Annual Report 2025 ANNUAL SUSTAINABILITY REPORT

ANNUAL REPORT 2025

Contents

LETTER FROM THE EXECUTIVE CHAIRMAN 3

KEY FIGURES 5

SUSTAINABILITY REPORT 2025 6

INTRODUCTION 6

ABOUT THIS REPORT 6

ABOUT US 6

SUSTAINABLE DEVELOPMENT 8

SUSTAINABLE DEVELOPMENT GOALS 9

STAKEHOLDERS 10

STAKEHOLDER ENGAGEMENT 11

OUR VISION: CREATING THE VALUE CHAIN OF MARINE MINERALS 11

OUR PEOPLE 15

HEALTH AND SAFETY 16

GOVERNANCE 17

POLICY COMMITMENTS 20

MATERIAL TOPICS 22

ENVIRONMENT 23

EMISSIONS 23

WATER & EFFLUENTS 29

WASTE 34

BIODIVERSITY 39

GRI CONTENT INDEX 45

FINANCIAL STATEMENTS GREEN MINERALS AS 46

PROFIT AND LOSS STATEMENT 46

BALANCE SHEET 47

CASH FLOW 49

‌LETTER FROM THE EXECUTIVE CHAIRMAN

Dear Shareholders and Stakeholders,

2025 marked a reality check for the deep-sea minerals industry in Norway. Following the historic opening decision in January 2024, expectations were high. The December 2025 budget agreement between the minority government and several smaller parties, however, delayed the first licensing round and removed Norway from its position as a global frontrunner. The long-term potential remains unchanged, but the timeline has shifted.

Global Developments

While Norway paused, other jurisdictions advanced.

President Trump's April 2025 Executive Order to accelerate permitting for deep sea mining has positioned the United States as the leading regulatory force. The order reflects a strategic response to China's tightening control over critical minerals essential to NATO's defence capabilities. The US is now setting the pace for the industry.

Progress at the International Seabed Authority remains slow. Our extended CCZ MoU reflects this environment and preserves optionality. Indeed, following the slow progress at ISA, TMC is now pursuing its permitting pathway through the United States under the Deep Seabed Hard Mineral Resources Act (DSHMRA), with NOAA as the responsible authority for both exploration and commercial recovery applications.

Meanwhile, jurisdictions like China, Japan, India, Sweden a.o are steadily moving towards exploitation.

Norway: Political Uncertainty

The delay to the licensing round came despite an 80/20 parliamentary (Storting) vote to open up for deep sea minerals. The minority government's decision was the result of closed door negotiations, and this "shadow deal" may delay the first licensing round by up to four years. The government has already suffered several defeats in the Storting, and its ability to remain in office is uncertain.

In June, Parliament will vote on a proposal (representantforslag) from members of the Progress Party to restart the process. The situation may change quickly.

Green Minerals is therefore fully prepared:

• License application ready for rapid finalization

• World class consortium in place

• Technology concept completed

• Multi year financial runway secured

• Cost cutting program exceeding guidance

• Strategic optionality maintained

When Norway moves, we will be ready immediately.

Strategic Positioning and Capital Discipline

2025 required decisive action.

Runway and cost reductions. We preserved core competencies, reduced capacity, and extended our runway significantly, strengthening our competitive position. The effect of our cost cutting program will exceed previous guidance. Bitcoin Treasury Strategy. We adopted a Bitcoin Treasury Strategy to hedge long term monetary debasement and align treasury management with future capital requirements. The equity market closed for Bitcoin related issuance only days after our announcement, and we therefore raised only an insignificant amount before the window shut. We believe our long tail projects are particularly well suited for this strategy, and we will continue to explore financing opportunities pending market conditions, maintaining flexibility in a rapidly evolving macro financial environment. CCZ MoU. The extension of our CCZ MoU to 2027 secures continued access to one of the world's most prospective resource areas, with the license holding more than 200 million tonnes of identified wet nodules. Strategic review. In December, we initiated a strategic review to maximize shareholder value. We will update the market if and when there is material information to report. Technology and Partnerships

Our HEDSM concept - developed with globally leading partners - remains the only known production system tailored for the Norwegian Continental Shelf. The SMS/VMS co processing study confirmed the industrial viability of our approach. Our full value chain strategy continues to differentiate Green Minerals in an industry under development.

Looking Ahead

The global race for critical minerals is accelerating. Supply chains are being re engineered, and the need for responsible, low impact mineral production is clearer than ever.

Norway's pause reinforces the importance of discipline, optionality, and readiness. Green Minerals is positioned to act when the window opens - whether in Norway or internationally.

I extend my appreciation to all our stakeholders for their commitment during a year of significant change.

Sincerely,

Ståle Rodahl

Executive Chairman, Green Minerals AS

30 April 2026

‌KEY FIGURES

Oslo, 30 April 2026

The Board of Directors and CEO of Green Minerals AS

Ståle Rodahl

Chairman

Ståle Monstad

Chief Executive Officer

Maxime Lesage

Board Member

‌SUSTAINABILITY REPORT 2025

‌INTRODUCTION

Green Minerals AS presents its updated Sustainability Report 2025. This report reflects our commitment to transparency and provides information to our stakeholders on progress towards our sustainability strategy and goals.

‌ABOUT THIS REPORT

This report details our environmental, social, and governance (ESG) initiatives and performance for the fiscal year ending December 31, 2025. Published annually, it serves as a cornerstone of our commitment to transparency and continuous improvement.

Reporting Frameworks & Publication The report has been prepared in accordance with the Global Reporting Initiative (GRI) Standards. Our ESG strategy and goals are aligned with the United Nations Sustainable Development Goals (SDGs) and the Ten Principles of the UN Global Compact. The 2025 Sustainability Report will be published on April 30, 2026, concurrent with our Annual Report. Assurance Following a review by the Board of Directors, Green Minerals has decided to maintain its current position and will not seek external assurance for the 2025 report. We will re-evaluate this decision as part of our planning for the 2026 reporting cycle. Purpose & Stakeholder Engagement The primary purpose of this report is to:

• Clearly communicate our ESG strategy, progress, and challenges to all stakeholders.

• Strengthen our sustainability framework by integrating stakeholder feedback.

• Foster an open dialogue that invites contribution and identifies opportunities for meaningful improvement.

We welcome feedback on this report. Any identified errors or updates will be formally addressed in subsequent publications.

‌ABOUT US

Green Minerals AS is a publicly listed company on Euronext Growth, headquartered in Norway. As a global pure-play marine minerals company, we are actively securing exploration licenses in strategic locations both in Norway and internationally.

Our business model is built on a capital-light partnership strategy, collaborating with specialized partners across the entire value chain. Based on current data and projections, our development timeline is structured to begin exploration activities before 2030, advance toward initial production by 2032/2033, and ramp up to full-scale commercial operations by 2034/2035.

MISSION

To deliver minerals necessary to the Green Shift in a responsible and sustainable manner.

- Deep sea mining of minerals and rare earth elements (REE) is key to the green energy transition, eliminating the huge social costs in onshore mining while reducing the environmental footprint by more than 90%.

VISION

To be a pioneer in offshore mining and the leader in Marine Minerals on the Norwegian Continental Shelf.

VALUES

Our values are driven by a sense of urgency to act toward the meaningful changes our planet and people need.

