Hafnia Limited(HAFN) - 2024 Q4 - Annual Report

Sustainability Statement 2024 This report outlines Hafnia's 2024 sustainability performance, adhering to ESRS and CSRD, covering environmental, social, and governance aspects Responsibility Statement 2024 Hafnia's 2024 Sustainability Statement adheres to European Sustainability Reporting Standards (ESRS) under the CSRD framework, providing a comprehensive view of ESG matters - Hafnia's 2024 reporting aligns with European Sustainability Reporting Standards (ESRS) and the Corporate Sustainability Reporting Directive (CSRD)[4] - The report provides a comprehensive view of sustainability for all stakeholders[4] - The Board of Directors and CEO are responsible for preparing the CSRD report, integrating sustainability into Hafnia's core business strategy[8] General Disclosures (ESRS 2) This section details the general basis for preparing Hafnia's 2024 Sustainability Statement, adhering to EU CSRD and ESRS General Basis for Preparation of the Sustainability Statement (BP-1) Hafnia's 2024 Sustainability Statement follows EU CSRD and ESRS, consolidating data consistent with financial statements, with an exception for GHG and pollutant emissions from joint ventures - Hafnia's 2024 Sustainability Statement adheres to EU's Corporate Sustainability Reporting Directive (CSRD) and European Sustainability Reporting Standards (ESRS)[12] - Data consolidation follows financial statement principles, including subsidiaries, but GHG and pollutant emissions include joint-venture vessels based on ownership share[13] - The statement covers Hafnia's entire value chain, upstream and downstream, with suppliers integrated into policies[13] Disclosures in Relation to Specific Circumstances (BP-2) This section defines time horizons for sustainability reporting and explains the spend-based approach for Scope 3 emissions estimation, with plans to enhance data accuracy from 2025 - Time horizons are defined as short-term (up to one year), medium-term (one to five years), and long-term (more than five years)[15] - Scope 3 emissions are estimated using a spend-based approach, with plans to engage suppliers directly from 2025 for more accurate data[16] - No comparative figures from prior years are included as 2024 is the first year of CSRD-aligned reporting[18] The Role of The Administrative, Management, And Supervisory Bodies (GOV-1) This section details the composition, gender diversity, and independence of Hafnia's Board of Directors, highlighting their extensive industry experience and specific expertise in sustainability matters - The Board of Directors brings extensive industry knowledge from maritime and shipping sectors[22] - The Audit Committee oversees ESG reporting and annually reviews the Double Materiality Assessment (DMA)[30][31] - The Board of Directors has expertise in key sustainability challenges, including climate change, air and water pollution, biodiversity, and business conduct[34][35] Hafnia's Board of Directors Metric (2024) | Metric | Value | | :--- | :--- | | Number of Executive Members | 0 | | Number of Non-Executive Members | 5 | | Representation of Employees | None | | Board of Directors Gender Diversity Ratio | 20% women | | Percentage of Independent Board Members | 80% (4 out of 5) | Information Provided to and Sustainability Matters Addressed by the Undertaking's Administrative, Management, and Supervisory Bodies (GOV-2) The Head of ESG presents the Double Materiality Assessment (DMA) and IROs to the Executive Management Team and Audit Committee for annual review, with quarterly updates on risks, impacts, and opportunities starting in 2025 - The Head of ESG presents the DMA and IROs to the Executive Management Team and Audit Committee for annual review and approval[39] - Starting in 2025, quarterly updates on risks, impacts, and opportunities will be provided to the Executive Management Team and Audit Committee[40] - ESG-related risks and opportunities are integrated into Hafnia's Enterprise Risk Management (ERM) framework, guiding strategic planning and investment decisions[41] - Hafnia has invested in sustainable fuel solutions, including four dual-fuel LNG vessels and four dual-fuel methanol chemical vessels[42] Integration of Sustainability-Related Performance in Incentive Schemes (GOV-3) Executive Management compensation includes incentive-based components, with key sustainability indicators annually assessed and discretionarily considered by the Remuneration Committee for variable remuneration - Key sustainability indicators are annually assessed for potential