Hafnia Limited

The role of the administrative, management and supervisory bodies

Reference: pages 5-7.

Hafnia's Board has five non-executive members and no executive members (Table 1, page 6). "Four out of five Board Members (80%) are independent", and two of the five directors are women (Table 2, page 7). The report says Hafnia has no employee-elected Board members.

The Board "delegates oversight of impacts, risks, opportunities, and ESG reporting to the Audit Committee, which annually reviews and approves the Double Materiality Assessment", with the Board "retaining final accountability for ESG strategy and decisions" (page 6). Sustainability targets are set each year in the corporate strategy by the Executive Management Team and approved by the Board, and progress is reported to the Board at least annually (page 6).

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

Reference: page 6.

Hafnia refers readers to GOV-1 for the information provided to governance bodies. It adds that "While the Audit Committee and Board of Directors do not manage individual material topics, they oversee the reporting process to ensure these topics are appropriately addressed by management" (page 6).

In 2025 the controls and procedures for managing impacts, risks and opportunities were built into the annual Enterprise Risk Management review and into strategic decision-making (page 6).

Integration of sustainability-related performance in incentive schemes

Reference: pages 8, 25.

Executive Management pay has fixed and incentive-based parts under the Board-approved remuneration policy. "Sustainability indicators are reviewed annually, and the Remuneration Committee decides whether they are reflected in variable pay. As this is discretionary, no fixed share of variable compensation is linked to sustainability targets" (page 8).

The 2025 KPI card for the CEO and CFO (page 8) covers health and safety for owned ships (LTIF below 0.4 and TRCF below 1.0), the yearly engagement survey, female representation onshore, compliance breaches, Scope 1 emissions, carbon intensity and SOX compliance by Q2 2025. The climate KPIs were to "remain on track towards net-zero by 2050 and a 40% reduction in carbon intensity by 2028 (compared to the 2008 baseline)" (page 25).

Statement on due diligence

Reference: page 8.

Hafnia gives its due diligence statement as a mapping table (Table 3, page 8) that points to where each core element sits in the statement:

• Embedding due diligence in governance, strategy and business model: GOV-1, GOV-2, GOV-3, SBM-1, SBM-3.
• Engaging with affected stakeholders: SBM-2, IRO-1, S1-2, S1-3, S2-2, S2-3.
• Identifying and assessing adverse impacts: E2-IRO-1, E1-IRO-1, E4-IRO-1, E5-IRO-1, S1-SBM-3, S1-2, S2-SBM-3, G1-IRO-1.
• Taking action: E1-1, E1-3, E2-2, E4-3, E5-2, S1-4, S2-4, G1-3.
• Tracking effectiveness and communicating: E1-4, E2-3, E4-4, E5-3, S1-5, S2-5, G1-4.

Risk management and internal controls over sustainability reporting

Reference: page 8.

Sustainability risks and opportunities sit inside the Enterprise Risk Management (ERM) framework, with the Audit Committee overseeing sustainability reporting, annual risk reviews, internal controls and how well those controls work (page 8).

The main reporting risks named are "data quality and information availability" (page 8). Data quality is handled through the Watershed platform, which collects data, flags anomalies and applies set methodologies, plus internal reviews. For information availability, "the ESG team conducts a gap assessment each year" and works with the business to close missing items (page 8).

Strategy, business model and value chain

Reference: pages 9-11.

Hafnia is a product and chemical tanker owner and operator, "managing a fleet of over 180 modern vessels", with technical management, commercial and chartering services, pool management across eight segments, and Seascale Energy, a joint venture with Cargill's bunker business (page 9). Key customers are oil majors, chemical companies and commodity trading firms.

Revenue was USD 2,281,909K in 2025 (USD 2,868,647K in 2024). USD 1,421,831K came from sector H.50.20 (sea and coastal freight water transport), all of it from oil, and USD 860,078K from other activities (Tables 5 and 6, page 9). Headcount was 277 shore-based employees and 4,599 seafarers (Table 4, page 9). Sustainability enters the strategy through the "Responsible and Reduce Emissions" pillar (Figure 1, page 10). Figure 2 maps the value chain (page 11).

