Höegh Autoliners ASA

The role of the administrative, management and supervisory bodies

Reference: pages 97-99 (composition also incorporated by reference from the Board of Directors and Executive Management sections, page 96).

The Board of Directors has 9 members (eight directors and one deputy): 4 (44%) women and 5 (56%) men. Four directors (44%) are independent of the major shareholders. No executive manager sits on the board and there are no employee representatives (page 98). The board approves the overall strategy and the investments needed for the targets, oversees the sustainability approach, approves the DMA and approves the annual Sustainability Statements (page 98).

Two committees help. The Audit Committee oversees reporting, audit and ESG reporting processes and "reviewed and assessed the DMA on behalf of the board of directors". The Governance and Compensation Committee covers executive compensation (page 99). The Senior Management Team (2 women, 6 men) defines and implements strategy and targets, and sustainability topics are assigned to departments within four strategic priorities (page 99).

Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

Reference: pages 100-101.

The Board of Directors receives quarterly updates on performance against targets. Health and safety are "routine topics of discussion", and climate topics, including decarbonization goals, are "frequently reviewed"; governance topics such as anti-corruption are also discussed (page 100). The Audit Committee was upskilled through "targeted training sessions and workshops" to oversee CSRD reporting (pages 100-101).

Management evaluates due diligence implementation, policy effectiveness and action outcomes annually, with special sessions when significant changes occur. The company is "exploring options for quarterly reporting of impacts, risks, and opportunities" (page 101). In the period, the senior management team and the board reviewed specific IROs on climate change, biodiversity, health and safety, and governance (page 101).

Integration of sustainability-related performance in incentive schemes

Reference: page 101, incorporated by reference from the Remuneration report, page 6, on the company website (listed on page 96).

The statement itself is short: Höegh Autoliners "integrates sustainability-related performance in management's short-term incentive scheme", covering environmental and social topics, and points readers to the Remuneration Report for detail (page 101). The E1 chapter repeats that sustainability-related performance metrics sit in management's short-term incentive scheme to support the decarbonization strategy (page 137). The Governance and Compensation Committee reviewed compensation elements for staff and the executive team in 2025 (page 99). The Remuneration Report is not part of this document, so the weighting of sustainability metrics and the specific targets used are not visible here.

Statement on due diligence

Reference: pages 131-132 (index entry, page 126).

The report has a dedicated "Due diligence" section (pages 131-132). It is a mapping table that places the core elements of due diligence (embedding it in governance, strategy and business model; engaging affected stakeholders; identifying and assessing adverse impacts; taking action; tracking effectiveness and communicating) against sections of the statement. Cited sections include the ESRS 2 strategy, impact, risk and opportunity management and governance sections, SBM-2, the S1 and S2 engagement and remediation disclosures (S1-2, S1-3, S2-3), G1 Business conduct, and the topical chapters E1, E2, E4, E5, S1, S2 and G1 for action and tracking.

The table does not itself describe how due diligence is run. The process content sits under S1 (Human Rights Due Diligence, page 211) and S2 (supplier due diligence, pages 246-247).

Risk management and internal controls over sustainability reporting

Reference: page 102.

The corporate reporting department develops the group-wide annual reports, including the Sustainability Statements, and leads the DMA, climate-risk assessments and data collection with a cross-functional sustainability team. The company names the main risk itself: the process "is exposed to risk of material misstatement due to human errors or missing data" (page 102).

Controls are still being built. The company "is currently establishing relevant internal controls over sustainability reporting", starting with standardized definitions, calculations and emission factors under the GHG Protocol. The aim is a centralized approach where the department acts as an information hub that corrects inconsistencies in business-unit data. Progress is reported to the management team, to the board quarterly, and to the Audit Committee quarterly (page 102).

Strategy, business model and value chain

Reference: pages 103-105 (the index points to the Strategy and business section, page 96).

Höegh Autoliners provides Roll-on Roll-off (RoRo) ocean transport of automobiles, mining equipment and breakbulk cargo on Pure Car and Truck Carrier vessels: more than 2,000 port calls a year, about 1.6 million car equivalent units, and a fleet of around 40 vessels (page 103). It has 481 onshore employees and 1,282 seafarers of 24 nationalities in 16 offices (page 103). The ambition is a fleet with net zero GHG emissions by 2040, under four priorities: customer centric, greener, highly efficient and digitally enabled (page 104). Seven Aurora Class vessels were in operation at the end of 2025 (page 103).

Coal, oil and gas are each stated at 0% of activities (page 105). Value chain: own operations are ocean transportation, ports, terminals and offices; upstream is shipbuilding at shipyards; downstream is ship recycling at end of life (page 105). The company applies a phase-in for SBM-1 paragraph 40b-c (page 96).

Interests and views of stakeholders

Reference: pages 106-109.

