D'Amico International Shipping S.A.
Material Topics
Sustainability statement, in full
The complete text of D'Amico International Shipping S.A.’s FY2025 sustainability statement is held here – 276 pages, captured from the published report. Every disclosure below also links to its own passage.
ESRS 2 – General Disclosures
GOV-1The role of the administrative, management and supervisory bodiesReported
The role of the administrative, management and supervisory bodies
Reference: pages 47-56, 73.
The Board of Directors "holds broad powers to achieve the Company's objectives... aiming for sustainable success and value for shareholders" and is assisted by two committees, the Nomination and Remuneration Committee and the Control and Risk Committee, plus a Supervisory Committee under Italian Decree 231 (page 47). In 2025 the Board had "nine" members, "seven men and two women", "three executive members and six non-executive members, of whom three were independent" (page 48). Since April 2024, "the Head of the d'Amico Group ESG Department has been serving as a non-executive member of the DIS Board of Directors" (page 73) following a 2024 self-assessment that "highlighted the need for broader expertise in sustainability-related matters within the Board."
GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodiesReported
Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies
Reference: page 73.
"As part of this process, the DMA results and details on the adopted methodologies are presented to the Board of Directors. Drawing on their expertise, the majority of the Board members - including all the Executive Directors - actively participated in the process, provided feedback on the final list of material topics and IROs, and endorsed the outcome" (page 73). "The endorsed list of material topics and IROs, together with the ESG Plan, forms the basis for the preparation of the Sustainability Statement... formally approved by the Board." In March 2025 the Head of the d'Amico Group ESG Department also briefed the Control and Risk Committee on the EU Omnibus package's effect on CSRD, Taxonomy and CSDDD requirements.
GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemesReported
Integration of sustainability-related performance in incentive schemes
Reference: pages 57-58.
The 2025-2027 Medium-Long Term Variable Incentive Plan allocates its bonus pool across six targets, two of which are climate-related: "EEDI/EEXI (5% of the pool)" and "EEOI (5% of the pool)", both based on CO2 emissions per design or operational metric (page 58). "The fifth and sixth targets are climate-related, as these indicators measure ships' energy and emissions performances from both a design perspective (EEDI/EEXI) and an operational perspective (EEOI)." For 2025, "the portion of variable remuneration linked to climate-related targets for the beneficiaries of the long-term incentive system amounts to 10% of total remuneration, as both climate-related targets in the LTI Plan were achieved."
GOV-3(was GOV-4)Statement on due diligenceReported
Statement on due diligence
Reference: page 74.
"DIS conducts thorough due diligence in the selection of suppliers and business partners, ensuring adherence to the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights" (page 74). The report maps the core due-diligence elements to specific chapters: embedding in governance via the Corporate Governance Statement and DMA; stakeholder engagement via "Our Value Chains" and "DIS' Stakeholders"; impact identification via the topical IRO tables; action-taking via the ESG Plan; and effectiveness tracking via the "2025 Progress overview" tables in each topical chapter (page 75).
GOV-4(was GOV-5)Risk management and internal controls over sustainability reportingReported
Risk management and internal controls over sustainability reporting
Reference: page 59.
"The Board of Directors oversees the Internal Control and Risk Management System, following the Corporate Governance Code and best practices", with the system "defined in accordance with the 'COSO Framework'" (page 59). "Since 2022... the Group has been reviewing its risk assessment methodology, incorporating an ESG perspective", and "since March 2025, the ESG dimension has been included in the annual risk-based audit plan." During 2025, "the Internal Audit Division conducted an evaluation of Entity Level Controls (ELCs) related to Sustainability reporting" and, "with the support of a specialized internal audit firm... initiated an audit of the sustainability reporting drafting process in December 2025."
SBM-1Strategy, business model and value chainReported
Strategy, business model and value chain
Reference: pages 9-11, 17-19, 76-78.
DIS "through its wholly owned subsidiary d'Amico Tankers d.a.c., controlled a fleet of 29 vessels" in 2025, "primarily engaged in the transportation of refined oil products" (pages 9-11), generating "US$ 346.5 million" of revenue, down 29% year on year. Its value chain spans vessel construction and disposal and a "Maritime operational VC" of ship maintenance, management and employment (pages 17-19). In 2024 the d'Amico Group "drafted and approved the first version of its ESG Plan", later "adapted and applied specifically to DIS", with KPIs and 2030 targets for each material topic (pages 76-78).