Interests and views of stakeholders

Reference: page 12.

Table 7 (page 12) lists the stakeholder groups, how and how often Hafnia engages them, and what each group wants: shore-based employees and seafarers, suppliers, pool partners, investors, customers, lenders, authorities, and industry and ESG associations. Channels include monthly townhalls and quarterly fleet letters for the workforce, biannual pool board meetings, investor roadshows and quarterly earnings presentations.

Stakeholder views reach the Audit Committee through quarterly informal discussions and are "formally reviewed annually as part of the Double Materiality Assessment (DMA)" (page 12).

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

Reference: pages 13-15.

Table 8 (pages 13-15) lists the material IROs with category, time horizon and link to strategy. Counting its rows gives 22: E1 (5), E2 (1), E4 (3), E5 (1), S1 (6), S2 (1) and G1 (5). The climate rows are vessel operating emissions, sustainable freight solutions, compliance with new environmental regulations, transporting new products and extreme weather. Other rows cover air pollution, invasive alien species, ship recycling, seafarer well-being and incidents, piracy, forced labor in the supply chain, and compliance, cyber and corruption risks.

Page 15 adds that no resilience analysis of the strategy and business model has been done yet, and that financial effects were assessed qualitatively.

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

Reference: pages 16-18.

Hafnia first ran its DMA in 2024 and refreshed it in 2025, covering own operations and the value chain (page 16). "An impact was considered material if the average score for scale, scope, irremediable (for negative impacts), and likelihood (for potential impacts) exceeded three." Negative impacts also count as material if any single criterion scores above three. Risks and opportunities were material if average magnitude and likelihood exceeded three on a 0 to 5 scale, assessed qualitatively with no monetary values (page 16).

The ESG Team ran the DMA; the CEO, CFO and Head of Investor Relations reviewed the scoring, and the Audit Committee and Board approved the results (pages 16-17). Affected communities were not included as stakeholders (page 17).

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

Reference: pages 1-2, 16.

The ESRS content index (pages 1-2) lists the covered disclosure requirements with a page number each, grouped as ESRS 2 (BP-1 to IRO-2), E1 (E1-GOV-3, E1-1, E1-SBM-3, E1-IRO-1, E1-2 to E1-6), E2 (E2-IRO-1, E2-1 to E2-4), E4 (E4-SBM-3, E4-IRO-1, E4-1 to E4-4), E5 (E5-IRO-1, E5-1 to E5-3, E5-5), S1 (S1-SBM-2, S1-SBM-3, S1-1 to S1-6, S1-8, S1-9, S1-10, S1-14, S1-16, S1-17), S2 (S2-SBM-3, S2-1 to S2-5) and G1 (G1-GOV-1, G1-IRO-1, G1-1, G1-3, G1-4). E2-4 is titled "Pollution of Air" in the index.

The index gives no datapoint list. Page 16 says all requirements under E3, S3 and S4 were omitted because those topics were assessed as not material.

Transition plan for climate change mitigation

Reference: pages 26-27.

Hafnia's climate strategy has three pillars: alternative fuels and cleaner solutions, better vessel performance, and emissions reporting that informs decarbonization decisions. Targets are a 40% cut in carbon intensity by 2028 against the 2008 baseline and net-zero Scope 1 emissions by 2050 (page 26).

The company is direct about the plan's limits: "Hafnia's current climate transition plan does not yet include a detailed multi-year roadmap showing how the business model and strategy will align with the Net-Zero target." It adds "In 2026, we will assess the feasibility of a comprehensive transition plan with clearly defined steps to achieve Net-Zero" (page 26). "Hafnia does not publicly disclose the OPEX and CAPEX allocated to its Climate Strategy" (page 26). It names locked-in emissions from a fleet where "most of the existing fleet still runs on fossil fuels" (page 26). The Executive Management Team approves the plan and the Board endorses it. Table 15 sets out three levers (pages 26-27).

