Transocean Ltd

2023 Swiss Non-Financial Matters Report

*This Swiss Non-Financial Matters Report (“Report”) was prepared in accordance with the requirements of article 964b of the Swiss Code of Obligations (“CO 964b”) for Transocean Ltd. and its subsidiaries (collectively, “Transocean,” the “Company,” “we,” “us” or “our”).

Our Business

Transocean is a leading international provider of offshore contract drilling services for oil and gas wells. As of February 21, 2024, we owned or had partial ownership interests in and operated 36 mobile offshore drilling units, consisting of 28 ultra-deepwater floaters and eight harsh environment floaters. Additionally, as of February 21, 2024, we were constructing one ultra-deepwater drillship.

We provide, as our primary business, contract drilling services in a single operating segment, which involves contracting our mobile offshore drilling rigs, related equipment and work crews to drill oil and gas wells. We specialize in technically demanding regions of the global offshore drilling business with a particular focus on ultra-deepwater and harsh environment drilling services. Our drilling fleet is one of the most versatile fleets in the world, consisting of drillships and semisubmersible floaters used in support of offshore drilling activities and offshore support services on a worldwide basis.

Transocean Ltd. is a Swiss corporation with its registered office in Steinhausen, Canton of Zug, and with principal executive offices located at Turmstrasse 30, 6312 Steinhausen, Switzerland. Our shares are listed on the New York Stock Exchange under the ticker symbol “RIG.” For information about the revenues, operating income, assets and other information related to our business and the geographic areas in which we operate, please see the Company’s latest annual report on Form 10-K, available athttps://investor.deepwater.com/sec-filings.

Topics Covered by this Report

Pursuant to CO 964b, the Company prepared this Report covering the following required topics (collectively, “Swiss Non-Financial Matters”):

Organization and Governance** – Swiss Non-Financial Matters**

Our Board of Directors (the “Board”) provides oversight of the Company’s sustainability practices, which include certain Swiss Non-Financial Matters included in this Report. The Board’s Health, Safety, Environment, and Sustainability (HSES) Committee assists the Board in fulfilling its oversight of the Company’s management of risk in the areas of health, safety, environment and sustainability. The Board’s Audit Committee is responsible for reviewing with Company management the environmental, social, and governance disclosures and the adequacy and effectiveness of internal controls related to those disclosures. The Board’s Corporate Governance Committee reviews updates from Company management regarding the Company’s sustainability activities as they pertain to the Board and management diversity.

For detailed information on the specific responsibilities of each committee, please refer to the charters of the HSES Committee, Audit Committee, and Corporate Governance Committee, available atwww.deepwater.com/investors/corporate-governance.

Transocean’s Chief Executive Officer (“CEO”), the Senior Vice President (“SVP”), Human Resources, Sustainability and Communications and other functional executives play a crucial role in the development and execution of the Company's sustainability strategies, targets, initiatives, and opportunities. The SVP is the functional executive responsible for facilitating the Company’s sustainability strategies. Together, the CEO and SVP integrate appropriate sustainability principles into the design of applicable business processes and activities, resulting in a cohesive, adaptable approach toward sustainability that aligns with Company objectives. The SVP reports directly to the CEO and acts as the primary liaison to the Board for sustainability matters.

The Company’s Legal Compliance and Ethics (“LCE”) Department, led by the Chief Compliance Officer, under the supervision of the General Counsel and the oversight of the Audit Committee, plays a pivotal role in safeguarding Transocean’s commitment to legal integrity and ethical conduct. Through diligent oversight and proactive measures, LCE helps ensure that all business activities adhere to applicable laws, regulations, and ethical guidelines.

Executive management is responsible for the day-to-day management of the risks the Company faces, while our Board, including through its various committees, has responsibility for the oversight of risk management for the Company. Through the Board’s oversight role and review of management’s active role, the Board seeks to ensure that (1) the risk management processes designed and implemented by management (as more particularly described below) are adapted to and integrated with the Company’s corporate strategy, (2) that those processes are functioning as designed, and (3) that steps are taken to foster a culture in which each employee understands his or her impact on the assessment and management of risk, his or her responsibility for acting within appropriate limits, and his or her ultimate accountability.