The company says stakeholder views are "essential inputs both to our annual materiality assessment and continuous due diligence efforts" (page 106). A table (pages 107-108) sets out engagement by group: customers (day-to-day support, tenders, ESG questionnaires), suppliers (questionnaires, on-site due diligence assessments, sanctions screening), employees (engagement surveys, the working environment committee, training), investors, analysts, banks and insurers (reporting, roadshows, ESG ratings), governments and regulators, media, and industry and sustainability associations. Each has a stated purpose and an example outcome.

For the own workforce, channels include town halls, focus groups and surveys (page 109). Value chain workers are engaged through supplier collaboration, regular audits and an independent whistleblowing mechanism (page 109).

Material impacts, risks and opportunities and their interaction with strategy and business model

Reference: pages 109-110; topic tables on pages 137-140 (E1), 156-157 (E2), 167-168 (E4), 176-178 (E5), 203-206 (S1), 241-243 (S2) and 251 (G1).

The 2025 DMA was a reassessment of the first (2024) one. The material topics are E1, E2 (air and water pollution), E4, E5, S1, S2 and G1 (page 110). Climate is the largest impact: shipping is "contributing to about 3% of total GHG emissions globally" (page 110). Biodiversity impacts come from invasive species via ballast water and anti-fouling, and underwater radiated noise. Resource use impacts come from steel in newbuilding and vessel waste. Value chain workers include shipyard staff, third-party seafarers and recycling workers.

The company says a "qualitative climate-related analysis has demonstrated the business model's resilience" and that it identified no material adjustments to its financial statements for this or the next period (page 110). It applies a phase-in for SBM-3 paragraph 48e (page 96).

Climate-specific resilience content is also presented under E1-3 (2025 ESRS numbering).

Description of the processes to identify and assess material impacts, risks and opportunities

Reference: pages 111-116.

The 2025 DMA builds on the 2024 one and covers the value chain, with the main focus on own operations and first-tier suppliers (page 111). It uses an "internal scoring methodology, updated this year to apply a more granular 1 to 5 scale". Impact severity is scored on scale, scope, remediability and likelihood; risks and opportunities use the same 1 to 5 scale for expected financial effects and likelihood. A topic's materiality "is determined by its final score", topics below the threshold are non-material, and a validation workshop with key stakeholders confirms the outcome (page 112).

Topic notes: the climate analysis was guided by TCFD and used two IPCC scenarios, SSP5-8.5 and SSP1-2.6 (page 113). Air and water pollution were confirmed as material, and noise moved from pollution to biodiversity (page 114). Water was screened and no water IROs were found (page 114). The TNFD-based biodiversity assessment is "targeted for completion in the next reporting year" (page 115).

Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: pages 126-130 (content index); pages 117-125 (datapoints from other EU legislation); page 96 (phase-in and incorporation by reference).

The report prints a content index titled "Disclosure requirements covered by Höegh Autoliners' Annual Report 2025" (page 126). It names the section for each requirement and gives no page numbers. Covered: all ESRS 2 requirements (BP-1 to IRO-2); E1-1 to E1-6; E2-1 to E2-4; E4-1 to E4-4; E5-1 to E5-5; S1-1 to S1-6, S1-14, S1-16 and S1-17; S2-1 to S2-5; G1-1, G1-3, G1-4 and G1-5; plus topic-level SBM-3 and IRO-1 entries and entity-specific metrics for E1, E2 and S1 (pages 126-130). A separate table (pages 117-125) marks each datapoint derived from other EU legislation as material or not. The company exercises phase-in for SBM-1 40b-c, SBM-3 48e, E1-9, E2-6, E4-6, E5-6, S1-7, S1-8, S1-11, S1-12 and S1-14 (page 96).

Transition plan for climate change mitigation

Reference: pages 134-137.

Two targets anchor the plan: cut fleet carbon intensity by more than 30% by 2030 from 2019 ("30 by 30"), and net-zero vessel operations by 2040 ("0 by 40") (page 134). The plan "is fully integrated into the company's business strategy and financial planning" and was approved by the board with the updated decarbonization strategy introduced in 2022. It covers well-to-wake emissions of fuel used in vessel operations (Scope 1 and Scope 3 category 3) and "already addresses more than 80% of the value-chain emissions reported in 2025". The company is assessing a wider scope and exploring external validation of 1.5°C alignment (pages 134-135).

Levers (page 136): fleet renewal (12 Aurora Class vessels, about USD 1.5 billion committed capex; eight existing vessels expected in service in 2040 and eligible for conversion) and alternative fuels (ammonia, biodiesel, bio-LNG). A First Movers Coalition commitment targets at least 5% of deep-sea transport on green fuels by 2030 (pages 136-137). Locked-in emissions: eight legacy vessels, and the first eight newbuilds unless converted or run on biofuels (page 137). The company is "not excluded from the EU Paris-aligned Benchmarks" (page 137).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 E1 IRO-1, where this content is disclosed in the FY2025 report (page 113). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Höegh Autoliners ran "a qualitative climate-related analysis of its business model, guided by the Task Force on Climate-related Financial Disclosures (TCFD) recommendations", covering own operations and relevant upstream and downstream activities, with chronic and acute hazards, as part of the DMA (page 113).

