Hapag-Lloyd

The role of the administrative, management and supervisory bodies

Reference: pages 80, 85-86.

Hapag-Lloyd has "five members in its Executive Board and 16 members in its Supervisory Board" (page 85). The Executive Board has no non-executive members; all 16 Supervisory Board members are non-executive, and eight of them represent the employees and workers (page 85). At 31 December 2025, 20.0% of Executive Board members were female (80.0% male) and 31.3% of Supervisory Board members were female (2024: 37.5%); 68.8% of Supervisory Board members were independent (2024: 68.8%) (page 86).

Each Executive Board member is accountable for IROs in their own area: the CEO covers Regulatory Affairs & Sustainability, the COO covers Fleet and Cargo Service/Dangerous Goods, the CIO/CHRO covers IT and Global Human Resources, the CFO/CPO covers Legal and Global Procurement, and the CTIO covers the Terminal & Infrastructure segment (page 85). The Sustainability Committee, chaired by the Sustainability department, "is the key governance body overseeing material sustainability topics for both segments" (page 80).

The Supervisory Board competence profile asks for seats with knowledge of shipping, port terminals, risk management, accounting and auditing (including sustainability reporting), compliance, human resources and IT security (pages 85-86). The Executive Board "is responsible for determining whether the necessary skills and expertise are in place or need to be developed" (page 86).

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

Reference: pages 80, 85, 88.

The Executive Board "receives comprehensive updates on all material topics through annual DMA reviews and validations", and responsible departments report on due diligence implementation, policy effectiveness and, if set, progress on actions and targets (page 85). The Sustainability Committee sits between the departments and the board: its members, senior managers responsible for material topics, get updates on policy, action and target effectiveness ahead of each meeting, and the Sustainability department summarizes the committee's results for the Executive Board (page 80). The Chief Compliance Officer briefs the Executive Board quarterly and escalates critical issues at once (page 80).

Sustainability-related risks and opportunities enter the risk management framework through quarterly reporting in line with German Supply Chain Act (GSCA) requirements (page 85). The Supervisory Board "was continuously informed about the development process" of Strategy 2030, and the two boards jointly evaluate stakeholder feedback and materiality analyses (page 88). The material IROs these bodies deal with are tabulated in section 1.9 (pages 89-94).

Integration of sustainability-related performance in incentive schemes

Reference: page 85.

Executive Board pay has fixed and variable parts. The short-term variable pay "is not linked to sustainability targets", while 25% of the Long-Term Incentive Plan "depends on a metric for CO₂ emissions reduction" (page 85). The Supervisory Board sets annual target values from the company's Sustainability Linked Bond Framework of March 2021. ESG payments are calculated as 25% of allocation amounts multiplied by performance percentages, with 100% target achievement at specified Annual Efficiency Ratio (AER) levels of Hapag-Lloyd's own vessels and maximum achievement at 200% (page 85).

For 2025, 17% of the Executive Board's variable remuneration was linked to the AER metric defined in the Sustainability-Linked Bond, which "has a different process and reference framework compared to the AER metric of Strategy 2030" (page 85). AER measures vessel carbon intensity based on deadweight capacity and distance covered (page 85). Supervisory Board compensation "remains unconnected to sustainability performance metrics" (page 85).

Statement on due diligence

Reference: pages 88, 133-134.

A table on page 88 maps the core elements of due diligence to chapters of the statement: (a) embedding due diligence in governance, strategy and business model, in 1.3, 3.2 and 4.1; (b) engaging with affected stakeholders, in 1.2, 1.7 and 3.2; (c) identifying and assessing adverse impacts, in 1.2 and 2.1; (d) taking actions to address adverse impacts, in 1.2, 2.1, 2.2, 3, 3.2, 4.1 and 4.3; and (e) tracking effectiveness and communicating, in 1.3, 2.1 and 3.1.

Human rights due diligence (section 3.2.2) follows five steps: embedding due diligence in company processes, risk analysis, prevention and remedy, effectiveness evaluation, and communication (page 133). The Policy Statement on Social Responsibility and Human Rights commits the company to the UN Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises (page 134). Since 2025 the Terminal & Infrastructure segment has applied the Group's approach and is rolling out the due diligence system on a risk basis, starting with a project in Latin America (page 134).

Risk management and internal controls over sustainability reporting

Reference: pages 86-87.

Hapag-Lloyd uses its Risk Management System (RMS) and Internal Control System (ICS) to manage risks in sustainability reporting (page 86). A cross-departmental project team was set up for the CSRD requirements, and the reporting risks were identified in process workshops and assigned to overarching key controls (page 86). The main process risk named is failing to ensure the reliability, timeliness and transparency of sustainability reporting, including non-compliance with regulations and standards (page 86).

Mitigation: a CSRD manual, a central IT system that collects the quantitative data, and four-eyes checks built into data collection and reporting (page 86). Selected key controls are documented on the central ICS platform with named control owners, who confirm the controls in the annual ICS evaluation; the results feed consolidated ICS reporting to the Executive and Supervisory Boards (page 86). The RMS principles are built into IRO assessment, and quarterly ESG reports in the RMS are reviewed by the Sustainability department for inclusion as IROs (page 87).

Strategy, business model and value chain

Reference: pages 73, 81-84, 105.