BUSINESS STRATEGY

THE CHALLENGE

Many studies have confirmed the huge discrepancy between demand and supply of critical minerals essential for key clean energy technologies needed to meet the global climate ambitions. The onshore mining industry leaves an unsustainable environmental footprint to extract the marginal tonne of mineral, as ore grades decline, deforestation increases and waste per tonne ore soars. Moreover, terrestrial mining exhibits significant social costs. Because mineral supply is currently concentrated in a few countries, sourcing critical raw materials has also become a national security matter for the EU and the USA. The following questions arise: how can we mine the metals needed for the green energy transition in a sustainable manner and where should they come from?

OUR SOLUTION

70% of our planet is covered by oceans. The seafloor contains vast amounts of minerals needed for the green shift. Careful deep-sea mining of these raw materials can reduce the environmental footprint in mining up to 90%, while solving the challenges related to social costs and the strategic supply to the EU and USA. With an estimated resource potential of more than NOK 1000bn combined with the vast knowledge of deep-water operations acquired through decades of offshore activity and a high quality, stable regulatory framework, the Norwegian Continental Shelf is the most attractive area in the world to kickstart the deep-sea mining industry from.

Side-by-side comparison offshore vs onshore mining (impact of minerals to 1 bn electric cars)

‌SUSTAINABLE DEVELOPMENT

Sustainable development is integral to our mission. By providing the critical minerals needed for the green energy transition-responsibly and sustainably-we aim not only to meet today's needs but also to safeguard the ability of future generations to meet their own.

Our sustainability strategy is built on two complementary dimensions:

External Impact: We supply minerals that enable renewable energy technologies and electric vehicles, helping entire industries reduce their carbon footprint.

Internal Responsibility: We systematically assess and manage the impacts of our operations, striving to improve environmental performance, create lasting value for stakeholders and local communities, and foster a safe, equitable, and inclusive workplace.

Our Approach to ESG Management Our ESG framework provides the structure to control our processes and manage their impacts. Through consistent stakeholder engagement, we identify potential risks and negative impacts. Guided by international standards and our internal expertise, we then develop policies and procedures to prevent, mitigate, and manage them. This disciplined process allows us to turn challenges into opportunities and continuously refine our corporate sustainability strategy.

Commitment to Integration & Partnership We are committed to systematically embedding sustainability across our entire business, operations, and value chain. Our policies define how we conduct business responsibly, and we expect our partners to adhere to these same high standards-complying with regulations and acting with strong moral and ethical integrity. We are currently developing enhanced processes to formalize our expectations for partners, including commitments to ambitious climate targets and respect for human rights.

Science-Based Environmental Stewardship A core element of our strategy is proactive environmental assessment. Our Ultra project, launched in 2021, utilizes targeted research cruises to gather critical baseline data. For example, PhD research we sponsor on the alteration of extinct seafloor massive sulfides will provide vital insights into pre-extraction environmental conditions. This includes understanding potential releases of heavy metals, which is pivotal for shaping mitigation strategies ahead of our planned exploration phase, expected to commence before 2030.

‌SUSTAINABLE DEVELOPMENT GOALS

The 2030 Agenda for Sustainable Development, adopted by all United Nations Member States in 2015, outlines 17 Sustainable Development

Goals (SDGs) as a global blueprint for a more sustainable and inclusive future.

Businesses are essential to achieving these goals, given their profound impact on economies, societies, and the environment. As a responsible corporate actor, Green Minerals supports the ambitions of the SDGs and is committed to contributing across their breadth. We concentrate our efforts where our operations can generate the greatest positive impact.

Our priority contributions are aligned with the following SDGs:

Increasing the share of renewable energy through the sustainable supply of critical minerals.

Creating quality jobs and fostering sustainable economic growth in the regions where we operate.

Enabling the green energy transition and reducing waste generation through innovative, resource-efficient practices.

Promoting responsible resource management by minimizing waste generation across our operations and enabling the transition to a circular, green economy.

Reducing CO₂ emissions by advancing energy-efficient technologies and powering operations with renewable energy sources.

Protecting marine ecosystems and biodiversity by conducting rigorous environmental impact assessments for deep-sea activities and implementing effective prevention and mitigation measures.

Upholding the rule of law and human rights across our value chain, supported by clear governance tools and channels for reporting concerns.

‌STAKEHOLDERS

Our stakeholder framework is built on a foundation of active dialogue, even as we focus on R&D. Following an initial identification based on internal expertise, we conducted a thorough update in 2024 to ensure our mapping remains relevant. The resulting stakeholder groups are outlined in the table below.

‌STAKEHOLDER ENGAGEMENT

Stakeholder engagement is a core management process integral to our strategy and operations. We systematically identify, consult, and partner with our key stakeholders to:

• Understand Impact: Identify and assess our actual and potential positive and negative impacts on society and the environment.

• Inform Strategy: Integrate stakeholder insights into decision-making to better manage risk, drive innovation, and create sustainable value.

• Ensure Accountability: Maintain transparency through regular, clear communication about our performance, challenges, and strategic goals.

This ongoing dialogue ensures our business remains responsive, responsible, and aligned with the expectations of those who affect and are affected by our activities.

‌OUR VISION: CREATING THE VALUE CHAIN OF MARINE MINERALS

Green Minerals endeavours to develop the value chain of marine minerals. Figure 1 presents this value chain from the company's perspective.

Figure 1: The value chain of marine minerals

With reference to the numbering presented in Figure 1, the main segments of the marine minerals value chains are:

1. Exploration and Engineering:

   The goal of exploration and engineering is to discover marine mineral resources and establish mining plans to sustainably mine the metals necessary for final users to produce e.g., wind- turbines, solar panels, electrical vehicles (EV) or electrical grid components.

   The first step of exploration consists in identifying areas where marine minerals accumulation can be present i.e., prospective areas. When prospective areas have been identified, the company must engage with the authorities responsible for the stewardship of the prospective areas. In the context of marine minerals, the prospective areas can be found in:

   • Exclusive Economic Zone (EEZ) e.g., Japan, the Cook Islands or Papua-New Guinea

   • National jurisdiction e.g., the Mohn-Knipovitch Ridge as part of Norway's extended continental shelf.

   • International areas (also called "The Area") which are regulated by the International Seabed Authority (ISA) mandated by the United Nations (UN).

     Generally, the right to explore a prospective area is granted to the company through a license delivered by the competent authorities. After being granted an exploration license, the company will start exploration works at regional scale using large scale information such as bathymetry and sub-surface expression which will enable the geologists to concentrate their efforts on smaller targets. These smaller targets will then be sampled:

   • to confirm the presence of mineralisation of interest and,

   • to define the size of the mineral deposit and the quality of the ore contained within it.

     In parallel, environmental baseline surveys are performed to determine:

   • the environmental conditions at the deposit (local)

   • the characteristics of the ecosystem present at the deposit (local) and its relationships with other ecosystems (regional)

     The geological (resource) and environmental information will support the mining engineers in determining if the candidate resource can be mined in a sustainable manner through a cycle of studies which encompasses technical, environmental, and economic criteria. The result of these studies supports the mining plan and Environmental Mitigation and Monitoring Plan (EMMP) necessary for the company to obtain mining authorisation from the competent authorities. In parallel with the feasibility studies, the company engages with local communities to understand its impact on the local society and tackle grievance issues as early as possible.

     As part of the mining plan, the company defines in tight collaboration with suppliers and 3rd. party verification bodies:

     • the mining system,

     • the mining procedures and related logistic plan (ore transportation and offshore operations support),

     • the mineral processing route or flowsheet determining how the metal commodities will be produced,

     • the environmental procedures and equipment necessary for executing the EMMP.

