially unidentified factors. Hydro will address this pay gap and work to ensure equitable compensation for work of equal value. To identify areas for improvement and gain actionable insight, the company conducted a detailed analysis across 42 business units in 21 countries. The ratio of the highest base salary to the median base salary for all permanent employees was 17.4. For more information, see the Remuneration report. See also note S1.6 for detailed pay gap analysis specific to Norwegian employees, based on the Norwegian Equality and Anti-discrimination Act. All Hydro employees are covered by the social security systems in their respective countries. At a minimum, all employees receive (in combination with statutory benefits and social security) business travel insurance, benefits covering work related events (accidents and illnesses), and retirement benefit. As part of the global reward strategy, Hydro introduced a global minimum standard of 16 weeks fully paid parental leave for primary caregiver and four weeks fully paid leave for secondary caregiver in 2024.

Hydro's commitments are based on a wide range of intergovernmental instruments. These are described in the respective sections of the Sustainability statements in the annual report and include, amount others, the Intergovernmental Panel on Climate Change (for climate change), the OECD Due Diligence Guidance for Responsible Business Conduct (for human rights management), the IFC Performance Standards on Environmental and Social Sustainability

Hydro continues to implement Human Rights due diligence in its business processes including own operations, procurement activities and projects, as well as building its internal competence on human rights management based on the OECD Guidelines on Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights.

Human rights related reporting, including disclosures required by the Norwegian Transparency Act 2021, the Australian Modern Slavery Act 2018, and the UK Modern Slavery Act 2015 are provided in the sections on Own Workforce, Workers in the value chain, and Affected communities. The reporting requirements in these regulations apply to Hydro as an enterprise resident in Norway with total assets of more than NOK 35 million combined with, on average, more than 50 full time employees, a supplier of goods with a total turnover of more than AUD 100 million in Australia and GBP 36 million or more in the UK, respectively. The human rights related disclosures are prepared based on information collected from all consolidated entities in Hydro. Hydro’s Human Rights Policy and further information about the company’s human rights management approach is available on Hydro.com. Hydro’s Code of Conduct sets out the company’s position on human rights in all operations, including the opposition to all forms of modern slavery. Entities that are not fully owned by, but are controlled by Hydro, can have different policies. Hydro expects that their relevant policies are aligned with the ones of Hydro. The Modern Slavery Transparency Statement is approved and signed by the Board of Directors of the parent company Norsk Hydro ASA. See also Hydro’s separate statements based on the Norwegian Transparency act at Hydro.com.

Hydro’s commitment to respect the human rights of affected communities associated with our operations and value chain, and to manage any potential or actual adverse impacts is set out in the company’s Human Rights Policy, which is approved by the Executive Leadership Team (ELT). The operational responsibility for ensuring that engagement with affected communities is conducted as set out in the policy is delegated to the business areas.

Hydro continues to implement Human Rights due diligence in its business processes including own operations, procurement activities and projects, as well as building its internal competence on human rights management based on the OECD Guidelines on Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights.

Hydro collaborates on industry initiatives and invests in partnerships for supporting human rights and positive social development, such as through its ICMM membership as well as partnership with Amnesty International in Norway

Human rights related reporting, including disclosures required by the Norwegian Transparency Act 2021, the Australian Modern Slavery Act 2018, and the UK Modern Slavery Act 2015 are provided in the sections on Own Workforce, Workers in the value chain, and Affected communities.

Own workforce, Workers in the value chain, Other communities

https://www.hydro.com/en/global/about-hydro/corporate-governance/policies-and-tools/

Approved by the Executive Leadership Team (ELT).

Hydro’s approach to human rights due diligence in relation to the rights of communities and indigenous peoples specifically is also set out in Hydro’s Human Rights Policy, and detailed further in the Position Statement on Human Rights Due Diligence. Potential or actual adverse impacts on local communities are managed through this process. If Hydro identifies adverse human rights impact that the company has caused or contributed to, Hydro works to cooperate in, promote access to and/or provide remediation.

Specific processes for stakeholder engagement exist in areas of the business where the potential impacts on affected communities have been considered salient.

Policy commitments are communicated to workers through various training programs, annually. Refer to Note G1.3 on Compliance training in the Appendix to the annual report. Policy commitments are communicated to business partners through Hydro's Supplier Code of Conduct and through regular stakeholder dialogue

The aluminium industry is subject to a broad range of local and global regulatory frameworks, including mining regulations, tariffs, labor laws and power industry regulations. Additionally, EU climate related regulations such as the implementation of national and regional CO2 taxes and increased attention on similar regulations in the U.S. are at the forefront of the current uncertainty. The growing pressure to meet climate goals is driving the pace of new regulations and their increased scope regarding all aspects of sustainability.

See descriptions in each respective policy for responsible business available at https://www.hydro.com/principles

See descriptions in each respective policy for responsible business available at https://www.hydro.com/principles

See descriptions in each respective policy for responsible business available at https://www.hydro.com/principles

Hydro continues to actively engage with regulators and industry associations, where appropriate, to ensure that aluminium’s position is taken into consideration. Hydro has been involved in the development of international frameworks on climate change and greenhouse gas emissions as well as raw materials policies supporting the establishment of a level playing field for the industry. For power industry regulations, Hydro engages in various activities to support and promote sustainable energy policies in the regions in which it operates, in addition to securing competitive energy supplies for its own operations.

Grievance mechanism Canal Direto is Hydro’s operational level grievance mechanism open to all external stakeholders in Brazil and targeted specifically at affected communities. The mechanism allows community members to raise their concerns anonymously. Grievances are assessed according to the criticality of each case. The process follows the criteria for effective grievance mechanisms set out in the UN Guiding Principles on Business and Human Rights. The effectiveness of the grievance mechanism is monitored through dialogue with the affected communities, monitoring of the type and volume of cases received, as well as through a satisfaction survey for users. In 2024, the Canal Direto registered 633 grievances via telephone, online form and email. Of the registrations, 92 percent were identified and eight percent anonymous. 84 percent were related to requests for information and the most frequently registered topics were sponsorships, job and career opportunities at Hydro, visits to operations, donations, commercial matters, auctions and interest in research, innovation and new technologies. See also note G1.1 for further details about grievances received through Canal Direto in 2024.

Human Rights Impact Assessment Alunorte, Albras and Paragominas began the implementation of a Human Rights Action Plan to mitigate risks in the operations in 2020. A new Human Rights Impact Assessment of Hydro’s operations in the state of Pará is currently underway, conducted by an external consultancy. As part of this process, a baseline study has been conducted, and the findings and recommendations are expected in 2025. Community dialogue Alunorte, Albras and Paragominas have implemented a structured approach to effective and inclusive engagement with diverse communities in the region. Hydro engages in dialogue with community groups, traditional groups and civil society organizations which represent women, children, human rights defenders or other underrepresented and at risk groups in the local communities. Hydro Sustainability Fund initiatives Since 2018 Hydro has supported, by Hydro Sustainability Fund initiatives, the Sustainable Barcarena Initiative (SBI) to enhance community dialogue. This is an independent forum to support sustainable development in Barcarena. The overall aim is to bring local stakeholders together to discuss challenges and opportunities, strengthen capabilities and decide about the main social investments supported by the Hydro Sustainability Fund (HSF). In 2024, about 178 community leaders participated in meetings, dialogues, or programs organized by the initiative. SBI also plays an important role coordinating the financing rounds of Hydro Sustainability Fund (HSF) to ensure Hydro’s social investments meet the local community’s needs. In 2024, HSF supported 36 community based projects. In November 2024, Hydro launched the Corridor Program with Mercedes-Benz. This is a strategic partnership and initiative to promote the social and economic development in the pipeline area, expanding the collaboration to create positive social and environmental impact in the Amazon. Working together with the Brazilian NGOs IPAM, Imazon, and CEA and other partners, Hydro aims to strengthen territorial development by fostering economic opportunities and biodiversity conservation in the communities where it operates, and promoting human rights. The program is aimed at generating social positive impact in the region along the pipeline. The program is in an initial phase and projects, activities and targets are still to be developed. In addition, Alunorte, Albras and Paragominas have a volunteering program for employees to increase internal engagement and address community needs. In 2024, over 3,700 employees participated in the volunteer programs in Brazil. The volunteers organized over 290 different actions, including food basket donations, fundraising, seed planting and training for community leaders. The activities reached approximately 27 000 people.

Hydro engages regulators, local authorities and communities directly on its environmental management and potential incidents of pollution. Potentially affected stakeholders or communities can use Hydro's grievance mechanism, AlertLine, to report environmental and social issues concerning Hydro operations. Hydro also engages civil society on environmental issues.

Grievances are assessed according to the criticality of each case. The process follows the criteria for effective grievance mechanisms set out in the UN Guiding Principles on Business and Human Rights. The effectiveness of the grievance mechanism is monitored through dialogue with the affected communities, monitoring of the type and volume of cases received, as well as through a satisfaction survey for users.

Hydro monitors business conduct incidents through cases reported to line management, supporting staff functions, Hydro’s grievance mechanism, AlertLine, quarterly and year-end compliance reporting from its business areas, and information collected from Hydro’s legal and compliance departments

In addition to AlertLine, the grievance mechanism Canal Direto in Brazil registered 633 reports, of which 84 percent were related to requests for information and the most frequently registered topics were sponsorships, job and career opportunities at Hydro, visits to operations, donations, commercial matters, auctions and interest in research, innovation and new technologies.

Hydro’s people strategy Hydro’s ambitious people strategy towards 2030 focuses on learning and development, innovation, leadership, and belonging. These global strategic priorities are supported by targets and activities that address the specific needs and challenges of the business areas. We grow Hydro’s purpose is to create a viable organization that empowers people to grow. The company invests in skills development aligned with both business and individual needs to achieve its business strategy and to be an attractive employer. Hydro provides opportunities for personal and professional growth opportunities, aiming to foster a continuous learning culture based on growth mindset among leaders and employees, where learning is integrated into daily work. Learning and development is offered through a blend of on the job training, social initiatives such as networking, mentoring and peer-topeer learning, along with formal learning programs. Hydro’s learning platform offers content from various learning providers and esteemed universities. In addition, every employee engages in an annual appraisal dialogue with their leader to discuss and document development goals and activities. See Note S1.4 for metrics related to completed training activities in 2024. We lead Leadership is a key lever for Hydro’s organizational success. Hydro has developed a leadership framework that combines valid research with Hydro’s unique needs, enabling leaders to effectively deliver the business strategy and embody Hydro’s values. This framework underpins Hydro’s leadership processes, development programs and tools. In 2024, Hydro continued to deploy this framework through its people processes, with established leadership criteria supporting the selection, development and succession of leaders. Leadership development and succession planning for critical positions remain strategic people priorities as Hydro moves towards 2030. To cultivate a strong pipeline of leaders with diverse experience, Hydro aims to rotate leaders across different parts of the organization, and offer development initiatives and programs tailored to the needs of both leaders and specialists. We innovate Innovation is the third pillar of the People Strategy, where technology and digital tools serve as enablers for better decision making and help freeing up time for value adding activities. We belong Belonging is the final pillar of the new people strategy. The ambition is that together Hydro creates a healthy and inclusive environment where everybody's contributions matter.

Non-compliance cases are normally reported to line management and/or supporting staff functions including Group Compliance, Group Internal Audit and Investigations, Human Resources, Legal, HSE, Finance and Accounting. Non-compliances can also be reported through Hydro’s confidential reporting channel, the AlertLine. Every report made through the AlertLine is classified as a case, meaning that several cases could be related to the same issue. The number of dismissals due to breach of Hydro policy is limited to cases reported to Hydro’s Internal Audit. The number of dismissals due to breach of Hydro policy is limited to cases reported to Hydro’s Internal Audit.

Since 2022, Hydro have had several awareness raising campaigns about AlertLine, which might be a reason for the significant increase in total number of cases reported in the following years.

Significant non-compliance cases are defined as all material pending or threatened litigation and claims to which a consolidated Hydro company is party. Instances of non-compliance with laws or regulations that have resulted in a fine of NOK 1 million being issued by a public authority, as well as relevant cases that could have a material reputational or financial impact, are reported below.

Cases are reported by the compliance and legal functions in each business area. Total fines received are calculated based on the monetary value of fines issued in the reporting year. Fines issued in the reporting year may be paid in full or may be subject to further consideration by a court or other legal body.

Interests and views of stakeholders Engaging with Hydro’s stakeholders helps the company understand what is expected of it, what is important to them, how Hydro impacts them and how Hydro can solve common challenges. Hydro consults affected stakeholders to identify, assess, and manage material social, health, safety, environmental, and economic impacts associated with its activities and business relationships. Dialogue with affected stakeholders gives input to action plans to manage Hydro’s impacts and the views of affected stakeholders are integrated in the reporting on sustainability topics to Hydro management. Hydro strives to act in an ethical and transparent manner, and gather views from interested parties, aiming for a common understanding of the decisions that are made so Hydro can act with integrity in everything it does. Hydro’s engagement includes representatives of affected stakeholders, such as unions, work councils, local community groups and non-governmental organizations, suppliers, business partners, customer representatives, and industry associations. Hydro also engages and partners with sustainability experts from academia, and actively engages users of Hydro’s sustainability statements such as authorities, banks, and investors on Hydro’s sustainability ambitions and progress toward Hydro’s sustainability goals. Information on Hydro’s engagement of affected stakeholders is described in the chapters Own workforce, Workers in the value chain and Affected communities. Stakeholder engagement is organized both at the corporate level and in the business areas through local community meetings, bilateral engagement of individual stakeholders, national, and international multi-stakeholder meetings, and through industry associations. All business areas have a forum for dialogue between management and union or employee representatives.

Hydro’s engagement includes representatives of affected stakeholders, such as unions, work councils, local community groups and non-governmental organizations, suppliers, business partners, customer representatives, and industry associations. Hydro also engages and partners with sustainability experts from academia, and actively engages users of Hydro’s sustainability statements such as authorities, banks, and investors on Hydro’s sustainability ambitions and progress toward Hydro’s sustainability goals. Information on Hydro’s engagement of affected stakeholders is described in the chapters Own workforce, Workers in the value chain and Affected communities. Stakeholder engagement is organized both at the corporate level and in the business areas through local community meetings, bilateral engagement of individual stakeholders, national, and international multi-stakeholder meetings, and through industry associations. All business areas have a forum for dialogue between management and union or employee representatives.

Engaging with Hydro’s stakeholders helps the company understand what is expected of it, what is important to them, how Hydro impacts them and how Hydro can solve common challenges. Hydro consults affected stakeholders to identify, assess, and manage material social, health, safety, environmental, and economic impacts associated with its activities and business relationships. Dialogue with affected stakeholders gives input to action plans to manage Hydro’s impacts and the views of affected stakeholders are integrated in the reporting on sustainability topics to Hydro management. Hydro strives to act in an ethical and transparent manner, and gather views from interested parties, aiming for a common understanding of the decisions that are made so Hydro can act with integrity in everything it does.

Hydro’s engagement includes representatives of affected stakeholders, such as unions, work councils, local community groups and non-governmental organizations, suppliers, business partners, customer representatives, and industry associations. Hydro also engages and partners with sustainability experts from academia, and actively engages users of Hydro’s sustainability statements such as authorities, banks, and investors on Hydro’s sustainability ambitions and progress toward Hydro’s sustainability goals.

Hydro’s major sites in Europe and Brazil are unionized. Extrusions has a major presence in North America, and 44 percent of Hydro’s employees in North America are covered by collective bargaining agreements. Overall, 67 percent Hydro’s global workforce are covered by collective agreements. Collective bargaining takes place at a frequency agreed with the local unions. See Note S1.6 in the appendix, for more details. In Norway, non-organized workers typically benefit from the same compensation adjustments negotiated at the industry level. In addition, workers on individual agreements may receive adjustments based on company and individual performance, and external benchmarking. In regions where union representation is no

Hydro’s sustainability statements in the Annual Report 2024 have been prepared in compliance with ESRS. • Hydro’s assessment and presentation of material sustainability matters were updated in 2024 based on the guidance issued by EFRAG. • Consumers and end users are no longer considered a material topic, as Hydro does not have a material impact on, and is not exposed to material risks associated with individuals who consume goods for personal use, based on an improved understanding of ESRS definitions of consumers and end users

• The presentation of material impacts, risks and opportunities (IRO) in relation to each ESRS topical standard in the Materiality assessment section is changed to better distinguish between actual and potential impacts, and to improve alignment of sustainability related risks with the aggregated risk profile presented in the Risk update. • The presentation of Scope 1 and Scope 2 GHG emissions has been updated to comply with ESRS E1 requirements. Historical GHG emissions have been recalculated to provide comparative data. • Sustainability metrics and indicators that were presented in the sustainability statements in 2023, but that are considered not relevant for material IROs, have been moved to the Appendix. Metrics in the appendix are part of Hydro’s management report, approved by the Board of Directors, and subject to the same level of control and external assurance as the sustainability statements. No material errors in prior periods have been identified, but some minor corrections have been made in individual metrics. Such corrections are described in the note to the respective metrics

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Materiality assessment Hydro assesses material sustainability related impacts, risks, and opportunities according to the ESRS concept and requirements of double materiality. The assessment is validated by Hydro’s disclosure committee and approved by the Board of Directors. The materiality assessment is based on input from Hydro’s subject matter experts in group functions for climate, environment, social responsibility, health and safety, communication and investor relations, compensation and benefits, diversity, inclusion and belonging, compliance, and enterprise risk management, as well as input from risk management and sustainability functions in each business area. Involvement of the risk management resources in the materiality assessment process supports the identification and further evaluation of sustainability related impacts and risks. The views of Hydro’s stakeholders are integrated in the materiality assessment that is updated every year. Hydro’s group functions and business areas summarize input provided to them through their engagement with affected stakeholders, and their interaction with external sustainability experts and users of Hydro’s sustainability statement.