SBM-2Interests and views of stakeholdersReported
Interests and views of stakeholders
Reference: pages 20-23, 71.
DIS maps internal stakeholders (personnel, shareholders, Board members) and external stakeholders (clients, suppliers, banks, insurers, flag and maritime authorities, NGOs) with their "needs and expectations" and engagement channels (pages 20-23), noting for example that "in 2024, all oil majors updated their vetting regime (SIRE 2.0), which shifted the focus of inspections." "During 2023 and 2024... stakeholders were also engaged through feedback surveys conducted during the initial phases of the Double Materiality Assessment", with "17 external stakeholders" participating in 2023 (76.5% response rate) and "10 responses" in 2024 (page 71).
SBM-3Material impacts, risks and opportunities and their interaction with strategy and business modelReported
Material impacts, risks and opportunities and their interaction with strategy and business model
Reference: pages 70-71, 82.
The 2024 DMA "identified 54 material IROs (29 impacts, 13 risk categories with 41 risks, and 12 opportunities)", finding "7 out of 10 sustainability topics from ESRS... material": Climate Change, Pollution, Biodiversity and Ecosystems, Circular Economy (inflows), Own Workforce, Workers in the Value Chain and Business Conduct (page 71). Each topical chapter opens with a table of "Material Impacts, Risks and Opportunities" placed across "Upstream VC", "Business Operations" and "Downstream VC", and a second table describing "their interaction with DIS' strategy and business model" (page 82 example for Climate Change).
IRO-1Description of the processes to identify and assess material impacts, risks and opportunitiesReported
Description of the processes to identify and assess material impacts, risks and opportunities
Reference: pages 70-71.
The DMA process ran in two rounds: "In 2023, the Group conducted its first Double Materiality Assessment (DMA)... During 2024, the focus on value chains was incorporated in the second round" (page 70). It proceeded through longlist set-up, internal and external stakeholder engagement, "digital questionnaires" rating each IRO "from 1 (low) to 5 (high)", and "a further qualitative analysis... with a top-down approach" (page 71). "In 2025, DIS did not perform a new assessment, as the previous assessment was designed with sufficient flexibility to capture potential developments", and no material changes were identified during the year.
IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statementReported
Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Reference: pages 186-196.
DIS publishes a full "ESRS Content Index" (pages 186-190) mapping each Disclosure Requirement to its report section and page, followed by a "List of datapoints deriving from other EU legislation" (pages 191-196) covering SFDR, Pillar 3, Benchmark Regulation and EU Climate Law cross-references. The index marks each DR as reported with a page reference, "Reported under MDR-P/MDR-A/MDR-T", "Not material" / "N.A.", or "Use of phase-in provisions in accordance with Appendix C of ESRS 1" where the Group has deferred disclosure, providing the authoritative map used throughout this entry.
E1 – Climate Change
E1-1Transition plan for climate change mitigationReported
Transition plan for climate change mitigation
Reference: page 89 (pages 60-63).
"DIS is actively working towards the definition of transition plan. Insofar, the Group has defined (in 2024) and monitored (in 2025) emission intensity reduction targets, included in the ESG Plan. In the next couple of years, the Group will model emission reduction targets in absolute terms, which will then integrate existing targets to form the transition plan towards Net Zero" (page 89, footnote 41). "While the Group has not yet adopted a formal transition plan, in 2024 DIS published its first ESG Plan, which establishes specific targets to measure progress towards climate change mitigation goals", focused on energy efficiency, fleet upgrades, alternative fuels and digitalisation (page 89).
E1-2(was covered under ESRS 2 IRO-1)Identification of climate-related risks and scenario analysisReported
Identification of climate-related risks and scenario analysis
Reference: pages 85-87.
Back-filled from ESRS 2 IRO-1 and the E1 climate-DMA section, where this content is disclosed in the FY2025 report (pages 85-87). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against. DIS assessed transition risks/opportunities using "the NGFS' 'Orderly' scenario ('Net Zero 2050'), which assumes global warming is limited to 1.5C by 2050", and physical risks using "the NGFS... climate scenario 'Hot house world - Current policies', assuming a 3C global warming by 2050 under existing policies" (page 86). Hazards were split into "chronic" (ice-cap melting, sea-level rise, hydric stress) and "acute" (cyclones, floods, droughts), and time horizons applied "short-term (within 1 year), medium-term (1 to 5 years), and long-term (over 5 years)", with the long-term horizon keyed to vessels' "useful life... typically around 25 years" (page 86). The analysis dates to the 2024 DMA update and was not refreshed in 2025.