2. Offshore Production:

   This part of the marine mineral value chain focuses on extracting mineral ore from the seafloor, transporting it to the surface, and transferring it to bulk carriers for transportation to land. The offshore production system i.e., the mining system, consists of:

   • The mining machines responsible for excavating the seabed,

   • The monitoring and support equipment, typically embodied by Remote Operated Vehicles (ROV),

   • The vertical transportation system e.g., a vertical riser pipe and the pumping system ensuring the convection of the excavated material to the surface,

   • The surface processing equipment responsible for receiving the excavated material when it reaches the surface, handling and storing the excavated material within the cargo hold of the mining vessel,

   • The offloading system equipment responsible for transporting the excavated material from the cargo hold of the mining vessel to the bulk carriers,

   • The mining vessel, the central asset which provides power and control to the equipment mentioned above.

     The company will engage in monitoring activities to ensure the mining activities are carried out within the criteria established within the EMMP. Prior to the start of the full-

     scale production of marine minerals at a given deposit, the company will execute some pilot mining to:

   • confirm the mining systems' performance as per the specifications established in the mining plan,

   • test the contingency and emergency procedures to ensure the adequacy of the Heath, Safety and Environmental (HSE) working procedures towards,

   • the safety of the working personnel,

   • the safety of the mining equipment,

   • the respect of the EMMP,

   • identify ways of improving operational procedures, HSE routines and the EMMP.

     In operation, the company will ensure that HSE is considered as the top priority through the presence of dedicated HSE advisors responsible for the management and the continuous improvement of HSE working procedures.

     The company currently intends to sub-contract the offshore production activity but will keep the overall responsibility for this activity to ensure the mining operations comply with the international and local regulations and the upcoming guidelines and best practices.

     The company will also ensure that maximum value is created for the local communities by:

   • engaging with local stakeholders such as fisheries,

   • behaving transparently towards environmental actors either public or NGOs,

   • promoting local training and hiring process.

3. Offshore logistics Offshore logistics ensure:

   The transport of mineral ore from the offshore worksite to a dedicated shore location The transport of personnel from/to the offshore worksite

   The delivery of fuel and equipment to the mining system

   The offshore logistics function is central to the value created by the mining system as it directly contributes to its performance.

   The company intends to sub-contract the logistics activities but will keep the overall responsibility for this activity to ensure the logistics operations comply with international and local regulations as well as upcoming guidelines and best practices.

   As for Offshore Production, the company will ensure that HSE is considered a top priority through constant monitoring of the selected suppliers' metrics through audits.

   The company will also ensure that maximum value is created for the local communities by preferably selecting local suppliers or suppliers that engage with the local communities themselves.

4. Onshore Production:

During Onshore Production, mineral ore, which has been excavated from the seabed by the mining system and transported to land by offshore logistics, is transformed

through mineral processing and refining into sellable metal commodities. Onshore Production is generally achieved in two steps as follows:

1. Processing of the delivered marine ore into a concentrate i.e. mineral processing

2. Refining of the concentrate into a sellable commodity i.e. smelting and refining

These two steps are generally performed by different facilities at different locations. Mineral processing, in the frame of land mining, can be performed at the mine site in a dedicated processing facility. Smelting and refining are generally subcontracted to smelting and refining facilities.

For mineral processing, the company considers the following options:

1. Entering a partnership with a mine complex including mineral processing facilities

2. Delivering the mineral ore to a partner processing plant

For mineral smelting and refining, the company intends to sell the concentrates produced by the mineral processing plant to a smelter which is de facto the company's final client.

When selecting its mining partner or mineral processing supplier, the company will consider the same ESG and HSE criteria as for Offshore Production and Offshore Logistics to ensure that the highest ESG criteria can be maintained through the value creation process of the company. In practical terms, the company will preferably select its partners/suppliers based on their ESG metrics but also look at the most sustainable options accounting for:

• Location of the mineral processing plant.

• to reduce the energy cost of transporting the ore from the Offshore Logistics harbor to the mineral processing plant.

• to ensure the lesser environmental footprint of the processing plant with regards to sensitive ecosystems, as a processing plant is a source of chemical waste which must be stored in the vicinity of the plant itself (tailing ponds or dams).

• The most attractive mineral processing route which minimises the energy footprint, the required chemicals, and the amount of mineral waste to be stored (tailings).

• The source of energy for the mineral processing plant itself by preferring facilities powered by renewable energies as opposed to e.g. coal-fired power plant.

‌OUR PEOPLE

At Green Minerals, there is a total of 5 professionals passionately engaged to contribute to the Green Shift. The company relies on their expertise and motivation to drive us towards our goals, until ultimately transforming into a truly circular economy business model.

DIVERSITY AND INCLUSION

At Green Minerals, we recognize that recent challenges have tested global commitments to Diversity, Equity, and Inclusion (DEI). Our conviction, however, is unwavering: a diverse and inclusive workforce is fundamental to our success and innovation. Respect for every individual, regardless of race, gender, sexual orientation, disability, or background, is embedded in our culture.

Our current team represents three distinct nationalities from across the globe, bringing the invaluable benefits of multicultural perspectives to our work. As we grow in this dynamic industry, we are committed to proactive measures that enhance diversity at all levels. This includes a specific pledge to prioritize gender balance in our recruitment and advancement practices, guided by Norway's progressive Equality and Anti-Discrimination Act, which forms the backbone of our internal policies. We are continuously evaluating and strengthening our approach to ensure Green Minerals is a place where talent from all backgrounds can thrive.

FLEXIBILITY AND WELL-BEING AT WORK

The COVID-19 pandemic fundamentally altered global work paradigms, demonstrating that operational flexibility is both viable and valuable. At Green Minerals, we have institutionalized flexible work arrangements, including remote work and adaptable hours, as a strategic component of our operational model. These practices are designed to enhance productivity, support employee well-being, and cultivate a sustainable work-life balance, thereby contributing to higher engagement, morale, and retention.

Our objective is to maintain a supportive environment where employees feel valued and empowered to excel both professionally and personally. By intentionally designing a workplace that prioritizes well-being, we foster a positive culture that drives performance and long-term organizational resilience.

‌HEALTH AND SAFETY

OCCUPATIONAL HEALTH AND SAFETY

The company is currently progressing to establish its occupational health and safety management system as described in Disclosure 403-1. The major part of the work carried out by the company is anticipated as performed by suppliers, the company will establish procedures for reviewing the supplier's occupational health and safety management system and will allocate internal resources for monitoring that suppliers' HSE procedures are followed when work is performed on the company's worksite e.g. within an offshore license belonging to the company or in the frame of a project owned by the company. The company will also disclose the information required by the:

• Disclosure 403-2 Hazard identification, risk assessment, and incident investigation i.e., documents pertaining to the HSE section of the company's BMS

• Disclosure 403-3 Occupational health services i.e., the job descriptions of HSE related personnel as part of the company's BMS

• Disclosure 403-4 Worker participation, consultation, and communication on occupational health and safety i.e., reporting the processes pertaining to this disclosure as described in the company's and suppliers' respective BMS

• Disclosure 403-5 Worker training on occupational health and safety i.e., reporting the description of any occupational health and safety training provided to workers, including generic training as well as training on specific work-related hazards, hazardous activities, or hazardous situations.

• Disclosure 403-6 Promotion of worker health i.e.