Impact materiality is assessed in terms of actual and potential, positive and negative sustainability impacts from Hydro’s own activities and/or business relationships in the upstream and downstream value chain. The assessment of impacts is in accordance with the GRI Standards and OECD Due Diligence Guidance for Responsible Business Conduct. The materiality of impacts is assessed based on the severity and likelihood of impacts occurring. When exercising judgment on whether an impact is considered material, reference is made to the primary consequence scales in Hydro’s global ERM directive. For environmental impacts, reference is also made to the environmental consequence scales in Hydro’s Guidance for HSE Incidents management. For human rights impacts, reference is made to the metrics for assessing severity of human rights impacts defined in the ICMM Human Rights Due Diligence Guidance Financial materiality is assessed in terms of risk of negative reputational, financial or commercial consequences for Hydro that are associated with sustainability topics, as well as potential sustainability related upside risks, or opportunities, for Hydro. The materiality of risks and opportunities is assessed based on the likelihood and magnitude of anticipated effects on Hydro’s performance, financial position, cash flow, access to finance or cost of capital. All identified sustainability related impacts, risks and opportunities, including risks arising from Hydro’s potential sustainability impacts and dependencies, that are considered material for affected stakeholders or users of Hydro’s sustainability statements are presented on the next four pages and described in the sustainability statement. These sustainability related risks are prioritized in the same way as other risks Hydro is exposed to, however, not all sustainability related risks in the sustainability statements are specifically highlighted in Hydro’s aggregate risk profile described in the Risk review section. Hydro’s sustainability statements include separate chapters on all material sustainability topics covered by ESRS. In addition, Hydro has included one Hydro specific sustainability topic: Legacy impact. The chapter for each material sustainability topic includes a description of Hydro’s sustainability context and dependencies (“why it matters”). The chapters also include a section on “our approach,” which presents Hydro’s due diligence and stakeholder engagement on identified IROs for the sustainability matter, as well as relevant disclosures on policies, strategy, actions, targets and metrics in relation to the sustainability topic.

Hydro assesses material sustainability related impacts, risks, and opportunities according to the ESRS concept and requirements of double materiality. The assessment is validated by Hydro’s disclosure committee and approved by the Board of Directors. The materiality assessment is based on input from Hydro’s subject matter experts in group functions for climate, environment, social responsibility, health and safety, communication and investor relations, compensation and benefits, diversity, inclusion and belonging, compliance, and enterprise risk management, as well as input from risk management and sustainability functions in each business area. Involvement of the risk management resources in the materiality assessment process supports the identification and further evaluation of sustainability related impacts and risks. The views of Hydro’s stakeholders are integrated in the materiality assessment that is updated every year. Hydro’s group functions and business areas summarize input provided to them through their engagement with affected stakeholders, and their interaction with external sustainability experts and users of Hydro’s sustainability statement.

All identified sustainability related impacts, risks and opportunities, including risks arising from Hydro’s potential sustainability impacts and dependencies, that are considered material for affected stakeholders or users of Hydro’s sustainability statements are presented on the next four pages and described in the sustainability statement. These sustainability related risks are prioritized in the same way as other risks Hydro is exposed to, however, not all sustainability related risks in the sustainability statements are specifically highlighted in Hydro’s aggregate risk profile described in the Risk review section.

Hydro assesses material sustainability related impacts, risks, and opportunities according to the ESRS concept and requirements of double materiality. The assessment is validated by Hydro’s disclosure committee and approved by the Board of Directors. The materiality assessment is based on input from Hydro’s subject matter experts in group functions for climate, environment, social responsibility, health and safety, communication and investor relations, compensation and benefits, diversity, inclusion and belonging, compliance, and enterprise risk management, as well as input from risk management and sustainability functions in each business area. Involvement of the risk management resources in the materiality assessment process supports the identification and further evaluation of sustainability related impacts and risks. The views of Hydro’s stakeholders are integrated in the materiality assessment that is updated every year. Hydro’s group functions and business areas summarize input provided to them through their engagement with affected stakeholders, and their interaction with external sustainability experts and users of Hydro’s sustainability statement.

Consumers and end users are no longer considered a material topic, as Hydro does not have a material impact on, and is not exposed to material risks associated with individuals who consume goods for personal use, based on an improved understanding of ESRS definitions of consumers and end users.

The presentation of Scope 1 and Scope 2 GHG emissions has been updated to comply with ESRS E1 requirements. Historical GHG emissions have been recalculated to provide comparative data

Hydro's industrial processes generate greenhouse gas (GHG) emissions that contribute to climate change, primarily because of the energy used in alumina refining and primary aluminium production and the process emissions from the electrolysis process in primary aluminium production. Hydro also depends on energy and material inputs that are associated with GHG emissions in Hydro’s value chain. At the same time, Hydro contributes significantly to climate change mitigation through its production of renewable energy, low-carbon primary aluminium, and recycled aluminium of post-consumer scrap. The aluminium Hydro produces is also a strategically important input material to many technologies that enable the green transition, including the development of renewable energy. Hydro is exposed to climate related risks such as acute or chronic changes in rainfall patterns, flooding, shortages of water or other natural resources, variations in sea levels, storm patterns, and intensities as well as temperature changes. Such risks can impact the integrity of Hydro’s assets or cause disruptions to Hydro’s operations or to Hydro’s value chain. The transition to a low-carbon economy can also pose risks to Hydro, including higher costs for greenhouse gas emissions and production inputs, or changes to market prices for aluminium based products. However, the transition to a 1.5-degree economy also presents significant opportunities for Hydro. Aluminium is an enabler for the transition away from fossil fuels and other activities that generate greenhouse gases. Aluminium demand in sectors such as renewable power production, transport and electrification are expected to grow as companies, states and society work to reach its commitments to reduce GHG emissions. Aluminium can save significant amounts of energy and GHG emissions in the use phase due to its lightweight properties, and building facades in aluminium can lead to lower operating costs and enable buildings to generate as much energy as they use during operation. In addition, Hydro aims to enable other sectors to decarbonize and transform to a low-carbon economy by utilizing its industrial and energy competence to develop renewable energy sources such as hydropower, wind, and solar.

Negative impacts on climate change associated with GHG emissions from fossil fuel use, as well as process emissions from the production of primary aluminium. Value chain impacts on climate change associated with the carbon footprint of raw materials that Hydro depends on in its aluminium production processes.

Net-zero Hydro Hydro has a defined ambition to reduce GHG emissions from own operations and to reach net-zero GHG emissions by 2050 or earlier. To concretize this ambition Hydro has established a technology and decarbonization roadmap for how to reduce direct and indirect GHG emissions by 10 percent by 2025 and 30 percent by 2030, from a 2018 baseline.2)

Hydro has participated in the International Aluminium Institute’s (IAI) work to develop a GHG emission reduction pathway for primary aluminium production toward 2050 consistent with the Paris Agreement. The analysis is based on the International Energy Agency’s (IEA) 1.5-degree scenario, combined with IAI’s analysis of demand in the aluminium market and material flows. Hydro’s net-zero ambitions and decarbonization pathway is in line with IAI’s emission reduction pathway for the aluminium sector and the 1.5-degree scenario. When the Science Based Target Initiative (SBTi) has developed a sectoral decarbonization approach (SDA) for the aluminium sector, Hydro will consider verifying the climate strategy against SBTi.

• Net-zero Hydro: Reduce Scope 1 and 2 GHG emissions by 30 percent by 2030 and become a net-zero Hydro by 2050 or earlier • Net-zero products: Deliver net-zero products to Hydro’s customers and reduce upstream Scope 3 GHG emissions per tonnes of aluminium by 30 percent by 2030 • Net-zero society: Use Hydro’s industrial and energy competence to contribute to the transition to a net-zero society.

Our approach Hydro identifies and measures impacts on climate change by calculating and managing its GHG emissions from all its operations and from material parts of its value chain. Hydro’s methodologies are aligned with international standards including the Greenhouse Gas Protocol and industry standards from the International Aluminium Institute (IAI). Hydro engages with a broad set of stakeholders on climate related issues, including industry organizations, international standard setters, and local stakeholders in countries where it has significant operations, such as Norway, Brazil and the U.S., as well as with regional structures like the European Union. Strategy and transition plan Hydro’s climate strategy and transition plan is an integral part of its overall business strategy. Hydro’s net-zero ambitions are based on a successful transition to a 1.5-degree economy, and are in line with climate science and the Paris agreement. Hydro’s climate strategy consists of three pillars, aiming to reduce the climate impact of its operations and create business opportunities by enabling its customers and society to do the same: • Net-zero Hydro: Reduce Scope 1 and 2 GHG emissions by 30 percent by 2030 and become a net-zero Hydro by 2050 or earlier • Net-zero products: Deliver net-zero products to Hydro’s customers and reduce upstream Scope 3 GHG emissions per tonnes of aluminium by 30 percent by 2030 • Net-zero society: Use Hydro’s industrial and energy competence to contribute to the transition to a net-zero society The climate strategy is integrated in the ELT’s remuneration and followed up as a quarterly KPI on the CEO’s balanced scorecard. See the remuneration report for more information. Hydro’s climate strategy is integrated in the overall strategy as set by the Executive Leadership Team. The business areas are responsible for Hydro’s performance and implementation of the climate strategy. All significant investment decisions are assessed for their impact on Hydro’s climate strategy according to Hydro’s policies addressing climate change mitigation. A thorough description of Hydro's climate related impacts and how Hydro works to prevent, mitigate and remediate these, is provided in the white paper 'Positioning Hydro for the just and green transition' from 2025.

Carbon capture and storage (CCS) – Decarbonizing existing operations To accelerate decarbonization of the aluminium industry and make Hydro’s existing aluminium smelters fit for the future, Hydro is developing carbon capture and storage (CCS) solutions that can be retrofitted into aluminium plants already in operation. Through capturing off-gases at Hydro’s existing smelters, the company aims to reduce emissions from the electrolysis process. In addition, and as a supplement, Hydro is exploring options for direct air capture (DAC) units at its smelters. For some capture technologies, this has the advantage that process heat can be recovered for use in the DAC unit, lowering power demand and operational costs. Hydro has evaluated more than 50 CCS technologies and developed a roadmap for testing and piloting the most promising up to industrial scale. The most likely outcome will be a combination of off-gas capture and direct air capture to eliminate 100 percent of the emissions. 2. HalZero chloride process – Decarbonizing new smelter capacity HalZero is a new production process for primary aluminium that emits oxygen instead of carbon dioxide (CO2). In the HalZero process, alumina is chlorinated and becomes aluminium chloride. Through closed loop processes, the electrolysis will be greenhouse gas emission free. The HalZero process differs significantly from the current production of primary aluminium and is being developed for use in new production facilities. Construction of Hydro’s HalZero test facility in Porsgrunn, Norway, is proceeding according to plan. For the next step, the feasibility study is ongoing and the project will proceed through the next phases towards construction of an industrial scale pilot facility by 2030. The HalZero process will be applicable for greenfield aluminium plants or brownfield replacement of obsolete potlines, where the smelter infrastructure can be re-used. This way Hydro can fully decarbonize the smelting process by eliminating emissions from both electrolysis and anode baking. 3. Net-Zero aluminium through scaling up volumes of post-consumer scrap (PCS) Aluminium recycling requires 95 percent less energy than the production of primary aluminium while still offering high-quality aluminium. Hydro is developing recycling technology and low-carbon products based on post-consumer scrap (PCS), and plans to improve its recycling capacity to sort and utilize more complex PCS aluminium. Hydro has already produced Hydro CIRCAL, which is a certified recycled and low-carbon product, with more than 75 percent PCS. Hydro CIRCAL has a market leading CO2 footprint of 1.9 kg of CO2e/kg aluminium, down from previously being 2.3 kg of CO2e/kg. This is done through advances in sourcing, sorting and traceability of post-consumer aluminium scrap. At Hydro’s recycling plant in Clervaux in Luxembourg, the company has also produced 130 tonnes of near-zero carbon aluminium with 100 percent post-consumer aluminium scrap, Hydro CIRCAL 100R, with a carbon footprint below 0.5 kg CO2e per kg aluminium. Hydro will make key capacity investments over the medium term to ensure its recycling portfolio can facilitate the increasing demand for Hydro CIRCAL and invest in technologies to increase usage of endconsumer scrap while securing access to scrap. Hydro has continued to strengthen its recycling position in 2024 by opening a new aluminium recycling plant in Szekesfehervar in Hungary with capacity of 90,000 tonnes, investing in a new recycling facility in Høyanger in Norway with capacity of 36,000 tonnes and investments in upgrading the recycling facility in Atessa in Italy to further increase the recycling capacity. Please see the Resource use and circular economy chapter for more information about recycling.

Hydro REDUXA is Hydro’s other brand of low-carbon aluminium using renewable energy from water, wind and solar in the production phase. This can reduce the full value chain carbon footprint per kg of aluminium to 4.0 kgCO2e per kilo aluminium, which is significantly less than the global average of 14.8. The production capacity for near-zero carbon aluminium will be developed in line with market demand for this near zero-carbon aluminium. This is also reflected in the ambition to deliver Hydro REDUXA 2.0 with a carbon footprint of less than 2 tonnes of CO2e per mt of aluminium by 2030. Hydro CIRCAL and Hydro REDUXA supports both margin and volume growth. Hydro earns additional premiums or volume commitments on its low-carbon products, and many customers choose Hydro’s aluminium due to its low-carbon footprint. Greener sourcing and scope 3 emissions Hydro reports Scope 3 emissions based on the guidelines issues by the International Aluminium Institute (IAI) Scope 3 Tool Guidance. Hydro is a large purchaser of raw materials and energy, including aluminium and the metal required for alloys. The aluminium Hydro purchases externally to supply its casthouses, recyclers and extrusion plants, and the greenhouse gas emissions associated with the production of this aluminium, makes up the majority of Hydro’s scope 3 emissions. As Hydro considers the carbon footprint of process scrap as equal to its metal origin, Hydro’s upstream scope 3 emissions are significant when including externally sourced metal. Hydro aims to source aluminium metal with a lower-carbon footprint and to increase the use of post-consumer scrap in its metal production. In 2022, Hydro set emissions reduction targets for upstream scope 3 emissions to reduce total upstream scope 3 emissions by 15 percent by 2030, and to reduce upstream scope 3 emissions per tonne aluminium delivered to the market by 30 percent by 2030. Both targets refer to a 2018 baseline. Downstream scope 3 emissions were not included in the targets as these emissions are more difficult to influence and control, and since upstream emissions represents 93 percent of the total scope 3 emissions. The 2024 results show that Hydro has reduced its total upstream scope 3 emissions by 44 percent, compared to the 2018 baseline. Per tonnes aluminium delivered to market, Hydro has already reduced its emissions by 40 percent. The reductions are mainly due to more conscious sourcing of metal, but also due to less volumes in Extrusions. Going forward, upstream scope 3 emissions may increase, both in total and per tonne, due to higher activity and thus more external metal input. Hydro is currently considering setting a net-zero target also for upstream scope 3 emissions. Net-zero society Net-zero society is an important pillar in Hydro’s climate strategy, with a defined ambition to use Hydro’s competence and capabilities to enable a net-zero society. The transition to a net-zero society must be a just and fair transition, which means a transition that is as fair and inclusive as possible to everyone concerned. Hydro’s approach to a just transition is further described in the chapters on Own workforce, Workers in the value chain and Affected communities. To move to a net-zero society, the world needs more renewable electricity generation and mechanisms to store that energy. Hydro is investing in renewable energy solutions, including projects that increase renewable electricity generation capacity and technologies to store energy. In addition, low-carbon aluminium is an enabling material for the green transition in different markets. Hydro Rein Hydro Rein is a leading provider of renewable energy solutions to industry. Hydro Rein supports Hydro and other industrial companies to decarbonize through large renewables energy projects in addition to onsite generation, energy efficiency, energy storage and flexibility management. Hydro Rein currently has a diversified portfolio of more than 60 renewable energy projects in core markets in the Nordics and Brazil, in addition to a pipeline of energy solutions projects in Europe and North America. During second quarter 2024, Hydro Rein and Macquarie Asset Management became partners to further accelerate Hydro Rein's growth in renewable energy. The two companies were already partners in a large-scale onshore wind farm in the northeast of Brazil which became commercially operational in fourth quarter 2024 and is estimated to avoid 11,767 KT CO2e over the project life. Through Power Purchase Agreements (PPAs), this project will supply electricity to Hydro’s bauxite mine in Paragominas and its alumina refinery in Alunorte in order to reach Hydro’s GHG reduction target. Hydro has been partnering with Macquarie since 2017 to enable the development of renewable energy capacity. Batteries The Batteries business unit in Hydro Energy was established in 2020 with an ambition to invest and grow sustainable battery materials companies. The portfolio includes Hydrovolt, E-magy, Lithium de France, Northvolt, Corvus and Vianode. In fourth quarter 2024, Hydro increased the ownership of Hydrovolt to 68 percent. To strengthen the focus on Hydro’s 2030 strategy and address challenging market conditions in the batteries sectors, battery materials will no longer be strategic growth areas for Hydro and the Batteries businesses unit will therefore be phased out.

Hydro is working to assess the potential consequences and necessary mitigating actions, and plans needed to adapt for climate change. The findings from the updated climate assessment are being integrated in Hydro’s risk management system. Several of Hydro’s assets have already undertaken significant upgrades to manage climate related risks such as the effects of increased precipitation and associated flood risks.

Market risk Hydro will benefit from increased demand for low-carbon aluminium, as customers decarbonize their value chains. The demand for lowcarbon aluminium is expected to grow at a higher rate than the overall demand for aluminium. In parallel, demand for (low-carbon) aluminium could strengthen further as aluminium substitutes steel, copper or other metals, in sectors such as production of renewable energy and thermal technologies, transport, construction and real estate. In an opposite scenario, the demand for aluminium could decline if Hydro does not succeed with the decarbonization of its value chain in line with its technology roadmap for net-zero GHG emissions by 2050. If Hydro fails to develop and implement HalZero, or other electrolysis technology while competing industries succeed in their decarbonization efforts, this could result in decreased demand for aluminium as steel or other metals substitute aluminium. Similar risks apply if Hydro does not succeed with retrofitting carbon capture at existing facilities. This can impact the value of Hydro’s existing aluminium smelters.

Technology risk New technology must be developed and implemented for production of primary aluminium in a net-zero GHG emission economy. Hydro is developing new, emission free, technology for use in future aluminium production facilities. In addition, Hydro is assessing options to implement carbon capture solutions at the existing smelters. For Hydro to retain the strategic benefit of lower-carbon emissions, developing technology that can be fitted to existing production facilities at an affordable price is important, and not succeeding in this constitutes a technological risk. In other parts of Hydro’s value chain, the company can achieve net-zero emissions with existing technologies, provided sufficient renewable energy is available at competitive prices in the regions. Potential carbon lock-in in the aluminium value chain Carbon lock-in occurs when fossil fuel assets continue to be used, despite the possibility to substituting them with low-emission alternatives. For Hydro, carbon lock-in is primarily a risk associated with fossil fuel dependencies in the production of the electricity used for aluminium production. At Hydro’s joint venture in Qatalum, Qatar, the electricity used for primary aluminium production is provided from an integrated natural gas-fired plant. The fuel switch project in Alunorte is an intermediate step towards full decarbonization of alumina refining by 2040 and this is therefore not considered as a long-term lock-in effect on GHG emissions

Climate related physical risks refer to the impact on business performance by climate related acute and/or chronic changes in rainfall patterns, flooding, shortages of water or other natural resources, variations in sea levels, storm patterns and intensities as well as temperatures. Such risks can result in flooding of facilities, interruptions to production processes, infrastructure failures and potential accidents. To understand and mitigate climate related physical risks for Hydro’s operations, the company has performed several climate risk assessments. In 2018, Hydro modelled future weather patterns and their impact on its facilities based on climate models and scenarios from the Intergovernmental Panel on Climate Change (IPCC). In 2023, Hydro updated the physical climate risk assessment, which included modelling the risk of climate related events in the current situation, in addition to RCP 4.5 and RCP 8.5 in a 2030, 2040 and 2050 scenario.