Scenarios used (page 113):

• High-emission: SSP5-8.5, warming above 4°C by 2100
• Low-emission: SSP1-2.6, warming of 1.5-2°C by 2100

Timeframes follow the SBM-3 horizons; the company defines medium term as 1-10 years and long term as more than 10 years (page 95). Conclusion: transition risks (regulatory uncertainty, shifts in market sentiment, technology) are the primary climate-related financial risks, and physical risks are considered immaterial for this year's reporting (page 113). Individual transition risks are described on pages 139-140. The text lists no key assumptions.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (page 110) and E1 IRO-1 (page 113). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The company "annually assesses material impacts and risks as part of its strategy review, evaluating the resilience of its business model over the medium term", and states that "A qualitative climate-related analysis has demonstrated the business model's resilience with adequate measures in place" (page 110).

The IRO-1 analysis concludes that "given the nature of the Company's assets, the current fleet is expected to remain resilient to anticipated physical climate risks throughout its expected lifetime". Under a lower-temperature scenario physical risks are less significant, and transition risks are the primary financial risks (page 113). Related E1 content: the roughly 30-year asset life and propulsion technology uncertainty are discussed on page 140, and capacity to adapt rests on fleet renewal and the conversion eligibility of eight existing vessels (page 136). No quantified resilience result is given.

Policies related to climate change mitigation and adaptation

Reference: pages 141-142.

IMO regulations are the stated guide for policy development, with policies reflecting "a near-zero emission future for shipping, through fleet transition and adoption of alternative fuels" (page 141). Three documents are named:

• Environmental Policy: manages and reduces the environmental footprint, with initiatives to cut emissions across the value chain; applies to all subsidiaries, and the CEO bears ultimate responsibility (page 141).
• Environmental Focus Plan: an annual plan of objectives, targets and actions, focused on GHG emissions and non-renewable resource use; approved by the Chief Operations Officer and driven by Operations leaders, including the Head of Höegh Technical Management (page 141).
• Supplier Code of Conduct: environmental requirements for suppliers and subcontractors, overseen by the CEO (page 142).

All policies are available to employees on the intranet (page 142). The text does not set out separate adaptation policies.

Actions and resources in relation to climate change policies

Reference: pages 142-146.

Two areas: energy efficiency on the existing fleet, and fleet transition with alternative fuels, run through Ship Energy Efficiency Management Plans (page 142).

2025 technical upgrades (page 143): new propellers on 2 vessels (expected 3-6% annual fuel savings per vessel), boss cap fins on 3 (2-2.5%), turbocharger modifications on 3 (2-3%), variable frequency drives on 4 (up to 2%), and a data-analytics platform on 6 (about 1%). About MUSD 4.5 of capex went to these upgrades in 2025, with MUSD 6.5 expected in 2026.

Fuels (page 144): about 8,400 metric tons of ISCC-certified biofuel (B100) delivered, cutting around 26,000 metric tons of CO2e; letters of intent signed along the clean-ammonia value chain.

Fleet (pages 145-146): three more Aurora Class vessels delivered (seven in total); about MUSD 231 paid in newbuilding installments in 2025; remaining capex USD 493 million (USD 459 million from secured debt, USD 34 million equity); a MUSD 720 sustainability-linked loan from early 2024; two older vessels sold.

Targets related to climate change mitigation and adaptation

Reference: pages 147-148, 155.

"30 by 30" (pages 147-148): reduce fleet carbon intensity by more than 30% by 2030 from a 2019 baseline. It is an intensity target covering all vessels owned or technically managed by the Höegh Group. 2019 was chosen as the latest full year of externally audited IMO DCS data under normal operations.

"0 by 40" (page 148): net zero in vessel operations by 2040. It is an absolute target covering all vessels operated by the Group in the reporting year and the life cycle emissions of fuels (Scope 1 and Scope 3 category 3), with 2023 as base year.

Progress: carbon intensity (IMO CII, cgDIST) was 4.45 gCO2/(nm*GT) in 2025 against 4.98 in 2024 and 5.53 in 2019, "a reduction of nearly 20% from 2019 levels" (page 155). The company states that "Both targets are not based on conclusive scientific evidence" (page 148). Only these two targets are stated. [uncertain: the 2040 column of the emissions table on page 152 appears to show 96% for Scope 1 and 90% for Scope 3 category 3; read from flattened table text, check against the PDF]

Energy consumption and mix

Reference: pages 148-151.

Total energy consumption was 4,422 GWh in 2025 (2024, restated: 4,049 GWh), up 9.2%, driven by more vessels in operation (page 148). Fossil sources were 4,338 GWh: crude oil and petroleum products 3,342 GWh, natural gas 283 GWh, other fossil fuel (marine diesel oil) 712 GWh, purchased electricity, heat, steam and cooling 1 GWh. Renewable energy (biofuels) was 84 GWh (page 149). No coal, nuclear, purchased renewable or self-generated renewable energy is reported.