  • an explanation of how the organization facilitates workers' access to non-occupational medical and healthcare services, and the scope of access provided especially for worksite where public medical and healthcare services are not available or not easily accessible.

  • a description of any voluntary health promotion services and programs offered to workers to address major non-work-related health risks, including the specific health risks addressed, and how the organization facilitates workers' access to these services and programs.

• Disclosure 403-9 Work-related injuries based on the company's HSE reporting which is common practice in industries such as Oil and Gas. The company commits to a Zero- target for work-related injuries.

• Disclosure 403-10 Work-related ill health based on the company's HSE reporting which is common practice in industries such as Oil and Gas. The company commits to a Zero- target for work-related illness.

  PROPOSED MONITORING SYSTEM

  The company will ensure the information concerning its HSE performance is available by implementing the necessary procedures within its Business Management System.

  ASPIRATIONAL GOALS

  The company has a zero-injury tolerance policy.

  ‌GOVERNANCE

  BOARD OF DIRECTORS

  Green Minerals' Board of Directors is diverse in age, experiences, and field of expertise, with high knowledge in corporate management, economy, and geoscience, fulfilling the strategy at this phase of the company. All Board members are involved in matters that are significant to the company's financing, operational, ESG performance and long-term sustainable development strategies.

  NOMINATION

  The members of the Board are proposed by the shareholders and are appointed in the Annual General Meeting.

  CHAIR OF THE BOARD

  The Executive Chairman of the Board of Green Minerals holds a unique position, actively participating in certain operational activities beyond the typical board-level

  interaction with management. This arrangement has been established to strengthen the management team in matters of a strategic and tactical nature and to create closer ties between management and the Board. Potential conflicts of interest are managed through frequent Board meetings by telephone/Teams, as well as regular interaction with the CEO and CFO.

  OVERSEEING THE MANAGEMENT OF IMPACTS AND DELEGATION OF RESPONSIBILITIES

  The Board of Directors has been directly involved in developing and approving the Company's vision, values, mission statement, strategies, policies, and goals related to sustainable development. These documents and objectives are reviewed by the Board every three years. Any proposed changes by senior management are subject to Board approval.

  Information received by the Company from relevant stakeholders through established communication channels, including information concerning actual or potential impacts that may affect sustainable value creation in financial, social, or environmental dimensions, is reported to the Board. Further information on stakeholder engagement is provided in the section "Stakeholder Engagement" on page 09. The Board also maintains direct contact with shareholders through the Investors section of Green Minerals' website.

  Actual negative impacts are presented to the Board together with an overview prepared by the management team, including proposed mitigation actions, expected outcomes, and relevant deadlines. This enables the Board to discuss the matter, approve an appropriate strategic response, and monitor follow-up and results.

  Responsibility for managing impacts is assessed and assigned by the Board on a case-by-case basis.

  THE BOARD AND THE SUSTAINABILITY REPORTING PROCESS

  The role of the highest governance body in sustainability reporting is structured as follows:

  The first step is for the Board to approve the material topics that were identified as the most relevant impacts through stakeholder engagement and the ones proposed by the management team.

  
  
  

  Upon the availability of all data pertinent to the reporting period, the sustainability report team assumes responsibility for gathering this information, which includes the results from communication with stakeholders, such as supplier ESG assessment, for instance. Subsequently, the sustainability report team drafts and submits the report to the Board for approval.

  CONFLICT OF INTEREST

  If a director has an interest in a case under investigation by the Board, the director should immediately declare the interest and be considered inapt to attend meetings and prevented from voting or exercising any influence on the matter.

  Other information about conflicts of interest is informed in our Code of Conduct available on our website, https://www.greenminerals.no.

  COMMUNICATION OF CRITICAL CONCERNS

  Green Minerals encourages everyone who wishes to make a communication of critical concerns to use the email address ir@greenminerals.no A member of the highest governance body is part of the process of monitoring anonymous reporting lines to help identify concerns or issues from formal grievances, which gives more credibility to the process. The whistle-blower e-mail is now our only available tool for raising any type of concern anonymously, due consideration on the current activities of the company.

  No critical concerns were communicated during the reporting period.

  Following the Guidance grievance mechanism from ICMM, Green Minerals focus in making the mechanism accessible and predictable, so we describe our standard process through the following flowchart (the process might suffer alterations depending on the severity of each case):

  
  
  

  COLLECTIVE KNOWLEDGE OF THE HIGHEST GOVERNANCE BODY

  The Board of Directors has played an integral role in crafting the Company's long-term vision and strategy for sustainable development. The Board actively participates in reviewing this strategy to ensure alignment with the organization's overall objectives and priorities.

  Furthermore, the Board maintains consistent and transparent communication channels with management, employees, investors, and business partners regarding sustainability matters. They remain attuned to concerns raised by various stakeholders.

  In its commitment to enhancing collective understanding, the Company has identified ongoing or forthcoming measures including:

  • Enhancing board diversity,

  • Conducting training sessions and workshops,

  • Nurturing a culture of continual learning and adaptation. REMUNERATION POLICIES

    Green Minerals aims to offer a level of remuneration that is fair, and motivates, attracts, and retains members of the Board and employees in accordance with the financial situation of the company, ensuring that remuneration supports and drives its strategic priorities.

    The remuneration of the Board members is decided by the shareholders at the Annual General Meeting. The Board members do not receive variable payments.

    The Board appoints the CEO and approves his/her remuneration and is further responsible for ensuring that management remuneration principles are aligned with the Company's objectives and shareholder interest.

    Remuneration for the Chief Executive Officer (CEO) consists of:

  • annual base salary (ABS)

  • long term incentives (Employee ownership scheme)

‌POLICY COMMITMENTS

Green Minerals commits to sustaining responsible business conduct that respects people, society, and the environment. Our Human Rights policy and our Code of Conduct guide our activities and were written under the following authoritative intergovernmental instruments: Guiding Principles on Business and Human Rights, Due Diligence Guidance for Responsible Business Conduct, The International Bill of Human Rights, International Labour Organisation Declaration on Fundamental Principles and Rights at Work, United Nations (UN), Rio Declaration on Environment and Development, 1992.

Following the 5-step Framework for Risk-Based Due Diligence from The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, the commitments stipulate a process for due diligence. The document is reviewed by top management and approved by the Board of Directors.

Being a lean and efficient organization means that it is vital for Green Minerals to partner with leading and upright companies. To ensure a thorough due diligence process, the company has developed the flowchart. below. The initial step is an ESG/HQS partners assessment, to get familiar with the partner´s ESG/HQS programs, commitments to internationally recognised standards, certifications, potential or actual negative impacts, and actions for mitigation or prevention. When negative impacts are identified or further information is needed, the process stipulates an audit. This assessment aims to identify early red flags and work closely with the partner on mitigation/remediation plans.

This Sustainability report is evidence of the company's application of the precautionary principle. Before the start of the exploration or production phases, the company is working to identify any potential environmental, social, and financial risks, and studying the opportunities for prevention or mitigation of the potential negative impacts.

Green Minerals' policy commitments for responsible business stipulate respecting human rights and advocate the belief that all human beings must be treated with dignity, equity, and empathy. Human Rights policy and the Code of Conduct are available to all our employees and stakeholders on our website https://www.greenminerals.no. Employees are required to read and sign all the policies and procedures. The company is also developing procedures to ensure that all parties across our value chain demonstrate their commitment to complying with applicable laws and respecting the authoritative intergovernmental instruments referred to in this report.