E1-3(was covered under ESRS 2 SBM-3)Resilience in relation to climate changeReported
Resilience in relation to climate change
Reference: pages 68, 87.
Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (pages 68, 87). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against. DIS states plainly that no formal resilience analysis has been carried out: "The Group has not yet carried out a complete resilience analysis. The following paragraphs, however, provide an assessment of how IROs arising from business operations and along VCs permeate the business strategy and orient strategic decisions" (page 87, footnote 39). A dedicated ESG Plan goal and KPI on conducting "a physical and transitional climate-related risk assessment and resilience analysis across the entire scope of the Group" was removed from the 2025 monitoring table "as the resilience analysis has been temporarily put on hold pending further assessment of the legal framework and the evolution of market scenarios", though "the goal continues to be monitored internally" (page 68).
E1-4(was E1-2)Policies related to climate change mitigation and adaptationReported
Policies related to climate change mitigation and adaptation
Reference: page 87.
"The Group's business model integrates environmental considerations and energy performance improvements through its Environmental and Energy Policy, demonstrating DIS' commitment to reducing emissions and minimizing its environmental impact" (page 87). "DIS adheres to ISO 50001 and ISO 14001 standards, focusing on preventing environmental threats and improving energy efficiency", with vessel performance "reviewed annually through the Integrated Management System Review." Climate-related risks are additionally managed through "its 'Carbon War Room', a dedicated internal framework used to monitor regulatory changes, assess decarbonization pathways and evaluate investments in retrofits and innovative technologies."
E1-5(was E1-3)Actions and resources in relation to climate change policiesReported
Actions and resources in relation to climate change policies
Reference: pages 89-91.
DIS' 2024 ESG Plan sets out five climate action strands: "Fleet renewal through the phase-out of oldest vessels", "Installation of energy-saving devices like propeller boss cap fins (PBCF), wake equalizing duct (WED)...", "Conducting feasibility studies on Carbon Capture technology", "Implementation of Xpert software to improve the efficiency of machineries", and "Testing of B50-B40 biofuel from renewable feedstock" (page 90). In 2025, "Optimum Ship Routing was effectively employed for 76% of spot voyages over 5 days of duration, compared to a target of 50%", and "DIS installed the first wake equalizing ducts on 2 vessels" (page 90), while biofuel use reached "almost 1% of total bunker fuel consumption across the owned and bareboat chartered fleet."
E1-6(was E1-4)Targets related to climate change mitigation and adaptationReported
Targets related to climate change mitigation and adaptation
Reference: page 89 (reported under MDR-T).
"DIS has not yet adopted a transition plan nor it has set emission reduction targets in absolute value. This decision reflects the complex nature of scope 1 emissions from the fleet, which account for approximately 98.2% of total GHG emissions... Setting a target based on a linear reduction relative to a base-year could be misleading" (page 91). Instead, the 2024 ESG Plan sets six intensity-based KPIs "in line with the first two 'levels of ambition' of the 2023 IMO Strategy": fleet EEDI/EEXI (2030 target 4.12), EEOI (2030 target 12.84), CII (2030 target 5.81), a "Zero-equivalent" vessels indicator, biofuel blend share (2030 target 5%) and Optimum Ship Routing uptake (2030 target 100%) (page 89).
E1-7(was E1-5)Energy consumption and mixReported
Energy consumption and mix
Reference: pages 92-96.
Total bunker fuel consumed by DIS' owned and bareboat fleet in 2025 "amounted to 168,557 tons", with "Very Low Sulphur Heavy Fuel Oil... remain[ing] the most employed fuel type, accounting for 60% of the total mix" and "Biofuel Oil consumption... more than tripled... accounted for 0.86% of the total mix" (pages 92-93). Total energy consumption from non-fossil sources was "1.10%" in 2025, against "98.90%" from fossil sources, and "In 2025, DIS' energy intensity has increased by 40%", mainly "due to the decrease in revenues with respect to 2024 levels (-28%)" (pages 95-96).
E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissionsReported
Gross Scopes 1, 2, 3 and Total GHG emissions
Reference: pages 99-103.
"Total Scope 1 GHG emissions" fell to "247,301.9" tCO2e in 2025 from "355,010.8" in 2024, a 30.3% reduction (page 99). Scope 2 market-based emissions were "15.4" tCO2e, down 38.2% (page 101), giving gross Scope 1+2 market-based intensity of "0.00092238" tCO2e/$ (page 102). On Scope 3: "For 2025, DIS is not reporting on Scope 3 GHG emissions, opting for the phase-in provision set out in ESRS, which was extended to F.Y. 2025 by the 'quick fix' delegated act for wave 1 companies with less than 750 employees", adding that time-charter emissions "will be reported under Scope 3" "starting from future editions" (pages 99-100).