Climate change adaptation and the transition to a 1.5-degree economy poses both opportunities and risks to Hydro. The company has assessed regulatory risks, market risks and technology risks consistent with a 1.5-degree scenario. As a result, Hydro’s long-term positioning, and operational and financial planning, reflect the company’s assessment of transition risks in a 1.5-degree scenario. The transition can lead to stricter regulations and more ambitious climate targets may drive costs within parts of Hydro’s asset base. The overall portfolio will likely benefit from such trends, as it will increase the demand and value of Hydro’s low-carbon products and portfolio. Aluminium is widely acknowledged as an enabler for the green transition and the low-carbon aluminium Hydro produces is a key lever to reduce scope 3 emissions for customers across several industry sectors. Hydro is well positioned to benefit from the transition to netzero GHG emissions and generates significantly lower GHG emissions than the industry average. The average carbon intensity of Hydro’s aluminium production is below the 2030 and 2035 targets in the 1.5 degree scenario that the International Aluminium Institute has defined for the aluminium industry. The carbon footprint of aluminium production is highly dependent on the source of electricity used to produce the metal. Hydro’s footprint reflects the fact that the majority of its primary production facilities use electricity from renewable sources.

Regulatory risks As the aluminium and alumina markets are global markets, relative competition between countries and regions influences which production sites will be viable in the future. In general, Hydro will benefit from globally aligned initiatives which sets a price on CO2 emissions and supports renewable energy use. Additionally, regulatory initiatives providing low-emission energy at competitive prices will benefit Hydro's existing production facilities. In the opposite scenario, Hydro will have a disadvantage if significant carbon taxes are imposed on emissions in countries or regions where Hydro’s production is placed, while similar regulation is not introduced in competing regions. Situations with severe limitations in availability of renewable electricity where Hydro’s production facilities are located will be a disadvantage for the company’s aluminium related assets. Hydro’s energy producing assets are renewable only, with the majority being hydropower in Norway. Hydro is also engaged in production of power from solar and wind resources, currently mainly in partnership with other companies and the majority of the projects are in development phase. These assets will benefit from stricter regulations on CO2 emissions. However, specific regulations might impact the competitiveness and value of individual facilities.

Internal carbon pricing A large amount of Hydro’s aluminium operations falls within the scope of the EU Emissions Trading System (EU ETS). Hydro purchases and surrenders allowances (EUAs) to fulfil the company’s compliance obligations under the EU ETS, and receives a proportion of free EUAs. The amount of purchased and received EUAs is publicly available information at a national level by the respective local EU ETS authorities. Hydro uses the EU ETS carbon price in internal decision making processes inside and outside of the EU/EEA, and the cost of carbon is integrated in financial and operational decisions. By including a carbon price in Hydro’s analysis, costs related to CO2 emissions become a variable operational cost at plant level and CO2 price expectations influence future investment decisions. Hydro's part owned primary aluminium producer, Alouette, is also subject to carbon market compliance obligations (under the Québec cap-and-trade system which is part of the Western Climate Initiative (WCI)).

Hydro identifies and measures impacts on climate change by calculating and managing its GHG emissions from all its operations and from material parts of its value chain. Hydro’s methodologies are aligned with international standards including the Greenhouse Gas Protocol and industry standards from the International Aluminium Institute (IAI). Hydro engages with a broad set of stakeholders on climate related issues, including industry organizations, international standard setters, and local stakeholders in countries where it has significant operations, such as Norway, Brazil and the U.S., as well as with regional structures like the European Union.

To understand and mitigate climate related physical risks for Hydro’s operations, the company has performed several climate risk assessments. In 2018, Hydro modelled future weather patterns and their impact on its facilities based on climate models and scenarios from the Intergovernmental Panel on Climate Change (IPCC). In 2023, Hydro updated the physical climate risk assessment, which included modelling the risk of climate related events in the current situation, in addition to RCP 4.5 and RCP 8.5 in a 2030, 2040 and 2050 scenario. Hydro is working to assess the potential consequences and necessary mitigating actions, and plans needed to adapt for climate change. The findings from the updated climate assessment are being integrated in Hydro’s risk management system. Several of Hydro’s assets have already undertaken significant upgrades to manage climate related risks such as the effects of increased precipitation and associated flood risks.

Hydro is also engaged in production of power from solar and wind resources, currently mainly in partnership with other companies and the majority of the projects are in development phase. These assets will benefit from stricter regulations on CO2 emissions. However, specific regulations might impact the competitiveness and value of individual facilities.

Positive impacts on climate change mitigation associated with generation of renewable energy, development of new renewable energy assets, and production of low-carbon primary and secondary aluminium.

Hydro is working to assess the potential consequences and necessary mitigating actions, and plans needed to adapt for climate change. The findings from the updated climate assessment are being integrated in Hydro’s risk management system. Several of Hydro’s assets have already undertaken significant upgrades to manage climate related risks such as the effects of increased precipitation and associated flood risks

Hydro identifies and measures impacts on climate change by calculating and managing its GHG emissions from all its operations and from material parts of its value chain. Hydro’s methodologies are aligned with international standards including the Greenhouse Gas Protocol and industry standards from the International Aluminium Institute (IAI). Hydro engages with a broad set of stakeholders on climate related issues, including industry organizations, international standard setters, and local stakeholders in countries where it has significant operations, such as Norway, Brazil and the U.S., as well as with regional structures like the European Union.

Net-zero Scope 1 and 2 GHG emissions by 2050 or earlier

Net-zero Hydro: Reduce Scope 1 and 2 GHG emissions by 30 percent by 2030 and become a net-zero Hydro by 2050 or earlier

Net-zero products: Deliver net-zero products to Hydro’s customers and reduce upstream Scope 3 GHG emissions per tonnes of aluminium by 30 percent by 2030

Net-zero society: Use Hydro’s industrial and energy competence to contribute to the transition to a net-zero society

10% Reduction in Scope 1 and 2 GHG emissions by 2025

30% Reduction in Scope 1 and 2 GHG emissions by 2030

30% Reduction in upstream Scope 3 GHG emissions per tonnes aluminium by 2030

E1.1 Total greenhouse gas emissions based on ownership equity

E1.2 Indirect (scope 3) greenhouse gas emissions

E1.3Greenhouse gas emissions intensity

16.1% Reduced Scope 1 and 2 GHG emissions, against 2018 baseline

8.98 Million tonnes Scope 1 and 2 GHG emissions (location based), by ownership equity

1.52 Tonnes Scope 1 GHG emissions per tonne aluminium from the electrolysis process

11.08 Million tonnes upstream Scope 3 emissions by ownership equity

Hydro is working to assess the potential consequences and necessary mitigating actions, and plans needed to adapt for climate change. The findings from the updated climate assessment are being integrated in Hydro’s risk management system. Several of Hydro’s assets have already undertaken significant upgrades to manage climate related risks such as the effects of increased precipitation and associated flood risks.

Hydro engages with a broad set of stakeholders on climate related issues, including industry organizations, international standard setters, and local stakeholders in countries where it has significant operations, such as Norway, Brazil and the U.S., as well as with regional structures like the European Union. Hydro also engages and partners with customers in different industries to deliver low-carbon aluminium and to develop technical solutions for low-carbon products.

Hydro engages with a broad set of stakeholders on climate related issues, including industry organizations, international standard setters, and local stakeholders in countries where it has significant operations, such as Norway, Brazil and the U.S., as well as with regional structures like the European Union. Hydro also engages and partners with customers in different industries to deliver low-carbon aluminium and to develop technical solutions for low-carbon products.

Aluminium production carries an inherent risk of pollution, linked to process emissions to air and water, and the potential for accidental spills or leakages. There is also risk of pollution in the supply chain for raw materials. Such pollution can have a negative impact on the local environment and local communities if not managed correctly. Hydro’s business activities are subject to emissions regulations, including local emission permits, as well as regional and international regulation of emissions. Stricter regulations related to emissions and pollution could impose new requirements on Hydro’s operations and value chain, which in turn could affect cash flow or impose capital investments to reduce the emissions from Hydro’s activities in the medium and long-term. Incidents resulting in spills, leakages and other non-compliance with emission permits can result in fines and remediation costs that have an impact on Hydro’s financial performance. Pollution linked to historical activities, at both existing operations and legacy sites, may also require active intervention and remediation. Actual or perceived pollution impacts on local communities can result in operational shutdown, legal disputes or negative reputational effects.

Potential negative impacts associated with unintended or accidental emissions of pollutants to air or water from alumina refining or primary aluminium production. Potential negative impacts associated with unintended or accidental emissions of pollutants to air or water in Hydro's supply chain for raw materials and energy.

Hydro’s Global Procedure on Environmental Management, which is approved by the EVP People and HSE, requires that all operational sites that are fully owned or operated by Hydro, identify, control, and appropriately monitor material emissions to air and water from its operations, in accordance with the environmental licensing and applicable legal requirements. T

In 2024, Hydro joined World Economic Forum’s Alliance for Clean Air, a cross sector initiative to the social and environmental benefits of collective action to reduce air pollution. As an Alliance Member, Hydro has worked with the Stockholm Environment Institute to develop inventories and baselines of material air pollutants, linked to its electricity sourcing and wider value chain. This data will be used as input for future disclosures and target setting, with the goal of reducing air pollutant emissions linked to Hydro’s full value chain.

Hydro’s products are subject to compliance declarations according to different EU and U.S. legislations. This includes registration, evaluation, authorization and restriction of chemicals (REACH) and restriction of hazardous substances (RoHS) in the EU, and the Toxic Substances Control Act and California’s proposition 65 in the U.S. This gives Hydro’s customers assurance that its aluminium profiles do not contain the prohibited substances above the defined limits.

Hydro has established a voluntary target to halve material non-GHG emissions (i.e. SO2, NOx and PM emissions to air) by 2030, from a 2017 baseline. These emissions are primarily linked to fossil fuel consumption in Hydro’s operations. To achieve this target, sites are required to decarbonize their processes where feasible. For more information about Hydro’s efforts to decarbonize and reduce emissions, see chapter on Climate change. In 2024, total emissions of SO2, NOx and PM10 were 57 percent, 67 percent and 37 percent lower, respectively, than the 2017 baseline. A key driver for this improvement has been the replacement of heavy fuel oil with natural gas at Hydro’s refinery, Alunorte. Additionally, to align more closely with the measurement hierarchy stated in ESRS E2, Alunorte changed its reporting approach in 2024 to report directly measured emissions of SO2 and NOx from its processes, through periodic sampling, instead of using the default emission factors taken from the Norwegian Authorities. This approach gives a closer approximation of actual emissions released, accounting for the technology and process efficiency at the site. Hydro has set targets to reduce fluoride emissions from its fully owned smelters. These smelters currently perform below the EU regulatory emission limit for existing smelters (0.6 kg F/t Al) and the average is also below EU regulatory emission limit for new smelters (0.35 kg F/t Al). Hydro will continue to invest in upgrades of gas treatment centers and strive for operational excellence such that individual smelter performances are all below the 0.35 kg F/t Al limit Inorganic mercury compounds are naturally occurring trace element within bauxite. Due to the high temperatures in the refining process, elemental mercury is produced and can be emitted to air and water. Hydro’s alumina refinery has a wastewater treatment plant to mitigate emissions to water that treats all liquid effluents prior to discharge. To reduce emissions of mercury to air, Hydro has initiated a project to install four non-condensable gases units (condensers) on Alunorte’s eight digestor lines. The first condenser was installed in 2018, as a pilot, and its technical performance was monitored prior to the installation of the remaining units. A second condenser was installed in 2023 and entered into operation in 2024. The third condenser was installed in 2024 and will be operational in early 2025. The final condenser will be installed and operational by end of 2025.

Incidents resulting in spills, leakages, or other non-compliances with environmental performance standards, could potentially result in material pollution. To minimize the risk of material pollution, operational sites are required to implement suitable process controls, inspection and maintenance routines and additional controls, such as secondary containment. In the events of an actual spill, incidents are assessed and classified according to the severity of impact. See Note E2.2 for reported spills and leakages and Note E2.3 for information on environmental permits.

Emissions and mitigating actions in the aluminium value chain Activity Emissions Mitigating actions Bauxite mining Water discharges to environment: suspended solids Clarification basins Alumina refining Water discharges to environment: pH and suspended solids Two step water treatment process, consisting of pH adjustment and clarification SO2, NOx and PM emissions to air Alunorte fuel switch project to replace HFO with LNG by 2025, reduction of coal use towards 2030 Fugitive PM emissions to air in dry season Water spraying of roads and open areas; use of non-woven geotextile materials (aka. Bidim) to cover bauxite residue deposits Mercury emissions to air and water Mercury condensers by end 2025, and wastewater treatment Primary aluminium production Water discharges to environment Wastewater treatment plants; oil separators; containment basins Fluoride emissions to air Alumina fed dry scrubbers SO2 and PM emissions to air Seawater fed wet scrubbers (fully owned smelters) Other emissions to air from casthouse and anode baking furnaces Bag filters Aluminium recycling Other emissions to air from casthouse Bag filters (where legally required) Extruded products Water discharges to environment (where applicable)* Wastewater treatment plants; oil separators; containment basins

Hydro has established a voluntary target to halve material non-GHG emissions (i.e. SO2, NOx and PM emissions to air) by 2030, from a 2017 baseline. These emissions are primarily linked to fossil fuel consumption in Hydro’s operations. To achieve this target, sites are required to decarbonize their processes where feasible. For more information about Hydro’s efforts to decarbonize and reduce emissions, see chapter on Climate change. In 2024, total emissions of SO2, NOx and PM10 were 57 percent, 67 percent and 37 percent lower, respectively, than the 2017 baseline. A key driver for this improvement has been the replacement of heavy fuel oil with natural gas at Hydro’s refinery, Alunorte. Additionally, to align more closely with the measurement hierarchy stated in ESRS E2, Alunorte changed its reporting approach in 2024 to report directly measured emissions of SO2 and NOx from its processes, through periodic sampling, instead of using the default emission factors taken from the Norwegian Authorities. This approach gives a closer approximation of actual emissions released, accounting for the technology and process efficiency at the site. Hydro has set targets to reduce fluoride emissions from its fully owned smelters. These smelters currently perform below the EU regulatory emission limit for existing smelters (0.6 kg F/t Al) and the average is also below EU regulatory emission limit for new smelters (0.35 kg F/t Al). Hydro will continue to invest in upgrades of gas treatment centers and strive for operational excellence such that individual smelter performances are all below the 0.35 kg F/t Al limit Inorganic mercury compounds are naturally occurring trace element within bauxite. Due to the high temperatures in the refining process, elemental mercury is produced and can be emitted to air and water. Hydro’s alumina refinery has a wastewater treatment plant to mitigate emissions to water that treats all liquid effluents prior to discharge. To reduce emissions of mercury to air, Hydro has initiated a project to install four non-condensable gases units (condensers) on Alunorte’s eight digestor lines. The first condenser was installed in 2018, as a pilot, and its technical performance was monitored prior to the installation of the remaining units. A second condenser was installed in 2023 and entered into operation in 2024. The third condenser was installed in 2024 and will be operational in early 2025. The final condenser will be installed and operational by end of 2025.

Incidents resulting in spills, leakages, or other non-compliances with environmental performance standards, could potentially result in material pollution. To minimize the risk of material pollution, operational sites are required to implement suitable process controls, inspection and maintenance routines and additional controls, such as secondary containment. In the events of an actual spill, incidents are assessed and classified according to the severity of impact. See Note E2.2 for reported spills and leakages and Note E2.3 for information on environmental permits.

Hydro’s Global Procedure on Environmental Management, which is approved by the EVP People and HSE, requires that all operational sites that are fully owned or operated by Hydro, identify, control, and appropriately monitor material emissions to air and water from its operations, in accordance with the environmental licensing and applicable legal requirements. These emissions are typically subject to regulatory controls and requirements such as emission limits, abatement and monitoring. The requirements are reflected in the operational licenses and will differ depending on the type of activity and applicable regulatory frameworks. Hydro’s most significant emissions to air are linked to fossil fuel consumption in alumina refining and process emissions linked to primary aluminium production. The largest non-GHG emissions are sulfur dioxide (SO2), nitrogen oxide (NOx), particulate matter (PM) and fluoride (F). SO2 and NOx emissions to air are primarily from the use of oil and coal as an energy source for the refining of bauxite to alumina. Another large contributor to Hydro’s total SO2 emissions to air is related to the aluminium electrolysis process in smelters. Where technically feasible, Hydro has implemented seawater fed scrubbers in order to reduce SO2 emissions. The largest emission to water is the sulfur captured by these seawater scrubbers. See Note E2.1 for an overview of emissions to air and water. Hydro uses ozone depleting substances in certain applications in its Brazilian operations and to some extent also in Extrusions. In 2024, Hydro used in total 8.2 tonnes of such substances in its operations. The reported value corresponds to the purchased amount of such substances and can vary significantly according to the need of refilling existing cooling devices. In Brazil, such substances are managed and reported according to Brazilian legal requirements. In Hydro Extrusions, hydrochlorofluorocarbon (HCFC) accounts for around one third of ozone depleting substances. Acid Mine Drainage (AMD) is not a material risk for Hydro. The chemical content of the ore is the primary cause of AMD and is typically associated with sulfur bearing metals, which is not present in bauxite mines in Brazil. To avoid incidents of pollution and mitigate impacts in the event of a spill or other unplanned event, all sites are required to have performed risk assessments, and establish action plans and controls to manage the risk, such as emergency action procedure, secondary containment, and storage basins. Hydro’s global procedures for health risk management and environment management require all operational sites that are fully owned or operated by Hydro, identify, risk assess, minimize, evaluate for substitution and appropriately manage all hazardous materials or substances, purchased or generated in its processes, that have the potential to cause ill health, or to negatively impact the environment. Hydro’s products are subject to compliance declarations according to different EU and U.S. legislations. This includes registration, evaluation, authorization and restriction of chemicals (REACH) and restriction of hazardous substances (RoHS) in the EU, and the Toxic Substances Control Act and California’s proposition 65 in the U.S. This gives Hydro’s customers assurance that its aluminium profiles do not contain the prohibited substances above the defined limits. Stakeholders and potentially affected communities can use AlertLine as a communication tool to report environmental and social issues concerning Hydro operations. See Business Conduct chapter for more information about AlertLine. In 2024, Hydro joined World Economic Forum’s Alliance for Clean Air, a cross sector initiative to the social and environmental benefits of collective action to reduce air pollution. As an Alliance Member, Hydro has worked with the Stockholm Environment Institute to develop inventories and baselines of material air pollutants, linked to its electricity sourcing and wider value chain. This data will be used as input for future disclosures and target setting, with the goal of reducing air pollutant emissions linked to Hydro’s full value chain.