EMBEDDING POLICY COMMITMENTS

Once the commitments are approved by the Board, the management team makes sure that all employees have read and understood the commitments. They are a support for our processes and relationships with our stakeholders.

PROCESSES TO REMEDIATE NEGATIVE IMPACTS

Green Minerals is committed to providing for or cooperating in the remediation of negative impacts that the organization identifies it has caused or contributed to. The company works to identify potential negative impacts in its future operations and projects and how to address grievances. Green Minerals will always act by law, with honesty and responsibility to account for any direct or indirect negative impact and its consequences.

MECHANISMS FOR SEEKING ADVICE AND RAISING CONCERNS

Anyone has the opportunity to seek advice or express concerns by engaging with our management team. For employees specifically, we encourage them to communicate with their line manager. Should anyone prefer to remain anonymous for any reason, they can submit their concerns via our website. Our whistle-blower procedure applies to anyone wishing to report a violation. Employees can access this procedure through our intranet and are required to confirm their comprehension of it.

Suppliers, subcontractors, and third-party personnel are briefed on our reporting procedure, which is also publicly available on the company's website.

All employees and business affiliates are obligated to report any suspected material violations of laws, company policies, or questionable business practices involving senior management or other employees.

Human resources and a member of the highest governance body oversee the anonymous reporting channels, analyze formal grievances, and promptly inform the CEO of reported violations. An internal investigative committee, guided by company policies, will investigate concerns raised, potentially enlisting external legal counsel or other resources deemed necessary for a thorough inquiry. Investigation findings are promptly relayed to the CEO and/or the Board for decision-making aligned with legal and company policy.

For projects with potential impacts on local communities or vulnerable groups, the company pledges to enhance transparency and accessibility by continuously promoting the reporting mechanism and maintaining open communication with community representatives. Should serious impacts arise, an unbiased third party, unaffiliated with the community, vulnerable groups, or the industry, will be invited to participate in the investigative committee.

‌MATERIAL TOPICS

Materiality assessment is key in the ESG program, as it guides the company to identify the most relevant economic, environmental, and social impacts in relation to the stakeholders' interests. Hence engagement with our stakeholders is vital to prioritize impacts and allocate resources where they are most needed.

The material topics were determined based on a general concern about the potential negative impacts from deep sea mining on the environment and specifically pointed out by internal expertise after assessment of significance of the impacts. These concerns have been expressed by governments, academia, non-governmental organizations, financial institutions, and shareholders through different channels: internet, traditional media, and meetings.

After the assessment, the material topics were approved by the Board of Directors.

‌ENVIRONMENT EMISSIONS‌

Regarding the value chain illustrated on page 11, the company expects the following emissions:

• Exploration: burning of fossil fuels as marine fuel for exploration vessel

• Offshore Production:

  • burning of fossil fuels as marine fuel necessary for:

    • the mining production vessel and various subsystems ensure excavation, vertical transport, and surface ore processing.

    • the bulk carriers ensure the transport of ore from the offshore mining site to a shore facility.

  • burning of fossil fuels if the shore facility is not the delivery point of the ore to the final client, the transport of ore from a shore facility to a mineral processing plant.

• Onshore Production:

  • Electricity production/consumption for:

    • Crushing and characterization units transforming the ore into a feed.

    • Floatation or Separation units to beneficiate the metals present in the feed into a concentrate.

    • Transport of produced concentrate to a refining facility.

      At present, the company does not have any plan for owning the above-mentioned activities following its CAPEX light strategy. Therefore, all emissions of significant impact are classified as Scope 2.

      The company intends to comply with IMO regulations i.e. MARPOL. Especially for emissions, MARPOL Annex VI is relevant. For any new ship, whose tonnage is higher than 400 gross tonnages, the following applies:

• For new ships, the Energy Efficiency Design Index (EEDI) has been developed as a technical measure. The objective of the EEDI is to ensure that ships are designed and constructed to be increasingly more energy efficient.

• The principal operational measure is the Ship Energy Efficiency Management Plan (SEEMP). Every ship of 400 gross tonnage and above is required to have a SEEMP. It is an on-board management tool and has two parts:

  • The first part sets out the requirements for energy efficiency management.

  • The second part is a requirement for monitoring and reporting the ship's annual fuel consumption.

Meeting both the EEDI and SEEMP criteria will allow the ship to be granted an International Energy Efficiency Certificate or IEEC. The company will favour working with marine assets which have been granted an IEEC when this option is available.

The following yearly previsions have been estimated for future operations: EXPLORATION

As a base case the company foresees utilising exploration vessels for a combined duration of 93 days per year i.e., 3 campaigns of 1 month as described in Table 1

Table 1: Expected vessel days for Exploration activities.

Exploration vessels are assumed to be similar to the ones used for oceanographic and seismic surveys. A major part of the energy consumption of these vessels relates to propulsion during transit and station keeping while at sea.

Based on the ESG reporting from Seabird Exploration, a seismic service provider and partner of Green Minerals, predicted fuel consumptions and associated emissions have been calculated and are reported in Table 2 based on typical fuel consumption and emission factors presented in Table 3:

Per campaign

Days

Fuel consumption (t)

CO2 Emission NOx Emission

Sox Emission (t)

(t)

(t)

Table 2: Expected emissions for Exploration activities.

Activity

Daily fuel consumption (t)

Table 3: Typical fuel consumptions and associated emissions for exploration vessels

The company highlights the fact that marine fuel space evolves rapidly. The company will challenge and encourage its future service providers to use renewable-based marine fuels e.g., green ammonia or biofuel to reduce the CO2 emission generated by exploration activities. The company is also considering other exploration platforms such as Unmanned Surface Vehicles (USV) which have by design reduced fuel consumption requirements and thus reduced CO2 emissions.

OFFSHORE PRODUCTION

The company has started a conceptual study of its mining system thus the following information is given and may change in the future. Existing systems are experimental, and little information is publicly available. The following figures have been established based on publicly available figures and the company's foreseen operations. The Offshore Production system consists of three main sub-parts:

• The Mining Supporting Vessel: supporting the excavation, vertical transport, and essential processing function e.g., slurry dewatering,

• The Ore Transport Shuttles: transferring the ore from the offshore mining site to a shore facility,

• The Personnel Transport Vessel: transferring personnel to/from the Mining Supporting Vessel.

  Based assumption:

• Mining Vessel will be used 365 days per year,

• Ore Transport Shuttles: one rotation every week, 96 hours of transit in and out resulting in a use of 208 days per year,

• Personnel Transport Vessel: one rotation every two weeks, 96 hours of transit in and out resulting in a use of 104 days per year.

1. Mining Support Vessel

   The energy required for propulsion and the supply of mining equipment will be ensured by the installed marine engines and association generators. The company assumes an onboard installed power of 40MW based on a previously proposed concept by others associated with a utilisation rate of 60%.

   The anticipated fuel consumption of such a vessel can be estimated using the Specific Fuel Oil Consumption (SFOC) of installed marine engines. In the absence of an established concept, the company considered the SFOC of currently available marine engines and assumed a typical value of 175g/kWh.

   The resulting anticipated emissions for the Mining Support Vessel are presented in Table 4.