E1-10(was E1-8)Internal carbon pricingReported
Internal carbon pricing
Reference: page 108.
Within the "EU ETS and Fuel EU Compliance" section, footnote 65 states plainly: "DIS does not rely on other ETS systems and it has not implemented an internal carbon pricing mechanism, yet" (page 108). The surrounding text explains that compliance costs are instead driven by the mandatory EU ETS, under which "the amount of emissions covered by the EU ETS has increased by more than 80% against 2024 and now accounts for around 10% of total emissions" (53,209.86 tCO2e in 2025), and by the FuelEU Maritime regulation, under which "DIS will result non-compliant with the regulation" for 2025.
E2 – Pollution
E2-1Policies related to pollutionReported
Policies related to pollution
Reference: page 122.
"This commitment is formalised through the Safety and Prevention of Pollution at Sea Policy, which establishes stringent measures to foster a culture of environmental protection... and continuously strive to minimise accidents and pollution incidents" (page 121). "The Environmental and Energy Policy asserts the Group's commitment to minimize air pollutant emissions and protect the marine environment." An "Open reporting system" lets "all personnel... report instances of environmental non-compliance without fear of retaliation", and the "STOP Working Card Policy... allows any seafarer to halt activities in cases of imminent environmental danger."
E2-2Actions and resources related to pollutionReported
Actions and resources related to pollution
Reference: page 122 (reported under MDR-A).
The ESG Plan's pollution actions include "Use of external audits to certify compliance with oil pollution prevention standards", "Implementation of the ISO 14001 management system", and "Continuous training on the subject of pollution at sea" (page 121). In 2025, "the voluntary environmental compliance audit (VECA) two-year programme (2025-2026) has seen 14 vessels visited during 2025, with no significant observation raised", DIS "completed the annual certification audit process, resulting in the confirmation of the certificate", and "a total of 5.104 hours of training were conducted on pollution and environmental protection for 486 seafarers" (page 121).
E2-4Pollution of air, water and soilReported
Pollution of air, water and soil
Reference: pages 124-128.
"In 2025, total air pollutants' emissions were estimated at 12.550 tons, representing a slight reduction compared to 2024 (-0.8%)... Nitrogen Oxides (NOx) accounted for the majority of emissions (76.6%), followed by Sulphur Oxides (SOx, 10.6%)" (page 122). For water, "DIS has identified copper and zinc as the main water pollutants that exceed materiality thresholds", with "Copper Emissions [tCu]" of "35.67" tonnes in 2025, down 12.1% (page 126). "In 2025, the owned and bareboat chartered fleet reported no spills of any kind" and "no maritime casualties occurred during the year" (page 127).
E4 – Biodiversity and Ecosystems
E4-2Policies related to biodiversity and ecosystemsReported
Policies related to biodiversity and ecosystems
Reference: page 129.
"At present, DIS has not adopted specific policies to manage its impacts, risks and opportunities related to biodiversity" (page 129). "However, the Group fully complies with IMO regulations and other legislation on the prevention of environmental harm and the protection of marine ecosystems", and "In compliance with the International Convention on the Control and Management of Ships' Ballast Water and Sediments, DIS has implemented plans, record books, and procedures to prevent ecosystemic damage associated with ballast water discharge" (page 129).
E4-3Actions and resources related to biodiversity and ecosystemsReported
Actions and resources related to biodiversity and ecosystems
Reference: pages 129-130.
DIS "has implemented several actions to protect biodiversity and the environment. These include developing a comprehensive biofouling management plan, monitoring biofouling risk profiles, retrofitting vessels to meet US Coast Guard BWTS certifications, enhancing BWTSs for turbid water conditions, and conducting periodic analyses to ensure compliance with the Vessel General Permit (VGP)" (page 129). Since 2021 DIS has also joined the "Right Whale Slow Zones program" and, since 2023, "Protecting Blue Whales and Blue Skies" voluntary speed-reduction programmes off California, "confirmed for 2025" (page 130).
E4-4Targets related to biodiversity and ecosystemsReported
Targets related to biodiversity and ecosystems
Reference: page 129.
