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
• Seafarer’s Rights Policy
• Drug & Alcohol Policy
• Policy on Harassment and Bullying
• 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 Report discloses our ESG strategic approach and performance data for 2023, including environmental and social KPI targets against which we measure our achievements and which will help us to comply with regulatory requirements and meet our strategic goals.

Scope

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 fulfilment at work and promote responsible engagement within the supply and value chains, networks and communities in which 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.

Sustainability Reporting Frameworks

Our sustainability reporting follows the latest Environmental, Social and Governance Reporting Guide (“ESG Guide”) of as set out in Appendix C2 to the Listing Rules of The Stock Exchange of Hong Kong (expected to be upgraded to “ESG Reporting Code”). 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 monitor developments and trends in areas of sustainability and sustainability reporting to better meet the expectations of our stakeholders in light of evolving societal expectations as well as business and regulatory requirements.

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 – consistent with IMO’s new target – which is already very ambitious for hard to decarbonise industry sectors like our Handysize/ Supramax dry bulk tramp shipping sector.

We have measured and tracked key aspects of our sustainability performance for several years and we meet the Stock Exchange’s ESG Guide’s disclosure requirements.

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 (the “Listing Rules”).

As such, the Board also 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 regularly reviews progress made against ESG-related goals and targets.

The Board delegates to the Sustainability Committee more regular oversight of the Group’s sustainability programme and the work of the Sustainability Management Committee (“SMC”).

Elevated Board-level Oversight

In January 2024, we elevated board-level oversight of sustainability from our Audit Committee to a newly established Sustainability Committee, comprising two Independent Non-executive Directors (“INEDs”) and one Non-executive Director (“NED”). The Sustainability Committee is appointed by the Board to assist the Board in overseeing the management team and advising the Board on matters that are material to the long-term sustainability of the Company, including ensuring effective management of the Company’s sustainability risks and opportunities, overseeing the Company’s sustainability approach, priorities and implementation, monitoring progress towards sustainability targets, and overseeing sustainability reporting.

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 Sustainability 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, marine & safety and decarbonisation & optimisation managers), the Commercial Operations Director and the Human Resources and Administration Director.

Our Sustainability Priorities

We further prioritise our ESG issues based on our assessments of what is currently most important to our stakeholders, our business, society and the environment, what is most urgent, and considering our levels of ambition towards the several sustainability issues that we deem material for our Company. We currently see these five ESG issues as our company’s top-most sustainability focus areas:

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. Some sustainability issues are matters increasingly raised in our routine dealings with customers, employees, banks and investors.

We also consider the requirements of reporting standards and frameworks such as GRI, IFRS S2 and SASB, and the criteria of ESG ratings agencies and platforms as proxies for investors’ and other stakeholders’ expectations.

We conduct annual ESG materiality surveys, reaching out to different stakeholder groups on a rotational basis. In 2022, our stakeholder survey was enhanced by independently 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.

All 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.