   Mining Vessel characteristic Value

Installed Capacity 40MW

Utilisation rate 60%

SFOC 175g/kWh

Fuel consumption 36,792t/year

CO2 3.20

NOx 0.04

SOx 0.0005

CO2 117,845t/year

NOx 1,389t/year

SOx 20t/year

Table 4: Expected emissions for offshore production Mining Vessel

1. Ore Transport Shuttles

   Expecting an annual ore production of 1.5Mtpa, assimilating the ore shuttles to bulk carriers of type Handy size (DWT<35,000T) and using the Green Voyage spreadsheet provided by IMO1, the estimated emissions for the ore transport shuttles for offshore production are presented in Table 5.

   Ore Transport Shuttle (Bulk Carrier

   DWT<35,000T)

   Value

   Fuel consumption 3,528.3t/year

   Emission Type Emission factor

Yearly utilisation rate 57%

CO2 3.20

NOx 0.04

Sox 0.0005

CO2 6,436t/year

NOx 80t/year

Sox 1t/year

Table 5: Expected emissions for offshore production - Ore Transport Shuttles

1. Personnel Transport Vessel

   The company assumes that the Personnel Transport Vessel will be similar to the offshore supply and service vessels operating in the oil & gas and the wind offshore industries. The electrification of these vessels is underway and current hybrid vessels have reported emission cuts in the range of 20% compared to vessels operating only using fossil fuels23.

   Using the Green Voyage spreadsheet provided by IMO1, and the emission reduction provided by the hybrid power system of the current and future generations' vessel, future emissions for the Personnel Transport Vessel have been estimated and are reported in Table 6.

   ‌1 https://greenvoyage2050.imo.org/fleet-and-co2-calculator/

   ‌2 https://www.equinor.com/en/magazine/battery-hybrid-supply-ship.html

   ‌3 https://www.danfoss.com/en/about-danfoss/news/dps/new-hybrid-vessels-deliver-impressive-20-emission- savings-and-flexible-transport-to-the-wind-farm-industry/

   Personnel Transport Vessel (similar to Offshore Service Vessels)

   Value

   Fuel consumption 1,362.3t/year

   Yearly utilisation rate 28%

   Hybrid Vessel emission reduction factor	20%
   Emission Type	Emission factor
   CO2	3.20
   NOx	0.04
   Sox	0.0005

   Predicted Emissions Value

CO2 244t/year

NOx 3t/year

SOx 0.04t/year

Table 6: Expected emissions for offshore production - Personnel Transfer Vessel

ONSHORE PRODUCTION

In the absence of a defined processing route, the company has made assumptions for the CO2 emissions related to copper ore processing based on public information4. The CO2 emissions from various copper processing plants in the world have been estimated at a 2.6t CO2/ t Cu produced, with a minimum value of 1t CO2/ t Cu produced and maximum 9t CO2/ t Cu produced. CO2 emissions tend to be lower if the ore quality (grade) increases and when renewable energies are available to the mineral processing plants. Because the company assumes an ore grade of 5% copper (7 times the ore grade of traditional copper deposits on land) and a mineral processing in Scandinavia where the energy has a relative low CO2 footprint, the company assumed a carbon intensity of 1t CO2/t Cu produced. The company's base case accounts for the yearly production of 81,000t Cu which would generate 81,000t CO2. The CO2 emissions related to onshore production are repeated in Table 7.

Ore processed 1.5Mtpa

Copper grade 6% wt.

Copper production 81,000t

CO2 intensity 1t/t Cu produced

CO2 81,000t/year

‌4 https://www.mining.com/pathways-towards-zero-emission-copper-mines-report/#:~:text=Based%20on%20a%20literature%20review,extraction%20methodology%2C%20and%20ore%20grades

Table 7: Expected emissions for Onshore Production

PROPOSED MONITORING SYSTEM

For vessels and as performed in previous sections, the emissions can be calculated from the amount of fuel consumed. The company will monitor the vessel-related emissions by collecting the Daily Progress Reports (DPRs) which record the daily use of fuels for every vessel under its direct or indirect control.

In addition, the company will comply with IMO regulations which include the reporting of the fuel consumption data to the Marine Environment Protection Committee (MPEC) as part of each vessel's SEEMP5.

ASPIRATIONAL GOALS

The company believes that the mineral processing activities for its products will be similar to those encountered in the Mining Sector. As such the company recognises the rapid pace of change within this industry regarding energy consumption and related emissions. The company believes carbon neutrality can be

achieved by 2050 at the latest (https://www.reuters.com/business/sustainable-business/worlds-largest-miners-pledge-net- zero- carbon-emissions-by-2050-2021-10-05/).

The company intends to enter a partnership with a mineral processing facility which does not allow the company to directly influence the design of the installation and thus energy consumption by design. Nevertheless, the company will use the intensity of emissions as an evaluation metric for the partner selection process.

‌WATER & EFFLUENTS

WATER AND THE COMPANY`S BUSINESS

Exploration does not involve significant use of water as most of the water consumed and discharged during this activity is related to water consumption for sustaining life

‌5 https://wwwcdn.imo.org/localresources/en/OurWork/Environment/Documents/278(70).pdf

at sea (personnel i.e., freshwater) and the cooling of marine engines (seawater). Similarly for Offshore Production, the intended mining system relies on using on-site seawater for both transporting the excavated material from the seabed to the mining vessel and for the cooling of marine engines. Freshwater is used for human consumption at sea and comes either from land (stored in the freshwater tank of the vessel) or produced at sea through desalination process. Water consumption for both Exploration and Offshore Production are expected to be regulated according to IMO rules.

The main water consumer of the company's activities is the Onshore Production where ore mined offshore is processed from a raw material to a metal concentrate that is then sold for further smelting and refining. At present, the company intends to perform the Onshore Production through a partnership with a concentration plant either independently or through an existing mining operation.

Based on existing research activities and the opinion of experts, the company assumes that the SMS ore can be processed using floatation. A summary of the floatation process is given in Figure 2.

Figure 2: Floatation process. Thick blue arrows represent the input of fresh water. The dashed blue lines represent the water being reclaimed during various stages of the process for re-use. Dashed orange arrows represent water losses due to evaporation and seepage/leakage as well as accidental discharge of residual products.

The process of floatation involves the following steps:

1. Crushing and grinding: the ore delivered by the Offshore Production is crushed and added to water to produce a pulp (crushed ore slurry).

2. Floatation: the pulp is injected in a cell together with chemical products; air bubbles combined with agitation float the minerals of interest as a froth thus separating them from non-valuable minerals (tailings).

3. Thickening and Filtration: the froth produced during floatation is dewatered and filtered to produce a concentrate (residual moisture around 10%) - water is reclaimed and re- injected in the upstream part of the ore mineral processing chain.

4. Tailing circuit: tailings produced during floatation are filtered and dewatered before disposal at the Tailing Storage Facility - water is reclaimed and re-injected in the upstream part of the ore mineral processing chain.

5. Tailing Storage Facility (TSF): tailings are finally disposed in a dam and subject to sedimentation - overflowing water is reclaimed and re-injected in the upstream part of the ore mineral processing chain.

Ideally water can be considered as a closed loop in such a mineral process, but evaporation losses are inevitable and are highly dependent on the process itself which can vary with the ore composition itself, the desired degree of mineral recovery, and the site of the processing plant itself. In addition, some water may be lost due to accidental leakage and seepage at the TSF despite its water-retaining property as per design.

Fresh water input into the mineral processing activities can be achieved by pumping water from rivers, water catchment or being produced out of seawater through reverse osmosis (desalination). The choice of fresh water source depends on the location of the mineral processing plant and can be a source of conflict with local communities and biodiversity.