Energy intensity was 3.10 GWh per USD million of net revenue (2024: 2.95), with 98% fossil and 2% renewable (page 150). The company classes its activities as a high climate impact sector (NACE H50.2) (page 150). The 2024 figures were restated after an improved calculation of onboard fuel combustion (pages 149-150). The company notes the metrics are "not validated by an external body other than the assurance provider" (page 149).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 151-155.

2025 (tCO2e, 2024 in brackets; page 152): Scope 1 1,214,587 (1,114,732; +9%; 2023 base year 1,103,090); Scope 2 location-based 455 (463); Scope 2 market-based 736 (478); Scope 3 563,893 (971,002); total location-based 1,778,934 (2,086,198; -15%); total market-based 1,779,215 (2,086,212). 12% of Scope 1 fell under the EU ETS (2024: 15%).

Scope 3 (pages 152-154): category 1 purchased goods and services 83,099; category 2 capital goods 151,360 (-75%, reflecting newbuilding installment timing); category 3 fuel and energy-related activities 266,404 (+10%); category 4 upstream transportation 60,830; category 6 business travel 2,200. Four categories are material, all upstream; categories 5 and 7 were scoped out as insignificant (page 154). Intensity: 1.25 thousand tCO2e per USD million of net revenue (2024: 1.51) (page 154). Method: GHG Protocol with IPCC AR6 factors (page 153). [uncertain: the report prints the Scope 3 change as -72%, but its own figures imply about -42%]

Policies related to pollution

Reference: pages 158-159.

IMO regulation, chiefly MARPOL, sets the framework, and the company says its policies are aligned with applicable regulations for own operations and, where relevant, the value chain (page 158). Air: policies on sulfur, nitrogen oxides and emission control areas under MARPOL set procedures to control NOx, SOx and particulate matter, and the "MARPOL Protected Areas" policy covers marine protected, special, emission control and particularly sensitive areas (page 158). Water: the "Sludge and Bilge Water Operation and Maintenance Policy" covers processing, record-keeping, leakages and equipment maintenance, and the "Sewage Handling and Responsibility Policy" covers MARPOL Annex IV compliance (page 159). Vessel-specific plans are approved by class, and the Chief Operating Officer is responsible for implementation (page 159). The Environmental Policy and Environmental Focus Plan are described under E1-2 (page 158).

Actions and resources related to pollution

Reference: pages 159-160.

Air (pages 159-160): the company ties air pollution to fuel use, so the decarbonization measures under E1-3 are "expected to deliver corresponding reductions in non-GHG pollutants". It commits to fuels that meet the IMO 2020 global sulfur cap and uses fuel-switching procedures for emission control areas. It "has not established specific actions addressing air pollution at ship yards", and as no vessels were recycled in 2025 there are no downstream measures (page 160).

Water (page 160): all vessels carry Oily Water Systems with oil content meters; bilge water that cannot be processed is kept onboard until discharged at an approved shore facility. Sewage, graywater and bunkering follow strict procedures, supported by crew awareness programs, spill-response training and emergency plans, and spills of any size must be reported immediately. In 2025 the actions continued "without any significant challenges". No budget or capex is stated for these actions.

Targets related to pollution

Reference: pages 161-162.

Two fleet-wide absolute targets, with no baseline: zero major operational oil spills and zero fines related to oil spills (page 161). Results: no major oil spills in 2025, as in 2024, and no oil-spill fines. The accounting policy puts the major spill category at 700 tons (page 163).

The company says the targets are "not based on conclusive scientific evidence" and support its policies and procedures (page 161). It sets no specific air pollution target: air pollution is "implicitly included in the targets outlined in ESRS E1-4", and the effectiveness of air policies and actions is tracked at the same level of ambition as climate (page 162). The metrics are not validated by an external body other than the assurance provider (page 161).

Pollution of air, water and soil

Reference: pages 162-164.

Air pollutants (metric tons, 2025; 2024 restated in brackets; page 162): NOx 28,861 (28,664); SOx 2,765 (2,870); black carbon 29 (29); carbon monoxide 1,133 (971); particulate matter 1,398 (1,594); VOC 1,368 (1,277). They are calculated from actual fuel consumption and emission factors, using the Scope 1 methodology.

Entity-specific metrics (page 163): 0 major oil spills; 0 in oil-spill fines; 1,741 days in ECA/SECA areas (1,784); 1 non-compliance with environmental laws (1), a minor air-emissions finding that was corrected; sludge water 6,456 m3 (5,884); bilge water 6,340 m3 (5,892). About 96% of sludge went to shore facilities, and 83% of bilge water was discharged to sea after oily water system processing or sent ashore. Coverage is vessels technically managed by the Group (page 164). No soil pollutant data are given. Appendix B lists the E-PRTR Annex II pollutant datapoint as material (page 120).

Transition plan on biodiversity and ecosystems

Reference: pages 165-166.