"DIS has not yet defined specific objectives and targets explicitly addressing biodiversity. However, the Group has implemented several actions to protect biodiversity" (page 129). The one quantified ESG Plan target is "Maintaining a voluntary speed reduction (VSR) along the California coast", measured as "Share of voyages with VSR along the California coast", with a 2023 baseline of 100%, and 2025/2027/2030 targets and results all at "100%" (page 129).
E4-5Impact metrics related to biodiversity and ecosystems changeReported
Impact metrics related to biodiversity and ecosystems change
Reference: pages 129-130.
"100% of managed vessels in 2025 are fitted with a Ballast Water Treatment System" (page 129). The "Proportion of Fleet with Ballast Water Exchange & Treatment Systems" table confirms "Fleet with installed ballast water exchange system (%)" and "Fleet with installed ballast water treatment system (%)" both at "100%" for 2025 and 2024 (page 130).
E5 – Resource Use and Circular Economy
E5-1Policies related to resource use and circular economyReported
Policies related to resource use and circular economy
Reference: page 133 (reported under MDR-P).
"DIS maintains an up-to-date inventory of hazardous material across its fleet. This inventory is continuously updated during procurement, repairs, and recycling to uphold the highest safety and environmental standards" (page 132). The Group "has implemented a Preventive Maintenance System (PMS) that reduces the risk of vessel failure through scheduled technical inspections", and "ensures that waste management in its fleet adheres strictly to IMO/MARPOL 73/78 regulations through comprehensive internal procedures", prioritising "waste reduction at the source, reuse, recycling, on-board treatment, and proper discharge at port facilities" (page 132).
E5-4Resource inflowsReported
Resource inflows
Reference: page 134.
"To successfully conduct its business activities, DIS relies on 3 key dependencies in terms of resource inputs: Oil for bunker fuel... Oil for transported products... Steel for newbuildings used in the construction of vessels entering the fleet" (page 134). "In 2025 the Group acquired 2 second-hand ships - the High Navigator and the High Leader - which together accounted for an inflow of 22,368 tonnes of steel", and "DIS recognizes the strategic importance of steel as a key resource and is committed to monitoring its use and impact" (page 134).
E5-5Resource outflowsReported
Resource outflows
Reference: pages 134-135.
"The double materiality assessment determined that the sustainability topic 'Circular Economy' is material for DIS, but only with reference to resources inflows. DIS has nevertheless chosen to report on resource outflows as well, on a voluntary basis" (page 131). Outflows take the form of fleet waste: "the total volume and weight of waste generated and disposed of by the fleet amounted to 116.1 tons" in 2025, of which "50.47%" was "discharged at sea, in full compliance with applicable regulations", "49.47%" disposed of ashore, and "0.06%" incinerated onboard (page 135).
E5-5(was E5-5-Waste)WasteReported
Waste
Reference: pages 134-135.
"As a service-oriented company, DIS does not engage in production processes that consume raw materials or generate outputs and waste related to manufacturing activities", but voluntarily reports fleet waste data (page 132). "In 2025, the total volume and weight of waste generated and disposed of by the fleet amounted to 116.1 tons, representing an increase of 16.5% in terms of weight compared to the previous year" (page 135), sorted on board into "food, operational, plastic, domestic, electronic, and incinerated ashes" and handed to the port agency, over whose final disposal "DIS... does not maintain direct oversight" (page 134).
S1 – Own Workforce
S1-1Policies related to own workforceReported
Policies related to own workforce
Reference: pages 142, 147, 150, 154, 158, 164.
Own workforce is a material topic, and footnote 82 notes DIS "benefits from the phase-in provision outlined in ESRS 1, Appendix C... However, due to the importance that the Group assigns to this topic, the following pages will provide information on several policies, targets, lines of action and relevant metrics on a voluntary basis" (page 138). Policies covering this topic include the d'Amico Group "Code of Ethics" and a dedicated "policy to ensure safe working conditions for all seagoing personnel" referenced in the Business Conduct chapter (page 74), alongside topic-specific policies set out throughout the Own Workforce chapter (e.g. Diversity Policy, page 56).
S1-2Processes for engaging with own workforce and workers' representatives about impactsReported
Processes for engaging with own workforce and workers' representatives about impacts
Reference: pages 140-163, 172.
Seagoing personnel are "represented by the International Transport Federation (ITF)" under the Collective Bargaining Agreement, and engagement channels include "Ongoing communication with the HR department and head of crew", the "Lighthouse" internal magazine, and periodic "engagement survey" feedback used to "develop an improvement plan based on feedback received" (pages 138, 140). Diversity within governance bodies and personnel feedback mechanisms are described throughout the Own Workforce chapter (pages 140-163).