Identification of climate-related risks and scenario analysis

Reference: pages 17, 25.

Back-filled from ESRS 2 E1-IRO-1 and E1-SBM-3, where this content is disclosed in the FY2025 report (pages 17, 25). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Hafnia drew on a 2023 TCFD exercise: "We analyzed two climate risk scenarios: a 1.5-degree Celsius and a 3-degree Celsius pathway" (page 17). The report does not name the underlying scenario models. Physical impacts were assessed at high level for vessels and seafarers, and "The assessment did not include a detailed hazard analysis" (page 17). Transition factors covered policy, renewable energy and energy-source shifts, for own operations only.

The DMA found one material acute physical risk (extreme weather damaging vessels and infrastructure) and one material transition risk (non-compliance with new environmental regulations) (pages 17, 25). The process text names sustainable freight solutions as the material opportunity (page 17); Table 14 also lists transporting new products as an opportunity (page 25). On decarbonization levers, "Climate scenarios have not been considered" (page 29).

Resilience in relation to climate change

Reference: pages 15, 25.

Back-filled from ESRS 2 SBM-3 and E1-SBM-3, where this content is disclosed in the FY2025 report (pages 15, 25). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Hafnia states it has not completed a climate resilience analysis. "While a comprehensive assessment of climate-related physical and transition risk resilience has not yet been completed, these risks are included in Hafnia's ERM framework, which incorporates vulnerability assessments and mitigation measures. Hafnia also conducts ongoing analysis of oil demand forecasts to assess potential financial impacts" (page 25).

The same gap is stated for the strategy as a whole: "A resilience analysis to evaluate the ability of our strategy and business model to address material risks and opportunities has not yet been conducted" (page 15).

Policies related to climate change mitigation and adaptation

Reference: page 28.

Hafnia has no standalone climate policy: "While we do not have a standalone policy, our approach to climate change is guided by our Climate Strategy, which defines targets and pillars that address material climate-related impacts, risks, and opportunities" (page 28).

The Climate Strategy summary (page 28) shows the CEO as accountable. It covers climate change mitigation, climate change adaptation, energy efficiency and renewable energy deployment, and maps to all five material climate IROs: vessel operating emissions, sustainable freight solutions, compliance with new environmental regulations, transporting new products as energy shifts to renewables, and extreme weather.

Actions and resources in relation to climate change policies

Reference: pages 27-28.

Most climate actions sit in the transition plan (page 28). Table 15 (page 27) lists them by lever: AI-driven Smartship technology installed on 32 vessels, class-verified emissions data through DNV's Emissions Connect platform, energy-saving devices such as Mewis Ducts and waste heat recovery, dual-fuel vessels (four LNG vessels operated since 2024, three methanol vessels delivered in 2025 and a fourth in January 2026), and 83 voyages carrying used cooking oil for biofuel in 2025.

"In 2025, Hafnia achieved an AER of 5.08, representing a 35% reduction in carbon intensity versus the IMO's 2008 baseline" (page 28); Table 16 shows 5.15 in 2024 and 7.84 for the baseline. "As noted in E1-1, Hafnia does not disclose OPEX or CAPEX for these actions due to commercial sensitivity" (page 28).

Targets related to climate change mitigation and adaptation

Reference: page 29.

Table 17 lists a Scope 1 carbon intensity reduction target (40% by 2028, 100% by 2050) and net-zero absolute Scope 1 emissions by 2050, with no Scope 2 or Scope 3 targets. "As part of Hafnia's climate strategy, we target a 40% reduction in carbon intensity by 2028 (compared to the 2008 baseline)", covering CO2 from all owned vessels on an equity-share basis (page 29).