The Company has an enterprise risk management process and framework, which includes an Executive Risk Management Committee and a Risk Committee Working Group. The Executive Risk Management Committee is composed of members of senior management, including our CEO and other members of management in key functions of the Company. The Risk Committee Working Group is composed of representatives of all key functions of the Company. The duties of the Executive Risk Management Committee and the Risk Committee Working Group include the following:

■ reviewing and approving appropriate changes to the Company’s policies and procedures regarding risk management;

■ identifying and assessing operational, commercial, strategic, financial, information security, cybersecurity, macroeconomic and geopolitical risks facing the Company;

■ identifying risks and taking corrective actions, within their respective functions, if appropriate; monitoring key indicators to assess the effectiveness and adequacy of the Company’s risk management activities; and

■ communicating with the Board at least once a year with respect to risk management.

The Executive Risk Management Committee and/or members of management present reports on risk management activities to the Board at least annually. The Risk Committee Working Group identifies risks facing the Company, makes an assessment of each risk and identifies preventive and mitigating controls such as obtaining insurance, which is a mechanism for reducing the financial impact of business interruption, or loss or damage to a Company asset. The Risk Committee Working Group then makes recommendations for improvement opportunities to senior management, as appropriate. Our management and Board continue to assess and respond to various risks that affect our industry, our Company and our employees, including but not limited to, operational offshore drilling risks, public health threats, such as pandemics and epidemics, market fluctuations among commodities and the costs and accessibility of goods and services procured throughout our supply chain.

Business Performance** and Results**** **

Please refer to the Company’s latest annual report on Form 10-K and the Company’s latest quarterly report on Form 10-Q, as applicable, available athttps://investor.deepwater.com/sec-filings, for information about the Company’s business performance and results for the periods referenced therein.

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Risk Factors

The Company’s business involves inherent risks. For more information about the main risks related to our business, including the certain Swiss Non-Financial Matters topics covered by this Report, please see the Company’s latest annual report on Form 10-K and the Company’s latest quarterly report on Form 10-Q, as applicable, available athttps://investor.deepwater.com/sec-filings.

Approach to****Swiss Non-Financial Matters

The Company integrates sustainability principles throughout the organization. Due to many factors, including global and regional energy security concerns, as well as the needs of both developed and developing economies to ensure continuous access to reliable, affordable sources of energy, demand for energy produced from traditional fossil fuels, principally oil and gas, will continue for many years to come. However, we recognize that oil and gas resources alone are not sufficient to meet the growing global energy demands. While Transocean remains committed to its core business, we recognize that our assets, core competencies, and capabilities also apply to renewables and other energy alternatives. We have continued to opportunistically pursue adjacent energy-related projects that leverage our strengths and experience in offshore drilling, including assisting with carbon capture and storage wells and working with companies engaged in exploration and development work associated with critical minerals resources found offshore.

Further, the Company recognizes the evolving landscape of sustainability regulations and associated disclosure requirements. By adapting to the evolving expectations of regulators and maintaining a dialogue about sustainability matters, including certain Swiss Non-Financial Matters included in this Report, with our customers and other stakeholders, the Company is better positioned to proactively address sustainability challenges and seize opportunities as they arise.

Stakeholder Engagement

As we develop and refine our sustainability framework across our organization, which includes certain Swiss Non-Financial Matters included in this Report, we have been guided, in part, by sustainability-focused engagements that we undertake from time to time with a diverse range of stakeholder groups, including the Board, community groups, customers, Company management and employees, industry organizations, investors, vendors, and regulators.

These efforts include in-depth discussions, submitting and responding to surveys, and/or reviewing certain stewardship guidelines. As a member of the global corporate community, we actively participate in committees, town hall assemblies, and industry events, advocating for the adoption of best practices and responsible operations in offshore drilling.

The results of our engagement efforts help to guide the development and refinement of our sustainability strategies. As part of these efforts, we developed a sustainability matrix representing the topics that arose most frequently during our engagements. We review and, where appropriate update, the sustainability matrix from time to time in accordance with our sustainability priorities, strategies, targets, initiatives, and potential opportunities. The following sustainability matrix describes the topics that were prioritized during 2023.

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The priorities reflected in the 2023 sustainability matrix guided our due diligence approach to the Swiss Non-Financial Matters described in this Report.

Environmental Matters

We strive to deliver services in a manner that minimizes the impact our business has on the environment, which we believe is in the interest of all of our stakeholders. We continuously seek new ways to advance our commitment to safely performing operations while simultaneously safeguarding the environments in which we work.

