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Norwegian Transparency Act Statement 2024
World Kinect Corpora on, its affiliates and subsidiaries (collec vely, “WK”, “World Kinect”) are commi ed
to respec ng the rights and dignity of all people and to opera ng in accordance with applicable human
rights, employment, environment and an -corrup on laws. Further, our approach to human rights is
aligned with the Norwegian Transparency Act (“the Act”) and key global ini a ves, such as the United
Na ons (“UN”) Universal Declara on of Human Rights and the UN Global Compact.

Our Code of Conduct, Human Rights Statement, and other relevant World Kinect policies are designed to
prevent human rights abuse in our opera ons and supply chains, including, but not limited to, slavery,
forced or compulsory labour, child labour and human trafficking. This Transparency Act Statement applies
enterprise-wide to all World Kinect en es and is issued with regard to our ac ons and ac vi es during
the financial year ending 31st December 2024.1

Relevant World Kinect subsidiaries in scope for Norwegian Transparency Act disclosure requirements are
as follows: (1) Kinect Energy AS, Kinect Energy Green Services AS, Kinect Energy Spot AS and Kinect Energy
Markets AS, with 83 employees based in Bergen and Oslo carrying out Energy Advisory ac vi es; and (2)
Norse Bunker AS with 2 employees based in Oslo carrying out Energy Procurement and related services
to Marine industries.

World Kinect is a publicly traded (NYSE:WKC) global energy management company headquartered in
Miami, Florida, with subsidiaries and affiliates opera ng around the world. We are principally involved in
providing energy procurement and related products and services to commercial and industrial customers
in the avia on, land, and marine transporta on industries. We offer a broad suite of energy advisory,
management and fulfillment services, digital and other technology solu ons, as well as sustainability
products and services across the energy product spectrum. We have expanded our product and service
offerings to include energy advisory services, sustainability and renewable energy solu ons, as well as
supply fulfillment for natural gas and power. An area of focus con nues to be advancing the energy
transi on to lower carbon alterna ves through expanding the company’s por olio of energy solu ons
and providing customers with greater access to sustainably sourced energy as well as mechanisms to
compensate for residual emissions in the near term.2




1
  The Sustainability and Corporate Responsibility Committee of the Board of Directors of World Kinect Corporation and the
Boards of Directors of Kinect Energy AS, Kinect Energy Green Services AS, Kinect Energy Spot AS, Kinect Energy Markets AS
and Norse Bunker AS have each provided their approval of this 2024 Transparency Act Statement.
2
  For more informa on regarding our business ac vi es, please see our most recent Annual Report and other relevant
corporate filings at h ps://corp.worldkinect.com
Given the nature of our business, our supply chains are connected with a variety of industries such as
technology, energy genera on, fuel distribu on, transporta on logis cs, and professional services. As a
result, we have adopted a number of policies and procedures designed to safeguard human rights in our
own opera ons and supply chains. We are guided by the human rights principles of the UN Global
Compact, to which WK is a signatory, and our employees are required to conduct business in accordance
with the WK Code of Conduct, which outlines in detail the high standards of ethics and integrity that we
expect from our employees and business partners.

As part of our global ethics and compliance program, which is overseen and enforced by our Legal
Department, we have already implemented numerous policies and procedures designed to iden fy,
respond to, and prevent unethical and illegal ac vi es, including modern slavery and other human rights
abuses. These include, but are not limited to:

      World Kinect Code of Conduct: The WK Code of Conduct makes clear to all employees,
       contractors, and agents the ac ons and behaviour expected of them when represen ng World
       Kinect. We strive to maintain the highest standards of employee conduct and ethical behaviour
       when opera ng domes cally and overseas, as well as when managing our global supply chain. Our
       Code of Conduct notes explicitly that we will not tolerate, and will not do business with partners
       that we know tolerate, human rights abuses including child labour, forced labour and/or human
       trafficking.

       Our Code of Conduct is available in mul ple languages at: h ps://www.world-kinect.com/about-
       us/ethics-and-compliance

      World Kinect Business Partner Code of Conduct: The WK Business Partner Code of Conduct
       affirms to all suppliers, contractors and agents, as well as any employees, subcontractors, and
       agents working on their behalf, that we require them to comply with both the le er and the spirit
       of all applicable laws and regula ons and to act ethically at all mes when doing work for us.
       Among other key requirements, the WK Business Partner Code of Conduct requires that our
       business partners conduct their ac vi es in a manner that complies with applicable human rights
       laws, including, but not limited to: refusing to use forced or child labour; refusing to tolerate
       discrimina on, harassment, abuse, or retalia on in their work place; and providing wages,
       benefits, and working hours that meet or exceed the applicable legal standards and regula ons.