The net-zero target is described this way: "While not science-based, the target aligns with the Paris Agreement and the IMO's 2050 pathway and has not yet been externally assured." "No targets are currently set for Scope 2 emissions, as they are non-material, or for Scope 3 emissions" (page 29). Target setting is led by the Technical and ESG Teams, with Executive Management and Board approval; external stakeholders were not directly involved.

Energy consumption and mix

Reference: pages 30-31.

Table 18 (page 30) breaks consumption into coal, crude oil and petroleum products, natural gas, other fossil sources, nuclear, renewable fuels including biomass, and purchased electricity, heat, steam and cooling. Total energy consumption was 7,160,822 MWh in 2025 against 7,800,572 MWh in 2024. Fossil sources made up 99.9% (2024: 100%), mainly crude oil and petroleum products at 7,150,771 MWh. Total renewable consumption was 9,533 MWh, or 0.1%, against 73 MWh in 2024.

Energy intensity on net revenue from high climate impact sector H.50.20 was 3.14 MWh per USD thousand in 2025 against 4.03 in 2024 (Tables 19-20, page 31).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 31-34.

In 2025 Scope 1 emissions were 2,008,387 tCO2e (2,200,393 in 2024, down 8.73%), market-based Scope 2 was 103 tCO2e, and Scope 3 was 867,047 tCO2e (up 31.7%), for market-based total emissions of 2,875,536 tCO2e (Tables 21-23, pages 31-32). Category 15 (investments) rose to 173,038 tCO2e after Hafnia bought a 13.97% stake in TORM in 2025 (page 32).

Scope 1 splits into 1,716,817 tCO2e under financial control and 291,570 under operational control (Table 22). "Currently 66.7% of Hafnia's Scope 3 emissions are based on primary data" (page 33). 2024 Scope 2 and 3 figures were restated (page 32). Emission intensity was 1.26 tCO2e per USD thousand of net revenue against 1.49 (Table 26, page 34).

Policies related to pollution

Reference: pages 35-36.

Hafnia relies on two policies (pages 35-36). The Health, Safety, Environment and Quality (HSEQ) Management policy aims to deliver cargo and services under "Zero Harm" principles, with the Head of People, Culture & Strategy and the Head of Technical accountable, and awareness tested through training and audits by flag states and classification societies.

The Environmental Management System (EMS) is built to "Comply with the ISO 14001 Environmental Management Standard", sits with the Head of Technical, and is monitored quarterly against the environmental plan with an annual management review. Both map to the air pollution IRO. The Climate Strategy targets also reduce non-GHG pollutants by lowering fuel use (page 36).

Actions and resources related to pollution

Reference: page 36.

Beyond the fuel-reduction work in E1, Hafnia takes specific steps to comply with MARPOL limits on NOx and SOx (page 36). Vessels must use compliant fuels at all times and meet international and local SOx limits. Vessels fitted with Exhaust Gas Cleaning Systems must follow strict operating parameters and monitoring requirements. The Newbuilding Team and vessel managers check that new designs meet NOx standards.

Effectiveness is verified through inspections by flag states and port state authorities, supported by management commitment and employee training (page 36).

Targets related to pollution

Reference: page 37.

Hafnia puts its effort into cutting GHG emissions, which also lowers overall air pollution, and "Hafnia has not set specific targets for individual air pollutants but remains open to developing them should future assessments indicate a need" (page 37).

The company reports it remains within MARPOL limits through regular monitoring of NOx and SOx emissions, and that any violations are reported in its quarterly Environmental Management Plan (page 37).

Pollution of air, water and soil

Reference: page 37.

The index and the chapter cover air pollutants only. Table 28 gives 2025 emissions (2024 in brackets): NOx 42,167 tonnes (93,330), SOx 4,997 (5,859), PM10 2,770 (5,184) and PM2.5 2,307 (4,770). CH4 and N2O are reported under E1 as part of Scope 1.