inclusion in Executive Management's variable remuneration, though this is discretionary[44] - 2024 Sustainability KPIs for CEO and CFO included maintaining high Health & Safety standards (LTIF <0.4, TRCF <1.0), achieving >90% favorable engagement survey results, being on track for 2030 gender diversity target (40% women in office), achieving >50% women onboard four Culture Labs ships, achieving zero breaches in five key compliance pillars and environmental regulations, maintaining trajectory to achieve 'net zero by 2050' and 40% carbon intensity reduction by 2028 (from 2008 baseline), and screening suppliers on ESG criteria[45][46] Statement on Due Diligence (GOV-4) Hafnia's due diligence process for people and the environment is embedded in its governance, strategy, and business model, involving stakeholder engagement, identification and assessment of adverse sustainability impacts, and taking action to address them - Hafnia's due diligence process is embedded in governance, strategy, and business model[47] - It involves engaging with affected stakeholders and identifying/assessing adverse sustainability-related impacts[47] - Actions are taken to address adverse impacts, and their effectiveness is tracked and communicated[47] Risk Management and Internal Controls Over Sustainability Reporting (GOV-5) Hafnia ensures sustainability reporting accuracy through annual risk assessments, Audit Committee oversight, automated processes, data validation, and external assurance - Hafnia ensures accuracy and reliability of sustainability reporting through annual risk assessment and Audit Committee oversight[48] - Main sustainability reporting risks are addressed through automated processes, data validation, and external oversight[49] Identified Risks and Mitigation Measures | Risks Identified | Mitigation Measures in Place | | :--- | :--- | | Data Quality | ESG reporting platform (Watershed) automates data ingestion, flags discrepancies, requires approvals | | Accuracy of Estimated Results | Collaboration with Watershed refines methodologies and validation processes | | Reporting Accuracy | Follows international standards, comprehensive internal process (Executive Management, Audit Committee, Board), external limited assurance | | Information Availability | ESG team informs business units of requirements, conducts gap assessments | Strategy, Business Model and Value Chain (SBM-1) Hafnia is a major owner/operator of product and chemical tankers, transporting refined oil products and chemicals globally, with sustainability as a core strategic pillar - Hafnia operates over 200 modern vessels for global transportation of refined oil products and chemicals[51][52] Number of Employees by Geographical Area (Headcount at end of 2024) | Country | Employees Count | | :--- | :--- | | Shore-based employees | 274 | | Singapore | 141 | | Denmark | 90 | | United States | 18 | | United Arab Emirates | 12 | | India | 11 | | Monaco | 2 | | Seafarers | 4,685 | | Asia | 3,863 | | Europe | 755 | | Africa | 60 | | North America | 5 | | Oceania | 1 | | South America | 1 | Revenue Breakdown (Thousands of USD) | ESRS Sector | Total Revenue | | :--- | :--- | | H.50.20 Sea and coastal freight water transport | 1,935,596 | | Others | 933,051 | | Total | 2,868,647 | - 'Responsible and Reduce Emissions' is one of Hafnia's four strategic pillars[56] - Hafnia joined the United Nations Global Compact in 2024, committing to human rights, labor, environment, and anti-corruption principles[58] - Hafnia is actively advancing sustainability efforts in new transportation services for biofuels, ammonia, and CO2[57] Interests and Views of Stakeholders (SBM-2) Hafnia engages with various stakeholders through tailored channels to build partnerships and promote transparency, integrating feedback into its strategy - Hafnia actively engages with stakeholders (employees, customers, suppliers, pool partners, investors, lenders, authorities, industry associations) through tailored channels[66][67][68] - Stakeholder feedback validates Hafnia's strategy and is integrated into its approach, ensuring alignment with evolving sustainability requirements[69] - Informal stakeholder insights are regularly discussed during leadership meetings, and formal updates are provided to the Audit Committee annually as part of the Double Materiality Assessment (DMA) review[70][71] Material Impacts, Risks and Opportunities and Their Interaction with Strategy and Business Model (SBM-3) Hafnia identifies material impacts, risks, and opportunities (IROs) across environmental, social, and governance