We maintain a global Environmental Management System (“EMS”) standard that is applied to our rigs, offices and facilities. The EMS is aligned to ISO 14001 and provides a framework to ensure that our worldwide operations are managed consistently and continuously in an environmentally responsible manner. We regularly assess the environmental impact of operations, focusing on ways to reduce greenhouse gas emissions. Our EMS, paired with our Operations Management System, sets forth the standards and processes to identify, consider and mitigate potential environmental impacts when planning and executing our operations.

Our approach to managing and minimizing our environmental impact is driven by our pursuit of operational efficiencies and our continued focus on innovative technologies to improve safety. Our President and Chief Operating Officer administers our EMS, which applies to all Transocean facilities onshore and offshore. These policies govern our management of waste, water and other resources in our facilities, aid in our compliance with all regulatory requirements, and guide the evaluation of our environmental performance. Our EMS, paired with our Operations Management System, sets forth the standards and processes for how our teams identify, consider and mitigate potential environmental impacts when planning and executing our operations. Consistent with our internal policies, we maintain individual rig energy management plans, which are aligned with ISO 50001 and International Maritime Organization (IMO) SEEMP frameworks, for all active rigs.

Energy Management and Emissions

Diesel fuel engines, which are used to generate power on the Company’s rigs, produce greenhouse gas emissions, including carbon dioxide. Operating emissions intensity, which we define as the carbon dioxide equivalent (CO2e) per operating day resulting from diesel consumed by our engines during operations, depends upon many factors. To reduce emissions intensity, it is critical to minimize fuel consumption and optimize power-management systems. To do so, we focus on both sides of the energy-management equation— how we generate and consume power, and how we can optimize this balance while sustaining the safety and efficiency of operations. We concentrate on certain initiatives, such as running the optimal number of engines at the most efficient power loads, strategic heading management (i.e., the orientation of the rig’s bow and stern)

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to minimize the impact of environmental conditions, such as tide and current, and using technologies like fuel additives to increase the combustion efficiency of our rigs.

We use technology to constantly evaluate the energy efficiency of certain equipment as we seek to reduce unnecessary power draws from inactive equipment, and we have developed operational guidelines designed to reduce power demand. Consistent with our internal policies, we maintain individual rig energy management plans, which are aligned with ISO 50001 and International Maritime Organization (IMO) SEEMP frameworks, for all active rigs.

Loss of Containment

We define loss of containment as an unintended and uncontrolled release into the surrounding environment. We have implemented comprehensive policies and procedures for strict compliance with all applicable requirements related to wastewater and other operational discharges.

While customers determine the well and chemicals used in drilling operations, we have operational control over the fluids used for routine rig operations and maintenance. Loss of containment can arise from various factors, including operational integrity events, routine maintenance activities, and equipment failures. Preventing loss of containment involves proactive measures and best practices aimed at operational integrity to ensure process safety. Reportable loss of containment events are recorded within the Company’s incident reporting system and significant events are reviewed by management. Findings and lessons learned are communicated across the fleet to improve future performance. Management reports loss of containment incidents to the HSES Committee.

We refer to process safety as Operational Integrity, which is fundamental to the management of major hazards that may lead to low-frequency, high-consequence events. Procedures governing Operational Integrity are an integral part of our Company Management System (“CMS”), which ensures appropriate and effective processes are in place.

Company management provides quarterly updates to the HSES Committee on the execution of our environmental practices and policies, assessing the sufficiency and efficacy of the CMS, reviewing performance, and identifying trends and areas for enhancement.

Please see the “Compensation Discussion and Analysis” section of our proxy statement for additional information related to this matter.

Social Matters

The development of traditional oil and gas resources in tandem with renewables and other energy alternatives – or the “energy expansion” – has gained importance in light of growing global energy needs. We are committed to doing our part – delivering safe, efficient, reliable and responsible operations. To that end, we prioritize recruitment and retention of skilled, qualified and capable personnel and invest in the training and development of our teams. Further, we continue to fund our innovation and technology programs to enhance the value of our services through improvements to safety, equipment performance, and fuel efficiency.

Our Health, Safety, Environment and Sustainability Policy Statement sets forth our principles for how we work safely. This policy is overseen by the Board’s HSES Committee.