S1-2(was S1-3)Processes to remediate negative impacts and channels for own workforce to raise concernsReported
Processes to remediate negative impacts and channels for own workforce to raise concerns
Reference: pages 140-163.
"DIS' Whistleblowing Policy establishes the procedure and channel to report on alleged or attempted violation of DIS' Code of Ethics, Organization, Management and Control Model, policies and any applicable law or regulation committed by the Company, any of its employees or business partners, ensuring thorough and independent investigation" (page 170). A dedicated "reporting platform" ensures confidentiality, and the platform "is also available for reporting incidents occurring onboard" seagoing personnel specifically.
S1-3(was S1-4)Taking action on material impacts on own workforceReported
Taking action on material impacts on own workforce
Reference: pages 136-163, 174.
"None of the material, potential, negative impacts linked to workforce occurred during 2025" (page 138). Actions addressing the identified material IROs (harassment, privacy, health and safety, psychological distress) run throughout the chapter: new training on "Sexual Harassment Prevention, avoiding Bias in Talent..." is being introduced for seafarers, and the "Generations" training programme addresses multi-generational workplace dynamics (pages 148-150 area).
S1-4(was S1-5)Targets related to own workforceReported
Targets related to own workforce
Reference: pages 136-163.
The ESG Plan sets workforce-related KPIs and targets such as training coverage goals, e.g. "Achieve 100% ESG training for all" employees and a project "training at least 75% of employees by the end of that year" for a sustainability-strategy training game delayed to 2026 (page 153 area). Targets for onshore and seagoing turnover, training hours and performance-review coverage are tracked throughout the chapter's ESG Plan tables (pages 136-163).
S1-5(was S1-6)Characteristics of the undertaking's employeesReported
Characteristics of the undertaking's employees
Reference: page 139.
"As of 31 December 2025, DIS employed 658 employees (-3.7% since 2024): 632 seagoing personnel and 26 onshore personnel. Notably, 10 women were part of DIS' workforce, compared to 648 men, who were employed mainly in Indian territory (583 employees)" (page 139). Breakdowns by country (Ireland, Monaco and others), gender and contract type are given in tables covering onshore and seagoing personnel (pages 139-141).
S1-6(was S1-7)Characteristics of non-employee workersReported
Characteristics of non-employee workers
Reference: pages 140-142.
"During 2025, there were no non-employees working within the onshore workforce" (page 140). For seagoing personnel, the chapter likewise states there were no independent workers (i.e., non-employees) in DIS' workforce, other than trainees, who are tracked separately: a chart of "Trainees among seagoing personnel" and "Temporary employees (excluding trainees)" is provided (page 142).
S1-7(was S1-8)Collective bargaining coverage and social dialogueReported
Collective bargaining coverage and social dialogue
Reference: page 142.
"DIS employs all its seagoing personnel under a seafarer employment agreement in line with international standards and regulations (Maritime Labour Convention 2006), as described in the Collective Bargaining Agreement (CBA). All of DIS' seafarers are represented by the International Transport Federation (ITF)" (page 142). Collective bargaining agreements cover "100% of hired" seagoing personnel.
S1-8(was S1-9)Diversity metricsReported
Diversity metrics
Reference: page 139.
"Women represented 38.5% of the onshore workforce and held 30.8% of management positions" in 2025 (page 139). Gender, age-band ("Under 30", "30-50", "Over 50") and management-level diversity are broken out across onshore personnel, Top Managers, Managers and onboard seagoing roles throughout the Own Workforce chapter (pages 139-142), alongside the Board, Nomination and Remuneration Committee, Control and Risk Committee and Supervisory Committee diversity tables (page 56).
S1-9(was S1-10)Adequate wagesReported
Adequate wages
Reference: page 140.
"In line with applicable benchmarks, all onshore employees receive wages that are commensurate with their roles and responsibilities" (page 140), and equally all seagoing employees "receive wages that are commensurate with their roles and responsibilities", with "the minimum reference salary... agreed every year with the International Transport Federation (ITF), in compliance with the minimum salary set by International Labour Organization (ILO)" (page 142 area). "Furthermore, no employee, whether onshore or seagoing, receives a wage below the fair wage standards."
S1-10(was S1-11)Social protectionReported
Social protection
Reference: page 150.