No positive impacts

Hydro identifies and assesses potential pollution impacts from all its operations by assessing risk of accidental spills, leakages, or other unplanned events and by monitoring emissions to air and water from its operations in the aluminium value chain based on the Best Available Techniques Reference documentation (BREF) for the non-ferrous metals industries. Hydro has established action plans and controls to manage potential pollution impacts, such as spill kits, secondary containment, storage basins. Environmental incidents are classified based on potential and actual impact; all material incidents, as well as all emissions to air and water above the thresholds defined in the European Pollutant Release and Transfer Register (E-PRTR), are reported in the Pollution chapter.

Hydro has established a voluntary target to halve material non-GHG emissions (i.e. SO2, NOx and PM emissions to air) by 2030, from a 2017 baseline.

50% Reduction in material non-GHG emissions by 2030 against 2017 baseline

E2.1 Emissions to air and water

E2.2 Spills and leakages

E2.3 Environmental permit breaches

57% Reduction in SO2 against baseline 67% Reduction in NOx against baseline 37% Reduction in particulate matter emissions against baseline

Incidents resulting in spills, leakages, or other non-compliances with environmental performance standards, could potentially result in material pollution. To minimize the risk of material pollution, operational sites are required to implement suitable process controls, inspection and maintenance routines and additional controls, such as secondary containment. In the events of an actual spill, incidents are assessed and classified according to the severity of impact. See Note E2.2 for reported spills and leakages and Note E2.3 for information on environmental permits.

Hydro engages regulators, local authorities and communities directly on its environmental management and potential incidents of pollution. Potentially affected stakeholders or communities can use Hydro's grievance mechanism, AlertLine, to report environmental and social issues concerning Hydro operations. Hydro also engages civil society on environmental issues. This includes Hydro's membership in the World Economic Forum’s Alliance for Clean Air to promote collective action to reduce air pollution and works with the Stockholm Environment Institute to develop value chain inventories and baselines of material air pollutants.

Hydro engages regulators, local authorities and communities directly on its environmental management and potential incidents of pollution. Potentially affected stakeholders or communities can use Hydro's grievance mechanism, AlertLine, to report environmental and social issues concerning Hydro operations. Hydro also engages civil society on environmental issues. This includes Hydro's membership in the World Economic Forum’s Alliance for Clean Air to promote collective action to reduce air pollution and works with the Stockholm Environment Institute to develop value chain inventories and baselines of material air pollutants.

Hydro depends on the supply of water as an ecosystem service and withdraws large volumes of water for beneficiation and pumping at its Paragominas mining operations, steam generation in the Bayer process at the Alunorte alumina refinery, and for cooling and operations in Hydro’s primary aluminium and recycling processes. Freshwater withdrawals can have a negative impact on local water resources in the event of drought. Hydro’s hydropower operations can have a positive impact on flood control and water flow. Potential negative impacts on water based ecosystems in the catchment areas are described in the biodiversity and ecosystems chapter. Hydro is exposed to water related risks associated with seasonal rainfall or drought, which can cause disruptions in the availability of water for electricity generation, cooling, operations, infrastructure, and logistics services in Hydro’s value chain. Climate change can exacerbate the scale and frequency of such risks.

Potential negative impacts of freshwater withdrawals on local water resources.

Hydro manages the quality of discharges to the external environment to ensure that Hydro operates within the relevant permit limits and regulatory frameworks. For information about emissions to water, refer to the Pollution chapter.

Potential negative impacts on water based ecosystems in the catchment areas are described in the biodiversity and ecosystems chapter. Hydro is exposed to water related risks associated with seasonal rainfall or drought, which can cause disruptions in the availability of water for electricity generation, cooling, operations, infrastructure, and logistics services in Hydro’s value chain. Climate change can exacerbate the scale and frequency of such risks.

Hydro depends on the supply of water as an ecosystem service and withdraws large volumes of water for beneficiation and pumping at its Paragominas mining operations, steam generation in the Bayer process at the Alunorte alumina refinery, and for cooling and operations in Hydro’s primary aluminium and recycling processes. Freshwater withdrawals can have a negative impact on local water resources in the event of drought.

Hydro uses the WRI Aqueduct tool to analyze Hydro’s freshwater footprint in water stressed areas, defined as locations with high or extremely high baseline water stress. Approximately one percent of Hydro’s freshwater withdrawals are related to operational assets located in water stressed areas, so over exploitation of natural water resource availability is not considered material for Hydro today. In addition, and due to seasonal heavy rainfall in Northern Brazil, managing flood risk is also a priority for both the mining operation and alumina refinery. With future climate change scenarios, location specific changes to the availability of water resources may occur. Such risks were evaluated in the physical climate risk assessment that was updated in 2023, described in the climate change chapter.

Hydro’s hydropower operations can have a positive impact on flood control and water flow

Hydro has established an overview of all surface water bodies impacted by its operations, as well as ecological and chemical status and mitigation measures, to ensure follow up of the WBMPs and that Hydro is in line with concession requirements. Hydro may be ordered to implement mandatory measures for impacted water bodies within specific deadlines. Current WBMPs were approved by the Norwegian Government in October 2022 and are valid until 2027. There is an ongoing process to establish WBMPs for the period 2027-2032.

All operations related to the aluminium value chain maintain a water balance, in line with regulatory requirements and the minimum disclosure requirements dictated by ICMM’s Water 2021 Water Reporting: Good practice guide. This includes volumes of withdrawals (by quality and source), discharge (by quality and destination), consumption (by type) and the percentage of the operational water demand met by water reuse and /or recycling, if applicable. Methods for calculating these values are site specific. Where operational sites receive their water supply from third parties, like the municipal water infrastructure, the quantities are based on invoiced volumes across the year. In operations that manage their own water extraction and discharges, the data can be directly measured using flow meters, or inferred from pumping capacity and run times. Hydro does not have instances of “Other Managed Water” (i.e., water that needs to be actively managed by does not enter the operational water system used to supply the operational water demand), so this parameter is not included in Hydro’s consolidated reporting. Hydro monitors water use in the construction and development of new energy projects, including water for construction processes and human consumption. Water consumption in Hydro Rein’s projects are not material in volume compared to consumption in other activities. All water use in construction and development of new energy projects is supplied by third parties.

Current WBMPs were approved by the Norwegian Government in October 2022 and are valid until 2027. There is an ongoing process to establish WBMPs for the period 2027-2032.

To address local water risks, Hydro has implemented strategies to minimize surface water withdrawals at its mining and refining operations in Brazil

Hydro continuously works with voluntary and mandatory rehabilitation and restoration measures in the waterways, and continues to develop its understanding of how to improve the ecological status of water bodies that are impacted by hydropower operations. Hydro also works with initiatives to reduce the risk of erosion and sedimentation around the reservoirs, such as reinforcement of reservoir edges with stones and gravel.

E3.1 Water interaction

Water withdrawal, by source

Water discharges, by destination

Total water consumption

Total Water reused/recycled

34 Number of sites in water stressed areas

1.2 million m3 Freshwater withdrawals in water stressed areas

68.9 million m3 Water recycled or reused

To address local water risks, Hydro has implemented strategies to minimize surface water withdrawals at its mining and refining operations in Brazil.

Hydro engages regulators, local authorities and communities directly on water related issues. For the hydropower operations in Norway, water resources are followed up by authorities through regional water management plans, in line with the EU Water Framework Directive.

Hydro engages regulators, local authorities and communities directly on water related issues. For the hydropower operations in Norway, water resources are followed up by authorities through regional water management plans, in line with the EU Water Framework Directive.

As a global aluminium and energy company, Hydro recognizes the material impact its global operations and their associated value chain can have on biodiversity and ecosystem services. Hydro’s activities are relevant to all five of the main drivers of nature loss: • Land and water use change • Direct exploitation of natural resources • Climate change • Pollution • Introduction of invasive, alien species Hydro’s operations are also dependent upon ecosystem services provided by nature, including the provision of water, regulation of climate, and protection from physical hazards, like floods and landslides. Aluminium production is also dependent on the supply of energy, raw materials and other services that can impact biodiversity and ecosystems at the local, regional, and global level. It is Hydro’s responsibility to manage the risks associated with these impacts and dependencies where they occur in the company’s operations and business activities. Stricter regulations related to impacts on biodiversity and ecosystems could impose new requirements on Hydro’s operations and value chain, which in turn could have a financial or reputational effect on Hydro. This could impose capital investments to reduce the impact of the company’s activities in the medium and long-term. Expectations from customers, investors, and banks could affect Hydro’s financial performance, cost of capital, or access to finance in the medium or long-term. The effects could be both positive and negative for Hydro, depending on the development of stakeholders’ expectations and the impact of Hydro’s activities to its peers.

Impacts associated with land use change in mining operations and new renewable energy development, and impacts from water use change in hydropower operations. Impacts associated with greenhouse gas emissions and potential incidents of pollution in alumina refining and primary aluminium production. Impacts associated with sourcing of energy and raw materials. Potential impacts associated invasive species introduction resulting from transportation of materials to and from Hydro operations.

Hydro has implemented a policy, Global Procedure for Biodiversity and Ecosystem Services, which covers all wholly owned or operated assets and are approved by EVP Chief Financial Officer. The procedure establishes minimum requirements for biodiversity risk management in operations, new project development, and merger and acquisition processes.

Hydro identifies and assesses impacts, risks and dependencies on biodiversity in its operations and value chain according to the LEAP methodology. Hydro conducts environmental impact assessments for its operations, new project development, and in relation to merger and acquisition processes. The assessments identify potential impact on biodiversity and ecosystem services within the operation’s area of influence and assess the materiality of these impacts to the operation, environment and affected communities. This assessment shall also identify and describe any priority biodiversity features or ecosystem services that occur within the operation’s area of influence and consider the full lifecycle of the operation, including closure. On going impacts are monitored by tracking the impact of land use change on local biodiversity and ecosystems. Sites located near biodiversity sensitive areas, their potential impacts and mitigation measures are disclosed in the Biodiversity chapter. Any accidents that result in pollution are assessed and classified according to actual and potential impacts. The impacts of water withdrawal and emissions are estimated using a lifecycle assessment model.

Hydro has developed a strong reforestation program that seeks to mitigate the impact of forest removal through timebound targets to replant and reforest the areas. Currently, Hydro works to progressively rehabilitate mined areas available for reforestation and replant these areas within two complete hydrological seasons, referred to as Hydro’s 1:1 rehabilitation target. In addition to rehabilitating mined areas, there is also a need to eventually rehabilitate long-term infrastructure, like the tailings storage facilities, when no longer required to support operations. Read more information about Hydro’s tailings management in the chapter Resource use and circular economy. Due to the clay like nature of the tailings material, a specialized rehabilitation technique must be developed. Hydro has ongoing research into developing this technique, amending tailings with organic material like green manure and decaying wood, with some promising results at pilot scale (Barral das Neves et al. 2024). To increase Hydro’s knowledge and secure a science based approach to biodiversity management and forest rehabilitation, the Biodiversity Research Consortium Brazil-Norway (BRC) was first established in 2013 and renewed in 2023 for a further five years. BRC consists of the University of Oslo and its Brazilian partners Museu Paraense Emílio Goeldi, Federal University of Pará, and Federal Rural University of the Amazon, in addition to Hydro.

The scope of the consortium is to create an environmental research program connected to the mining operations. The aim is to strengthen Hydro’s ability to preserve natural biodiversity and to better rehabilitate the areas where the company mines bauxite. Twenty five research projects have been funded to date and a new research program was developed in 2023 to support the renewed BRC agreement. Announced in 2023, Hydro has also increased its No Net Loss ambition for biodiversity for the bauxite mine. In addition to achieving No Net Loss for the future expansion of the mine, Hydro will also include impacts that have occurred since 2020 for the existing mining footprint as well. As part of delivering on this No Net Loss roadmap, Hydro has established a partnership with a Brazilian Research Institution that is actively engaged in scientific research on biodiversity restoration within the Amazon biome. Hydro has also entered into partnership with three Brazilian NGOs, Imazon, CEA and IPAM, which are dedicated to the conservation and sustainable development of the Brazilian Amazon. This multistakeholder partnership, called Corridor Program, will explore opportunities to scale biodiversity projects that can also generate sustainable income for local communities. In September 2024, Hydro entered into a Memorandum of Understanding with the MercedesBenz Group, which is now an active partner of the program. For quantitative information on land use and rehabilitation in Paragominas, see Note E4.4. There are specific closure plan requirements for the Paragominas mine including rehabilitation of the mine and tailings ponds. In addition, there is a similar requirement for the bauxite residue disposal areas at Alunorte. Read more about closure management in the Legacy impact chapter and bauxite residue disposal in Resource use and circular economy. Actions to minimize impacts in hydropower operations Hydro is an active member of the International Hydropower Association (IHA) and Renewables Norway’s sustainability network, working actively together with energy industry associations to address negative impacts on nature for new projects and operations. The company takes a scientific approach to managing its biodiversity impacts through collaboration with other power producers in Norway, as well as supporting and collaborating with research on nature impacts from renewable energy. In operations, Hydro always follows the relevant requirements stated within concessions and regulation established by the authorities, including the implementation of mitigation actions where required. In relation to renewal of concessions, rehabilitation projects are carried out in rivers and lakes to improve fish habitats and aesthetic qualities. The company also monitors the impact of its operations on aquatic life in rivers connected to catchment areas. As per end of 2024, Hydro has two revisions of its hydropower concessions in process, Fortun-Granfasta and Vigelandsfoss. Hydro is awaiting approval from The Norwegian Water Resource and Energy Directorate (NVE). For Fortun-Granfasta, all necessary studies have been carried out and filed with NVE. Hydro has proposed several restoration and improvement activities targeting aquatic biodiversity. For Vigelandsfoss, biodiversity studies on fish have been performed as part of the concession applicatio, and measures to reduce impacts to eel are proposed. Independently of concession renewals, Hydro is performing biodiversity risk assessments for all its operated hydropower and wind power in Norway. The risk assessments are being carried out by a third party specialist, with the aim of identifying the main risks to priority biodiversity features impacted by these operations. These assessments are planned to be finalized in 2025. In Hydro’s regulated river basins, there is a potential for habitat improvements for fish, and aquatic fauna and flora. Therefore, following the completion of biodiversity risk assessments, the company plans to establish Biodiversity Action Plans by the end of 2025, to be implemented in the operational system, to systematicallyperform mitigation activities targeted on biodiversity risks from operations. This will include both mandatory and voluntary measures to reduce risks to biodiversity. As part of Hydro’s hydropower operations today, measures are implemented to reduce impacts to biodiversity. The measures are summarized in the table below. Risks to wild reindeer is also a consideration for Hydro. As part of operation and project execution, there are mitigating measures undertaken to avoid impacts to wild reindeer, such as investigating the reindeer herd position before activities are carried out. However, Hydro recognizes the need to get a better understanding on the impacts from the hydropower production and new projects. Hydro also needs a more systematic approach for reducing the impacts to wild reindeer and their habitats. Hydro has therefore established dialogues with Norsk Villreinsenter Sør, to support the development of a wild reindeer strategy during 2025. According to the Norwegian Whitepaper on wild reindeer (Stortingsmelding 18 2023-24), establishment of national action plans to improve the population is ongoing and Hydro is engaging in the discussions for areas where it operates. This includes Hardangervidda and Setesdal-Ryfylke.

Actions to minimize impacts in development of wind and solar power Hydro’s joint venture, Hydro Rein, applies the biodiversity mitigation hierarchy as early as possible in project development to avoid and minimize project impact upon biodiversity and ecosystems as much as is practically and technically feasible. Hydro Rein is developing biodiversity management/action plans to align existing projects to international standards (IFC Performance Standards and Equator Principles), using the projects’ fauna and flora monitoring campaigns to enable the identification of significant residual impacts to priority biodiversity features. Additional impacts on biodiversity caused during the construction and operation phase of the project, are addressed and mitigated as part of the construction and operational activities. To support the company’s biodiversity ambitions, the company works with project partners and qualified specialists to perform additional biodiversity studies, such as Collision Risk Modelling, Critical Habitat Assessment and Ecosystem Services Assessments in project areas and surroundings so the company can define its project specific biodiversity strategies. There has been no vegetation suppression in Hydro Rein’s projects during 2024, but there are ongoing reforestation measures related to past vegetation removals in Hydro Rein’s Brazilian projects. These measures include continuous monitoring with the support from local qualified specialists in biodiversity management. All Brazilian projects in Hydro Rein’s portfolio have explicit vegetation compensation commitments, compliant with local regulation, which can include the operation of seedling nurseries and reforestation actions in project area, surroundings, or even other areas located within the same hydrological basin.

Biodiversity actions plans to work towards No Net Loss of priority biodiversity features

Release of water to maintain ecological flow, winter and summer Release of fish in reservoirs and rivers, planting fertilized eggs and yolk sac fry, etc.

Release of minimum water flow Salmon ladders and other fish passages both on ponds/thresholds and at natural migration barriers (two way fish passage) Restoration in water bodies Controlled effect power production

Salmon ladders and other fish passages both on ponds/thresholds and at natural migration barriers (two way fish passage)

Site specific measures and involvement of relevant externals before entering into wild reindeer areas

Participation in relevant fora (action plans per wild reindeer area) Removal or closure of relevant roads, in dialogue with authorities and relevant stakeholders

Biodiversity actions plans to work towards No Net Loss of priority biodiversity features

Release of water to maintain ecological flow, winter and summer Release of fish in reservoirs and rivers, planting fertilized eggs and yolk sac fry, etc.