Our safety program focuses on three key components: personal safety, process safety, and occupational health. We conduct our business while prioritizing both the health and safety of our people and the integrity of our operations. Our safety vision is to conduct our operations in an incident-free workplace, all the time, everywhere. Underpinning this vision is our robust CMS, which details the policies and tools employed by our teams to complete their work safely, efficiently, and effectively. In 2023, our Company Total Recordable Incident Rate (“TRIR”), which represents the number of recordable work-related injuries or illnesses for every 200,000 hours worked, of 0.23 improved on our prior year’s performance, demonstrating the consistency of our execution and prioritization of safety in all our operations. We extended our safety program to focus more on leading indicators of safety performance, and in particular, workplace assurance and verification conversations, branded as WorkSight. In tracking the frequency and quality of these conversations, our HSE team can

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proactively provide additional coaching and support to our offshore rig teams, and we are seeing positive trends in our safety performance, such as a decline in the severity of incidents.

Additionally, we embrace our role as a global corporate citizen, and we aim to positively impact communities where we live and operate. Our support focuses on education, health and well-being and environmental conservation and restoration. Some examples of the community organizations with whom we have partnered include the Galveston Bay Foundation, Houston Food Bank, Udaan Foundation (India), Texas Children’s Hospital Heart Center (International Programs), and Women Offshore Foundation.

Our safety vision is to conduct our operations in an incident-free workplace, all the time, everywhere. This vision is supported by our robust CMS, which details the policies and tools employed by our teams to complete their work safely, efficiently, and effectively. Compliance with all local regulations and a comprehensive set of internal policies and procedures that govern our operations is required. We prioritize the protection of everyone onboard our rigs and in our facilities, the environment, and our property at all work locations. Incidents are reported and investigated to determine the root cause, with fleetwide communication of lessons learned. Potential areas of improvement are targeted with a topic-specific improvement program.

Transocean maintains a rigorous competency-based training program to provide our employees with the skills and tools needed to work safely. Our internal training board maintains and regularly updates our training matrix to meet or exceed industry standards, and it oversees our competency assurance management system, which is accredited by the Offshore Petroleum Industry Training Organization. We provide various offshore training formats designed to encompass all learning styles through on-the-job training, e-learning, customer-specific training, certifications, and leadership and licensing programs. We also offer unique simulation-based education, augmented by digital twin modeling, enabling our workforce to more accurately visualize equipment performance and target efficiencies. The certifications, skills and competencies needed for each role are communicated to the workforce, and workers are required to successfully complete the relevant training and attain necessary certifications prior to taking on new roles.

Our safety policies are implemented through a diverse range of programs, requirements, and tools. Through ongoing compliance assessments and audits, management monitors and verifies that work is executed following established policies and procedures. Findings are analyzed and quickly shared across the fleet to bolster the Company’s safety performance and culture.

For example, in 2022, we introduced the above-mentioned tool called WorkSight, a digital assurance and verification application used to emphasize leading indicators of personal safety performance on our rigs. It fosters a culture of continuous improvement among our rig teams by encouraging them to proactively identify potential hazards in their work and identify opportunities to eliminate or mitigate them, assess and challenge their behaviors, and continuously seek areas for improvement. WorkSight leverages the expertise of our crews, frontline leaders, and senior rig leadership, along with data analytics and visualization, to influence behaviors and impact many aspects of our daily operations, thereby reinforcing process safety.

Central to our management of process safety are our Critical Operations Assurance centers recently introduced in Houston, Texas, and Stavanger, Norway. These centers remotely monitor key rig activities in real-time to verify they are executed in accordance with Company requirements to promote safe and consistent outcomes across the fleet.

The combined focus on personal safety, occupational safety and process safety enables Transocean to protect people, the environment, and our assets, while conducting our work efficiently and effectively. Additionally, job roles are carefully evaluated to identify any associated potential hazards to implement effective processes and standards to mitigate risks and support the well-being of employees while on the job. We maintain strict requirements around personal protective equipment, task design, procedures, and equipment selection and maintenance to reduce risk and maintain a healthy environment. All rigs are staffed with a medical professional, equipped with an onboard clinic bolstered by 24/7 shore-based medical support and overseen by our Company medical director, a licensed physician.

We measure our safety performance in terms of widely accepted ratios with the use of industry standards, including (a) Total Recordable Incident Rate (“TRIR”), which represents the number of recordable work-related injuries or illnesses for every 200,000 hours worked and (b) Lost Time Incident Rate (“LTIR”), which measures

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the number of incidents that result in lost time due to work-related injuries or illnesses for every 200,000 hours worked.