Hafnia also emits hydrochlorofluorocarbons but says it cannot report them "due to inconsistencies across available datasets". 2025 figures use DNV's refined methodology, so 2024 is not comparable and was not restated. DNV verifies these figures together with Scope 1 (page 37).

Transition plan on biodiversity and ecosystems

Reference: pages 38-39.

Hafnia has no biodiversity transition plan. Its DMA and ERM reviews led to no change in strategy: "biodiversity and ecosystem-related IROs did not result in the adaptation of our strategy or business model" because the strategic focus went to climate change (page 38). "Hafnia has not conducted a resilience analysis to assess the resilience of its strategy or business model" (page 38).

Table 29 (page 38) lists three material IROs: release of invasive alien species (potential negative impact), marine biodiversity and ecosystem degradation (actual negative impact) and environmental disasters such as cargo spills (financial risk). Hafnia has no sites in or near biodiversity-sensitive areas because vessels are not "sites" under the ESRS definition (page 38).

Policies related to biodiversity and ecosystems

Reference: page 38.

Hafnia's main biodiversity policy is its Environmental Management System, covered under E2. The company is plain about the gap: "Hafnia's policy does not explicitly reference biodiversity or ecosystem loss, nor does it directly address the identified material impact of invasive alien species" (page 38). It "outlines a general commitment to minimizing the environmental impact of our operations, including impacts on biodiversity."

The report lists eight matters the policy does not cover because the DMA found them not relevant or material, among them social consequences, sites near protected areas, product traceability, sustainable land and ocean practices, and deforestation (page 38).

Actions and resources related to biodiversity and ecosystems

Reference: page 39.

Table 30 (page 39) sets out actions by IRO. For invasive alien species, "Hafnia's entire fleet is equipped with ballast water treatment systems, in compliance with IMO regulations". For marine biodiversity, Hafnia reroutes vessels around Marine Protected Areas where it can and follows IMO guidelines (speed limits, limits on ballast discharge and anchoring) where passage cannot be avoided. A pilot with DNV on underwater radiated noise had monitoring systems installed on two vessels in 2025, and data analysis is under way.

For oil spills, Hafnia runs on-site MARPOL training and monthly spill drills and keeps a Shipboard Marine Pollution Emergency Plan. "No significant OPEX or CAPEX is required to implement the action planned or underway." It has used no biodiversity offsets or nature-based solutions (page 39).

Targets and metrics related to biodiversity and ecosystems

Reference: page 39.

"We have not adopted any biodiversity targets that comply with the mandatory minimum disclosure requirements set out in ESRS 2." Shipping legislation gives limited guidance, and Hafnia is working with classification societies on measurement methods for marine protected areas and cetacean habitats. Targets will follow "Once these methods and suitable metrics are in place" (page 39).

On spills, "In 2025, we experienced a minor incident involving a 100-liter operational bunker spill in port, which was immediately contained and cleaned up." Hafnia says it has since improved onboard crew training and coordination between teams (page 39).

Policies related to resource use and circular economy

Reference: page 40.

The single material E5 IRO is ship recycling and scrapping, a potential negative impact (Table 31). Hafnia's ship recycling policy aims to "Commit to responsible ship recycling and comply with the Hong Kong Convention 2009 and EU Ship Recycling Regulation 1257/2013". The Head of Technical is accountable, and monitoring relies on controls from the flag state and classification societies (page 40).

"Our policy does not address the transition away from virgin resources, sustainable sourcing, or renewable resources, as resource inflows were not assessed as material in our Double Materiality Assessment (DMA)" (page 40).

Actions and resources related to resource use and circular economy

Reference: page 41.

Hafnia is committed to recycling every vessel at the end of its life at certified facilities holding a valid class-issued Statement of Compliance with the Hong Kong Convention (2009) or the EU Ship Recycling Regulation (Table 32, page 41). It keeps a Ship Recycling Guideline up to date, and "we have shortlisted three compliant shipyards in Turkey". Quarterly forums between the Technical and Asset Management teams track regulatory changes and end-of-life planning.