The company states plainly that it has no dedicated plan: "While we have not developed a dedicated biodiversity transition plan", its assessment indicates that new technologies and better operating practice, together with management of emerging risks, "will strengthen the long-term resilience of our business model". It judges these measures "appropriate at this stage" (page 166).

Basis: the resilience of the business model to climate change and biodiversity loss is assessed through transition and physical risks, "informed by the Taskforce on Nature related Financial Disclosures (TNFD)", and considers marine impacts, regulatory developments, fleet adjustments and future operating costs, with input from internal and external stakeholders (page 166). The company has no operational sites in or near biodiversity-sensitive areas (page 167).

Policies related to biodiversity and ecosystems

Reference: pages 169-170.

Policies govern deep-sea operations and are available on the intranet (page 169). Named policies: the Ballast Water Management Overview (control of ballast water to prevent invasive alien species; under US and IMO requirements and ISO 14001, with a ballast water management plan for each vessel; page 169); the Biofouling Management Overview (under IMO MEPC 207(62) and ISO 14001, with vessel-specific biofouling plans; page 170); and Speed Restrictions to Protect North Atlantic Right Whales, with guidelines for transits of the US East Coast and Canada East Coast, linking speed to underwater radiated noise (page 170). The Chief Operations Officer oversees policy development and implementation, and monitoring is "a continuous process" (page 170). Appendix B lists the sustainable oceans and seas policy datapoint as material (page 121).

Actions and resources related to biodiversity and ecosystems

Reference: pages 170-173.

Actions are guided by IMO requirements (page 170). Ballast water (page 171): compliant treatment systems on all vessels, ballast voyage optimization and pre-arrival biosecurity submissions. A Tokyo and Paris MoU inspection campaign (1 September to 30 November 2025) produced two minor findings, on logging accuracy and alarm functionality. Anti-fouling (page 172): high-standard anti-fouling paint, hull cleaning and Marine Growth Protection Systems; coatings were renewed on vessels dry-docked in 2025; quarterly propeller polishing, with attention to Australia and New Zealand. Underwater noise (page 172): full compliance with speed restrictions in the 2025 Right Whale season, plus voluntary adjustment of sailing patterns.

No biodiversity offsets are included, and speed restrictions are considered a nature-based solution (page 173). No financial resources are stated for these actions.

Targets related to biodiversity and ecosystems

Reference: pages 173-174.

Three targets apply to all owned and technically managed vessels (page 173): zero incidents from Ballast Water Management resulting in PSC deficiencies, delay or fine; zero non-compliance with anti-fouling regulations; and no violation of speed restrictions. 2025 results (pages 173-174): two minor ballast water incidents with port state control deficiencies (2024: 0), no vessel detentions; zero anti-fouling non-compliances (as in 2024); no speed restriction violations (as in 2024).

The company says the targets are "not formally aligned with the Kunming-Montreal Global Biodiversity Framework", nor based on ecological thresholds, but pursue similar goals: preventing the spread of invasive species, reducing environmental impact and protecting threatened species (page 173). The metrics are not validated by external parties other than the assurance provider (page 174).

Policies related to resource use and circular economy

Reference: pages 178-179.

The group-wide Environmental Policy covers waste handling in operations, newbuilding and recycling. The annual Environmental Focus Plan adds focus areas and targets, "putting emphasis on our zero-waste overboard principle and green recycling" (page 178). Policies draw on MARPOL and the EU Ship Recycling Regulation, and the Chief Operations Officer oversees them (page 178).

Vessel waste: a fleet-wide Garbage Management Plan plus vessel-specific plans, monitored by the QA Machinery team, and a Biofouling Management Plan for waste from hull cleaning (page 178). Newbuilding and recycling: yards and recycling facilities must follow the Supplier Code of Conduct; the Green Recycling Policy aligns recycling with the Hong Kong Convention; a policy on the Inventory of Hazardous Materials (IHM) applies, with vessel-specific manuals (page 179). The company has "not established a separate policy specifically addressing reduced reliance on virgin resources" (page 179).

Actions and resources related to resource use and circular economy

Reference: pages 180-181.

Vessel waste (page 180): strict onboard segregation under a zero-waste overboard principle; only certain food waste goes to sea under MARPOL; labeled, color-coded containers and a garbage management officer on each vessel; MARPOL Annex V compliance is assessed by class every five years; LED lights replace cargo hold lights; suppliers must minimize plastic packaging and take it back where practical; garbage is logged daily.

Newbuilding (page 180): "no formal actions are currently in place" on steel use, because mitigation options are limited once a project is agreed; the company says it will consider the impact more before future projects.

Recycling (pages 180-181): each vessel keeps IHM documents, and a Ready for Recycling certificate is obtained when recycling is scheduled. No vessels were recycled in 2025. A letter of intent with Nordic Circles explores upcycling recovered steel into construction; timing is not set (page 181).

Targets related to resource use and circular economy

Reference: pages 181-182.