We measure the reliability and efficiency of our operations using uptime. Uptime is measured as total operating hours, minus downtime hours, expressed as a percentage of the maximum total operating hours. Operating hours are defined as the number of hours a rig is operating under a contract. Downtime is defined as the number of hours the rig is not engaged in drilling activities, resulting from Company mechanical failure or human performance error.

Please see the “Compensation Discussion and Analysis” section of our proxy statement for additional information related to this.

Employee Matters

Transocean prioritizes the well-being of its employee population—from physical and financial health to emotional and social health. These four pillars guide our approach to employee benefits to help our team succeed professionally and personally.

We endeavor to provide those who work at Transocean with an inclusive, supportive, safe and respectful environment in which they can flourish. We periodically assess our workplace and adapt our practices and policies to ensure that our approach reflects contemporary norms and meets the needs and expectations of current and future talent. Our aim is to recruit, develop, and retain the best workforce in the offshore drilling industry. As a company with an international operational and customer base, we view the diversity of our workforce as a key factor in our success.

Due to the nature of our business and the many countries in which we operate, we offer regionally competitive benefits and adhere to internal global practices that meet or exceed local market standards. As certain benefits and programs may not be universally accessible, we augment regional benefits with supplementary programs wherever required.

Physical**.** Our physical-wellness benefits program emphasizes promoting a healthy lifestyle through educational initiatives, preventive-care measures, and convenient access to medical advice and resources.

Financial. We offer our employees regionally competitive compensation and benefits packages that meet all regulatory requirements. In addition to providing competitive remuneration, we understand the importance of helping employees prepare for their future financial well-being and we provide resources and guidance to assist our team in setting and achieving financial goals.

Emotional. We recognize the significance of emotional well-being and are dedicated to fostering and enhancing programs that support the emotional health of employees and their families.

Social. Our social well-being strategy places a significant emphasis on the communities where we operate. As global corporate citizens, we embrace our responsibility to make positive contributions through financial support and volunteerism. Community initiatives and partnerships focus on areas, such as education, health and well-being, and environmental conservation and restoration.

We continually assess and adapt to evolving social and technological practices toward creating a work environment that is mutually beneficial for our employees and the Company. This, along with providing a respectful and inclusive work environment in which our global workforce can thrive, is essential to attracting and retaining top talent. For example, in 2023, we worked with an independent third party to review our benefits offerings in the U.S., as well as certain of our HR policies. With a diverse employee population—comprised of different ages, nationalities, cultures, genders and races—we strive to implement and adjust, as needed, our plans and policies to account for the needs of our different employee groups. One of our goals was to identify potential gaps between the value we intended to provide and what we actually provide for different groups within our organization. The project is ongoing, but we’ve been able to build a roadmap to narrow certain unintended gaps. For example, some of our offshore employees indicated that they were not aware of the financial education resources that exist within our current plans; as a result, we invited vendors who specialize

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in providing such educational resources to a Company event to present to both our offshore employees and shore-based employees.

We aim to strategically cultivate a best-in-class workforce to offer the innovation, local knowledge and experience required of the world’s premier offshore drilling contractor. We seek to maintain our competitive advantage while benefitting our local communities by offering regionally competitive compensation and benefits packages, a technically challenging work environment, global opportunities, and rotational development programs. We continually assess and adapt our offerings and our policies, based on evolving social and technological practices, to provide a modern work environment, which is essential to attract and retain top talent. We also assess and adapt our offerings and policies in support of a respectful and inclusive work environment in which our global workforce can thrive. Our focus on the quality of our workforce is designed to maximize the quality of our work performance, and ultimately, the value we deliver to our stakeholders.

We value our employees and business partners and treat their personal data with care. We respect their data privacy rights and follow all applicable data protection laws and regulations in the jurisdictions in which we operate. Personal information (e.g., information that can be used to identify an individual) is only used for appropriate and legitimate business purposes and only to the extent allowed by applicable law.

We invest in our workers by providing them with the transferrable skill sets essential to advancing their professional development. To optimize the competitive position of our business, we maintain a rigorous competency-based training program. Our internal training board maintains and regularly updates our training matrix to meet or exceed industry standards, and it oversees our competency assurance management system, which is accredited by the Offshore Petroleum Industry Training Organization. We provide various offshore training formats designed to encompass all learning styles through on-the-job, e-learning, customer-specific training, certifications, and leadership and licensing programs. We also offer unique simulation-based education, augmented by digital twin modeling, enabling our workforce to more accurately visualize equipment performance and target efficiencies. We clearly articulate to our workforce the certifications, skills and competencies needed for each role, and workers are required to successfully complete the relevant training and attain necessary certifications prior to taking on new roles.