ONSHORE PRODUCTION

In the absence of an existing mining study or existing operations, the company used some publicly available information to establish some predictions of its water consumption. According to USGS figures for a copper mineral processing plant which specifications are reproduced in Table 8 along with its expected water balance reproduced in Table 9.

Daily plant capacity 50,000t

Operating days per year 350

Annual plant ore capacity 17.5Mt

Copper ore feed grade 0.5%

Annual concentrate production 292,000t Final concentrate moisture content 10%

Final concentrate copper grade 27%

Tailing deposited in the TSF per year 17.2Mt

Solids contained in tailings slurry 50%

Table 8: Mineral processing plant specification assumed for this document (USGS, 2012)

Type of water use or

water loss

Estimated total annual

water requirements

Estimated percentage of total annual water requirement

Estimated water losses

Total annual process plant water requirement

Floatation circuit

process water

requirement

Water contained in copper concentrate

Water contained in tailings slurry and deposited in the TSF

Water entrained in the TSF

Water deposited in the TSF attributed to evaporative losses

Water deposited in the TSF attributed to seepage losses

Water losses attributed to dust control, evaporative losses from plant flotation cells, and thickeners.

Water reclaimed from the TSF for process water

Water acquired from other sources for process water (e.g., water catchment)

Total annual makeup water requirement

Table 9: Water balance for the mineral processing plant assumed in this document.

To evaluate the water consumption and losses pertaining to the company's activities, the following information is considered:

• Annual ore delivery to the processing plant: 1.5Mt

• Copper grade average: 6%

  Mineral processing requires a steady input and thus the ore delivered by the company will have to be blended with the other ore treated by the processing plant. It is also possible that the higher- grade ore delivered by the company leads towards an increase of the design ore feed grade (0.5% in the assumed case). Company assumes that the water consumption to treat its ore should be equivalent i.e., 2.5t water per tonne of ore:

• Annual process water requirement: 3.75Mt which represents 8.5% of the process plant annual requirements,

• Annual freshwater requirements: 0.94Mt,

• Annual water disposal (seepage in the TSF): 0.04Mt.

  In the company's plan only 20% of the annual ore production capacity of the mining system is used in the first two years of the project. Accordingly, the figures for water consumption and disposal should be reduced for 2026 and 2027. A summary of the forecast water consumption and disposal is provided in Table 10.

  Description	Year 2026/2027	Year 2028 onward
  Annual freshwater requirements	0.19Mt	0.94Mt
  Annual water disposal	0.008Mt	0.04Mt

  Table 10: Expected annual freshwater consumption and water disposal.

  PROPOSED MONITORING SYSTEM

  As the company intends to enter into a partnership with a concentration plant, the company will rely on the reporting from the concentration plant operator. Nevertheless, and as a minimum, the company expects the concentration plant operator to provide operational data to the company to report results as per GRI 303's requirements. The company will also require from its mineral processing partner regular reporting, monthly as a minimum, to allow for the early identification of deviation underlining possible technical issues that must be diligently dealt with.

  ASPIRATIONAL GOALS

  The company will ensure through its evaluation of partners that mining processing plants are selected based on:

• An efficient water reclaiming process throughout the mineral processing.

• A sustainable freshwater source i.e., from a replenishable catchment and not conflicting with local populations and biodiversity.

• A minimal amount of unwanted disposal through an efficient TSF design and a satisfactory maintenance program of the mineral processing plant.

• A comprehensive quality system where relevant data is collected and systematically analysed for remediation and improvement purposes.

  In addition to this, and apart from inevitable water loss due to evaporation, the company commits to a zero-target for water disposal due to seepage. This target is also linked to the fact that water that has been used for processing is not readily disposable in the environment as it can be contaminated with chemical and toxic elements.

  ‌WASTE

  WASTE AND THE COMPANY´S BUSINESS

  Exploration does not involve significant production of waste as it entails only marine operations and the processing of negligeable amount of minerals coming from sampling activities. Waste produced during Exploration is expected to be regulated and reported according to IMO rules.

  As part of Offshore Production, the production of waste can be separated into two classes:

• Waste produced as part of vessel utilisation which is regulated and reported according to IMO rules.

• Waste produced as part of the extraction of seabed material which is considered the most significant part of the waste produced during Offshore Production. This document will focus on waste production for this activity.

As part of Onshore Production, waste is produced by processing the mineral ore from Offshore Production into a concentrate. This waste is referred to as tailings, see Section

3.2. As advised in GRI-306, the reporting of waste should focus on solid waste unless effluents must be integrated within the waste reporting due to either regulatory or industry specific reasons. Tailings include a large amount of water, but this water is partially lost due to evaporation and partially re-used as process water. In the absence of an available process flowsheet describing the type and amount of chemical necessary for the floatation process and given that any unwanted loss of process water will be reported in Section 3.2, this section of the document will only report waste as solid material (thus excluding the moisture weight).

A summary of the waste produced by the company's activities is presented in Figure 3.

Figure 3: Waste produced by the company's activities. Waste flows are indicated by thick red lines. The activities which are under the control of the company or under the control of its direct partner are delimited by the dashed red box.

OFFSHORE PRODUCTION

At the start of the mining operation, some sediments and non-economical material may have to be displaced from the top of the deposit. This material is referred to as overburden. In the absence of a mining study for a real case deposit, the company

has considered provisional figures from a similar mining operation (Solwara 1, Nautilus Minerals) where the average overburden was estimated to roughly 10% of the deposit tonnage. In mining operations, some parts of the mineral deposit are excavated but will not be processed because their metal tenor is below an economical threshold known as the cut-off grade. The process of determining the cut-off grade of a mine is complex and requires a dedicated mining study per site. Again, in the absence of a dedicated mining study, the company assumes that the value from previous mining studies for a similar study is relevant. In the case of Solwara 1, all the excavated material apart from the overburden was qualified as ore i.e., exceeding the defined cut-off grade. A metric for estimating the ratio of produced mining waste and produced ore is the stripping ratio (SR) defined as such:

During pilot production, only 20% of the annual production is available. During full-scale production, 100% of the annual production is available. Using the formulas described above and an annual production rate of 1.5 million tonnes, the projected waste production is presented in Table 11.

Description

Pilot production Full scale

production

Annual waste

production (Mining) 30,000t 150,000t

Table 11: Expected waste production during Offshore Production

The waste handling strategy of the company is not yet defined as the design of the mining system is not complete and no mining plan has been established for a real project. The company projects two options for the handling of waste:

1. Land storage: all the excavated material is lifted to the mining vessel and further transported to land where the ore and waste can be sorted. In this option, the mining waste is stored in a landfill under the responsibility of the processing plant owner.

2. Subsea storage (Seabed landfill):

   1. All the excavated material is lifted to the mining vessel, then waste and ore are sorted using characterisation techniques. The waste is then disposed of to the seabed through the vertical transportation system.

   2. Waste and ore are sorted at the seabed and only the ore is lifted to the mining vessel. The waste is then stored on the seabed.

These options offer trade-offs in terms of technical complexity, operational efficiency, and amount of impact on terrestrial land mobilised for landfill:

Option 1 - Land Storage: technically easier as characterisation is performed on land, which is an already well-established technique but has the largest impact in terms of terrestrial area mobilisation. In addition, storing mining waste from SMS deposits can lead to environmental challenges such as Acid Mine Drainage (AMD) and thus requires mitigation measure for draining and treating the effluents from the waste dump.