Hapag-Lloyd is a business-to-business container liner shipping and terminal group with two segments, Liner Shipping and Terminal & Infrastructure. For the second, the statement says its content "primarily relate to Hanseatic Global Terminals (HGT) Latin America" (page 73). The company had 18,117 employees at 31 December 2025 (page 82) and net revenue of EUR 18,632.8 million (page 105).

The upstream value chain covers vessel shipyards, fuel suppliers, shortsea and inland transport providers, rail and truck services, port equipment and operational consumables; the downstream chain covers contract partners, customers and vessel recycling services (page 81). The company reports no involvement in the fossil fuel industry, so "zero revenue from fossil fuel-related activities", and no activities in chemical production, tobacco or controversial weapons (page 82).

Strategy 2030 makes decarbonization of the fleet "a key pillar": a one-third cut in container fleet emissions by 2030 against 2022 and an ambition of net-zero GHG emissions by 2045 (page 83). For the Terminal & Infrastructure segment, a sustainability strategy "is currently being developed" (page 83).

Interests and views of stakeholders

Reference: pages 87-88.

A table on page 87 lists each stakeholder group and how it is engaged. Customers are reached through DMA interviews, quarterly "Customer Connect Calls" with the CEO and a Customer Experience Survey. Suppliers take part in DMA interviews, sustainability workshops on decarbonization and human rights, and regional supplier days run by Procurement. Investors and banks are met one-to-one and at the Annual General Meeting, investor conferences and Capital Markets Days. Employees are engaged through the annual Employee Engagement Survey, annual reviews (the Global Staff Dialogue), town halls and mid-year reviews, and the Executive Board keeps up a regular dialogue with the Works Council.

The Sustainability Council, with members from science, politics, media, UN organizations and NGOs plus a climate activist, meets twice a year as a sounding board. Other groups are industry initiatives, a classification society, the local community (Heritage Day), policymakers (World Shipping Council, European Sustainable Shipping Forum), top management and the Supervisory Board (page 87). The company states that the current engagement framework requires no fundamental changes (page 88).

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

Reference: pages 82-84, 89-94.

Material topics (page 84): climate change mitigation and adaptation, energy, pollution of air and water, pollution as a driver of biodiversity loss, species population size, and resource inflows; working conditions and equal treatment for own workforce and value chain workers; corporate culture, protection of whistleblowers, management of relationships with suppliers, and corruption and bribery. Four entity-specific topics are material: corporate citizenship, data protection, IT security and security (page 83). Water and marine resources (E3), affected communities (S3) and consumers and end-users (S4) "were deemed not material" (page 83).

Section 1.9 (pages 89-94) tabulates the IROs by topic with type, value chain position, time horizon and policy. On strategy, the company says it "considers its strategy and business model resilient" and that "No business model change is required until 2030 to address material impacts" (page 84). It classifies the aggregated short-term financial effects of material opportunities as low and those of material risks as critical (page 84).

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

Reference: pages 76-79.

The DMA runs in steps: analyze the value chain and identify stakeholders, set the methodology and ESG topic list, identify IROs through stakeholder engagement and internal analysis, map IROs to the most granular topic level, assess and validate them, and calculate topic materiality (page 76). In 2025 the DMA was updated from the 2024 documentation and stakeholder insights, and IROs were assigned at sub-sub-topic level rather than sub-topic level (page 78). Impact materiality scores scale, scope, reversibility (negative impacts only) and likelihood; for potential negative human rights impacts, severity is weighted more heavily than likelihood (pages 78-79).

Risks and opportunities use 1-4 scales: likelihood from Remote (10% or less) to High (above 50%), and magnitude from Negligible (1 mUSD or less for risks, 5 mUSD for opportunities) to Critical (above 250 mUSD). "The IRO materiality threshold is set at 2 out of 4" (page 79). Risk management and functional experts in both segments validated results top-down (page 79). For climate, a risk and vulnerability assessment covered 60 locations and all vessels, and 17 transition events were reviewed (page 77). Engagement with affected communities and indigenous knowledge "will be considered in future iterations when deemed necessary" (page 76).

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

Reference: pages 88, 148-154.

Annex 5.2 (pages 153-154) is a content index of ESRS disclosure requirements. It gives chapter numbers (for example 2.1.1, 3.2.2), not page numbers. It lists ESRS 2 (BP-1 to IRO-2), E1-1 to E1-8, E2-1, E2-2 and E2-4, E4-1 to E4-5, E5-1 to E5-4, S1-1 to S1-7, S1-9, S1-14, S1-16 and S1-17, S2-1 to S2-4, and G1-1 to G1-4, with IRO and minimum disclosure requirement rows per topic and entity-specific rows for IT security, data protection and corporate citizenship. Annex 5.1 (pages 148-152) lists datapoints derived from other EU legislation with chapter references, marking several "not material for Hapag-Lloyd", some "not applicable for Hapag-Lloyd" and some "Phase-in".

Material sub-topics are listed on page 88 (E1; pollution of air and water; pollution as a driver of biodiversity loss and species population size; resource inflows; selected S1 and S2 sub-topics; G1 corporate culture, whistleblower protection, supplier relationships excluding payment practices, and corruption and bribery; four entity-specific topics). The company says "certain data points were not deemed relevant", naming G1-6 and the biogenic CO₂ datapoints (page 88). Datapoints under phase-in that are not reported "are not shown" (page 152).