As a business in the energy industry, we must operate with integrity, discipline and an unconditional respect for our people, our communities and our environment. Our SVP partners with our other functional leadership to manage and execute our sustainability program, including investments in:

Human Rights Matters

As a global company, we view it as our obligation to uphold human rights throughout all operations, regardless of whether those rights are protected by local laws. We work hard to ensure that business operations do not cause or contribute to (directly or indirectly) adverse impacts on human rights. We demonstrate our respect of human rights by maintaining a healthy and safe work environment, observing fair employment practices, and providing competitive employment terms. Practices such as modern slavery, child labor, forced or indentured servitude, and other human rights abuses are strictly prohibited.

Transocean maintains a Code of Integrity and Human Rights Policy Statement that applies to all members of our Board, executives, employees, and business partners, including contractors, suppliers, vendors, and joint venture partners.

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Transocean’s commitment to respecting human rights applies to employees, suppliers (including contractors), and business operations both onshore and offshore.

In our Business Operations. We expect Transocean employees and representatives to act lawfully and respectfully toward other employees, customers, business partners, and those in the local communities in which we operate. These expectations are outlined in our Code of Integrity, as well as various enterprise-wide policies. We ensure the protection of Transocean employee rights through policies and procedures established by the Human Resources, Health, Safety & Environment, and Legal department functions.

Throughout our Supply Chain. We expect our business partners, including our suppliers, to share our commitment to respect human rights. Suppliers must comply with our Code of Integrity, which specifically outlines our expectations related to human rights. Suppliers must also comply with our standard contract provisions, which require strict adherence to all applicable laws, including human rights laws.

To manage the Company’s human rights risk, we must select suppliers and business partners carefully, and we require them to manage their own suppliers and business partners with the same care. Before engaging in a business relationship with a supplier, we conduct background screenings and contractually obligate suppliers to comply with (a) all applicable laws, which include those pertaining to human rights or modern slavery; (b) our Code of Integrity, which outlines the expectations of supplier conduct and imposes an obligation to report any conduct that does not meet those expectations; (c) human rights audit exercises conducted by us or a third party that we appoint to make sure they are meeting those obligations; and (d) our policy that our suppliers impose the same human rights obligations on their suppliers. Throughout the business relationship, we periodically engage with suppliers to reinforce Company expectations; monitor their performance via tools like continuous restricted party screening and conduct formal and informal site visits; and conduct human rights audits pursuant to a risk-based audit plan.

Periodically, Transocean conducts a Human Rights Risk Identification and Assessment exercise to identify, evaluate, and monitor potential risks of adverse impacts on human rights and decent working conditions. We consider a variety of factors in assessing the Company’s risk of causing, contributing to, or otherwise being linked to actual and potential adverse impacts on human rights and decent working conditions, including with scale, scope, and remediation.

We are proud of our Speak Up Culture and encourage our workforce and business partners to report any concerns. In instances where someone has a concern or believes that there has or may have been a violation of our human rights policies or any other policies, the individual is encouraged to report any concerns to a manager, Human Resources, or through the HelpLine accessible atwww.transocean.ethicspoint.com. Helpline reports can be made anonymously, at any time, by anyone, and by phone or the web. To ensure consistency around how reports are managed and investigated, the Human Resources and Legal Compliance and Ethics functions follow investigation policies and procedures. Transocean adheres to a strict non-retaliation policy for concerns raised in good faith.

Because Transocean’s operations are mostly comprised of employees and contractors performing highly technical services in an industry with tightly controlled regulatory environments, the Company’s overall human rights risk can be characterized as relatively low. In 2023, Transocean did not identify any actual adverse impacts on human rights or decent working conditions in its operations, supply chain, or business partner relationship. Continuous focus on identifying these areas helps us prioritize how we address and prevent adverse human rights impacts across operations and extended supply chain. Further, all employees are required to complete our Code of Integrity training on an annual basis, which covers various topics, including human rights. Additionally, to make sure we are aware of, and can adequately address, any actual or suspected human rights violations, Transocean provides a 24-hour, third-party managed HelpLine, where individuals can raise concerns in good faith without the fear of retaliation.