Release of minimum water flow Salmon ladders and other fish passages both on ponds/thresholds and at natural migration barriers (two way fish passage) Restoration in water bodies Controlled effect power production

Salmon ladders and other fish passages both on ponds/thresholds and at natural migration barriers (two way fish passage)

Site specific measures and involvement of relevant externals before entering into wild reindeer areas

Participation in relevant fora (action plans per wild reindeer area) Removal or closure of relevant roads, in dialogue with authorities and relevant stakeholders

Stricter regulations related to impacts on biodiversity and ecosystems could impose new requirements on Hydro’s operations and value chain, which in turn could have a financial or reputational effect on Hydro. This could impose capital investments to reduce the impact of the company’s activities in the medium and long-term. Expectations from customers, investors, and banks could affect Hydro’s financial performance, cost of capital, or access to finance in the medium or long-term. The effects could be both positive and negative for Hydro, depending on the development of stakeholders’ expectations and the impact of Hydro’s activities to its peers.

Hydro has developed this strategy as part of its transition plan to align with the 2030 objective and targets of the Global Biodiversity Framework agreement and address the main drivers of nature loss most relevant to its business model. By doing so, Hydro aims to contribute meaningfully to the global effort to transition to a nature positive future.

Hydro has implemented a policy, Global Procedure for Biodiversity and Ecosystem Services, which covers all wholly owned or operated assets and are approved by EVP Chief Financial Officer. The procedure establishes minimum requirements for biodiversity risk management in operations, new project development, and merger and acquisition processes. The requirements include assessments to identify potential impacts on biodiversity and ecosystem services within the operation’s area of influence and to assess the materiality of these impacts to the operation, environment, and affected communities. The assessment shall identify and describe priority biodiversity features or ecosystem services that occur within the operation’s area of influence, consider the full lifecycle of the operation, including closure, and establish requirements for mitigation actions according to the biodiversity mitigation hierarchy

No Net Loss of biodiversity for Hydro’s bauxite mine, from a 2020 baseline

1:1 Rehabilitation of mined areas within two hydrological cycles

E4.1 Threatened species within Hydro’s area of influence

E4.2 Land use and rehabilitation in Paragominas

Actions to minimize impacts in development of wind and solar power Hydro’s joint venture, Hydro Rein, applies the biodiversity mitigation hierarchy as early as possible in project development to avoid and minimize project impact upon biodiversity and ecosystems as much as is practically and technically feasible. Hydro Rein is developing biodiversity management/action plans to align existing projects to international standards (IFC Performance Standards and Equator Principles), using the projects’ fauna and flora monitoring campaigns to enable the identification of significant residual impacts to priority biodiversity features. Additional impacts on biodiversity caused during the construction and operation phase of the project, are addressed and mitigated as part of the construction and operational activities. To support the company’s biodiversity ambitions, the company works with project partners and qualified specialists to perform additional biodiversity studies, such as Collision Risk Modelling, Critical Habitat Assessment and Ecosystem Services Assessments in project areas and surroundings so the company can define its project specific biodiversity strategies. There has been no vegetation suppression in Hydro Rein’s projects during 2024, but there are ongoing reforestation measures related to past vegetation removals in Hydro Rein’s Brazilian projects. These measures include continuous monitoring with the support from local qualified specialists in biodiversity management. All Brazilian projects in Hydro Rein’s portfolio have explicit vegetation compensation commitments, compliant with local regulation, which can include the operation of seedling nurseries and reforestation actions in project area, surroundings, or even other areas located within the same hydrological basin

Hydro has developed a strong reforestation program that seeks to mitigate the impact of forest removal through timebound targets to replant and reforest the areas. Currently, Hydro works to progressively rehabilitate mined areas available for reforestation and replant these areas within two complete hydrological seasons, referred to as Hydro’s 1:1 rehabilitation target. In addition to rehabilitating mined areas, there is also a need to eventually rehabilitate long-term infrastructure, like the tailings storage facilities, when no longer required to support operations. Read more information about Hydro’s tailings management in the chapter Resource use and circular economy. Due to the clay like nature of the tailings material, a specialized rehabilitation technique must be developed. Hydro has ongoing research into developing this technique, amending tailings with organic material like green manure and decaying wood, with some promising results at pilot scale (Barral das Neves et al. 2024). To increase Hydro’s knowledge and secure a science based approach to biodiversity management and forest rehabilitation, the Biodiversity Research Consortium Brazil-Norway (BRC) was first established in 2013 and renewed in 2023 for a further five years. BRC consists of the University of Oslo and its Brazilian partners Museu Paraense Emílio Goeldi, Federal University of Pará, and Federal Rural University of the Amazon, in addition to Hydro.

Hydro engages local authorities and people in local communities directly on biodiversity and ecosystems impacts, including recreational impacts, from on going operations as well as the planning and execution of new projects. To increase Hydro’s knowledge and secure a science based approach to biodiversity management and forest rehabilitation, Hydro supports the Biodiversity Research Consortium Brazil-Norway (BRC). Hydro has also established a partnership and actively engage with two Brazilian NGOs in the State of Pará on the conservation and sustainable development of the Brazilian Amazon. For its hydropower operations, Hydro engages the International Hydropower Association and Renewables Norway, as well as the Norwegian Institute for Nature Research to take a scientific approach to managing biodiversity impacts.

Hydro engages local authorities and people in local communities directly on biodiversity and ecosystems impacts, including recreational impacts, from on going operations as well as the planning and execution of new projects. To increase Hydro’s knowledge and secure a science based approach to biodiversity management and forest rehabilitation, Hydro supports the Biodiversity Research Consortium Brazil-Norway (BRC). Hydro has also established a partnership and actively engage with two Brazilian NGOs in the State of Pará on the conservation and sustainable development of the Brazilian Amazon. For its hydropower operations, Hydro engages the International Hydropower Association and Renewables Norway, as well as the Norwegian Institute for Nature Research to take a scientific approach to managing biodiversity impacts.

Hydro’s aluminium manufacturing processes are resource intensive and depend on non-renewable resources. Hydro’s operations also generate significant resource outflows, including different waste streams. Managing resource dependencies and waste streams are key to reduce operational and compliance costs, exposures to price volatility, and supply chain disruptions in material sourcing, as well as the environmental footprint in Hydro’s supply chain. Hydro’s integrated value chain, including captive renewable energy generation, traceable, secure material supply, and integrated recycling operations, as well as aluminium’s inherent properties of durability, lightweight, and recyclability, position the company for commercial and financial opportunities in the transition to a more circular and less resource intensive economy

Value chain impacts associated with Hydro's dependency on raw materials for alumina refining and primary aluminium production. Impacts associated with resource outflows, including tailings from mining operations, bauxite residue from alumina refining and waste generation from operations in the aluminium value chain.

Hydro’s Global Procedure for Environmental management define the company’s ambition towards a circular economy by promoting efficient use of resources and continuous improvement in waste management. The procedure is approved by the EVP for People and HSE, and all employees are responsible for working in accordance with this procedure. The line management is responsibility to ensure the global procedure is implemented and the required information, training, instruction, supervision, and auditing systems are in place. Hydro is currently updating their sustainability procedures and directives to include more information about circular economy expectations

Hydro identifies and assesses impacts, risks, and dependencies associated with resource use and circular economy by measuring its resource use and resource outflows from all operations. This includes energy and raw material use for production processes, recycled content in resource inflows, as well as the generation of tailings, residue and waste from its operations, and the waste treatment and disposal methods for different waste streams.

Hydro’s technology and decarbonization roadmap and strategic focus on metal recycling aims to contribute to a circular economy by supplying the transition to a low-carbon and resource efficient economy with sustainable materials use through partnerships and innovative business models. To enable this transition, Hydro has set up a framework to prioritize sectors, geographies, suppliers, and customers to take a proactive approach to integrate circular economy principles in business development around three main pillars: innovate for circularity, recycling and sorting, and waste to value. Hydro’s Global Procedure for Environmental management define the company’s ambition towards a circular economy by promoting efficient use of resources and continuous improvement in waste management. The procedure is approved by the EVP for People and HSE, and all employees are responsible for working in accordance with this procedure. The line management is responsibility to ensure the global procedure is implemented and the required information, training, instruction, supervision, and auditing systems are in place. Hydro is currently updating their sustainability procedures and directives to include more information about circular economy expectations

Hydro’s aluminium manufacturing processes are resource intensive and depend on non-renewable resources. Hydro’s operations also generate significant resource outflows, including different waste streams. Managing resource dependencies and waste streams are key to reduce operational and compliance costs, exposures to price volatility, and supply chain disruptions in material sourcing, as well as the environmental footprint in Hydro’s supply chain. Hydro’s integrated value chain, including captive renewable energy generation, traceable, secure material supply, and integrated recycling operations, as well as aluminium’s inherent properties of durability, lightweight, and recyclability, position the company for commercial and financial opportunities in the transition to a more circular and less resource intensive economy

Hydro has made progress on diversifying its recycled product portfolio to be able to utilize a broader range of scrap types. Hydro acquired a Polish recycled foundry alloy producer, Alumetal, in 2023 and made progress on integrating the company and realizing synergy potential with the existing extrusion ingot portfolio. An upgrade and expansion of Alumetal’s Kety plant is currently underway. Operations are ramping up in Hydro’s greenfield plants opened in 2023, advanced extrusion ingot recycler in Cassopolis, Michigan, USA and the forge stock plant in Rackwitz, Germany. . During 2024, Hydro announced a decision to invest in the state-of-the-art specialty extrusion ingot recycler Torija in Spain with the total capacity of 120,000 tonnes.

Circular economy is also identified as a material opportunity for Hydro

To enable this transition, Hydro has set up a framework to prioritize sectors, geographies, suppliers, and customers to take a proactive approach to integrate circular economy principles in business development around three main pillars: innovate for circularity, recycling and sorting, and waste to value.

Eliminate landfill of all recoverable waste by 2040

Recycling is an important part of Hydro’s 2030 strategy

Hydro’s goal is to increase post-consumer scrap utilization through advanced sorting capabilities combined with multiple product outlets.

E5.1 Resource inflows

E5.2 Resource outflows – Products and materials

E5.3 Resource outflows –Waste

Waste directed to disposal, by disposal operation

Waste diverted from disposal, by recovery operation

451 kt Recycled post-consumer scrap

19 % of total waste directed to landfill

43 % SPL to landfill

The amount of generated waste sent to landfill increased in 2024, thereby raising the percentage of waste-to-landfill from 15 percent in 2023 to 19 percent in 2024. This trend was not driven by a worsening in Hydro's waste management performance, but by an improvement in waste accounting and management at Alunorte. In 2024, Alunorte conducted a comprehensive review of its waste management systems to provide a more complete and accurate accounting of wastes deposited on DRS1. This effort serves as a step for its long-term strategy to eliminate waste-to-landfill by 2040. Additionally, several circularity initiatives were implemented to reduce landfill disposal, such as repurposing materials and promoting the reuse and recycling of waste streams. These actions reflect Hydro's commitment to advancing waste circularity and minimizing environmental impacts. Although this adjustment presents itself as a negative development in Hydro's aggregated statistics for 2024, it is a critical step toward longterm improvements. Hydro expects to see continued progress in real performance and further advancements in waste circularity in 2025.

Waste management is part of Hydro’s Global Procedure for Environmental management. Hydro’s goal is to first minimize the amount of waste produced in its operations, and then reuse or recycle it. When this is not possible, the company shall deposit it in a secure way in compliance with regulatory standards and legal requirements. All targets related to waste is set by Hydro on a voluntary basis and are not imposed by legislation or regulations

Potential incidents or accidents affecting the health and safety of people or the environment near legacy industrial sites.

Hydro’s governance structure for tailings management is clearly defined. The governance structure starts at Hydro’s Board of Directors. Independent reviews by the Independent Tailings Review Board (ITRB) are carried out twice per year for the tailings facilities at Alunorte and Paragominas and annually for the tailings facilities at Schwandorf. By August 2023, the conformance of the Alunorte’s and Mineração Paragominas’ tailings facilities was assessed and confirmed through a self-assessment in line with the ICMM’s Conformance Protocol. A third party validation was undertaken in 2024 and attested the conformance of Valley, TDA, DRS1, and DRS2 to GISTM. GISTM implementation is ongoing at the three closed tailings facilities at the Schwandorf legacy site and is on track to achieve conformance by the August 5, 2025, deadline. The Marienschachthalde tailings facility in Stulln has been classified as safely closed in accordance with the GISTM definition.2 The remaining two facilities in Stulln (Grube Erna 1 and 2) are expected to reach safe closure status by the second quarter of 2025. More information, including Hydro’s Tailings Management Policy, the GISTM Public Disclosure Report and GISTM conformance status, can be found at Hydro.com.

Impacts and risks are assessed through on going assessment of legacy sites and industrial operations. Sites are screened for potential impacts and risks, land and waterbodies near material industrial sites are tested for pollution. Hydro's legacy project has developed a methodology to evaluate legacy risks and their potential financial effects for Hydro.

By implementing a proactive approach to legacy management, Hydro aims to identify risks and opportunities at an earlier stage to enable the development and implementation of robust and cost efficient solutions which are in line with stakeholder expectations. Through Hydro’s legacy and closure management program, the company aims to avoid or minimize the creation of additional legacies as well as to minimize impacts of legacies from the past. Hydro manages risks and opportunities throughout all phases of an asset’s life cycle, including investment (design/construction or acquisition), operation, closure and post-closure. Failure to identify legacy impacts and costs in the design/construction phase of a new asset or in acquisition processes could lead to future remediation and closure costs which are disproportionate in size to the benefit of the investment. This risk is mitigated through the implementation of corporate governance requirements that mandate financial assessment with respect to legacy aspects during project planning and acquisition evaluations.

The main risk related to legacy management is failure to identify legacy risks and opportunities early enough, which could result in negative impacts on health, safety or the environment, and create unnecessary cost, and reputational damage for the company. Managing legacies is an important responsibility for Hydro to protect the environment and human health. History has shown that inferior tailings facility management can in the worst case compromise public safety. Over the past decade, several tailings facility failures within the global mining industry have resulted in hundreds of fatalities, severe environmental and social harm, and substantial financial losses. In countries with a large mining sector, there is an increasing concern that legacies from mining operations represent a financial risk to the society since there have been several cases where mining companies have gone bankrupt prior to fulfilling their remediation or closure obligations. Managing the potential impact of Hydro’s industrial legacy on local communities and the environment is therefore key to building trust, and to managing sustainability related risks in Hydro. There is a high degree of uncertainty related to the financial effects of legacies, because the timing, scope, and cost of remediation and closure obligations is unpredictable. Environmental authorities have a large room for judgement when it comes to enforcing the environmental laws and it is difficult to foresee far in advance what will be required. In general, requirements tend to increase over time as more knowledge about the environmental issues and its impacts becomes available, and as new or improved remediation techniques are being developed. Going forward, the risk of extreme weather events due to climate change is expected to be a driver for increased legacy management requirements. See Note 4.1 to the financial statements for details on uncertain assets and liabilities, including asset retirement obligations.

Failure to manage tailings facilities properly could compromise the safety of workers and the local community as well as cause significant environmental, social, and financial damage.

Hydro commits to best practice tailings management to protect the health and safety of people, host communities and the environment. Hydro plans, designs, constructs, operates, maintains, closes, and relinquishes its tailings facilities in accordance with regulatory compliance requirements, internal company standards, the International Council on Mining and Metal (ICMM) framework, and the Aluminium Stewardship Initiative (ASI) practices. Furthermore, Hydro is committed to implement the Global Industry Standard on Tailings Management (GISTM), which requires that tailings facilities operated by Hydro with Extreme or Very high potential consequences1 conform to the standard by August 5, 2023, while other tailings facilities operated by Hydro not in a state of safe closure, will conform to the standard by August 5, 2025. Hydro is a member of ICMM which is one of the three co-conveners of GISTM alongside UN Environment Program (UNEP) and PRI, an investor initiative in partnership with UNEP Finance Initiative and UN Global Compact.

The company aims to avoid or minimize the creation of additional legacies as well as to minimize impacts of legacies from the past.

After several years of thorough mapping, investigations, testing and planning, the execution of the remediation project started in 2023. The aim of the project is to isolate the environmental toxins to prevent them from spreading and to prevent uptake in the food chain. The project is expected to be completed in 2025.

At the legacy bauxite residue facilities at Schwandorf in Germany, key activities in 2024 included the planning and site preparations for a new water treatment as well as implementation of the Global Industry Standard on Tailings Management (GISTM). Both the water treatment plant and the GISTM implementation is expected to be completed in 2025.

Several decades ago, Hydro’s operations at Herøya in Norway caused contamination of the nearby fjord, Gunneklevfjorden. In 2018, the Norwegian Environmental Agency (NEA) ordered Hydro to remediate the fjord by capping the fjord bed with clean geologic materials. After several years of thorough mapping, investigations, testing and planning, the execution of the remediation project started in 2023. The aim of the project is to isolate the environmental toxins to prevent them from spreading and to prevent uptake in the food chain. The project is expected to be completed in 2025.

Resource use

Tailings

Several decades ago, Hydro’s operations at Herøya in Norway caused contamination of the nearby fjord, Gunneklevfjorden. In 2018, the Norwegian Environmental Agency (NEA) ordered Hydro to remediate the fjord by capping the fjord bed with clean geologic materials. After several years of thorough mapping, investigations, testing and planning, the execution of the remediation project started in 2023. The aim of the project is to isolate the environmental toxins to prevent them from spreading and to prevent uptake in the food chain. The project is expected to be completed in 2025. At Stulln in Germany, Hydro continued to execute a structured remediation and reclamation plan in collaboration with authorities at the former fluorspar mines dated back to the 1920s in Germany. The projects involve securing of underground mining structures, and reshaping and closure of tailings facilities to mitigate potential risk to the public and to the environment. For the Marienschachthalde tailings facility, the execution of the closure plan, including the final inspection by mining authorities, was completed in 2024. A post closure groundwater monitoring program will continue until 2029 or until mining authorities approve the discontinuation.

At the legacy bauxite residue facilities at Schwandorf in Germany, key activities in 2024 included the planning and site preparations for a new water treatment as well as implementation of the Global Industry Standard on Tailings Management (GISTM). Both the water treatment plant and the GISTM implementation is expected to be completed in 2025. The Aluchemie anode producer, which is a joint operation company owned by Hydro (47 percent) and Rio Tinto (53 percent), located near Rotterdam in the Netherlands, closed its operation at the end of 2021. Demolition of buildings and infrastructure continued, and the implementation of the site wide environmental remediation activities was initiated in 2024, and progresses according to the schedule and in line with the remediation strategy defined with the relevant authorities. The property is owned by the Rotterdam Port Authority and Aluchemie is required to return the site to the same condition existing in 1962, before the plant was constructed. The remediation program is expected to be completed in 2025. At the Kurri Kurri legacy site in Australia, the construction of an onsite, engineered containment cell and remediation of the site was completed in August 2024. The cell is being managed under a longterm environmental management plan with the completion of the independent audit undertaken by a NSW EPA accredited auditor, consolidating the key site investigations and validation of completed remediation, expected in Q2 2025.

