The Group has published the following documents to guide our actions and improve our performance in areas of Corporate Sustainability

• HSEQ Policy
• Commitment to a Healthy & Safe Workforce
• Environmental Policy Guide
• Drug & Alcohol Policy
• Code of Conduct (staff; counterparty)
• Whistleblowing Policy
• Workplace Practices Policy Summary
• Due Diligence Process Policy
• Board Diversity Policy
• Anti-Bribery Policy
• Privacy Policy
• Social Media Policy
• Business Continuity Plan
• Counterparty Code of Conduct & Form
• Trading Restriction Policy
• Information Security Policy
• Remote Working Policy

Sustainability Reporting Framework and Scope

Our sustainability reporting follows the latest Environmental, Social and Governance Reporting Guide (“ESG Guide”) of The Stock Exchange of Hong Kong. It is also prepared with reference to standards and recommendations of the GRI, TCFD, SASB and the Integrated Reporting frameworks. We also draw on the guidelines and principles of the United Nations Global Compact.

We do not currently work with the Science Based Targets initiative (SBTi) in part because SBTi Maritime Guidance advocates action to achieve net zero by 2040, while our current ambition is net zero by 2050 - already some way ahead of IMO’s target. We will reassess our possible participation in SBTi in due course.

The scope of this report covers the significant ESG initiatives of our business that reduce our environmental impact, reinforce our class-leading safety and wellbeing culture and mitigate ESG risks, enhance job fulfilment and promote responsible engagement within the networks and communities where we operate.

Our sustainability reporting boundary focuses on the majority portion of our core fleet that comprises owned vessels that we control both commercially and technically. It also covers Greenhouse gas emissions of our chartered-in vessels.

It is our owned vessels over which we have the authority to mandate and control Health, Safety, Environment and Quality (HSEQ) policies and actions. By contrast, we do not control HSEQ, crewing and other technical management aspects for chartered-in vessels, although we do hold our tonnage providers to ensure that they and their ships, certificates and practices comply with all relevant labour, health & safety, environmental, sanction and other laws and regulations and are consistent with our Counterparty Code of Conduct.

We also report on our company-wide staff engagement and our network and community initiatives.

Sustainability Governance

Sustainability is a Board Responsibility

The Board is responsible for, among other things, the development of the Group’s long-term corporate strategies and broad policies. In setting its standards, it considers the needs and requirements of the business, its stakeholders, the Corporate Governance Code and ESG Reporting Guide encompassed in the Stock Exchange’s Rules governing the listing of securities.

As such, the Board has overall responsibility for, and is engaged in, the Group’s sustainability strategy and reporting, including identifying, evaluating and managing ESG-related risks, and ensuring appropriate and effective ESG risk management and internal control systems are in place. Management provides confirmation to the Board of the effectiveness of these systems. The Board also reviews progress made against ESG-related goals and targets.

The Board delegates to the Audit Committee more specific responsibility for reviewing the effectiveness of the Group’s sustainability initiatives and the work of the Sustainability Management Committee (“SMC”).

Functions of SMC

The Group's SMC comprises the CEO, CFO, Head of Sustainability and five more senior executives from different functions. It reports to the Audit Committee at least twice a year, and is responsible for reviewing, assessing and enhancing the Group's sustainability policies, strategies and performance, and ensuring the Group is in full compliance with ESG requirements. This approach affirms and enables the Group's commitment to sustainability, and ensures that members with different backgrounds and expertise are represented to deliver meaningful outcomes.

Day-to-day Implementation

We have a dedicated sustainability team to enhance and help to coordinate our approach to sustainable business practices and investments in sustainable assets. Supported by the sustainability team, day-to-day execution of sustainability initiatives and sustainable business practice lies with managers across the business, most notably the Fleet Director (supported by his technical, personnel, and risk & safety managers), the Commercial Operations Director and the Human Resources and Administration Director.

Our Sustainability Priorities

Still a work in progress, we currently see these five ESG issues as our top-most sustainability focus areas:

Our prioritisation is based on our assessments of what is currently most important to our stakeholders, our business, society and the environment, and considers our levels of ambition towards the several sustainability issues that we deem material for our Company. We are further building out our strategies to better inform our programmes and measure progress.

What is material is defined as an issue that would impact our senior management, Board and Board Committees’ decisions, applying several criteria such as:

• the potential economic impact of an issue on the business and its value over the short, medium and long term;
• our main stakeholders’ concern with an issue and its likely effect on them;
• the extent to which an issue impacts society and the environment; and
• the extent to which an issue is likely to grow in significance and impact in the future.

Materiality

We determine in a number of ways what sustainability issues really matter to us. Several of them are risks and responsibilities that we are mandated to manage by our industry’s regulators and other authorities; we engage actively with associations that work to influence and respond to regulations that affect our industry. Some sustainability issues are matters increasingly raised in our routine dealings with customers, employees, banks and investors. We also consider the requirements of reporting frameworks such as GRI, TCFD and SASB and the criteria of ESG ratings platforms as proxies for stakeholder expectations. (More on ESG ratings below.)

We also continue to conduct annual ESG materiality surveys, reaching out to different stakeholder groups on a rotational basis.

In 2022, we engaged independent consultant The Purpose Business to run focus group workshops with 45 stakeholders to clarify what sustainability issues are important to them and how they think we are doing. This was part of a larger sustainability strategy review, which also entailed ambition-setting for our various sustainability issues – a process that is ongoing and will be constantly revisited to ensure that we keep challenging ourselves to make positive differences where they are needed the most.

These engagements enable us to map issues that are of greatest importance to our business, our stakeholders, society and the environment, and to determine the key issues for discussion in our sustainability reporting. Our ESG materiality matrix reflects our combined findings.