We periodically include a module on Human Rights in our annual LCE training to ensure all employees, including management, are equipped with a fundamental understanding of protecting human rights, including taking all reasonable measures to avoid contributing to adverse human rights impacts, and how to identify and report potential issues encountered in work and personal lives.

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Anti-Corruption Matters

Earning and maintaining trust requires a commitment to integrity in every aspect of our business, from how we obtain business opportunities to compliance with the most technical of laws. We always endeavor to conduct business fairly and transparently—and without cutting corners. It is what Transocean is known for, and what our stakeholders expect from the world’s leading offshore drilling provider.

Our approach to ethics and compliance is grounded in a risk-based methodology aligned with the expectations of effective compliance programs enumerated by various regulators, including the U.S. Department of Justice and the U.S. Securities and Exchange Commission. Accordingly, we conduct annual risk assessments, establish and enforce policies and procedures, related to, among others, antibribery and anticorruption, gifts, meals and entertainment, and financial controls, provide associated training and communication, perform auditing and monitoring activities, and conduct investigations, where necessary. Together, these elements serve as the foundation of our LCE program. At Transocean, we know that everyone, whether they work for or on behalf of the Company, is responsible for ethics and compliance. To ensure that our stakeholders are fully aware of the Company’s ethical expectations and equipped with the knowledge to uphold them in their daily work, we conduct annual LCE training on relevant topics, as well as periodic training tailored to specific audiences, delivered through a variety of in-person and digital formats. It is crucial for us to seamlessly integrate our LCE program into our business processes, ensuring its relevance and alignment with our activities for its sustained effectiveness. We collaborate across the organization to identify ethics and compliance risks and ensure they are appropriately addressed and mitigated. Transocean’s Code of Integrity Committee holds monthly meetings with key management personnel, fostering discussions on the integration of LCE program controls and initiatives into our business operations and project execution. These meetings also serve as a platform to identify areas for improvement.

The Code of Integrity applies to all individuals associated with Transocean, including Board members, executives, employees, and business partners, such as contractors, suppliers, vendors, and joint venture partners. We require such stakeholders to read, understand, adhere to, and periodically certify compliance with the Code of Integrity, which includes compliance with all applicable laws. In situations where the Code of Integrity may conflict with local customs or laws, we follow the more stringent standard. To promote an ethical business culture and underscore the importance of complying with all applicable laws and Company policies, we provide training, focusing on our Code of Integrity and other relevant compliance topics.

Transocean’s Anti-Corruption and Business Conduct Standard strictly prohibits making, offering, receiving, or agreeing to receive bribes of any kind. A bribe is made when anything of value, financial or otherwise, is offered to gain or retain an improper business advantage, even if the advantage is ultimately not received. Bribes can hurt communities, enable corruption, harm reputations, and expose companies and individuals to criminal liability.

Transocean has implemented measures to prevent and detect potential bribes, and our most important tool will always be the vigilance of our employees and business partners in identifying and reporting any instances or suspicions of impropriety.

In addition to the diligence measures described in the Human Rights Matters section above, when we engage with third-party intermediaries (“TPIs”), a subset of suppliers that interact with government officials on our behalf, we take the supplier evaluation and review process a step further. We subject TPIs to a stringent vetting, training, and monitoring process at the time of onboarding and throughout their business relationship with the Company. Our internal TPI Oversight Committee oversees this process and regularly meets throughout the year. Also, the Board has a well-defined policy regarding related party transactions, which entails a thorough recurring review, approval, or ratification process. The responsibility for reviewing, approving, and/or ratifying any related person transaction lies with the Audit Committee, supported by the Company’s General Counsel. It is mandatory for directors and executive officers to disclose in a timely manner any transactions in which they, their immediate family members, or other related persons have an interest. This transparent approach ensures proper oversight and safeguards against any potential conflicts of interest.

Transocean also encourages its stakeholders to report any concerns they may have, including potential violations of our Code of Integrity. Through the HelpLine, a third-party managed service available 24/7 on a

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global scale, we provide a reporting channel, that may be used to report anonymously. Upholding our commitment to protect those who make reports in good faith, we strictly enforce a zero-tolerance policy against any form of retaliation. We take Code of Integrity violations seriously and allocate all necessary resources to conduct fair and thorough investigations. All investigations are handled with confidentiality, in accordance with legal requirements. To the extent possible, confidentiality is maintained throughout the entire investigation process, from the initial reporting to the final resolution.