The company follows a fleet-wide zero-waste overboard principle. Voluntary waste targets (page 181): a 10% reduction in consumption of mercury-containing fluorescent tubes compared with the previous year (15,819 tubes in 2024; 1,126 in 2025; a 92% reduction), and a 5% year-over-year reduction in plastic waste generated onboard HTM vessels (871 cubic meters in 2025 against 769 in 2024, a 13% increase).

Ship recycling target, required by legislation (page 182): all vessels recycled shall comply with IMO-IHM and the EU Ship Recycling Regulation; no vessels were recycled in 2025. "No specific targets related to resource inflow related to our newbuilding process are set" (page 182).

Resource inflows

Reference: page 183.

Resource inflow is reported as steel consumed in the newbuilding program: 10,145 metric tons in 2025, against 71,012 in 2024. The company explains the fall by the milestone and delivery schedule: six vessels progressed through the relevant construction phase in 2024 and one in 2025 (page 183). Three vessels were delivered in 2025 and five remained in the program at year end. Steel is allocated to vessels when construction milestones are reached; for 2025 the single qualifying vessel's figure comes from its design specifications and lightweight data. The metric is not validated by an external body other than the assurance provider (page 183). No data on other materials, recycled content or renewable share are given, and the company sets no resource inflow targets (page 182).

Resource outflows

Reference: pages 184-186.

Waste from vessel operations is classed as hazardous or non-hazardous and delivered to shore facilities in port (page 184). The Höegh Group operated 47 vessels in 2025: 35 technically managed by the Höegh Autoliners Group and 12 by third parties; waste from the 12 is excluded. The company "does not actively recycle any type of waste", and the recyclable share of operational waste "remains unknown" because third parties handle disposal ashore (page 184).

Total waste generated was 2,111.6 m3 (2024: 1,980.0 m3), of which 1,804.0 m3 was directed for disposal and 307.5 m3 was reported as diverted from disposal (page 185). No data on product or material durability, recyclable content or packaging are given. Waste detail is under the Waste entry.

Waste

Reference: pages 185-186.

Waste is reported in cubic meters, not metric tons (page 185). Directed for disposal at approved shore facilities, 2025 (2024): food waste 20.3 (21.1), cooking oil 16.6 (29), scrap iron from the engine room 29.9 (14.5), plastics 870.6 (769.5), domestic waste 515.4 (495.3), aerosol cans 1.4 (1.2), expired pyrotechnics 1.0 (1.0), incinerator ash 22.2 (21.1), used batteries 1.4 (2.4), paint residues 38.6 (16.3), defective electrical equipment 44.1 (59.7), carbon soot from economizer 1.0 (0.2), operational waste 237.8 (242.5), expired medicines 3.8 (3.9). Total directed for disposal 1,804.0 (1,676.7); total waste generated 2,111.6 (1,980.0).

Waste generated is the sum of waste diverted from disposal (307.5; 2024: 302.6, a group headed by food waste incinerated 2.0, food waste to sea 138.6 and domestic waste incinerated 167.0) and waste directed for disposal (page 186). The report splits both into hazardous and non-hazardous materials [uncertain: the table layout is flattened in the extracted text, so the hazardous split is not read here]. Quantities come from the garbage record book, based on bin capacity, and are aligned with port facility receipts that Port State Control inspectors scrutinize (page 186).

Policies related to own workforce

Reference: pages 207-211.

Policies cover land-based employees and seafarers and are reviewed annually (page 207). All employees: the Code of Conduct (safety, mental health, human rights including a ban on forced labor, working hours and wages, non-discrimination; pages 207-208); the HSSE Policy, approved by the Director of Global HR with the Chief Operating Officer (page 208); the Employee Whistleblowing Policy and grievance mechanisms (page 208); the Human Rights Policy, with zero tolerance for harassment, discrimination and exclusion (page 210). Seafarers only: Crew Operations recruitment guidelines (fixed-term contracts under the MLC), the Crew Operations Manual (working and rest hours, health and safety training), the Safety and Environmental Management System (ISM Code, ISO 14001, 9001 and 45001), disciplinary guidelines and the Just Culture Policy (pages 208-209). Land-based only: Working Arrangement, Compensation and Employee Promotion policies (page 210). Human rights due diligence follows the UN Guiding Principles, the ILO Declaration and the OECD Guidelines (page 211).

Taking action on material impacts on own workforce

Reference: pages 214-219.

Secure employment (seafarers, page 214): benchmarking of compensation and benefits (adjustments effective 1 January 2026); health insurance for seafarers and dependents up almost 30% from 2025; from 2026 the company covers all company-specific training costs.

Working time (pages 214-215): extra seafarers on older or technically challenged vessels and an additional engine officer on vessels with new technology; risk assessments on rest hours; "Rest hours and workload management in busy ports" as a standing item at Officers' Conferences; stronger overtime guidance for land-based staff.