Option 2 - Subsea storage: no-impact in terms of terrestrial area mobilisation but is the most technically challenging as underwater characterisation techniques are not well- established. This option may also provide a less significant environmental impact as seawater lessens the potential of AMD.

ONSHORE PRODUCTION

As explained in the Water and Effluents Section, the valuable minerals are extracted from the ore produced in Offshore Production to produce a concentrate. This process generates waste as tailings. Reminding the assumptions of this section, only solid waste is considered as waste. The following describes how the tailings production has been calculated for this document:

• The annual ore production from Offshore Production,

  - The grade of the ore,

  - The quantity of copper in the ore, = ∗

• The recovery factor i.e., the quantity of copper recovered at the end of mineral processing,

  - The quantity of copper recovered from mineral processing, = ∗

  - The grade of the produced concentrate,

• The quantity of concentrate produced

  
  
  

- The quantity of tailings produced, = −

The assumptions taken regarding the fixed values and the resulting tailings projections are summarized in table 12.

For pilot production, only 20% of nominal ore production has been accounted for.

Table 12: Waste generated during Onshore Production (tailings)

The storage of tailings, as described in the Water & Effluents Section, is performed by disposal into the TSF. The TSF is considered a landfill according to the GRI classification.

SMELTING AND REFINING FROM PILOT PRODUCTION ONWARDS

Even though not controlled by the company, it is possible to estimate the amount of indirect waste generated by the use of the company's product, the concentrate produced during Onshore Production, and data from literature. According to generic data, the waste produced during the smelting process can contain 0.5 to 0.7% of copper and the amount of solid waste per tonne of produced copper does not exceed 3t. The following calculation has been considered for this section:

Using the figures presented on page 30, and the assumptions given in this section, a provisional estimation of future waste production during Smelting and Refining is given in Table 13.

Waste per tonne of copper 3 3

producted at smelter

Smelter waste (Slag) 45,198t 225,990t

Table 13: Waste generated during Smelting and Refining (slags)

Copper slag has various applications and thus the waste produced during Smelter and Refining can be re-used for applications such as grit blasting, and concrete production as a partial replacement for sand and as a road construction material. Non-reusable slag is assumed to be stored in a landfill.

PROPOSED MONITORING SYSTEM

The waste generated during Offshore Production is intended to be recorded according to the data provided for the operational DPR of the Offshore Mining System.

The waste generated during Onshore Production is intended to be recorded according to the data provided by the mineral processing plant as part of its regular reporting to the company.

The waste generated during Smelting and Refining is intended to be recorded according to the quantity of concentrate delivered to the client smelters and calculated based on the ESG reports of the client smelters.

ASPIRATIONAL GOALS

The company intends to favour options for storing waste that is the most sustainable. As an example, the company already considers methods for offshore pre-concentration of the offshore produced ore. Pre-concentrated ore would exhibit a higher grade when entering the Onshore Production activity which would be beneficial as it would reduce the amount of tailing produced by the mineral processing plant. From a balanced perspective this would increase the quantity of waste produced during Offshore Production and reduce the quantity of waste produced during Onshore Production. However, the company believes it would be a positive trade-off because Offshore Production's waste is not chemically treated and does not pose any threat to water catchment.

For Onshore Production, the company will favour partnering with a mineral processing plant that presents a high degree of ESG awareness, and which TSF does not conflict with local communities and ecosystem.

For Smelting and Refining, the company will make efforts to discuss with its client smelters to ensure produced waste is re-used as much as possible.

‌BIODIVERSITY

BIODIVERSITY AND THE COMPANY'S BUSINESS

As for other extractive industries, the marine minerals industry will entail interactions with various ecosystems and the company endeavours to perform its activities most sustainably. Consequently, the company has a strong focus on the protection of biodiversity and commits to collaborating with third parties transparently to ensure that its activities do not threaten biodiversity and do not lead to irreversible damage.

As shown in Figure 4, the company intends to apply a precautionary approach to its extraction activities. Since the beginning of exploration, the company intends to acquire environmental and biological data to construct a baseline that can be used as a reference for its Environmental Impact Assessment (EIA). Then before starting full-scale production, the company intends to perform test mining which will support the elaboration of an Environmental Monitoring and Mitigation Plan (EMMP) which will describe how the company will monitor environmental deviations from the established baseline and react and mitigate these deviations. The EMMP is expected to be a requirement for the future production permit process as it is already the case in terrestrial mining. The company believes that this precautionary approach is the best guarantee for the protection of biodiversity.

Exploration

• Acquisition of

  environmental data from the start

• Close collaboration with scientists and independent 3rd parties

• Establishment of an Environmental Baseline as a way to evaluate production impact

  Test Mining

• Acquisition of

  environmental data during mining

• Confirmation of environmental performance of the mining-system

• Support the Environmental Impact Assessment

• Possibility to step-back and develop mitigation plans

• Witnessing from

  authorities, scientific

  communities and independent 3rd Parties

  Production

• Delivery of Environmental Performance Guarantee as part of production permitting process

• Continuous monitoring based on EIA recommendations

• Plan in place for temporary closure/early-closure

• Plan in place for mine closure including e.g. activities for re-colonization and rehabilitation

• Witnessing from

authorities, scientific

communities and independent 3rd Parties

EXPECTED DISCLOSURES

When in operation, the company commits to disclose information according to the Disclosure 304-Biodiversity which includes:

Disclosure 304-1 Operational sites owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value outside protected areas:

Exploration and offshore production will be conducted in offshore licenses which are granted by the local authorities. At present, none of the areas which the company expects to operate in have been classified as protected areas of high biodiversity value. Nevertheless, due to the limited level of scientific knowledge of these areas, the company expects some prospective areas' classification to change in the future and will amend this report accordingly.

As previously mentioned, the company does not intend to own, lease, or manage mineral processing facilities. Nevertheless, the company will report on the location of its mineral processing partners.

Disclosure 304-2 Significant impacts of activities, products, and services on biodiversity

1. Nature of significant direct and indirect impacts on biodiversity with reference to one or more of the following:

   1. Construction or use of manufacturing plants, mines, and transport infrastructure.

      Typical subsea "mine" concepts do not include the construction or use of local infrastructures as it is found with terrestrial mines. The company does not intend at this stage to construct any processing plant. The company does not currently have any mining sites but will report on any future mining development.

   2. Pollution (introduction of substances that do not naturally occur in the habitat from point and non-point sources).

Exploration: The company has not identified any operation that would introduce substances that do not naturally occur in the habitat. Especially for the coring and drilling activities, the company does not intend to use reverse circulation techniques involving drilling mud as commonly encountered in the O&G industry.

Offshore Production: The currently considered mining system does not involve the introduction of substances that do not occur naturally from the habitat. For the vertical transportation of the excavated ore, the company's considered design uses local seawater for mixing the ore into a slurry. Following dewatering, the same local seawater is disposed of at the seabed following filtration. Potential residuals in form of fine sediments will be minimised and originate from the seabed where the original ore has been excavated, thus the potential sediment release comes from a naturally occurring source. It is possible that similarly to other underwater activities, technical failure of subsea machinery may lead to hydraulic fluid spillage. The amount of such spillage is usually very small and does not lead to major changes in water chemistry which could impact the local biodiversity. In addition, underwater machinery designs are shifting towards full electrification and thus remove the aforementioned oil spillage risks.

Onshore Production: Mineral processing uses chemical products that may be released either through slippage or as part of the tailing disposal process. Even though the company does not plan to own or manage such facilities, the