       Our Business Partner Code of Conduct is available in mul ple languages at: h ps://www.world-
       kinect.com/about-us/ethics-and-compliance

      Addi onal Policies and Procedures: We have also developed addi onal policies focused on
       human rights, worker safety, and compliance with employment regula ons. These include, for
       example, the WK Human Rights Policy and our Health, Safety and Environment (“HSE”) Principles,
       which embody our commitment toward: maintaining opera ons free of human rights abuses;
       working with those business partners that comply with applicable employment laws and safety
       regula ons; sustaining a diverse, inclusive, and safe work environment for our own employees;
       and overall suppor ng the principles of the UN Global Compact, to which we are a signatory.
    In addi on, we maintain a full complement of employment-related policies and procedures to help
    comply with local employment regula ons in the many countries where we operate. Such policies
    and procedures are implemented through our Human Resources, Legal, HSE, and other key
    departments, in compliance with internal protocols.

    Certain key policies and            programme      materials    are    available   publicly    at:
    h ps://corp.worldkinect.com

   Employee Educa on and Training: We require all our employees to a end ethics and compliance
    training, both at the point of joining the company and then at addi onal points throughout their
    career. Our training is monitored and a endance recorded for future audi ng purposes. Our Code
    of Conduct and our compliance training direct employees to contact the Legal Department
    immediately if they suspect any viola ons of our Code of Conduct, such as human rights abuse in
    our opera ons or the opera ons of any partner.

    We have taken addi onal steps toward our commitment to maintaining the highest ethical
    standards and our desire to educate employees on how they might iden fy poten al human rights
    issues and report their concerns. For example, we have created internal resources specifically
    informing our employees on the risks of modern slavery, such as our key policies and statements,
    access to modern slavery training, and other guidance materials. We will con nue to look for
    addi onal ways to train key personnel to iden fy ways human rights abuse might enter our supply
    chains.

   Compliance Hotline & Whistleblower Protec ons: We encourage all our employees, customers,
    and other business partners to report any concerns that they may have to their supervisors, lead
    business contact, and/or directly to our Legal Department. We have procedures to protect those
    who report their concerns, and we maintain a compliance hotline that can be accessed free of
    charge by telephone or online, 24 hours a day, 7 days a week. The hotline, which allows for
    anonymous disclosures, is managed by an independent third-party company. All reports, including
    those related to human rights abuse, will be reviewed and acted upon as appropriate by our Legal
    Department.

    We make our hotline available to all stakeholders online in mul ple languages at
    compliance.world-kinect.com.

   Assessments and descrip on of human rights risks: In our opera ons we do not u lize forced or
    compulsory labour and all our employees are of legal age and employed under condi ons that
    comply with applicable laws and regula ons. The area of highest risk for World Kinect is in our
    supply chains and we have assessed our ac vi es and those of our suppliers as regards to human
    rights risks, considering, for example, our differing lines of business, hiring prac ces, supplier
    ve ng, geography of opera on, and risk mi ga on efforts described in this Statement. Key
    stakeholders, such as members of our Legal Department and compliance team, engage with key
    business units and leadership across our opera ons with the goal of be er understanding current
    and planned business ac vi es, their poten al legal implica ons, and supply chain risks, including
    poten al human rights risks. Our compliance programme con nuously seeks to iden fy ways to
    improve engagement across opera ons and this will be a focus area in 2025.
      Third Party Due Diligence: We will refuse to do business with, or discon nue ongoing business
       with, any partner that fails to meet our ethical standards. In addi on to our Business Partner Code
       of Conduct, we undertake risk-based due diligence when considering new partners, including
       suppliers, as well as when reviewing exis ng partner rela onships. Depending on the ac vi es of
       a supplier, their loca on, and/or other specific risks, we may require addi onal informa on and/or
       confirma ons related specifically to the supplier understanding.

      Contractual Requirements: In addi on to other measures such as our Business Partner Code of
       Conduct, and depending on rela ve risk and specific circumstances, we may require suppliers and
       other third-party vendors to sign specific human rights related cer fica ons and/or for their
       contracts to include clauses specific to their compliance with, for example, applicable labour laws,
       employment regula ons, and an -modern slavery efforts.

      Assessing Effec veness: Our approach to managing the risk of modern slavery forms part of our
       broader efforts to respect human rights and we are always striving to enhance our supplier ve ng
       processes. In 2024, we undertook a number of ac vi es to be er assess our performance. These
       included targeted in-country assessments to be er understand our poten al human rights risks
       and impacts in high-risk opera ng environments.

The World Kinect Legal Department has oversight of this Norwegian Transparency Act Statement and
related policies and procedures. It will be reissued at the end of each financial year to provide further
updates on the steps we have taken to assess and address the risk of human rights abuse in our opera ons
and supply chains.
                   Signatures to the Norwegian Transparency Act Statement for year 2024

Dated the 17th April 2025

Signed by all board members:

Kinect Energy Spot AS

Kinect Energy Green Services AS

Kinect Energy Markets AS



_________________________________                   ___________________________________

Richard D. McMichael, Director                      Stephen Paul Mor mer, Director



Kinect Energy AS



_________________________________                   ___________________________________

Richard D. McMichael, Director                      [navn skjult], Director



Norse Bunker AS



_________________________________                   ___________________________________

Richard D. McMichael, Director                      Michael J. Ranger, Director