Transition plan for climate change mitigation

Reference: pages 95-99.

Hapag-Lloyd does not present a full transition plan. After the IMO postponed its net-zero roadmap in autumn 2025, the company "decided to await further IMO decisions before further developing a comprehensive transition plan" (page 95). It does disclose Strategy 2030: an absolute target of one-third lower fleet GHG emissions (Scope 1 and related Scope 3.3) by 2030 against a 2022 baseline of 15.6 million t CO₂e, to around 10 million t, and an ambition of net-zero fleet emissions by 2045 (pages 96-97). The levers are fleet transformation, operational efficiency and alternative fuels. Measures delivered a 4.5 million t CO₂e reduction against 2022 by 2025, and a further 8.6 million t is expected to reach the 2030 target (page 98).

EUR 650.5 million of current CapEx is reported as EU Taxonomy-aligned and EUR 4.5 billion is allocated to future investments; no significant OpEx is planned for the measure (page 98). The company says its 2045 ambition deviates from the SBTi net-zero definition (page 97). The commitment covers Liner Shipping fleet operations only, and no targets exist for Scope 2, other Scope 3 categories, energy efficiency or adaptation (pages 97-98).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and E1 IRO-1, where this content is disclosed in the FY2025 report (pages 76-78, 89). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Physical risk (page 77). A climate risk and vulnerability assessment (CRVA) was run in the 2024 reporting year, using the Delegated Regulation (EU) 2021/2139 hazard classification and three IPCC-aligned scenarios (SSP 1-2.6, SSP2-4.5, SSP5-8.5) across 20 climate models. It screened 60 locations chosen by asset value, "around 90% of assets in the category" Land and Buildings, over short (2015-2044), medium (2035-2064) and long-term (to 2099) horizons. Vessels were assessed by region with RCP 8.5 (equal to SSP5-8.5), covering 100% of vessels. Cyclone exposure, glacial lake outbursts and ocean acidity were excluded because of service provider constraints. The result is 35 material physical risks (page 89).

Transition risk (page 77). Experts in five departments reviewed 17 transition events across the four TCFD dimensions to 2030, informed by a 1.5°C Paris Agreement-consistent scenario. No material transition risks were found. The report gives no global average temperature projection per scenario.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 (E1 SBM-3), where this content is disclosed in the FY2025 report (page 106). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The company says its resilience analysis "builds on the results of the CRVA and confirms that the Company's strategy and business model effectively adapt to and resist climate-related risks" (page 106). The period to 2030 was chosen "to reflect the current strategic direction of Hapag-Lloyd". Material physical risks sit mainly at office locations and terminals; the responses named are concrete foundations for terminal surfaces, maintenance of sewers, gutters and drains, emergency plans and firefighting drills. Vessels and containers are described as resilient to climate hazards, and all fossil-fuel-powered vessels "can operate on or be retrofitted for alternative fuels". Financing under the Green Finance Framework supports decarbonization investment (page 106).

On uncertainty, the statement says climate change adaptation "continues to be outside the strategy's explicit scope" and that adaptation risks "currently represent analytical uncertainties for long-term strategic planning" (page 99).

Policies related to climate change mitigation and adaptation

Reference: pages 98-99.

Hapag-Lloyd manages decarbonization-related IROs through Strategy 2030, with climate change mitigation as a core focus area "targeting a one third GHG reduction by 2030 and the ambition of net-zero fleet emissions by 2045" (page 99). The policy table gives the scope as the Hapag-Lloyd Group, with the climate commitment currently covering liner shipping activities of the operated fleet. Accountability sits with the Senior Managing Director Regulatory Affairs & Sustainability and the Senior Director Sustainability. Standards referenced are the 1.5 degree Paris Agreement and the DNV 1.5°C decarbonization trajectories for shipping. Stakeholder input came through a Global Strategy Summit, senior management sessions and research including customer insights and stakeholder interviews (page 99).

The Executive Board monitors progress quarterly through the Strategy 2030 dashboard, and the entire owned fleet (100% of vessels) is certified to ISO 9001 and 14001 (page 99). The company states the policy's limit: "no comprehensive climate policy addresses all identified material climate change-related IROs, as climate change adaptation continues to be outside the strategy's explicit scope" (page 99).

Actions and resources in relation to climate change policies

Reference: pages 98-99.

The company describes "a comprehensive strategy spanning fleet transformation, enhancing operational efficiency and alternative fuel innovation of both owned and chartered vessels" (page 98). The Fleet Upgrade Programme covers propeller installations, coatings, bulbous bow and engine refinements; 339 measures were implemented on vessels by end-2025, 90 of them in 2025 (page 98). Four newbuilds of 23,664 TTEU entered service in 2025 (page 98).

Alternative fuels: four LNG vessels delivered in 2025, 24 more LNG newbuilds ordered for delivery 2027-2029, eight smaller dual-fuel methanol ships ordered, 14 efficient newbuilds chartered for delivery by 2029, and a chartering partnership with Seaspan to convert five vessels from 2026. Biofuel use reached about 204 k metric tonnes of certified waste-based blends, and long-term supply agreements are in place for biomethane and green methanol (page 98).

