Strategy playbook2 The strategy playbook provides guidance on responding to carbon-pricing policies. Carbon-pricing policies create new obligations for businesses considered to be key emitting entities, requiring compliance actions, internal resource development and operational changes. Companies outside traditionally high-emitting sectors can also take steps to prepare, particularly where their value chains include carbon-intensive inputs or processes – for example, photovoltaic manufacturers relying on aluminium frames or wind turbine producers dependent on steel and composite materials. Ideally, national policies will help companies become more efficient and competitive while preparing for the impacts of BCAs. Companies can organize their responses to carbon-pricing policies, including BCAs, using the PACE framework: 1. Plan administration of carbon-pricing policies: Develop internal governance mechanisms and resources to comply with policies, create strategies, promote strategic forecasting to leverage the dynamic carbon- pricing environment and drive implementation 2. Achieve domestic and international compliance: Take actions required to satisfy regulations under domestic carbon-pricing systems and BCAs, addressing divergences where necessary 3. Change operations to decarbonize: Implement improvements in sourcing, production, delivery and other activities to reduce GHG emissions 4. Engage stakeholders: Collaborate within the value chain and with policy-makers, civil society and other stakeholders to advance decarbonization For strategic management of risk and opportunities related to BCAs, cross-functional coordination is essential. We have an internal taskforce that includes representatives from sustainability, finance, market analysis, logistics, procurement and public affairs, which not only allows for more effective strategic decisions but also greater efficiency and knowledge-sharing. Sarah Hay, Climate Policy Lead, Norsk Hydro Climate and Competitiveness: Border Carbon Adjustments in Action 21

Climate and Competitiveness Border Carbon Adjustments in Action 2025