Health and safety (pages 216-218): a "Stop work authority" framework; senior officers inspect within two weeks of embarking; loose-cargo and freak-wave procedures; Risk of Overboard Fall placards after the July 2025 missing-crew incident; fire blankets, thermal imaging cameras and EV fire training; an Aurora simulator project with ammonia training; a mental health survey and course.

Equal treatment (pages 218-219): Gender Balance Program contacts and pre-departure dialogues for female seafarers; annual equal pay audits.

Targets related to own workforce

Reference: pages 220-222.

Seafarers (page 221): retention above 98% (all crew for HSFC, all officers for HSFP, per Shipping KPI 4.0), reviewed annually and monitored quarterly; Lost Time Incident Frequency (LTIF) of 0.7; zero port state control detentions and at most 0.7 deficiencies per inspection.

Land-based employees (pages 221-222): "no fixed target for working hours"; a work-life balance index of 85% in the 2025 engagement survey (same as 2024) is monitored annually.

No formal targets: discrimination and harassment (zero tolerance, with effectiveness tracked through reported incidents and complaints) and equal pay (the company is preparing for the EU Pay Transparency Directive in 2026 and continues equal pay audits) (page 222).

Results: LTIF 0.88 against 0.7 (page 224); deficiency per inspection ratio 0.83 against the 0.7 maximum, with no detentions; officer retention 97.6% (HFSP) and crew retention 99.3% (HFSC) (page 227).

Characteristics of the undertaking's employees

Reference: pages 233-240.

Headcount at year end, 2025 (2024; pages 233-234): land-based employees 481 (469), of whom 219 women and 262 men; seafarers 1,282 (1,212), of whom 34 women and 1,248 men. No "other" or undisclosed gender is reported.

Land-based: 470 permanent and 11 temporary; 475 full-time and 6 part-time; no non-guaranteed hours staff (page 234). By country, Norway has 74 and the Philippines 223 (page 234); a contract-type table covers 15 countries, including the USA 24, China 40, France 26, Germany 23 and Japan 23 (page 237). Seafarers: all 1,282 are on fixed-term contracts and counted as temporary, 478 in China and 804 in the Philippines (pages 235, 239-240).

Data come from SuccessFactors (land-based) and the OCS HR system (seafarers), as headcount at period end; the by-country headcount follows S1-6 AR 55 (pages 239-240). Leavers: land-based 37 (turnover 7.69%), seafarers 82 (6.40%) (page 223).

Health and safety metrics

Reference: pages 224-225 (index entry, page 129).

Seafarers only (page 224): 100% of the workforce is covered by the health and safety management system. 2025 (2024): fatalities 1 (0); lost time injuries 6 (4); Lost Time Incident Frequency 0.88 (0.64), against a target of 0.7 (page 221). The narrative says "five LTIs, up from four in 2024" while the table shows 6 [uncertain: the text and the table differ]. Recurring causes were slips, trips, manual handling and hand and finger injuries, plus more equipment-related incidents involving pressurized systems and lifting equipment.

The report also describes a crew member who went missing from the Höegh Trove in the Indian Ocean in July 2025; a search and rescue operation ended without result and an external investigation could not establish the cause (page 225). Cases of work-related ill health are "not reported as per the ESRS1 appendix C phase in provisions" (page 224). The metrics cover seafarers, not land-based staff.

Compensation metrics (pay gap and total compensation)

Reference: pages 229-230.

In 2025 the scope was widened to land-based employees and seafarers, and the 2024 figures were restated (page 229). Total remuneration ratio: 32.8 (2024: 144.4). The highest-paid individual earned 32.8 times the median total remuneration of all employees; the change is "primarily driven by the vesting profile of long-term incentive plan (LTIP) awards" for executive management, with a significant portion vesting in 2024 (page 229). The ratio covers land-based employees only (page 230). Gender pay gap: -11.9% (2024: 5.2%), meaning women earned on average 11.9% more than men; the company attributes this to "differences in workforce composition, seniority, and role distribution" (page 229). It uses average gross hourly pay, covers land-based employees and seafarers, and converts all pay to USD (page 230).

Incidents, complaints and severe human rights impacts

Reference: pages 231-232.

2025 (2024): severe human rights incidents connected to the workforce 0 (0); incidents of discrimination and harassment 0 among land-based employees and 2 among seafarers (1 and 5); complaints filed through grievance mechanisms 1 (0); total fines, penalties and compensation paid 0 (0) (page 231). The one office grievance led to no disciplinary action. The two seafarer incidents were reported to the crew manager under the onboard complaint procedure, with "appropriate disciplinary actions" where required. Complaints counted are those filed through the externally available whistleblowing channel (page 231). The company warns: "There is a risk of underreporting incidents of discrimination, harassment, and severe human rights violations within the workforce, as employees may fear retaliation" (page 232).

Policies related to value chain workers

Reference: page 244.