Resources: EUR 650.5 million of current CapEx is EU Taxonomy-aligned (activity 6.10) and EUR 4.5 billion is allocated to future investments; "no significant operating expenditure (OpEx) is planned for the measure" (page 98). Delivery "is partly dependent on the continued availability and allocation of resources", such as alternative fuels and shipyard capacity (page 99).

Targets related to climate change mitigation and adaptation

Reference: pages 96-98.

Absolute target: cut Scope 1 and Scope 3.3 fleet emissions by one-third by 2030 from the 2022 baseline of 15.6 million t CO₂e, to about 10 million t. Relative target: an AER of 4.3 g CO₂/DWTnm by 2030, "more than halving the 2022 baseline of 9.13g CO2e/DWTnm" (page 96). The 2025 AER was 7.36 g CO₂e/DWTnm against 7.91 in 2024 (adjusted from 7.96), a 19% reduction versus 2022 (page 96). Fleet emissions rose to 18.6 million t CO₂e (2024: 17.7), made up of 15.8 million t Scope 1 and 2.8 million t Scope 3, as transport performance grew 13% (page 96).

The base year is "the latest complete year without COVID-19 distortions" (page 96). DNV validated the targets against a 1.5°C maritime model at "medium confidence levels" (page 96). The targets cover owned and chartered Liner Shipping vessels; "no additional targets exist for Scope 2 emissions, other Scope 3 categories, energy efficiency or climate change adaptation" (pages 97-98). The ambition of net-zero by 2045 deviates from the SBTi definition; remaining emissions are to be offset only by removal or compensation measures (page 97).

Energy consumption and mix

Reference: pages 100-101.

Energy intensity was 3.1 MWh per kEUR of net revenue (2024: 2.9) (page 101). The company attributes the rise to higher transport performance of the fleet and says cylinder oil use on chartered vessels was reclassified from Scope 3.4 to Scope 1 for 2024 (page 100). Hapag-Lloyd treats all its revenue as high climate impact sector (NACE H50) (page 101).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 102-105.

Scope 1 rose 4.6% while Scope 3 fell 14.9%, mainly because capital goods (category 3.2) dropped from 7,712,974.0 to 3,404,332.2 t as fewer containers and newbuild vessels entered service; upstream transportation (3.4) was the largest category at 11,050,788.5 t (pages 102-103). Intensity is 1.8 tCO₂e per kEUR of net revenue (2024: 1.9) on EUR 18,632.8 million (page 105). Scope 1 under regulated emission trading schemes was 17.6% (2024: 20.3%) (page 102). Primary data covers 0.2% of Scope 3 (2024: 0.1%, restated from the 49.4% first reported) after a change in the definition of primary data (page 103). Biogenic CO₂ outside the scopes is about 198,094 t (page 105).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 105.

No GHG removals or storage are reported: removals, reversals and associated emissions are all nil for 2025 and 2024 (page 105). The company says its strategy prioritizes direct emission reductions "at the source" in its own operations rather than internal removal projects or storage partnerships (page 105).

Carbon credits are bought separately: 23,248 t CO₂e were purchased and retired in 2025 (2024: 29,100 t), all from reduction projects (none from removals), all Gold Standard certified, and bought centrally to cover business flights and office-related emissions such as heating oil, district heating, natural gas and company cars (page 105). None of the credits qualifies as a corresponding adjustment under Article 6 of the Paris Agreement (page 105). The statement notes that the 2045 net-zero ambition "will require neutralising activities for residual emissions", with the assessment still under development (page 105). Avoided emissions from biomethane use are not quantified and not credited (page 105).

Internal carbon pricing

Reference: page 106.

Hapag-Lloyd uses an internal carbon pricing scheme covering Scope 1 and Scope 3.3 (fuel- and energy-related activities) to steer asset investment decisions (page 106). The CapEx shadow price is EUR 76 per t CO₂e (2024: EUR 82), set as a base case of USD 90 per t, which is marginally above current EU ETS levels, and is applied to all investments in new vessels (newbuilds and charter vessels) and vessel retrofits (page 106). A separate carbon price of EUR 110 (2024: EUR 78) is assumed in impairment testing, based on forecast EU ETS certificate prices (page 106).

The share of gross Scope 1, 2 and 3 emissions covered by internal carbon pricing is 0% (2024: 0%), "as it is solely applied to future investments in vessels" (page 106). The company says there is no connection to carbon prices in the financial statements (page 106).

Policies related to pollution

Reference: pages 80, 107-108.

The pollution chapter carries a combined "E2-1 - 3" heading (page 108), and its policy content is short. The company says it "complies with all relevant international pollution prevention regulations, including IMO Emission Control Area requirements, and its decarbonisation efforts are already indirectly pursuing the goal of pollution reduction" (page 108). Vessel operations are named as the primary pollution risk, through SO₂, NOx and particulate matter in engine exhaust, and the company says it complies with IMO Emission Control Areas and uses shore power in port where facilities exist (page 107).

No dedicated pollution policy is described. The governance chapter says measures exist for E4, S2 and G and guidelines for S2 and G, "However, neither of these are yet available for topics E2 and E5" (page 80). Material pollution sub-topics are air and water; the statement identifies seven material pollution impacts and risks across the value chain (pages 88, 107).

Actions and resources related to pollution

Reference: pages 107-108.