DIS provides seagoing and onshore personnel with benefits "including life insurance, supplementary healthcare, disability and" other protections (page 150 area), and the chapter includes a table "Seagoing personnel - Employees covered by social protection" setting out the share of the workforce covered against loss-of-income events such as sickness, unemployment, and incapacity (page 150).
S1-11(was S1-12)Persons with disabilitiesReported
Persons with disabilities
Reference: page 147.
"As of 31 December 2025, DIS had no employees with disabilities in its" onshore workforce (page 147), following an earlier statement of commitment regarding employees with disabilities in the onshore workforce (page 146 area). This nil finding is reported as the disclosed metric for the period.
S1-12(was S1-13)Training and skills development metricsReported
Training and skills development metrics
Reference: pages 154-158.
"Training activities for onshore personnel are organised according to the dedicated planning and management" process, and "Concerning seagoing personnel, DIS has a long-standing approach to collaboration with various maritime training institutions" (page 154 area). Metrics reported include "average hours of training for onshore" and "average hours of training for seagoing" personnel, alongside ESG Plan training-coverage KPIs (pages 154-158).
S1-13(was S1-14)Health and safety metricsReported
Health and safety metrics
Reference: pages 150-154.
"During 2025, DIS recorded no work-related injuries, including high-consequence injuries, losses of personnel, or fatalities" (page 153 area). Work-related injuries are defined to include "only 'serious injuries', i.e., those resulting in the crew member being disembarked and/or at least one [lost workday]" (page 151 area). Average hours of training on occupational health and safety for seagoing personnel are also tracked (pages 152-154).
S1-14(was S1-15)Work-life balance metricsReported
Work-life balance metrics
Reference: page 150.
DIS reports "employee satisfaction with work-life balance for onshore personnel and accommodations" and describes benefits covering "psychological well-being, work-life balance, and additional benefits that exceed legal" minimums (page 150). A dedicated "Work-life balance" section (page 150) addresses balance practices for both onshore and seagoing personnel.
S1-15(was S1-16)Compensation metrics (pay gap and total compensation)Reported
Compensation metrics (pay gap and total compensation)
Reference: pages 158-162.
"The gender pay gap for onshore and seagoing personnel is calculated as the difference between the average gross hourly pay of male employees and the average gross hourly pay of female employees compared to the average gross hourly pay of male employees" (page 159 area), with a table of "Onshore personnel - gender pay gap by professional category" (page 160). The "gender pay gap" is "not applicable for seagoing personnel, as no woman was part of the workforce as of 31.12.2025" (page 162).
S1-16(was S1-17)Incidents, complaints and severe human rights impactsReported
Incidents, complaints and severe human rights impacts
Reference: pages 172, 175-176.
"In 2025, no severe human rights violations or discrimination incidents were reported onboard" (pages 175-176). A table of "Severe human rights incidents - onshore and seagoing personnel" reports "Number of severe human rights incidents (e.g. forced labour, human trafficking...)" as zero, alongside zero associated fines. "No discrimination found during the year 2025" and no "forced labour and debt bondage situations" were identified "in the recruitment phases, ensured with annual audits" (page 172 area).
S2 – Workers in the Value Chain
S2-1Policies related to value chain workersReported
Policies related to value chain workers
Reference: page 164.
"At present, DIS has not adopted specific policies to manage its impacts, risks, and opportunities related to workers in the value chain" (page 164). "However, to prevent forced labour within its own operations and those of its vessel operation partners, particularly in case of debt bondage along the value chain, the Group conducts annual audits to verify that seafarers have not paid any fees or other charges for recruitment or placement. This requirement is also explicitly included in shipowner contracts with seafarer recruitment and placement services" (page 164).
S2-3(was S2-4)Taking action on material impacts on value chain workersReported
Taking action on material impacts on value chain workers
Reference: page 164.
"The ESG department, in coordination with several organisational functions, is currently developing the Group's Supplier ESG Code of Conduct, which will be rolled out to strategic suppliers from 2027 onward. This initiative is part of a broader strategy to gradually align with the incoming Corporate Sustainability Due Diligence Directive (CSDDD)" (page 164). Annual audits on seafarer recruitment fee practices are also conducted (page 164).
S2-4(was S2-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunitiesReported
Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reference: page 164.
"At present, DIS has not yet defined specific objectives, actions and targets explicitly addressing value chains and their workers. However, following the mapping and analysis of the vessels, maritime operational, and transported product value chains in the second half of 2024, DIS has gained a much deeper understanding of its VC stakeholders and dynamics. As a result, the overall strategy for managing material IROs will be revised to incorporate VC-related commitments" (page 164).