The work is not expected to need material CAPEX; costs are limited to OPEX, mainly internal resources and monitoring, "with no significant additional OPEX or CAPEX required" (page 41).

Targets related to resource use and circular economy

Reference: page 41.

"Hafnia currently has no specific vessel-scrapping targets, as no vessels have been scrapped to date." Targets such as material recovery rates may be considered as experience builds (page 41).

Hafnia has set one near-term circularity target for operational resource use: "a near-term target to reduce plastic usage on board by 10% by 2028, using 2023 as the baseline". Progress is monitored and reported quarterly through the Environmental Management Plan (page 41).

Resource outflows

Reference: page 42.

Hafnia's E5-5 section covers waste only. Waste comes from three sources: onboard vessels (mixed plastics, food, domestic waste, incinerated ash, operational waste, e-waste, slops and sludge disposed ashore), offices, and vessel scrapping, which is "not applicable as no vessels have been scrapped to date" (page 42).

Onboard waste is measured by volume, entered into fleet reporting systems on arrival in port, and reviewed and consolidated by the HSEQ team. "Once waste is handed over to port reception facilities, Hafnia no longer has direct oversight of its final treatment or disposal", so end-of-life treatment is estimated from standard disposal practices (page 42). The section reports no product or material outflows.

Waste

Reference: page 42.

Table 33 (page 42) reports 34,667,907 kg of waste in 2025 against 35,405,442 kg in 2024. Hazardous waste was 33,604,323 kg (2024: 34,056,336 kg, restated to include hazardous waste classified differently before). Radioactive waste was zero. Non-recycled waste was 34,265,645 kg in 2025, or 99% of the total, the same share as in 2024.

Table 34 splits the 2025 total by treatment type and hazard class. Waste handled onboard follows MARPOL and is subject to random audits by internal auditors, class authorities, SIRE and Port State Control inspections; office waste is estimated by location (page 42).

Policies related to own workforce

Reference: pages 44-46.

S1 covers shore-based employees, in-house fleet seafarers and seafarers hired by technically outsourced managers (page 44). Table 36 (page 45) lists the policies and the IROs each one addresses: Vision, Purpose, Values; Human Rights Policy; Anti-Harassment and Anti-Bullying; DIBE; HSEQ Management; Drug and Alcohol; the maternity leave (seafarers) and parental leave (onshore) policies; Personal Relationship Onboard; and the Code of Conduct.

"While we do not have a formal piracy policy, we have a Security and Anti-Piracy Manual and vessel security guidelines in place" (page 45). The DIBE Policy bars discrimination on grounds such as age, nationality, gender identity, sexual orientation, ability and background, and onboard measures for women include properly fitting PPE and planning for at least two women onboard where possible (pages 45-46).

Taking action on material impacts on own workforce

Reference: pages 47-49.

Table 37 (pages 48-49) sets actions per IRO. Actions in 2025 include mental health sessions, a shorter contract for female seafarers returning after maternity leave, a campaign to cut seafarer paperwork, a new female Board director, inclusive-language training for the leadership team, and 50% female crews on three internally managed and three externally managed vessels in May 2025. Nine vessels now carry 40% women. Piracy risk is handled through procedures based on Best Management Practices. From 1 January 2026 all seafarers must complete IMO-mandated training on preventing harassment and bullying (page 49).

"The implementation of Hafnia's action plans and actions underway related to S1 does not require significant OPEX or CAPEX expenditures" (page 47).

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

Reference: page 50.

Table 38 lists the S1 targets: 40% female representation across offices, 30% female representation at manager level by 2030, 40% women onboard "New Normal" ships, more than 85% favorable result in the 2026 engagement survey, LTIF below 0.4 and TRCF below 1.0 observation per inspection for owned ships, and a 90% crew retention KPI. For harassment the aim is zero cases, with no set target.