Named actions: increased use of shore power "in line with regulations", which reduces SO₂ and NOx emissions in port areas, and installation of AMP containers on vessels so that shore power can replace auxiliary engines in port (pages 107-108). In 2024 the company allocated resources and commissioned a classification society to provide a methodology for measuring pollutants and emission quantities, then developed separate measurement methods for vessels, terminals, depots, offices and fleet vehicles (page 107).

Operational controls: laboratory tests commissioned for each bunker purchase verify compliance with limit values; leakages above 10 liters that harm soil or water are tracked; accidental releases go through a two-step evaluation (page 108). "No relevant spills or leakages occurred in 2025 (2024: 0) and there was no related OpEx or CapEx" (page 108). The company states that decarbonization work already pursues pollution reduction indirectly (page 108), and that no measures are yet available for E2 (page 80).

Pollution of air, water and soil

Reference: pages 107-108 (E2-4, MDR-M); methods pages 75, 107-108.

Air pollutants from ships use ICCT emission factors applied to fuel consumption; water pollutants come from hull paint (standard composition, wetted surface area, annual paint loss) and scrubber discharges (pages 75, 108). The company warns that "Pollutant measurement remains complex due to unclear guidelines and limited raw data", so it uses simplified calculations with higher uncertainty than its GHG figures (pages 107-108). Prior-year water emissions were restated from 59 t to 73 t after more complete modeling of ship-side energy consumption (page 107). No soil emissions are reported.

Transition plan on biodiversity and ecosystems

Reference: pages 76, 109.

The report does not describe a biodiversity transition plan. Under an "E4-1" heading it presents a biodiversity resilience analysis, done by internal experts only (Risk Management, Sustainability and Regulatory Affairs) using a TNFD-aligned scenario analysis across two contrasting futures: moderate ecological damage with substantial regulatory pressure, and severe ecosystem degradation with a moderate regulatory response. ENCORE database analysis identified medium-to-high materiality impacts for cargo handling, water transportation services and coastal transport (page 109).

The company concludes its container shipping and terminal operations "demonstrate resilience to biodiversity-related implications up to 2030" (page 109). It examined the effect of new protected marine and coastal areas on shipping and points to experience with route restrictions such as the Arctic Corporate Shipping Pledge and IMO-defined PSSA (page 109). Page 76 adds that no material risks or habitat deterioration needing mitigation were found, while systemic risks (ecosystem collapse, aggregated biodiversity loss) and financial risks "remain unassessed".

Policies related to biodiversity and ecosystems

Reference: pages 80, 109-110.

The pollution and biodiversity chapters describe commitments rather than a stand-alone biodiversity policy. The company says it is committed to "strict compliance with MARPOL" and other marine protection regulations, evidenced by Port State Control audits, and that its vessels comply at all times with marine environmental protection rules set at international level and by coastal states (page 110). It supports voluntary vessel speed reductions in line with the World Shipping Council Whale Chart and says the chart's data is considered in route planning (pages 109-110).

The governance chapter lists measures for E4 but guidelines only for S2 and G: "measures already exist for topics E4, S2 and G and guidelines for S2 and G" (page 80). Whether operations affect endangered species "has not been assessed" (page 109). The company says it does not use biodiversity offsets (page 110).

Actions and resources related to biodiversity and ecosystems

Reference: pages 109-110.

Whale protection is the main named action. Shipping lanes cross whale migration routes, and "10-knot speed reductions" cut collision risk, air pollution and underwater noise (page 110). The company has joined the "Protecting Blue Whales and Blue Skies" program in the San Francisco Bay Area and Santa Barbara Channel, run with NOAA National Marine Sanctuaries and the Marine Sanctuary Foundation; the voluntary program, ongoing since 2012, asks vessels above 300 gross tonnes to keep to 10 knots from mid-May to mid-November. Speed is monitored through engine systems and GPS tracking with NOAA verification, and Hapag-Lloyd reached at least 90% compliance in the Santa Barbara Channel in the reporting year (page 110). Captains adjust speed by area and season (page 110).

The company says these measures need no significant financial investment, and that further activities align with EU Taxonomy Do No Significant Harm criteria for activity 6.10 (page 110). For the Guayaquil terminal (25 hectares), potential negative effects on surrounding flora and fauna from vessel operations "cannot be fully excluded" (page 109).

Targets related to biodiversity and ecosystems

Reference: pages 80, 153.

The content index lists E4-4 against the governance chapter (page 153), and the heading of section 1.3 includes "E4-4, MDR-T" (page 80). There the company states that "Targets have not yet been developed for ESRS topics E2, E4 and E5, as well as S2 and G, as we are currently continuing to examine our exact impact in these areas" (page 80). No biodiversity target, baseline or timeline appears in the biodiversity chapter (pages 107-110).

Effectiveness is handled by review rather than targets: "The respective departments hold responsibility for examining the effectiveness of policies, actions, ambitions and targets by conducting annual reviews and informing the SC of any necessary adjustments" (page 80). The same page notes that measures already exist for E4 and are being implemented (page 80). The company's speed-reduction compliance figure (at least 90% in the Santa Barbara Channel) is reported as an activity result, not as a target (page 110).

Impact metrics related to biodiversity and ecosystems change

Reference: pages 108-109 (E4 SBM-3, E4-5, MDR-M).