dimensions, which are integrated into its corporate strategy Material IROs for Hafnia (Selected Examples) | IRO Name | IRO Category | Description | Time Horizon | Connection to Strategy | | :--- | :--- | :--- | :--- | :--- | | Scope 1 emissions | Actual Negative Impact | Combustion of fossil fuels in vessel operations increases GHG emissions | Short-term, Medium-term, Long-term | Yes | | Scope 3 emissions | Actual Negative Impact | Emissions from value chain are a significant part of GHG footprint | Short-term, Medium-term, Long-term | Yes | | Providing new services: Sustainable freight solutions | Financial Opportunity | Attracts new customers, strengthens market position | Mid-term | Yes | | Inability to comply with new environmental regulations | Financial Risk | Stricter rules increase operational costs, exposure to fines | Mid-term | Yes | | Reduction in revenues in oil transport due to shift towards renewable energy | Financial Risk | Sudden shift in demand could reduce vessel demand and charter rates | Long-term | Yes | | Air Pollution from non-GHG emissions | Actual Negative Impact | Vessel operations release pollutants, affecting air quality | Short-term, Medium-term, Long-term | Yes | | Vessel scrapping | Potential Negative Impact | Improper recycling can lead to pollution from hazardous substances | Short-term, Medium-term, Long-term | Yes | | Equal parental leave for both parents for office employees | Actual Positive Impact | Boosts employee satisfaction, promotes gender equality | Short-term, Medium-term, Long-term | Yes | | Gender Diversity onboard above industry norms | Actual Positive Impact | Provides equal opportunities for female seafarers, broadens talent pool | Short-term, Medium-term, Long-term | Yes | | Shortage of talent in the shipping industry | Financial Opportunity | Investing in diverse talent pool drives growth, reduces hiring costs | Short-term | Yes | | Healthy corporate culture driving the company towards shared goals | Actual Positive Impact | Fosters collaborative and motivating work environment | Short-term | Yes | | Legal liabilities due to compliance breach | Financial Risk | Illegal conduct results in reputational damage and financial losses | Short-term | Yes | | Reputational effects from Corruption and bribery | Financial Risk | High levels of bribery/corruption disrupt operations, cause legal/financial damage | Short-term | Yes | - All identified material impacts are integrated into the corporate strategy with established policies and targets[79] - Qualitative scenario analysis was used for financial effects of risks and opportunities, without numerical quantification this year[81][87] Description of the Processes to Identify and Assess Material Impacts, Risks and Opportunities (IRO-1) Hafnia's Double Materiality Assessment (DMA) methodology, guided by ESRS, covers the parent company and subsidiaries, including the entire value chain, using a scoring methodology for both impact and financial materiality - The DMA methodology is grounded in ESRS disclosure requirements and covers Hafnia Limited and all its subsidiaries, including the entire value chain[83][84] - Impact materiality is assessed using a scoring methodology for scale, scope, irremediable character, and likelihood[84] - Financial materiality for risks and opportunities is evaluated based on magnitude and likelihood, using a qualitative assessment this year[86][87] - Key decisions in the DMA process are validated by the Executive Management and Audit Committee[88] - ESRS E3 (Water and Marine Resources), S3 (Affected Communities), and S4 (Consumers and End-users) were assessed as non-material and omitted[90] Disclosure Requirements in ESRS Covered by the Undertaking's Sustainability Statement (IRO-2) This section provides an index of all material disclosure requirements under ESRS standards covered in Hafnia's Sustainability Statement, along with their corresponding page numbers - The report includes an index of material disclosures covering ESRS 2 (General Disclosures), E1 (Climate Change), E2 (Pollution), E4 (Biodiversity and Ecosystems), E5 (Resource Use and Circular Economy), S1 (Own Workforce), S2 (Workers in the Value Chain), and G1 (Business Conduct)[111][112][113] Environment This section details Hafnia's environmental performance, focusing on climate change mitigation, EU Taxonomy reporting, pollution control, biodiversity protection, and resource use/circular economy Climate Change (E1) Hafnia's climate strategy aims for net zero by 2050 and a 40% carbon intensity reduction by 2028 (vs. 2008 