G1 – Business Conduct
G1-1Business conduct policies and corporate cultureReported
Business conduct policies and corporate culture
Reference: pages 170, 178.
"DIS promotes ethical conduct within the workplace as outlined in its Code of Ethics, which forms the foundation of the Company's corporate culture" (page 170). "The Group prohibits forced labour, child labour, and human trafficking and is unconditionally committed to respecting the human rights of seafarers... formalized in the 'Seafarers' Human Rights Policy'" (page 170). "Anchored in its Corporate Social Responsibility Policy, DIS's approach to business conduct and negotiations is guided by a strong sense of social responsibility and grounded in integrity and transparency" (page 170).
G1-2Management of relationships with suppliersReported
Management of relationships with suppliers
Reference: pages 178-181.
"DIS supplier screening procedures select and evaluate candidates based on their performance in quality, safety, and respect for the environment" (page 178). In 2025 the Group "conducted an in-depth analysis of its top 50 suppliers to identify 'strategic' ones. The analysis led to the identification of 24 suppliers to whom the [ESG] Code will be administered... accounting for around 48% of total expenditure" (page 179), to be rolled out from 2027. "Suppliers screened using environmental criteria" reached "50 (12.8%)" of the supplier base in 2025 (page 180).
G1-2(was G1-3)Prevention and detection of corruption and briberyReported
Prevention and detection of corruption and bribery
Reference: pages 175-176.
"The Anti-Corruption Policy adopted by DIS seeks to prevent all forms of corruption, including bribery... The policy promotes a 'zero tolerance' approach to bribery in any form" (page 175). "Compliance with the Anti-Corruption Policy is actively monitored through various mechanisms, including expense reimbursement and gift tracking systems, internal and external audits, and self-assessment reports of potential violations" (page 175). "In 2025, no cases of corruption, bribery, or anti-competitive behaviour were reported" (page 175), and all "at-risk" onshore functions received anti-corruption training (page 176).
G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conductReported
Targets related to business conduct
Reference: pages 175-176.
Back-filled from the business conduct chapter's MDR-T "other limb" description of how effectiveness is tracked in the absence of a stated target; this is the renumbered 2025/2026 successor to the 2023 ESRS MDR-T minimum disclosure requirement. "Compliance with the Anti-Corruption Policy is actively monitored through various mechanisms, including expense reimbursement and gift tracking systems, internal and external audits, and self-assessment reports of potential violations" (page 175), and training coverage for all at-risk onshore functions is tracked annually (page 176). No quantified target (e.g. an incident-reduction percentage) is set; effectiveness is instead tracked through these periodic monitoring mechanisms and the "zero" confirmed-incidents outcome reported for both 2025 and 2024 (page 175).
G1-4Incidents of corruption or briberyReported
Incidents of corruption or bribery
Reference: page 175.
The "Incidents of corruption" table reports, for both 2025 and 2024: "Total number of confirmed incidents of corruption" = 0; "Total number of confirmed incidents in which employees were dismissed or disciplined for corruption" = 0; "Total number of confirmed incidents when contracts with business partners were terminated or not renewed due to violations related to corruption" = 0; "Number of convictions resulting from violations of anti-corruption and anti-bribery laws" = 0; and "Total amount of monetary losses/fines as a result of legal proceedings" = "$0" (page 175).
G1-5Political influence and lobbying activitiesReported
Political influence and lobbying activities
Reference: page 177.
"DIS does not engage in direct or autonomous lobbying activities and does not provide political contributions - whether financial or in-kind - to political parties, their elected representatives, or individuals seeking political office" (page 177). The Group instead contributes to industry associations such as "INTERTANKO", "ECSA", "CONFITARMA" and "BIMCO", and "the Executive Chairman of DIS has been Chairman of INTERTANKO from November 2018 to November 2024" (page 177).
G1-6Payment practicesReported
Payment practices
Reference: page 181.
"A notable example is the Port Agencies supplier category, where contractual terms almost always require an advance payment of 95% of the total agreed amount at the time of appointment" (page 181). "In 2025, DIS maintained an efficient payment process... The average payment days recorded were" 2.41 days for "Technical suppliers" (down from 6.70 in 2024) and 2.49 days for "Shipping service providers" (down from 4.98), a reduction "mainly attributable to the settlement of high-value invoices related to drydock operations and vessel acquisitions" (page 181).