Hapag-Lloyd "has not identified any operational sites located in biodiversity-sensitive areas that are negatively affected by business operations", but four locations sit near areas of biodiversity in need of protection per public Key Biodiversity Area registers, using a one-kilometer distance to judge significance (page 108). No instances of soil degradation, desertification or soil sealing were observed (page 108).

Sites listed (page 109): ATL Haulage Contractors, Stanford-le-Hope, UK (transport; Thames Estuary and marshes, Natura 2000); Hapag-Lloyd AG office, Leipzig (Leipziger Auwald landscape protection area and Natura 2000); Hapag-Lloyd (New Zealand) office, Auckland (offshore Important Bird and Key Biodiversity Area); and Terminal Portuario de Guayaquil, Ecuador (25 hectares; mangroves, estuaries, wetlands and forests of the Gulf of Guayaquil), the only site with a "Potential negative impact within the protected areas" (page 109). Vessel operations in sensitive marine areas are covered by the KBA and IMO PSSA screening (page 84).

Policies related to resource use and circular economy

Reference: pages 80, 110.

The chapter is headed "E5-1, E5-2, E5-3" and gives one shared narrative. Resource use and circular economy have been "a cornerstone of Hapag-Lloyd's sustainability strategy since 2021", with one material negative impact: the extraction and use of fossil energy sources, which cause adverse environmental and social effects along the upstream value chain through the company's continued dependence on them (page 110). The approach centers on resource inflows and circular economy principles, including steel floor container use and responsible practices in ship recycling and fuel extraction (page 110).

No resource-use or circular economy policy is described. The governance chapter says measures exist for E4, S2 and G and guidelines for S2 and G, "However, neither of these are yet available for topics E2 and E5" (page 80). The statement refers readers to the Sustainability Progress Report for comprehensive information on ship recycling and steel floor containers (page 110).

Actions and resources related to resource use and circular economy

Reference: pages 110-111.

The one action-type item is the use of steel floor containers, which the company says improves recyclability and reduces repair requirements (page 111). Hapag-Lloyd tracks two entity-specific metrics: containers with steel flooring were 5.8% of owned containers (2024: 6.2%), and the stock was 122,168 TEU (2024: 122,277 TEU), counting owned containers only (page 111). Information on ship recycling and steel floor containers is deferred to the Sustainability Progress Report (page 110).

The company ties the material impact to "the current limitations of available technologies" and says it is "actively monitoring emerging innovations and market developments" (page 110). The governance chapter states that no measures are yet available for E5 (page 80). No resources, budget or timeline are given for resource-use actions.

Targets related to resource use and circular economy

Reference: pages 80, 110-111.

No resource-use or circular economy target is set. In the governance chapter the company says: "Targets have not yet been developed for ESRS topics E2, E4 and E5, as well as S2 and G, as we are currently continuing to examine our exact impact in these areas" (page 80). Effectiveness is reviewed annually by the responsible departments, who inform the Sustainability Committee of needed adjustments (page 80).

The two steel-floor container indicators (share of owned containers with steel flooring, 5.8% in 2025 against 6.2% in 2024; stock of 122,168 TEU against 122,277 TEU) are described as providing "information on progress and development regarding this specific topic" (page 111), but no target level or date is attached to them.

Resource inflows

Reference: pages 110-111 (E5-4, MDR-M).

Material resource inflows "are mainly related to the Company's Liner Shipping segment in the form of containers and container vessels", with steel the main resource component; for terminals the focus is ship-to-shore container cranes, reach stackers and terminal tractors. "No other material resource inflows" were identified in own operations or the upstream value chain (page 110).

The fall in tonnage reflects fewer containers and newbuild vessels brought into operation (page 111). Collection covers significant materials only: vessels and owned containers in Liner Shipping, and equipment in Terminal & Infrastructure. Vessel lightship weight counts as technical material, leased containers are excluded, and recycled content is conservatively set to zero because shipyards and container makers give no recycling information (page 111).

Policies related to own workforce

Reference: pages 125-127, 129-132, 134, 136.

For own-workforce and value chain worker IROs, Hapag-Lloyd has "six policies in place": the Global Code of Ethics, the Supplier Code of Conduct (SCoC), the Policy Statement on Social Responsibility and Human Rights, the ISM Manual, the Academy Playbook and the Security Policy (pages 125-127). The Global Code of Ethics applies to Hapag-Lloyd AG and majority-held companies and sets expectations on fair working conditions, human rights, diversity and inclusion (pages 126, 129). It was reviewed in 2025 to cover the Terminal & Infrastructure segment, with rollout planned for 2026 (page 132).

The Policy Statement prohibits "any form of child or forced labour, slavery and human trafficking" and commits the company to the Universal Declaration of Human Rights, ILO Declaration and OECD Guidelines (page 134). The ISM Manual governs seafarer safety, and a Health, Safety, Quality and Environmental (HSQE) Policy was added in 2025 (page 136). The Academy Playbook frames training for Liner Shipping employees other than seafarers (pages 127, 129). Each policy carries a named accountable role and a review cycle (pages 126-127).

Taking action on material impacts on own workforce

Reference: pages 127, 129-130, 133-134, 136.