Several decades ago, Hydro’s operations at Herøya in Norway caused contamination of the nearby fjord, Gunneklevfjorden. In 2018, the Norwegian Environmental Agency (NEA) ordered Hydro to remediate the fjord by capping the fjord bed with clean geologic materials. After several years of thorough mapping, investigations, testing and planning, the execution of the remediation project started in 2023. The aim of the project is to isolate the environmental toxins to prevent them from spreading and to prevent uptake in the food chain. The project is expected to be completed in 2025.

Potentially affected stakeholders are engaged directly and through local media, and informed and consulted when potential impacts have been identified. Local authorities and NGOs are also engaged on impact assessments to identify potential risks.

Potentially affected stakeholders are engaged directly and through local media, and informed and consulted when potential impacts have been identified. Local authorities and NGOs are also engaged on impact assessments to identify potential risks.

Hydro has a responsibility to provide a safe and inclusive work environment for all workers, including own employees, temporary employees, agency workers, and contractors. Hydro values human life above all other considerations and will not compromise the health and safety of those working for the company or affected by its activities. Hydro believes a safe work environment also promotes efficiency and lower operating costs. Hydro relies on a safe, healthy, competent, and engaged workforce to ensure quality and efficiency in all operations. Safeguarding the rights, health, and safety of the workforce, while fostering a culture for learning, equal treatment, and opportunities is essential for attracting and developing talent, ultimately enhancing the company’s performance. Hydro’s organizational culture, which emphasizes learning and development, innovation, leadership, and belonging aligns with the company’s strategic priorities and drives success. Conversely, an adverse psychosocial work environment or accidents that affect the health and safety of Hydro’s workforce can result in disruption of business operations. Such incidents may result in legal proceedings, fines or other financial consequences, and damage to the company’s reputation, which can erode trust in both the short, medium and long-term. Failure to comply with applicable regulations for working conditions, equal treatment and/or reporting on workforce related issues could also result in fines and negative reputation. Hydro positively impacts employees by offering secure employment, learning and development, fair wages, and social protection. However, potential negative impacts can arise from unintended incidents of discrimination, harassment, or accidents resulting in injury, illness, or even fatalities involving employees or contractors. Hydro’s workers are exposed to a variety of safety risks that, if not controlled, could result in accidents leading to injuries or fatalities. The inherent risks of negative impacts on health and safety are higher when performing non-routine work such as building and construction projects, and in work related to energy, work at height, mobile equipment, overhead cranes, confined spaces, molten metal and projects.

Potential fatal or life changing accidents affecting own workforce. Potential incidents of discrimination or harassment affecting own workforce.

As part of Hydro’s human rights due diligence, the company maps salient potential and actual human rights impacts across its operations. See the position statement on human rights due diligence for more information about the company’s human rights management and due diligence approach. Hydro is committed to, and has a human rights policy based on, the UN Guiding Principles on Business and Human Rights, and other global frameworks that define human rights principles for businesses.

Hydro’s health and safety activities are governed by the company’s HSE policy and the Global HSE Directive, which are owned by the EVP for People and HSE, and applicable for all own employees and contractors. Health and safety standards are aligned with ISO standards. Health and safety are identified as salient human rights with potential adverse impacts on employees and contractors across Hydro’s operations. Hydro’s ambition is to provide safe and healthy workplaces, promote health and wellbeing, and prevent work related injuries and illness.

Impacts and risks are identified and assessed using employee engagement surveys, grievance mechanisms including AlertLine, root cause reviews of incidents affecting employees, health and safety network meetings, and regular employee reviews meetings conducted by line managers.

Hydro identifies and monitors its impact on own employees and contractors according to the same standards, Code of Conduct, and other governing policies and documents, including the HSE Policy and Hydro’s people strategy. The EVP People and HSE, the highest ranking official in this area, is responsible for guiding Hydro’s approach to health, safety, and workforce engagement concerning impacts and risks. The operationalization of this is delegated to the HSE and People organizations in the Business Areas, respectively. Hydro identifies and measures impacts on its workforce through direct involvement of employees in incident identification and investigation, regular network meetings within Business Areas, employee reviews, and engagement surveys. As part of Hydro’s human rights due diligence, the company maps salient potential and actual human rights impacts across its operations. See the position statement on human rights due diligence for more information about the company’s human rights management and due diligence approach. Hydro is committed to, and has a human rights policy based on, the UN Guiding Principles on Business and Human Rights, and other global frameworks that define human rights principles for businesses. Health and safety, discrimination and harassment, and vulnerable individuals and groups have been identified as salient human rights risk areas related to own workforce. See the sections on occupational health and safety, and diversity, inclusion and belonging for more information. Hydro’s human rights policy explicitly addresses forced or compulsory labor and child labor, but these are not identified as salient risks for Hydro’s own workforce. Regarding other potential human rights impacts, see the section on labor rights.

Hydro drives safety improvements by systematically reducing risks, training personnel, and regularly following up by line management and safety delegates. All injuries and high risk incidents are investigated to find root causes, and to share lessons learned between Hydro sites. Employees are engaged on health and safety issues through frequent network meetings across the business areas. Hydro works continuously to avoid damage to property and loss of production. Hydro has developed a comprehensive health and safety management system, and the company’s manufacturing sites are certified to internationally recognized health and safety standards. Hydro embraces digital tools where possible and has developed an advanced incident management system, self-assessment tools, risk management processes, e-learning training modules, a digital HSE assistant using Artificial Intelligence etc., all easily accessible to employees. In addition, Hydro has strengthened its behavioral tools using human performance techniques and the consistent use of peer-to-peer job observations. Hydro has developed employee assistance programs at site level to support affected workers. This includes as a minimum psychological support for those needed, but also include other types of support depending on the area they operate in, such as financial advice.

Just Transition The green transition will create new employment opportunities as well as changes to existing ones. Innovations in Hydro’s production methods and advancement of technologies risks the automation of jobs. Additionally, Hydro’s focus on decarbonization must not exacerbate social inequalities or discrimination. Hydro has developed a framework for supporting a just transition, through which the company seeks to contribute to positive development in the societies where it operates, including for its own workforce. The framework is focused around three key outcomes: People have human rights protected and have access to equal opportunities; Local communities are resilient in a changing world; and People have the necessary skills and jobs for the future low-carbon economy. Hydro contributes towards these outcomes in its own workforce by respecting and promoting human rights, supporting positive local development in the local communities where its employees live and work, and through developing skills and jobs relevant to the future low-carbon economy. In 2024, Hydro continued to develop and deliver learning and skills development for all its employees. Hydro also works to increase inclusiveness among Hydro employees and tracks the perception of inclusiveness in the Hydro Inclusion Index, which is part of the biannual Hydro Monitor survey. See Note S1.2 for Hydro employee engagement metrics.

We grow Hydro’s purpose is to create a viable organization that empowers people to grow. The company invests in skills development aligned with both business and individual needs to achieve its business strategy and to be an attractive employer. Hydro provides opportunities for personal and professional growth opportunities, aiming to foster a continuous learning culture based on growth mindset among leaders and employees, where learning is integrated into daily work. Learning and development is offered through a blend of on the job training, social initiatives such as networking, mentoring and peer-topeer learning, along with formal learning programs. Hydro’s learning platform offers content from various learning providers and esteemed universities. In addition, every employee engages in an annual appraisal dialogue with their leader to discuss and document development goals and activities. See Note S1.4 for metrics related to completed training activities in 2024. We lead Leadership is a key lever for Hydro’s organizational success. Hydro has developed a leadership framework that combines valid research with Hydro’s unique needs, enabling leaders to effectively deliver the business strategy and embody Hydro’s values. This framework underpins Hydro’s leadership processes, development programs and tools. In 2024, Hydro continued to deploy this framework through its people processes, with established leadership criteria supporting the selection, development and succession of leaders. Leadership development and succession planning for critical positions remain strategic people priorities as Hydro moves towards 2030. To cultivate a strong pipeline of leaders with diverse experience, Hydro aims to rotate leaders across different parts of the organization, and offer development initiatives and programs tailored to the needs of both leaders and specialists. We innovate Innovation is the third pillar of the People Strategy, where technology and digital tools serve as enablers for better decision making and help freeing up time for value adding activities. We belong Belonging is the final pillar of the new people strategy. The ambition is that together Hydro creates a healthy and inclusive environment where everybody's contributions matter.

Hydro’s ambitious people strategy towards 2030 focuses on learning and development, innovation, leadership, and belonging. These global strategic priorities are supported by targets and activities that address the specific needs and challenges of the business areas.

0 fatalities or life changing injuries

25% women overall and in leadership position by 2025s

78% score on the Inclusion Index by 2024

S1.1 Characteristics of Hydro’s employees by gender and region

Number of employees

Number of permanent employees

Number of temporary employees

Number of non-guaranteed hour employees

Number of full-time employees

Number of part-time employees

S1.2Diversity, inclusion and belonging

Inclusion Index (II)

Employee Engagement Index (EEI)

Psycosocial Risk Index (PRI)

Integrity Culture Index (ICI)

S1.3 Health and safety

Total recordable injuries, lost-time injuries, and fatal accident

High risk incidents (HRI)

Occupational illness rate and sick leave

75% score on the Inclusion Index

24%/21% women overall / in leadership positions

1/1 fatality /life-changing injury in consolidated operations

The total recordable injuries rate in 2024 was 2.0 per million hours worked, compared to 2.4 in 2023. An improvement is seen in the number of injuries occurred to own employees. The majority of injuries were relatively minor. However, there was one fatality involving a contractor at the aluminium smelter Albras in Brazil. Action plans and global learning plans have been established and implementation is ongoing. There was also one life changing accident at Albras, when a contractor lost two fingers. The deployment of fatality prevention procedures, and associated life saving rules and behaviors continued in 2024. This contributed to a continued reduction in the number and rates of high risk incidents with the potential to be life changing, however, there was an increase in the high risk incidents with the potential to be fatal. Key initiatives include a self-assessment process for critical programs, electrical committees reviewing high risk incidents and required controls to be put in place, digitalizing systems and tools with integrated artificial intelligence functionality increasing the quality of the root cause investigations and risk assessments, monthly deep-dive incident data analyzes to support continuous improvement through root cause and use identification, and defining actions to prevent incidents from recurring. Quarterly health, safety, security, and environment network meetings are used to connect specialists from all business areas to discuss findings and actions taken from high risk incidents, and to share best practice and innovative solutions. Hydro also increased its emphasis on installing engineering controls to prevent high risk incidents from occurring. Hydro’s approach to continual improvement of physical and chemical occupational health is based on work environment risk assessments (WERA), and implementation of risk reduction measures followed up through an associated key performance indicator. WERA provides a systematic approach for evaluating the exposure of similar exposure groups, identifying the most exposed work operations and measures can be implemented before ill health occurs, which applies to both own employees and contractors. The group online HSE tool, IMS, provides a WERA module to facilitate the work process and ensure transparency.

Hydro engages its employees on health and safety issues through frequent health and safety network meetings in business areas. Engagement on diversity and inclusion issues is primarily done through employee reviews and the range of initiatives sponsored by members of the Executive Leadership Team.

Hydro engages its employees on health and safety issues through frequent health and safety network meetings in business areas. Engagement on diversity and inclusion issues is primarily done through employee reviews and the range of initiatives sponsored by members of the Executive Leadership Team.

With a network of over 30,000 suppliers across more than 40 countries and 30,000 customers worldwide, Hydro exerts a substantial impact throughout its value chain. Upholding a responsible value chain is a core component of Hydro’s Just Transition framework, which outlines the company’s ambition to fostering a future that is both environmentally sustainable and socially equitable. Hydro may positively influence workers by creating job opportunities. By establishing rigorous standards for suppliers regarding human and labor rights, and by actively engaging, influencing, and collaborating with them to enhance their human rights commitments and management practices, Hydro can contribute to increasing access to decent work for a greater number of individuals, ensuring their rights are upheld. However, Hydro’s procurement includes raw materials, products and services from industries and regions that present inherent risks to workers’ rights. Within a complex and extensive supply chain, the potential negative impacts on workers affected by Hydro’s operations can be significant. These may include violations of rights, challenges related to decent working conditions, limited access to a safe and healthy working environment, and the risk of accidents or unforeseen incidents leading to injuries, illness, or fatalities. Failure to deliver on requirements and expectations for workers' safety and rights in the value chain can lead to loss of public trust and operational disruptions.

Potential fatal or life changing accidents affecting workers in the value chain. Potential incidents resulting in breaches of the rights of workers in the value chain.

The process is described in more detail in the document Human Rights Due Diligence in Hydro available on Hydro’s website under Policies and Tools. Hydro is an active member of the Aluminium Stewardship Initiative (ASI) and promotes ASI’s certification program to its aluminium suppliers for the sustainable development of their operations.

The mandatory process for due diligence of all suppliers is described in the company wide procedure, Sustainability in the supply chain.

Hydro’s Supplier Code of Conduct sets out the minimum sustainability requirements for all its suppliers. The code is based on internationally recognized standards such as the Universal Declaration of Human Rights and the International Labor Organization, ILO Core Conventions.

Hydro engages and collaborates with stakeholders internally and externally when relevant, to help inform and evaluate the effectiveness of its approach to responsible sourcing. See the human rights due diligence process and the section on Partnerships for more information.

Contractors working on Hydro's sites are subject to the same requirements and due diligence on health, safety and worker's rights as Hydro's own workforce. Impacts and risks on other workers in the value chain are identified and assessed by performing supplier due diligence activities using data on inherent risk of negative impacts by geography and industry. High and medium risk suppliers are subject to further due diligence using self-assessments, screening tools, direct engagement and audits to determine residual risk of negative impacts, and direct engagement on corrective action plans related to residual risk of negative impacts.

Hydro’s approach to responsible sourcing is based on the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct and can be summarized in three steps: 1. Mapping of risks and due diligence activities All suppliers are subject to a qualification process, including a screening for risks related to human rights and workers’ rights. As part of creating a common and consistent approach to supply chain management, suppliers in Hydro categorized as medium or high inherent risk, are subject to further screening, using either qualified third party ratings or standard self-assessment forms combined with desktop research. If further due diligence is needed, Hydro conducts a comprehensive review or audit of the supplier to assess if it meets Hydro’s requirements before any agreements are signed. For suppliers with a high inherent sustainability risk, follow-up assessments shall be conducted regularly during contract period. If any non-compliance with Hydro’s requirements is identified, the supplier is subjected to a corrective action plan where mitigative actions are outlined to address the gaps. This plan is designed to ensure that all identified gaps are closed effectively. The mandatory process for due diligence of all suppliers is described in the company wide procedure, Sustainability in the supply chain. 2. Clear expectations Hydro’s Supplier Code of Conduct sets out the minimum sustainability requirements for all its suppliers. The code is based on internationally recognized standards such as the Universal Declaration of Human Rights and the International Labor Organization, ILO Core Conventions. The principles set out in Hydro’s Supplier Code of Conduct are made binding through contractual clauses. Hydro’s Supplier Code of Conduct requires suppliers to conduct due diligence in their own supply chain, and sustainable procurement expectations are reflected in Hydro’s supplier self-assessments, which is specified in its contracts and assessed in visits and audits. 3. Support and development Hydro builds its relationship with its suppliers on mutual trust and development. Hydro works to strengthen and improve its suppliers’ sustainability performance through efforts such as dialogue, knowledge sharing, innovation processes, incentives, and supplier development programs. Hydro actively discusses and promotes human and workers’ rights. While failure to comply with Hydro’s Supplier Code of Conduct may as a last resort result in a termination of the contract, Hydro always seeks to work with its suppliers with intention of continuous improvement as long as it considers this to be in the best interest of the people in its supply chain. As a part of Hydro’s work to strengthen its procurement processes, the company has also incorporated living wage requirements. According to the supplier Code of Conduct, wages and benefits paid for a standard working week shall as a minimum meet national legal or industry standards, whichever is higher. Wages should be sufficient to cover basic needs and provide some discretionary income. Hydro engages and collaborates with stakeholders internally and externally when relevant, to help inform and evaluate the effectiveness of its approach to responsible sourcing. See the human rights due diligence process and the section on Partnerships for more information.