Transocean maintains a risk-based monitoring and response program designed to detect inconsistencies in control execution and to ensure the continuous improvement of the LCE program. Transocean also regularly reviews its policies and systematic controls to identify potential control enhancements. We actively seek feedback from the workforce regarding our program initiatives, utilizing their input to enhance policies and procedures for maximum effectiveness. Most recently, we gathered employee feedback through participation in a voluntary and anonymous ethical culture survey. We use the results of this survey to inform our annual plan and to drive the continuous improvement of the program. Using tools like the ethical culture survey and data analytics derived from our annual training allows us to measure the effectiveness of initiatives and tailor the program to address, in real-time, the needs of our people, customers and business.

In 2023, the Company's annual LCE training was assigned to 5,360 onshore and offshore personnel. The training was made available in English, Brazilian Portuguese, and Norwegian, and covered anti-corruption; gifts, meals, and entertainment; conflicts of interest; and respectful workplace behavior. The completion rate for the 2023 LCE training campaign was 100%. Additionally, in-person LCE training was conducted to the Company’s shore-based locations.

The Company also rolled out the 2023 LCE Third-Party Training to certain of the Company’s TPIs and other business partners. While all TPIs are required to complete the Company’s online training at onboarding and recertification, the annual LCE Third-Party Training is an additional requirement for those TPIs identified through LCE’s risk-based methodology.

All HelpLine reports regarding alleged Code of Integrity violations are diligently reviewed and investigated, and LCE presents regular updates to the Audit Committee of the Board of Directors.

Transocean 2023 AP-11 Proxy Statement

FORWARD LOOKING STATEMENTS

The statements described herein that are not historical facts are forward-looking statements within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended. These statements could contain words such as “possible,” “intend,” “will,” “if,” “expect,” or other similar expressions.

Forward-looking statements are based on management’s current expectations and assumptions and are subject to inherent uncertainties, risks and changes in circumstances that are difficult to predict. As a result, actual results could differ materially from those indicated in these forward-looking statements. Factors that could cause actual results to differ materially include, but are not limited to, estimated duration of customer contracts, contract dayrate amounts, future contract commencement dates and locations, planned shipyard projects and other out- of-service time, sales of drilling units, timing of the Company’s newbuild deliveries, operating hazards and delays, risks associated with international operations, actions by customers and other third parties, the fluctuation of current and future prices of oil and gas, the global and regional supply and demand for oil and gas, the intention to scrap certain drilling rigs, the success of our business following prior acquisitions, the effects of the spread of and mitigation efforts by governments, businesses and individuals related to contagious illnesses and other factors, including those and other risks discussed in the Company’s most recent annual report on Form 10-K for the year ended December 31, 2023, and in the Company’s other filings with the U.S. Securities and Exchange Commission (“SEC”), which are available free of charge on the SEC’s website atwww.sec.gov.

Should one or more of these risks or uncertainties materialize (or the other consequences of such a development worsen), or should underlying assumptions prove incorrect, actual results may vary materially from those indicated or expressed or implied by such forward-looking statements. All subsequent written and oral forward-looking statements attributable to the Company or to persons acting on our behalf are expressly qualified in their entirety by reference to these risks and uncertainties. You should not place undue reliance on forward-looking statements. Each forward-looking statement speaks only as of the date of the statement, and we undertake no obligation to publicly update or revise any forward-looking statements to reflect events or circumstances that occur, or which we become aware of, after the date hereof, except as otherwise may be required by law. All non-GAAP financial measure reconciliations to the most comparative GAAP measure are displayed in quantitative schedules on the Company’s website atwww.deepwater.com.

This report, or referenced documents, do not constitute an offer to sell, or a solicitation of an offer to buy, any securities, and do not constitute an offering prospectus within the meaning of the Swiss Financial Services Act (FinSA) or advertising within the meaning of the FinSA. Investors must rely on their own evaluation of Transocean and its securities, including the merits and risks involved. Nothing contained herein is, or shall be relied on as, a promise or representation as to the future performance of Transocean.

Information contained on or accessible from our website is not incorporated by reference into this Report and should not be considered a part of this Report or any other filing that we make with the SEC. References to website URLs are intended to be inactive textual references only.

Transocean 2024 AP-12 Proxy Statement