Four action areas are named: promoting equal opportunities for women, facilitating training access for all Liner Shipping employees, promoting human rights in own operations, and "Our Way of Working@Hapag-Lloyd" (page 127). The women's program (Diversity@Hapag-Lloyd, with a Women@Hapag-Lloyd group, networking events and training) is open to female land-based Liner Shipping employees and ties to the 50% parity target (page 130). Training runs through the Learning Management System launched in 2020, the Learning Campus pathways, and SAiL, a leadership program for land-based people leaders launched in 2025 with roll-out due to complete in 2026 (page 129). Human rights training includes mandatory onboarding and targeted sessions (page 134).

Our Way of Working allows hybrid work up to twice a week for shore-based staff; Starlink connectivity was added on vessels for seafarers' well-being (page 133). Mental health measures include a "Risk Assessment Mental Stress" for seafarers, trauma therapy support, and mental health ambassadors in England and Ireland (page 136). The company says it took no further overarching global actions beyond those described, and departments review effectiveness and inform the Sustainability Committee (page 127).

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

Reference: pages 130-131 (S1-5, MDR-T).

One own-workforce target is set: "50% participation of women in TDP and ALPHA by 2030", where TDP is the Talent Development Program and ALPHA is a leadership program (page 130). The baseline year is 2022, when women were 47% of TDP and 37% of ALPHA; in 2025 the shares were 47% (46.9%) and 39% (39.0%) (page 130). The target was set with Executive Board members and HR functions, covers land-based Liner Shipping employees, and is tracked by HR through a quarterly diversity dashboard (page 130). The company states the target and its metrics "have remained unchanged since its establishment" (page 130). It is linked to the policy objectives of the Global Code of Ethics (page 130).

The share is the number of enrolled female participants divided by total participants enrolled on 31 December 2025 (page 130). The statement describes no other S1 target.

Characteristics of the undertaking's employees

Reference: pages 127-128 (S1-6, MDR-M).

Hapag-Lloyd had 18,117 employees at 31 December 2025 (2024: 16,905): 11,351 male, 6,765 female and 1 diverse (pages 82, 127). By contract type: 15,172 permanent, 1,760 temporary and 1,185 without guaranteed working hours (page 128). Men hold 8,826 of the permanent contracts and women 6,345 (page 128).

Employees left the Group at a rate of 8.7% (1,585 leavers; 2024: 10.3%, 1,741) (page 128). Two countries hold at least 10% of employees: Germany with 4,134 (2024: 3,822) and India with 2,807 (2024: 2,476) (page 128). Numbers are headcount at period end, include apprentices and dual students, and the rise reflects growth in shore-based personnel in Liner Shipping and the acquisition of a French terminal in Le Havre (page 128). The headcount ties to the figure in the financial statements (page 128).

Characteristics of non-employee workers

Reference: pages 82, 128 (S1-6, S1-7).

The company reports 2,861 non-employees in its own workforce (2024: 2,126) (page 128). The KPI counts people provided by third-party employers, such as dock workers, facility management services and agency truck drivers; leased personnel are included, while external companies providing services and self-employed people are excluded as they are not part of the workforce (page 128). The worker-type table on page 82 defines three groups: employees, self-employed non-employees, and non-employees provided by third-party undertakings primarily engaged in employment activities.

For some locations, mainly terminals and inland logistics sites, the count uses the total who worked at the location in the last month instead of the headcount on the key date; this method applies to non-employees at eight locations (page 128). The statement says it discloses selected phase-in data points for S1 own workforce "to provide better understanding in the context of non-employee workers" (page 74).

Diversity metrics

Reference: pages 130-131 (S1-9, MDR-M).

Top management (the two leadership levels below the Executive Board in Liner Shipping, plus HGT management in Terminal & Infrastructure) had 159 people at year-end 2025: 125 men (78.6%) and 34 women (21.4%), against 154 in 2024 with 127 men (82.5%) and 27 women (17.5%) (page 131). No diverse persons are recorded at this level.

Age distribution of all employees in 2025: under 30, 4,443 (24.5%); 30-50, 10,490 (57.9%); over 50, 3,184 (17.6%) (page 131). In management development programs, women were 46.9% of Talent Development Program participants (2024: 46.1%) and 39.0% of ALPHA leadership program participants (2024: 41.2%) (page 130). Board-level gender shares are reported under GOV-1 (page 86).

Health and safety metrics

Reference: pages 136-138 (S1-14, MDR-M).

The company recorded "two fatal incidents in 2025": an employee at a terminal and a crew member on an owned vessel under third-party management (page 137). From 2025 the accident count includes commuting accidents; where Group-wide data is missing they are estimated from German data and added for 2025 and retrospectively for 2024, and the company reports 121 recordable accidents (2024: 121) before that estimate (pages 137-138). Fleet Management's occupational safety system is certified to ISO 45001, and the QEM system holds ISO 9001 and 14001 (page 136).

Compensation metrics (pay gap and total compensation)

Reference: page 131 (S1-16, MDR-M).

The gap is the difference between average gross hourly pay of male and female employees divided by the male average (page 131). The company says "no substantive conclusions can be drawn from the unadjusted gender pay gap" because it ignores role complexity, experience and regional pay differences (page 131). The rise from 2024 is attributed mainly to data availability after a new HR management system went live in 2025 for Liner Shipping land staff; the Terminal & Infrastructure segment runs its own system. The company is assessing an adjusted gap (page 131). Compensation includes base pay, cash benefits and direct remuneration; company cars and expat costs are left out as immaterial, and employer pension expenses are not included (page 131).