Hafnia is candid about quality: "Hafnia's current targets are not aligned with the ESRS framework, as they are forward-looking goals rather than measurable targets with defined baselines or years." Business unit owners monitor targets without involving the workforce, and the Board gets annual reports (page 50).

Characteristics of the undertaking's employees

Reference: pages 50-52.

At year end Hafnia had 4,876 employees (4,959 in 2024): 277 shore-based, 2,368 seafarers on the internally managed fleet and 2,231 on the externally managed fleet (Table 39, page 51). Women were 104 of the shore-based staff and 643 of the total. Table 40 shows Denmark with 87 and Singapore with 146 shore-based staff.

Counts are year-end headcount, and the report notes that "headcount may overstate the active seafaring workforce by including employees who are off duty at the reporting date" (page 50). Male and female headcounts for 2024 were restated because they had been "inversely stated" (page 51). Turnover was 9.0% overall: 25 shore-based leavers (9.0%), 147 internally managed seafarers (6.2%) and 268 externally managed seafarers (12.0%) (Table 43, page 52).

Collective bargaining coverage and social dialogue

Reference: page 52.

"All our seafarers are covered by a Collective Bargaining Agreement (CBA)." Shore-based employees are not covered "because they are typically not unionized and can negotiate their employment terms individually upon hired" (page 52).

Hafnia has no employee representation agreements through a European Works Council, an SE Works Council or an SCE Works Council (page 52). Seafarer pay scales are set with the union through the CBA (page 52).

Diversity metrics

Reference: pages 51-52, 6.

The Executive Management Team of five has four men and one woman, an 80% and 20% split (Table 44, page 52). Women are 40% of the Board (Table 1, page 6). Across the workforce, women are 104 of 277 shore-based employees and 539 of 4,599 seafarers (Tables 41-42, page 51).

Table 45 (page 52) gives age bands: 1,239 employees under 30, 2,971 aged 30 to 50 and 666 over 50, from 4,876 in total.

Adequate wages

Reference: page 52.

Hafnia states that all employees receive fair wages above statutory minimum levels, set against local market benchmarks (page 52). Seafarer pay is governed by a Collective Bargaining Agreement that sets monthly salary scales with the union (page 52).

The report gives no table of employees paid below an adequate wage benchmark, and does not name a benchmark beyond local market levels.

Health and safety metrics

Reference: page 52.

Table 46 reports that 100% of workers are covered by a health and safety management system, with zero work-related fatalities in 2025 and 2024. Hafnia recorded 14 work-related accidents in 2025 (one incident involved two recordable injuries), a Total Recordable Case Frequency of 0.65 and a Lost Time Injury Frequency of 0.26 for the whole fleet. There were no cases of recordable work-related ill health (page 52).

Days lost is reported as not applicable: "seafarers work on fixed contract rotations rather than a standard work day calendar", so it is impracticable to quantify "workdays lost" consistently (page 52).

Compensation metrics (pay gap and total compensation)

Reference: page 53.

Table 47 (page 53) gives a gender pay gap of 39.2% for shore-based employees (2024: 42.9%) and 56.8% for seafarers (2024: 61.0%, restated from 62%). The report says the shore-based gap "reflects workforce composition, particularly in senior leadership and technical roles". For seafarers it says "There is no gender pay gap among seafarers of the same rank and nationality", because pay follows the Collective Bargaining Agreement.

The ratio of highest paid individual to median pay is 25.5 for shore-based employees (2024: 26) and 7.7 for seafarers (2024: 8.0, restated from 30 after an external technical manager reported total remuneration instead of monthly wages for some seafarers). Seafarer figures use base salary only (page 53).

Incidents, complaints and severe human rights impacts

Reference: page 53.

Table 48 (page 53) covers discrimination incidents and complaints from whistleblowing channels and the Designated Person Ashore (DPA) channel for seafarers. The report explains that "The increase in discrimination cases in 2025 is due to the inclusion of reports through the DPA channel", and whistleblowing reports were added for both 2024 and 2025 for comparability.