Salient human rights risks affecting workers in the value chain In the aluminium value chain several stages present heightened human rights risks, particularly in the sourcing of raw materials and metals. While all the identified salient risks may be relevant across the value chain, each process step, from bauxite mining to smelting and the use of traders as intermediaries, carries specific concerns. To mitigate these risks, Hydro places significant emphasis on ensuring suppliers achieve ASI (Aluminium Stewardship Initiative) certification, as this provides a comprehensive framework for responsible production, sourcing, and governance for the bauxite, alumina and aluminium flow. For the other supply chains, Hydro focuses on engagement with tier one suppliers and progressively aim to deepen our understanding and oversight further upstream where we see additional risks. Initial screenings guide the adaptation of our due diligence checklists, which are further strengthened by third party assessments, such as those provided by EcoVadis. This risk-based approach supports targeted interventions at critical points in the value chain, addressing specific concerns at each stage. 1. Sourcing of Bauxite Direct sourcing to the Alunorte refinery in Barcarena, Brazil, comes from two mines: Hydro’s own mine Paragominas (70%) and the MRN mine in Trombetas (30%). Both mines are ASI certified. These bauxite sources provide close to 100 percent of the supply to the alumina production going to Hydro’s Norwegian smelters and 100 percent to the Albras smelter. Hydro also has an indirect link to bauxite sources through metal procured to its smelters, casthouses and extruders. In total for both direct and indirect sourcing in 2024, more than 80 percent of the bauxite can be traced back to mines in Brazil and Australia, where Hydro has a good overview of the risks. The third biggest bauxite source, at approximately 8 percent, is indirectly sourced from Guinea. Most of this comes from two mines in Guinea, both of which are ASI certified. However, given the challenging situation in Guinea, Hydro monitors the situation continuously. The remaining 10 percent of the indirectly sourced bauxite are spread on small volumes from different mines across the world. Risks that receive special considerations include land conflicts, labor rights issues such as decent working conditions and health and safety, as well as environmental impacts, which can infringe on human rights. 2. Alumina refining In addition to the bauxite from Paragominas and MRN, the refining process at Alunorte requires electric energy, coal, caustic soda, fuel oil and lime. Coal is sourced from suppliers with mines located in Colombia. As the combination of product category and country is consider a high risk, the suppliers are continuously monitored, through desktop screening and engagement with the suppliers, depending on the findings identified, at regular intervals. Suppliers in high-risk categories are also subjected to on-site assessments. Caustic soda is sourced from the U.S., while the energy, fuel oil and lime come from Brazil. They are subjected to continuous standard due diligence processes that has not identified any material issues in 2024. Situated in the upstream part of the value chain with, Hydro sees similar heightened risks for workers in the value chain as for the bauxite part related to decent working conditions and environmental

For Hydro’s smelters, the key risk commodities outside of alumina have been identified as alloys, anodes and external aluminium used to accelerate the casting process. Key risks in smelting include forced or exploitative labor in alloy and anode production, particularly in China, and the difficulty in tracing materials traded through intermediaries. Close to 100 percent of the alumina used by Hydro’s smelters in Norway comes from the company’s Alunorte refinery. If additional alumina is needed for balancing, the sources are either ASI certified or subject to Hydro audits. The aluminium Hydro produces typically contains between one and 11 percent alloys. Most of the alloys are sourced from China, either through traders or directly from refineries. These are mostly long-term and strategic contracts lasting for many years. Hydro conducts regular audits of the refineries for a range of topics including sustainability issues. When Hydro has negative findings or observations, the company establishes improvement plans with the suppliers. Hydro also sources around 40 percent of the anodes for its Norwegian smelters, directly from producers in China on annual or multi-annual contracts. The rest is produced by Hydro either in Norway or Slovakia, and the suppliers are subjected to the same processes as for alloys sourcing. The metal Hydro sources to its smelters are traded through the London Metal Exchange, which requires the brands to verify compliance with OECD due diligence requirements, reducing the need for Hydro to run independent assessment of these supplies. 4. Casting and extrusions Since Hydro’s casting capacity exceeds its own smelting production, cold metal is also acquired from external sources and traders. Sourcing metal from traders introduces extra challenges related to human rights due diligence due to more complex traceability of the materials. Without full transparency into the origin of the metal, there is a heightened risk of being linked to suppliers who may engage in unethical labor practices. In 2024, Hydro started to map the flow of metals beyond external smelters to better understand where the alumina and bauxite originates. As described above under Sourcing of Bauxite, the vast majority of the bauxite comes from a handful of countries and from mines that are either ASI certified, or that Hydro has supplier-specific data on. Hydro will continue to develop a better understanding of this flow and the mines that are linked to the company, also for smaller volumes, and then assess whether further due diligence may be needed. 5. Recycling As production of recycled aluminium increases, so does Hydro’s demand for scrap. The nature of scrap sourcing is local, and the vast majority of scrap suppliers will be in the immediate vicinity of Hydro’s recyclers. In 2024, approximately 80 percent of externally sourced scrap was supplied by vendors in the same country as Hydro’s recyclers, with close to 92 percent of the scrap suppliers residing in Europe, Canada or the U.S. In addition, Hydro sources some volumes of process scrap from the Middle East. Hydro has a bespoke due diligence process for smaller and local scrap suppliers based on the in-depth knowledge from the scrap sourcing teams. For the larger suppliers, including the ones in the Middle East, Hydro categorizes scrap suppliers as high sustainability risk and assesses them accordingly. Recycling introduces risks such as informal labor arrangements among smaller local suppliers, which may lead to exploitative practices like poor working conditions. There are also challenges in ensuring full supply chain transparency, particularly with process scrap from the Middle East. Additionally, improper handling of scrap materials can create occupational health hazards. 6. Construction, maintenance and logistics Hydro prioritizes human rights due diligence across logistics, construction, and maintenance services to ensure that these workflows are conducted responsibly. Logistics services and transportation carry risks related to excessive working hours, unsafe conditions, and the exploitation of migrant workers. Construction and maintenance on Hydro’s sites may present risks related to hazardous work environments and the potential for unfair labor practices, including wage theft and elements of forced labor. Maintenance services, which are essential for safe operations, also pose occupational risks if safety measures are not strictly followed. To address these risks, Hydro requires that its standards are implemented and conduct audits to verify compliance. 7. Renewable energy production value chain Hydro’s energy production sourcing share risks with those found throughout the raw materials supply chains for aluminium. This includes an indirect risk associated with mining and refining processes in the lower tiers for products and equipment needed for power generation. Components such as generators and turbines require a range of input materials, such as copper, steel and nickel, that have concentrated supply chains associated with upstream social and environmental risks. Hydro will continue to develop a better understanding of the material flows related to energy production sourcing activities with a special focus on souring activities for electromechanical equipment in 2025. Hydro Energy has a selection of investments in the battery value chain, which can be exposed to human rights risks in relation to the extraction and processing of minerals. This includes a 24.1 percent ownership in the maritime energy storage systems company Corvus, which has around 150 suppliers globally, including battery manufacturers. Corvus is sourcing battery cells from Chinese suppliers, which means there are known sector level risks as well as raw material sourcing risks. Hydro Energy has actively supported Corvus's work with supply chain sustainability and included Corvus’ in a human rights risk assessment on China in early 2024. Corvus also publishes its own transparency act statement in accordance with the Norwegian Transparency Act, where further information can be found. Hydro Energy also owns 0.6 percent of Swedish cell manufacturer Northvolt, which has similar risks in their supply chains.

Due diligence of customers Hydro follows closely regulations for sanctions or restrictions on countries and specific companies. Hydro regularly screens customers and business partners for any potential sanctions. In addition to this, Hydro conducts a sustainability due diligence process before it enters new sales contracts with partners in countries with identified high human rights risks. In 2024, several new business opportunities were assessed and discussed to identify any potential adverse human rights impacts related to the projects and country of operation. Hydro continues to engage in several external networks to understand how to efficiently implement human rights due diligence downstream in its value chain. Supplier and business partner screening As part of the integrity risk management process, more than 9,000 potential or existing counterparties were screened for human rights violations, corruption, money laundering, politically exposed persons, and violations relating to sanctions using the Moody’s Grid integrity risk tool during 2024. New business partners related to most operations are screened before registered in the ERP system. Hydro’s operations in North America also use the denied parties risk tool MK Denial to screen suppliers against 16 official sanction lists multiple times a year. In 2024, approximately 13,600 customers and vendors were screened in MK Denial. All suppliers, customers and other business partners registered in Hydro’s main accounting systems are screened on a weekly basis against recognized international sanction lists. Hydro has developed a spend cube to visualize external spend, measure procurement initiatives, and manage supply chain risk. See Note S2.1 for metrics related to supplier screening and due diligence activities.

Hydro may positively influence workers by creating job opportunities. By establishing rigorous standards for suppliers regarding human and labor rights, and by actively engaging, influencing, and collaborating with them to enhance their human rights commitments and management practices, Hydro can contribute to increasing access to decent work for a greater number of individuals, ensuring their rights are upheld.

Findings and impacts Hydro’s risk-based approach directs in-depth due diligence efforts towards critical upstream suppliers within the aluminium value chain, especially in countries with weaker environmental regulations and identified risk of forced labour like conditions. These assessments are supplemented with reviews of suppliers where both sector and country risk may be lower but still well known, for example within logistic services and for larger maintenance and construction projects on our sites. Through Hydro’s audits and reviews in 2024, it has identified three cases of adverse impacts: • In pre-screening of potential supplier, one case of document retention for its sub-supplier was identified. • In pre-screening of potential supplier, lack of overtime payment for its sub-supplier was identified. • In standard supplier audit, one case of insufficient management systems had led to unhygienic working conditions. Hydro takes these issues very seriously and have established corrective action plans in dialogue with the supplier to address the issues and help close the gaps. Of the material issues identified in 2024, all were closed or in the process of being so, by year-end.

Transparency and traceability of key sustainability data for our products by end of 2025

While there were no group wide quantitative targets for engaging directly with workers in the value chain in 2024, Hydro has set a new target to track the share of suppliers that have a corrective action plan in place for human rights residual risks identified in the due diligence process. Hydro will report performance against the new target in 2025.

2.1 Supplier metrics

S2.2 Supplier due diligence

Hydro Energy has actively supported Corvus's work with supply chain sustainability and included Corvus’ in a human rights risk assessment on China in early 2024. Corvus also publishes its own transparency act statement in accordance with the Norwegian Transparency Act, where further information can be found. Hydro Energy also owns 0.6 percent of Swedish cell manufacturer Northvolt, which has similar risks in their supply chains.

9,520 Total suppliers screened in 2024

2,878 High and medium sustainability risk suppliers in 2024

Through regular assessment, follow up and collaboration with selected high risk suppliers, Hydro seeks to contribute to continuous development. Hydro conducted 215 supplier audits in 2024, including topics related to human rights, working conditions and HSE. Key findings from the audits relate to lack of management systems, environmental awareness, compliance controls and emergency preparedness. Around 30 percent of the audits led to action plans, and by the end of 2024, almost 100 percent of the corrective actions proposed by Hydro resulted in improved performance.

Contractors working on Hydro's sites are engaged directly on health and safety standards the same way as Hydro's own workforce. Other potentially affected workers in the value chain are engaged indirectly though Hydro's requirements and expectations for workers' rights as set out in Hydro's Supplier Code of Conduct.

Contractors working on Hydro's sites are engaged directly on health and safety standards the same way as Hydro's own workforce. Other potentially affected workers in the value chain are engaged indirectly though Hydro's requirements and expectations for workers' rights as set out in Hydro's Supplier Code of Conduct.

As a global aluminium and energy company with mining interests, Hydro’s operations impact communities in association with its own operations and operations in Hydro’s value chain. Hydro’s business activities impact a large number of people in local communities positively through job creation and local value creation. Hydro contributes to the societies to which it belongs by offering decent jobs and by paying taxes and fees. In some communities, Hydro also establishes and maintains infrastructure and supports social programs and investments. Hydro’s business also has the potential to adversely impact local communities. The company’s approach to identifying and addressing such impacts is described in this chapter. Hydro can only succeed as a company if the communities around its operations also succeed. The company depends on local institutions and infrastructure, and trust and good relationships with local communities are of key importance to Hydro’s operations. Failure to deliver on local communities’ requirements and expectations towards Hydro’s environmental and social responsibilities can lead to loss of public trust and operational disruptions.

Potential incidents affecting the rights of people in local communities. Potential accidents negatively impacting the health and safety of people in local communities.

Hydro’s commitment to respect the human rights of affected communities associated with our operations and value chain, and to manage any potential or actual adverse impacts is set out in the company’s Human Rights Policy, which is approved by the Executive Leadership Team (ELT). The operational responsibility for ensuring that engagement with affected communities is conducted as set out in the policy is delegated to the business areas. The policy is aligned with the UN Guiding Principles on Business and Human Rights and Hydro’s commitment to respect human rights is guided by internationally recognized human rights and labor standards, including those contained in the International Bill of Human Rights. The policy provides reference to the UN Declaration on the Rights of Indigenous Peoples and the Indigenous and Tribal Peoples Convention (International Labor Organization, ILO, Convention 169) and other conventions relevant to affected communities. All affected communities are covered by the policy. The policy includes Hydro’s commitment to be particularly attentive to the rights of indigenous and tribal peoples, as well as traditional communities, in particular with regards to their rights to self-determination, to lands which they traditionally occupy, to their customs, traditions and institutions, and to their free, prior and informed consent (FPIC). In the policy, Hydro also commits to be particularly attentive to the rights of human rights defenders, considering in particular their rights to freedom of expression, association, peaceful assembly and to protest against Hydro’s business and operations. Hydro’s approach to human rights due diligence in relation to the rights of communities and indigenous peoples specifically is also set out in Hydro’s Human Rights Policy, and detailed further in the Position Statement on Human Rights Due Diligence. Potential or actual adverse impacts on local communities are managed through this process. If Hydro identifies adverse human rights impact that the company has caused or contributed to, Hydro works to cooperate in, promote access to and/or provide remediation.

Impacts and risks are identified and assessed by mapping the local sustainability context and transition challenges where Hydro operates using data on inherent risk of negative impacts by geography and industry. Potential human rights impacts are further assessed by direct engagement of potentially affected stakeholders through stakeholder dialogue to understand what is expected of the company, what is important to local communities, how Hydro impacts them and how the company can solve common challenges.

Potential and actual adverse impacts As part of Hydro’s human rights due diligence process, the company identifies the risk of salient human rights impacts on affected communities. The risks are identified through Hydro’s annual human rights risk assessment process, and additional processes for new projects and investments, drawing on internal and third-party human rights assessments, internal and external expertise, and other relevant sources. Any actual adverse impacts and specific risks are identified through the ongoing human rights due diligence process. In cases where mitigating actions are implemented, these are documented as part of Hydro’s annual human rights risk assessments and human rights data collection, and effects are monitored to the extent possible. For information about cases of non-respect of the UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work or OECD Guidelines for Multinational Enterprises that involve affected communities in own operations or in the value chain (ref. ESRS S3-1), see note G1.1 in the Business Conduct chapter.

Hydro uses human rights risk levels per country to help guide its human rights management. The risk levels are based on a range of independent human rights sources, such as the UN Human Development Index and the TI Corruption Perception Index. Hydro’s assessments are also based on Hydro’s internal risk evaluation and, for the aluminium production and sourcing, drawing on materiality assessments conducted by the International Aluminium Institute (IAI), on the severity and likelihood of potential impacts on people at the different stages of aluminium production. Hydro has identified salient risks of adverse impacts on affected communities for some parts of the aluminium production process. Hydro has not identified salient risk of adverse impacts on affected communities in the extrusions and recycling part of its aluminium business. Hydro’s fully owned primary metal plants are located in Norway, which has been assessed as a low-risk country related to adverse impacts on human rights in affected communities associated with Hydro’s aluminium production. In addition to Hydro’s Norwegian production, Hydro is the main indirect shareholder of Albras primary metal and the alumina refinery Alunorte in Barcarena, Brazil. Hydro also owns the bauxite mine Paragominas. Hydro has identified the inherent risks related to communities in Northern Brazil as the most salient due to the combination of the country and regional risk and the industrial processes conducted in this part of the production process. The industrial industrial processes within aluminium production carry an inherent risk of pollution, linked to process emissions to air and water, and the potential for accidental spills or leakages. Such emissions can have a negative impact on the local environment and local communities if not managed correctly. Hydro’s business activities are subject to emissions regulations, including local emission permits, as well as regional and international regulation of emissions. Hydro’s approach to environmental management is covered in the chapter Pollution. This is closely linked to the health and safety of local communities, which has been identified as a salient human rights risk across Hydro’s business. Hydro has not identified the risk of adverse impacts on affected communities to be salient in its own operations in Hydro’s energy business. Please see the section “Affected communities in value chain including joint ventures and joint operations” for information about other identified salient human rights risks and impact in relation to joint ventures and the value chain in Hydro’s energy business. Context specific salient human rights risks are described in the section “Affected communities in value chain including joint ventures and joint operations” and in the section “Joint ventures and value chain,” where applicable

Grievance mechanism Canal Direto is Hydro’s operational level grievance mechanism open to all external stakeholders in Brazil and targeted specifically at affected communities. The mechanism allows community members to raise their concerns anonymously. Grievances are assessed according to the criticality of each case. The process follows the criteria for effective grievance mechanisms set out in the UN Guiding Principles on Business and Human Rights. The effectiveness of the grievance mechanism is monitored through dialogue with the affected communities, monitoring of the type and volume of cases received, as well as through a satisfaction survey for users. In 2024, the Canal Direto registered 633 grievances via telephone, online form and email. Of the registrations, 92 percent were identified and eight percent anonymous. 84 percent were related to requests for information and the most frequently registered topics were sponsorships, job and career opportunities at Hydro, visits to operations, donations, commercial matters, auctions and interest in research, innovation and new technologies. See also note G1.1 for further details about grievances received through Canal Direto in 2024. Human Rights Impact Assessment Alunorte, Albras and Paragominas began the implementation of a Human Rights Action Plan to mitigate risks in the operations in 2020. A new Human Rights Impact Assessment of Hydro’s operations in the state of Pará is currently underway, conducted by an external consultancy. As part of this process, a baseline study has been conducted, and the findings and recommendations are expected in 2025. Community dialogue Alunorte, Albras and Paragominas have implemented a structured approach to effective and inclusive engagement with diverse communities in the region. Hydro engages in dialogue with community groups, traditional groups and civil society organizations which represent women, children, human rights defenders or other underrepresented and at risk groups in the local communities. Hydro Sustainability Fund initiatives Since 2018 Hydro has supported, by Hydro Sustainability Fund initiatives, the Sustainable Barcarena Initiative (SBI) to enhance community dialogue. This is an independent forum to support sustainable development in Barcarena. The overall aim is to bring local stakeholders together to discuss challenges and opportunities, strengthen capabilities and decide about the main social investments supported by the Hydro Sustainability Fund (HSF). In 2024, about 178 community leaders participated in meetings, dialogues, or programs organized by the initiative. SBI also plays an important role coordinating the financing rounds of Hydro Sustainability Fund (HSF) to ensure Hydro’s social investments meet the local community’s needs. In 2024, HSF supported 36 community based projects.

Hydro’s business activities impact a large number of people in local communities positively through job creation and local value creation. Hydro contributes to the societies to which it belongs by offering decent jobs and by paying taxes and fees. In some communities, Hydro also establishes and maintains infrastructure and supports social programs and investments.