Incidents, complaints and severe human rights impacts

Reference: pages 134-135 (S1-17, MDR-M).

Discrimination counts include harassment and confirmed cases that led to proceedings, termination or disciplinary action. A complaint that is later confirmed in a different year is counted as a complaint in the year filed and as an incident in the year confirmed (page 135). The company reports no cases of non-respect of the UNGPs, ILO Declaration or OECD Guidelines involving workers in its own operations and defined value chain (page 134). Separately, "six severe human rights incidents (2024: 1) occurred within Hapag-Lloyd's upstream value chain across different countries and at sea", and the company says it began remedy with the suppliers and authorities concerned at once (page 135).

Policies related to value chain workers

Reference: pages 125-126, 134, 147.

The Supplier Code of Conduct (SCoC) is the main value chain worker policy and covers suppliers, subcontractors and other third parties fulfilling Hapag-Lloyd's Liner Shipping contracts, plus external managers of its ships. It is owned by the Senior Managing Director Global Procurement and carries monitoring rights including self-assessments, audits and documentation reviews (page 126). The social criteria listed for supplier assessment are abolition of child labor, an end to forced labor and modern slavery, occupational safety and health, freedom of association and collective bargaining, diversity and inclusion, adequate remuneration, and community rights and security (page 147).

The SCoC expects wages at least equal to local minimum wage regulations and "always adequate living wages", promotes equal pay for equal jobs, and bans wage deductions as discipline (page 134). It is in line with the ILO Core Conventions and the Maritime Labour Convention (page 134). About 1,950 suppliers are now in continuous monitoring, a 6% increase on the previous year (page 147). The Policy Statement on Social Responsibility and Human Rights also applies (pages 125-126).

Taking action on material impacts on value chain workers

Reference: pages 134-135, 147-148.

Actions focus on suppliers. The supplier monitoring program sends questionnaires, secures commitment to the SCoC and adds high-risk suppliers to media monitoring; it excludes Terminal & Infrastructure suppliers, and about 1,950 suppliers are covered (page 147). Supplier engagement calls, workshops and visits started in 2024 and exceeded 100 calls by year-end 2025 (page 147). Procurement teams are trained on a Playbook on Engaging Suppliers on Social Sustainability, and a central case management system records cases and measures (page 147). In Terminal & Infrastructure, actions are taken ad hoc (page 147).

On effectiveness: "The analysis of its effectiveness has not yet been conducted" for the case management and due diligence action (page 147). Six severe human rights incidents occurred in the upstream value chain in 2025 (2024: 1), and remedy was started at once with the suppliers and authorities concerned (page 135). The company "did not identify any material risks arising from impacts and dependencies or any material opportunities affecting workers in the value chain" (page 148).

Business conduct policies and corporate culture

Reference: pages 131-132, 139-142.

Hapag-Lloyd "has ten policies in place to manage its material IROs related to governance" (page 139). The set is: Corporate Guideline Compliance Organisation, Corporate Guideline Business Courtesy, Anti-Bribery and Anti-Corruption Policy, Whistleblower and Non-Retaliation Policy, Third-Party Management Policy, the Supplier Code of Conduct, Corporate Guideline Information Security, Corporate Guideline Sponsoring and Donations, the Hapag-Lloyd Cares Guideline and Corporate Guideline Data Protection (pages 140-141). The Chief Compliance Officer reviews the five compliance policies annually (page 140). The whistleblower policy rests on the German Whistleblower Protection Act (HinSchG), which implements EU Directive 2019/1937 (pages 140, 142).

On culture, the Global Code of Ethics sets the values "We care. We move. We deliver."; the competency model has eight value-based behaviors, and culture is checked through internal controls, the Employee Engagement Survey and the Speak Up Line, with disciplinary measures up to termination for non-compliance (page 132). A "Values Day" was held in 2025 (page 132).

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Hapag-Lloyd sets no business conduct targets. The company states: "Targets have not yet been developed for ESRS topics E2, E4 and E5, as well as S2 and G, as we are currently continuing to examine our exact impact in these areas" (page 80).

Consistent with MDR-T, effectiveness is tracked in the absence of targets:

• Departments examine "the effectiveness of policies, actions, ambitions and targets by conducting annual reviews and informing the SC of any necessary adjustments" (page 80).
• The Chief Compliance Officer reviews each compliance policy annually and reports quarterly to the Executive Board (pages 80, 140-141, 143).
• The effectiveness of the whistleblowing procedure "is reviewed internally annually and ad hoc if necessary" (page 143).
• Anti-corruption training coverage is tracked as a KPI: 98.8% of functions-at-risk in 2025 (page 144).

Incidents of corruption or bribery

Reference: page 144 (G1-3, G1-4, MDR-M).

No convictions and no fines are reported for 2025; one conviction was recorded for 2024 (page 144). Cases leading to a conviction in the period are counted regardless of when the case arose (page 144). The content index lists this disclosure as "Confirmed incidents of corruption or bribery" (page 154).

Reports are processed by the Compliance department, and outcomes of investigations go to the Supervisory Board through the annual compliance report (page 143). The statement does not describe the 2024 conviction.