Three policies apply. The Human Rights Policy, based on the UN Guiding Principles, addresses forced labor, child labor, trafficking and slavery, fair and equal treatment and respect for regulations everywhere the company operates (detail under S1-1). The Supplier Code of Conduct sets requirements on forced labor, working hours, wages and benefits, and health and safety; it is public on the company website (detail under G1-1). The Whistleblowing Policy allows anonymous reporting and protects whistleblowers from retaliation (detail under G1-1). The company ties its business to supplier relationships: "The success of our business relies on maintaining strong relationships with suppliers who share our ethical principles." The policies are on the internal document management system (page 244).

Taking action on material impacts on value chain workers

Reference: pages 246-248.

Actions are continuous processes built into procedures "rather than specific short-term actions": ongoing risk assessments, human rights requirements in supplier contracts and compliance monitoring; "no specific budget is allocated for future actions" (page 246). New suppliers: a standardized registration procedure (since 2024) with third-party sanctions screening and a signed Supplier Code of Conduct (page 246). Existing suppliers: an internal functional risk assessment, then a third-party platform (introduced late 2024) that scores suppliers on location, industry and spend; high-risk suppliers get self-assessment questionnaires and further engagement (page 247). Yard audits: DNV ESG audits and annual internal follow-up at China Merchant Heavy Industry (page 247). Outcome: no severe human rights violations or breaches of the UN Guiding Principles, ILO Declaration or OECD Guidelines involving value chain workers were reported, and no incident needed remediation (pages 247-248). More detail is promised in a Transparency Act report due by 30 June 2026 (page 248).

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 248.

The company sets no targets for value chain workers. It states: "we have not set specific targets for managing potential material negative impacts on value chain workers". It monitors potential cases through external grievance mechanisms, supplier audit findings and ongoing stakeholder engagement, but "no formal qualitative or quantitative indicators are applied in this monitoring process". It is "assessing the appropriateness of introducing measurable targets and related indicators" for its supplier due diligence activities (page 248). This is the company's stated position under S2-5.

Business conduct policies and corporate culture

Reference: pages 251-254.

Four material G1 IROs are listed (page 251): an actual negative impact on responsible business conduct; potential negative impacts from corruption, bribery and facilitation and from whistleblower protection; and a potential positive impact from political engagement supporting maritime decarbonization. The Code of Conduct is described as "our moral compass"; it was reviewed in 2025 and gained a section on digital ethics, data privacy, cybersecurity and responsible AI use (page 252). The Board governs, the Audit Committee supports it, the Legal Department runs the compliance program, and local office leaders act as Compliance Ambassadors (page 252). Whistleblowing: an anonymous third-party platform open to employees and external stakeholders; cases are handled by Legal and HR; no specific training exists for handling reports (page 253). Supplier Code of Conduct: reviewed in 2025; new suppliers face third-party sanctions screening and must sign it (page 253). Training: mandatory Code of Conduct training, a gamified Attensi app and an annual Integrity Day (page 254).

Targets related to business conduct

Back-filled from the business conduct chapter. G1-3 became a standalone DR only in the 2025/2026 ESRS, and the report was prepared under the 2023 ESRS.

The G1 chapter states no business conduct targets. Effectiveness is tracked through monitoring instead (pages 255-256): incidents and demands are reported through HIS, assessed by the Legal Department and "regularly communicated to both the management team and the Board of Directors"; seafarer anti-corruption training completion is measured (65.6% in 2025, 63% in 2024); and demands for bribes (8 in 2025, 6 in 2024) and convictions or fines are counted. No target is set for these figures. The only forward-looking aim in the chapter is political: advocacy for a global level-playing field in line with the IMO net-zero 2050 target (page 257), which is an advocacy aim and not a conduct target.

Incidents of corruption or bribery

Reference: pages 256-257.

In 2025 the company received eight reports through HIS of demands for bribes or facilitation from its fleet, against six in 2024. Demands included requests for cigarettes, crew provisions and cash; crews rejected them, citing the zero-tolerance policy (page 256). The company says "There is a risk that seafarers are underreporting incidents", so it issued guidelines to vessel masters for ports with a MACN Local HelpDesk and updated the onboard anti-corruption computer-based training (page 256). It reports no convictions or fines for violations of anti-corruption or anti-bribery law in 2025 and no legal action on corruption or bribery (page 256). Definitions: demands for bribes are those reported through HIS; convictions and fines cover legal proceedings against any Group entity (page 257).

Political influence and lobbying activities

Reference: pages 257-258.

In 2025 the company advocated for a regulatory framework that ensures a global level-playing field and supports first movers in decarbonizing shipping, in line with the IMO target of net-zero by 2050, working through international regulatory bodies, industry coalitions and governments. The Chief Operating Officer oversees these activities (page 257). There is no specific policy on political engagement; the Code of Conduct says special caution applies to political contributions, which must meet public disclosure requirements and be reported through internal processes. The company is registered in the EU Transparency Register (971383591538-27) and the German Transparency Register (R007089). No financial or in-kind political contributions were made in the reporting year, and no management or board member held a comparable public administration position in the two years before appointment (page 257). Definitions are on page 258.