Affected communities in value chain including joint ventures and joint operations Aluminium production Based on an assessment of country and regional risk, the industrial processes and affected communities in the surrounding areas, Hydro has not identified significant risks of adverse human rights impacts for affected communities linked to Hydro’s joint venture operations outside Brazil. This includes one joint asset, Alouette (Canada), and one joint operation, Tomago (Australia), which are in the vicinity of indigenous or traditional communities. Potential and actual impacts identified in the external aluminium value chain are covered in the chapter Workers in the value chain. Energy This section describes potential and actual adverse impacts on affected communities in Hydro’s renewable energy value chain and joint venture operations. The projects mentioned below are the ones where Hydro assesses the inherent risk to affected communities to be the highest. Solar and wind projects in Brazil Hydro Rein is a joint venture owned by Hydro and Macquarie Asset Management and an important supplier of renewable energy to Hydro. Hydro Rein has a minority stake in two solar plant complexes in Brazil, Mendubim and Boa Sorte, that started operations during 2024. Hydro Rein also has a minority stake in the wind park Ventos de São Zacarias, which is currently under construction. Alunorte, Albras and Paragominas own 98 percent of the voting rights and 10 percent of the equity in these projects. In 2024, six families were resettled due to the construction of Ventos de São Zacarias. Two families were resettled due to the construction of Mendubim. The families were engaged in a participatory consultation process on the resettlement process and the definition of appropriate mitigation measures. A Resettlement Action Plan has been developed in accordance with IFC Performance Standards and mitigation is monitored in line with this. To address the impact on the families’ livelihood, a “Livelihood Restoration Plan” has been established and will be monitored. Follow up with some of the resettled families show that they are satisfied, follow up is still to be conducted with some of the families. There are two self-identified Quilombola communities in the vicinity of the Ventos de São Zacarias project. The project is engaging in FPIC consultations with the communities in accordance with ILO Convention 169 and the IFC Performance Standards. Compensation actions agreed upon by the stakeholders in FPIC consultation are either ongoing or completed. Wind project in Sweden Hydro Rein is a joint venture partner of Stor-Skjälsjön, a wind farm in the northern part of Sweden which entered into full operation at the end of 2024. Four nearby Sami communities were initially consulted about their land use, and only Ohredahke sameby reported use of the northern area of the project for occasional reindeer winter grazing. Oherdahke Sami community acts as the focal point for the overall Sami community dialogue. During development, the project engaged in dialogue with the nearby Sami communities as a part of the regular public consultation process and during the Environmental Impact Assessment (EIA) process. The dialogue was facilitated by a project representative speaking the Sami language, with the objective of gathering input on the use of the project area to minimize the impacts from construction and operation on their livelihoods and cultural practices of reindeer husbandry. Based on the dialogue, the parties agreed on mitigation measures that were included as permit conditions. The measures include minimizing project activities during winter grazing period, unless otherwise agreed upon by the affected community. The project annually, and as needed during construction and operation, informs the nearby Sámi communities about construction, maintenance, services, repair, and potential ice-related risks at the wind farm to minimize disturbances to reindeer husbandry and support their planning. The support also extends to relocating reindeer if needed. In addition, the project has previously provided support to affected Sámi communities for reindeer infrastructure. The agreed mitigation measures with the Sami Communities have been followed and the implementation of these permit conditions are reported to the supervisory authority on an annual basis. Power purchase agreement in Norway In Norway, Hydro has an offtake agreement with Nordic Wind Power DA for delivery of power from the Fosen wind power installation. Nordic Wind Power is a minority owner of Fosen Vind DA. The projects on the Fosen peninsula are located within Sami reindeer grazing land. Agreements on mitigating measures and compensation for extra costs during the construction phase were previously entered into with the two affected reindeer herding groups. In October 2021, the Norwegian supreme court determined that the construction of the wind park had not sufficiently taken into account the rights of the Sami population. In December 2023, the Sør-Fosen Sijte reindeer herding district and Fosen Vind entered into an agreement. In March 2024, an agreement was reached between Nord-Fosen Siida and Fosen Vind. Hydro has been and will continue to monitor the situation. Power purchase agreements in Brazil Hydro has several offtake agreements in Brazil. In general, Hydro assesses the human rights risks to be high in relation to the construction of hydropower dams in the country. Environmental impacts with a resulting impact on local communities, land issues and gaps in FPIC processes have been assessed as the most significant risks. Please see the chapter Workers in the value chain for information about Hydro’s processes for managing supply chain risks. Input material for hydropower and clean energy systems Hydro is procuring a wide range of products and equipment needed for power production. Copper, cobalt, lithium and nickel are key transition minerals and input material for several components needed for energy production and the infrastructure development of clean energy systems. These minerals are key inputs in electromechanical components for hydropower operations, such as generators, turbines and cables, as well as energy storage systems (BESS), solar and wind. Although these minerals are important enablers of the green transition, their extraction and associated supply chains can cause harm to the environment and may negatively impact the land rights of local community members, including indigenous communities. Hydro will continue to map and assess impacts from mining, processing and refining of materials used in key products and components for power production.

Hydro has established a framework through which the company seeks to contribute to a transition that leaves no one behind, in line with the UN’s 2030 Agenda (“Just Transition Framework”).

Improve lives and livelihoods wherever Hydro operates by contributing to Improve lives and livelihoods wherever Hydro operates by contributing to

Improve lives and livelihoods wherever Hydro operates by contributing to Resilient local communities in a changing world

Improve lives and livelihoods wherever Hydro operates by contributing to Skills and jobs for the future low-carbon economy

S3.1 Community investments, donations, and sponsorships

S3.2 Socialresponsibility target

A risk associated with decarbonization efforts is that social inequalities increase as new technologies introduce the need for a different type of skillset or bring other changes to the labor market. To address this, Hydro’s Just Transition framework includes a focus on ensuring that people have the necessary skills and jobs for the future low-carbon economy. Hydro’s ambition is to equip 500,000 people with essential skills for the future economy by 2030. The insight from measuring the people reached and the impact of its initiatives make Hydro better equipped to select and execute future initiatives with a positive impact. In 2024, Hydro reached more than 44,000 people, which makes the total number reached since 2018 to 241,000 people. Hydro is still on track to reach the target of 500,000 by year end 2030. Continuous improvement of current initiatives and the development of new high impact initiatives are important focus areas.

A key element in Hydro’s Just Transition framework is to strengthen the societies and communities where it operates. The way Hydro does this differs from country to country and between communities. The main contribution is generated from the company’s operations through production and purchase of goods and services, direct and indirect job creation, and tax payments. While Hydro’s approach to supporting resilience varies depending on the local context, a common factor is the partnership approach, working with local partners with strong knowledge of the local context, as well as strong engagement with local community representatives. Hydro has a number of social programs aimed at building local community resilience. Some of its community investments and programs are linked to for example mining license requirements in Brazil and regulated watersheds in Norway, while others are voluntary commitments. The programs target education, economic growth, decent work, entrepreneurship, capacity building and the strengthening of institutions. In 2024, Hydro spent around NOK 300 million in total on community investments, investments through Hydro Sustainability Fund, charitable donations, sponsorships and TerPaz (local community centres). Excluding TerPaz, there is a 30 percent increase compared to the prior year, mainly due to the increased community efforts in Brazil and an increase in the Hydro Sustainability Fund. Please see the Note S3.1 for more information. In 2024, Hydro piloted a program to increase funding to projects aligned with the company’s Just Transition Framework in the communities where it operates. The project invited employees to apply for support for external partners, such as community organizations, to conduct projects supporting a just transition in the local community. 36 projects were selected for support in the pilot phase. Hydro also supports local communities through the transfer of competence that takes place through the company’s cooperation with universities and research institutions. This includes the cooperation with three academic institutions in Pará, Brazil, and the University of Oslo through the Biodiversity Research Consortium Brazil-Norway. In addition, Hydro provides scholarships to selected PhD candidates doing research relevant for its business areas. Hydro is also the sponsor of a professorship in Norway and has several adjunct professors among its own employees. See the section on partnerships in the Business Conduct chapter for more information.

Potentially affected stakeholders in local communities are engaged directly through stakeholder dialogues and through local media, and informed and consulted when potential impacts have been identified. Local authorities and NGOs are also engaged on impact assessments to identify potential risks.

Potentially affected stakeholders in local communities are engaged directly through stakeholder dialogues and through local media, and informed and consulted when potential impacts have been identified. Local authorities and NGOs are also engaged on impact assessments to identify potential risks.

As a global aluminium and renewable energy company with operations in more than 40 countries and interaction with a large number of business partners including more than 30,000 suppliers, Hydro depends on transparency, trust, ethical conduct and compliance throughout its organization and value chain. Compliance with applicable laws, regulations and Hydro’s policies, procedures and guidelines can help mitigate a range of risks, including those associated with corruption, competition, economic sanctions, human rights, security, health, safety, environment, data privacy, and corporate reporting requirements. Failure to comply with applicable regulations and expectations for responsible business conduct can result in loss of license to operate and could expose Hydro to investigations, administrative, criminal and civil sanctions such as fines and penalties, materially impacting financial results. In addition, there could be adverse consequences for individuals and reputational damage for the company.

A breach of cyber security could result in a broad range of impacts including HSE events, financial and reputational, operational disruptions and the leakage of private or confidential data.

Failure to comply with applicable regulations and expectations for responsible business conduct can result in loss of license to operate and could expose Hydro to investigations, administrative, criminal and civil sanctions such as fines and penalties, materially impacting financial results. In addition, there could be adverse consequences for individuals and reputational damage for the company.

Hydro is committed to applying ethical business practices and compliance throughout its organization and supply chain. Hydro’s board approved Code of Conduct creates the foundation that supports its efforts to do the right things, and to always act with integrity throughout its global organization, wherever it operates and conducts business, on behalf of Hydro.

Hydro’s AntiCorruption Program provides an overview of the main elements in Hydro’s anti-corruption efforts, which includes risk assessments, tone from the top, policies and procedures, training and communication, third party risk management, reporting and investigation, and disciplinary measures.

Hydro’s global data protection constitutes the company’s binding corporate rules for data protection (BCR) and ensures compliance with the EU General Data Protection Regulation (GDPR).

Hydro identifies inherent risk of corruption and other business conduct issues through corruption indexes and other screening tools, and assess potential impacts and risks through supplier and business partner due diligence processes. Hydro monitors business conduct incidents through cases reported to line management, supporting staff functions, Hydro’s grievance mechanisms, AlertLine and Canal Direto, quarterly and year end compliance reporting from its business areas, and information collected from Hydro’s legal and compliance departments

Anti-corruption Acting with integrity and combating corruption is an essential part of what Hydro considers responsible business conduct. Hydro does not tolerate any forms of bribery or corruption, including facilitation payments and kickbacks. Further, Hydro is committed to complying with all applicable laws and regulations to fight corruption and bribery, including the UN Convention against corruption. Through Hydro’s comprehensive compliance framework, the company works systematically to combat corruption and ensure compliant behavior throughout its global organization. Hydro’s AntiCorruption Program provides an overview of the main elements in Hydro’s anti-corruption efforts, which includes risk assessments, tone from the top, policies and procedures, training and communication, third party risk management, reporting and investigation, and disciplinary measures. The key pillars of the compliance framework are illustrated in the figure, below. Functions involved in commercial activities and interactions with government officials, especially in regions with heightened inherent corruption risk, are most at risk and hence targeted for compliance training. Data protection and cybersecurity Hydro’s global data protection constitutes the company’s binding corporate rules for data protection (BCR) and ensures compliance with the EU General Data Protection Regulation (GDPR). Designated data privacy coordinators for all business areas and staff functions form part of the data privacy network chaired by the head of data privacy. Hydro is continuously working on the robustness of the data privacy network, which is seen as a key point for a well functioning data privacy program. With a program established in 2018, Hydro has also worked on several data privacy program improvements in procedures and supporting processes to ensure continuous fit to the business. Cybercrime is increasing globally, exposing Hydro to a range of threats to the integrity, availability and confidentiality of its systems. Threats may include attempts to access information, ransomware attacks, destructive installation of viruses, denial of service and other digital security breaches. A breach of cyber security could result in a broad range of impacts including HSE events, financial and reputational, operational disruptions and the leakage of private or confidential data. Hydro’s CFO is the executive sponsor and owner of Hydro’s group wide multiyear cyber security improvement program following the cyber attack on Hydro in 2019. Further, the Board Audit Committee exercises oversight over Hydro’s aggregated risk profile, where cyber security risk is regularly assessed. Cyber security risk assessment is an integrated part of Hydro’s enterprise risk management system, in order to facilitate the business areas’ awareness on cyber security risk to their critical assets and operations. Critical assets both in plants and in the enterprise IT platform are subject to security monitoring as well as internal and external requirements to security. All personnel with access to sensitive information are bound to secrecy and required to handle information according to corporate guidelines and requirements. Hydro’s enterprise IT platform provides services as digital collaboration, enterprise resource planning, personnel databases and systems for external reporting. This platform is being modernized to withstand the developing cyber security threats and also segregated from plant industrial control systems. Offensive security testing of the enterprise IT platform as well as critical assets in the plants is also executed on a regular basis. Employee’s personal awareness and behavior is important to mitigate cyber risk. Cyber security training for all 13,000 IT users and role specific training for Industrial Control System users are conducted yearly. Training of crisis management relating to cyber security incident scenarios is also conducted at regular intervals on group level. Compliance training In Hydro, compliance awareness training is provided on a range of topics and consists of classroom-training, workshops, town hall meetings and various e-learning modules. The Code of Conduct states that all employees are expected to participate in required training. In 2024, training was provided on topics in anti-corruption, Hydro’s code of Conduct, competition law, data privacy, trade sanctions, human rights, integrity and market regulations. Companywide campaigns on the revised Code of Conduct and on data privacy were run 2024. Hydro also provides anti-corruption training to selected third parties, including suppliers. Compliance training is mainly carried out by Group Compliance and Group Legal, but other group functions and compliance professionals in the business areas also carry out compliance training. See Note G1.3 in appendix for metrics on compliance training and Note S1.4 in appendix for metrics on training activities completed by Hydro’s employees in 2024. There is a yearly compliance deep dive session for the board Audit Committee.

Management of relationships with suppliers Combating corruption and respecting human rights are integral to Hydro’s supplier requirements. See the Workers in the value chain chapter for information about Hydro’s supply chain and how the company screens its suppliers and business partners. Hydro tracks on-time payment statistics to prevent late payments to suppliers, with automatic dashboards to track performance on a daily basis for approx. 80 percent of Hydro’s units globally. Payment terms vary between categories of purchase, between regions, and by type of business. In 2024 for upstream units, the average payment term days were 33, while for downstream units it was 45 days. 92 percent of invoices were paid on time in line with agreed-upon terms.

Hydro’s employee engagement survey, Hydro Monitor, benchmarks employee perception of Hydro’s integrity culture. The score is measured against external benchmarks and is part of the KPIs of the CEO scorecard. In 2024, the integrity culture index was measured again and the scores showed a positive trend since 2020

Hydro can contribute to responsible business conduct through its regular engagement with suppliers, customers, and business partners. By being vocal about compliance and ESG topics, consistently acting with integrity, following ethical standards, and requiring counterparts to adhere to the same standards, Hydro can have a positive impact on business conduct more broadly.

Hydro also aims to have a positive impact on the fight against bribery, corruption, and human rights breaches through participation in partnerships and industry associations, and by actively engaging with public authorities and other stakeholders on these issues

Commitment to building a culture of integrity and trust

Hydro is committed to applying ethical business practices and compliance throughout its organization and supply chain. Hydro’s board approved Code of Conduct creates the foundation that supports its efforts to do the right things, and to always act with integrity throughout its global organization, wherever it operates and conducts business, on behalf of Hydro.

The European Green Deal is a roadmap on policies to achieve carbon neutrality in the EU by 2050 and includes policies to develop markets for low-carbon and circular products, in combination with stricter targets for emission reduction. Hydro sees interesting opportunities in both this roadmap, and the Critical Raw Materials Act and Net Zero Industry Act.

G1.1 Non-compliance with business conduct standards

G1.2Non-compliance with laws and regulations

The cases below are developments in 2024 related to lawsuits filed after the 2018 Alunorte Rainfall event by associations or public entities. For an overview of the Alunorte rainfall event, please see Hydro’s Annual Report 2018. On August 1, 2019: About 100 Individuals from Abaetetuba and Barcarena (State of Pará) filed a lawsuit against Alunorte. The case relates to the 2018 rainfall event and claims for compensation for alleged environmental damage. Currently there are 142 lawsuits filed by these individuals with the same allegations and requests. Of these 142 cases, in 102 cases the Court issued a decision to stay the cases until a final decision under another collective lawsuit related to the 2018 event related to the same facts and allegations is rendered. The remaining 40 cases are ongoing and pending a decision on the request to stay the cases by the lower Court. Other collective lawsuits were previously filed by Cainquiama and other associations in Brazil after the 2018 rainfall event alleging pollution from Alunorte, Albras and Paragominas, as well as impact on the communities located in Barcarena and surroundings. All these lawsuits are pending a decision at the lower court level. On February 5, 2021, Cainquiama and nine Brazilian individuals filed a lawsuit with the Rotterdam District Court, in the Netherlands, against Hydro’s Dutch entities and Norsk Hydro ASA (Hydro) seeking compensation for alleged financial damages and personal injuries suffered as a result of Alunorte and Albras activities in the municipality of Barcarena, Brazil. According to the plaintiffs, Hydro’s Dutch entities and Hydro are part of Alunorte and Albras’ corporate group and therefore should be liable for alleged environmental violations caused in the municipality of Barcarena throughout the years. An interim judgement on certain procedural aspects of the lawsuit was rendered by the Rotterdam court in May 2024, and the case will proceed to a hearing on the merits scheduled for March 2025. Other cases In 2019, Cainquiama filed a lawsuit claiming compensation for alleged delay in the implementation of the fuel switch project at Alunorte. In a court decision issued by the Pará lower court in May 2024, the companies were ordered to pay BRL 50 million in moral damage. The defending companies do not agree with the decision as the fuel switch was timely implemented and have appealed the decision. Following an overflow of storm water from the bauxite residue deposits at Alunorte in 2009, there are still legal issues pending. In 2012, more than 5,400 lawsuits related to the overflow were filed by individuals with the local court. Of the 5,400 lawsuits, only two are still ongoing pending final decision. All the other lawsuits were closed with favorable decision to Alunorte. Besides these cases, there are also two class actions filed by local associations under which unfavorable decisions were issued against Alunorte. The decisions understood that Alunorte was liable for damages and, therefore, compensation should be paid. One of the cases is pending a decision by the Court of Appeal and for the other case the Superior Court of Justice denied Alunorte’s appeal based on procedural rules. This case is pending an enforcement decision and in Alunorte’s view there are severe legal errors in the decision that must be addressed. In addition, a criminal lawsuit was also filed by the Federal Public Prosecutor Office (MPF) on this same event. In July 2024, the Federal lower Court understood that Alunorte was liable for alleged environmental damages and, therefore, should pay a penalty of BRL 100 million. Alunorte disagree with the decision and has appealed.

Hydro engages its major shareholder, the Norwegian state, on compliance and business conduct in quarterly meetings and engages local authorities, civil society, and industry associations and other companies regularly. Hydro also participates in the development of industry practices through engagement with organizations such as Transparency International Norway, the Maritime Anti-Corruption Network, the International Council on Mining and Metals (ICMM) and the Aluminium Stewardship Initiative (ASI).

Hydro engages its major shareholder, the Norwegian state, on compliance and business conduct in quarterly meetings and engages local authorities, civil society, and industry associations and other companies regularly. Hydro also participates in the development of industry practices through engagement with organizations such as Transparency International Norway, the Maritime Anti-Corruption Network, the International Council on Mining and Metals (ICMM) and the Aluminium Stewardship Initiative (ASI).