Hafnia reports zero severe human rights issues and incidents connected to its own workforce, zero complaints to National Contact Points for OECD Multinational Enterprises, and USD 0 in fines, penalties and compensation for discrimination and for severe human rights incidents, in 2025 and 2024.

Policies related to value chain workers

Reference: page 54.

Hafnia's commitments on value chain workers sit in its Supplier Code of Conduct and Human Rights Policy. "The Supplier Code of Conduct is an essential part of contractual agreements with suppliers and requires adherence to applicable labor laws and non-discrimination principles." The Human Rights Policy, described under S1-1, rests on the UN Guiding Principles and the ILO Declaration and addresses trafficking and forced labor (page 54).

Suppliers must comply with applicable laws and international labor and human rights standards, supported by random inspections of selected suppliers (page 54). The material IRO is potential negative impact on workers of suppliers and in shipyards (Table 49).

Taking action on material impacts on value chain workers

Reference: page 56.

Table 32 (page 56) sets the action plan for human rights and forced labor: enforce the Supplier Code of Conduct and Human Rights Policy and apply stricter human rights criteria to supplier selection. In 2025 Hafnia "Performed four audits related to areas outlined in the Supplier Code of Conduct" and ran a sustainability questionnaire for its largest suppliers. For 2026 it plans a supplier qualification process with ESG and human rights criteria in vendor selection.

"No breaches of the Supplier Code of Conduct or human rights violations have been identified through audits, background checks, or the whistleblowing platform", and "Hafnia is not aware of any reported or unreported severe human rights incidents involving workers in our value chain" (page 56).

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

Reference: page 56.

Hafnia says it monitors the effectiveness of its policies and actions on value chain workers, but "It has not yet set time-bound or outcome-orientated targets to address negative impacts or promote positive outcomes" (page 56).

The planned and ongoing actions are not expected to involve significant OPEX or CAPEX, though minor costs go to supplier engagement and due diligence (page 56).

Business conduct policies and corporate culture

Reference: pages 59-61, 58.

Table 37 (pages 59-61) lists each business conduct policy with the IROs it covers, how it is monitored, its scope and who is accountable. The policies are Anti-Bribery and Anti-Corruption, Supplier Code of Conduct, Corporate Governance, Anti-Trust, Anti-Money Laundering, Whistleblowing, Vision Purpose and Values, Human Rights, Anti-Harassment and Anti-Bullying, Code of Conduct, DIBE, GDPR and Privacy, Sanctions, Insider Trading, HSEQ Management, the Artificial Intelligence Policy, and Enterprise Risk and Fraud Risk Management. Monitoring ranges from training assessments and annual reviews of compliance breaches to supplier audits and an annual declaration form for the Code of Conduct.

Culture is built through the Code of Conduct and the CARE values, and Hafnia prohibits retaliation against whistleblowers (page 61).

Targets related to business conduct

Reference: pages 58-61, 8.

Back-filled from the business conduct chapter, where targets and effectiveness tracking fall under MDR-T rather than a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

The chapter has no business conduct target table. Two items stand in for one. The 2025 CEO and CFO KPI card lists compliance breaches and SOX compliance by Q2 2025 (page 8). Effectiveness is tracked through the policy table's monitoring column, where awareness is assessed through training courses and "compliance breaches on an annual basis" are evaluated for most policies (pages 59-61). "Hafnia's Compliance Program Plan is submitted annually to the Board of Directors, with any compliance breaches and material changes reported through formal board reporting" (page 58).

Incidents of corruption or bribery

Reference: page 62.

Table 53 (page 62) reports zero convictions for violation of anti-corruption and anti-bribery laws and USD 0 in fines, in both 2025 and 2024.

Hafnia's detection channels are the whistleblowing platform and the MACN reporting line, with allegations investigated independently and outcomes used to strengthen policies, controls and training (page 62).