baseline), two years ahead of IMO targets - Climate-related KPI for CEO and CFO (2024): Stay on track for 'net zero by 2050' and 40% carbon intensity reduction by 2028 (vs. 2008 baseline)[115] - Hafnia's climate strategy is built on three key pillars: lead long-term industry changes, optimize vessel performance, and improve transparency in emissions reporting[116][119] - Decarbonization Targets: Achieve IMO's target of 40% carbon intensity reduction by 2028 (vs. 2008 levels), two years ahead of schedule, and achieve Net Zero by 2050 in line with the Paris Agreement[119] - Decarbonization levers include: Optimizing Technical Performance (modern fleet, energy-saving devices, machine learning), Optimizing Fleet Operations (ZeroNorth platform, data transparency, Mass Flow Metering), and Developing Clean Solutions (dual-fuel LNG/methanol vessels, biofuel/ammonia/CO2 transport, clean hydrogen ammonia production)[118][119][120][121][125][126] - OPEX and CAPEX for the Climate Strategy are not publicly disclosed due to commercial sensitivity[122] - Hafnia achieved an Annual Efficiency Ratio (AER) of 5.15 in 2024, representing a 33% reduction in carbon intensity compared to the IMO's 2008 baseline, on track for the 40% reduction target by 2028[137][140] Energy Consumption and Mix (2024) | Metric | Value (MWh) | Share of Total (%) | | :--- | :--- | :--- | | Fuel consumption from crude oil and petroleum products | 7,799,871 | 100% (fossil) | | Consumption of purchased or acquired electricity, heat, steam, and cooling from fossil sources | 607 | | | Total fossil energy consumption | 7,800,486 | 100% | | Total renewable energy consumption | 73 | 0% | | Total energy consumption | 7,800,573 | | GHG Emissions (2024) | Scope | Emissions (tCO2e) - Market-based | Emissions (tCO2e) - Location-based | | :--- | :--- | :--- | | Scope 1 | 2,200,393 | 2,200,393 | | Scope 2 | 156 | 129 | | Scope 3 | 685,455 | 685,454 | | TOTAL | 2,886,004 | 2,885,976 | - Scope 1 emissions are verified daily by classification society DNV[168] EU Taxonomy Reporting in 2024 Hafnia's EU Taxonomy reporting identifies eligible and aligned economic activities, with 31 chemical/IMO Type II tankers aligned for climate change mitigation - Hafnia's primary business activities (chartering, operating, maintenance of owned vessels) are considered EU Taxonomy-eligible under 'Sea and Coastal Freight Water Transport'[174] - 31 of Hafnia's chemical tankers and IMO Type II tankers are considered EU Taxonomy-aligned for Climate Change Mitigation, meeting EEDI and zero-direct CO2 emission fuel criteria[175] - No activities were identified as EU Taxonomy-aligned for Climate Change Adaptation[177] Taxonomy-Aligned Financials (2024) | Metric | Absolute Value (USD '000) | Proportion of Total (%) | | :--- | :--- | :--- | | Turnover | | | | Taxonomy-eligible | 1,688,956 | 59% | | Taxonomy-aligned | 451,333 | 16% | | CAPEX | | | | Taxonomy-eligible | 72,155 | 87% | | Taxonomy-aligned | 19,509 | 23% | | OPEX | | | | Taxonomy-eligible | 150,021 | 100% | | Taxonomy-aligned | 46,016 | 31% | Pollution (E2) Hafnia identifies air pollution from non-GHG emissions as a material impact, managed through its HSEQ Management and Environmental Management System policies, ensuring MARPOL compliance - Air pollution from non-GHG emissions is identified as a material negative impact[190] - Policies like HSEQ Management and Environmental Management System (ISO 14001) are in place to manage pollution[191] - Actions include ensuring MARPOL compliance for NOx and SOx emissions, using compliant fuels, and designing new vessels to meet NOx standards[195][196] - No specific targets for air pollutants are set, but Hafnia remains fully compliant with MARPOL limits and regulations[197] Pollutants Emitted (2024) | Pollutant | Emissions (tonnes) | | :--- | :--- | | Nitrogen oxides (NOx) | 93,330 | | Sulphur oxides (SOx) | 5,859 | | Particulate matter (PM10) | 5,184 | | Particulate matter (PM2.5) | 4,770 | Biodiversity and Ecosystems (E4) Hafnia identifies the release of invasive alien species through ballast water discharge as a material negative impact on marine biodiversity, addressed by installing ballast water treatment systems on 100% of its fleet - The release of invasive alien species from untreated ballast water is identified as a material negative impact on marine biodiversity[205] - Hafnia's Environmental Management System policy aims to minimize the adverse impact on the environment, including biodiversity[208] - Actions include installing ballast water treatment systems on 100% of the fleet, avoiding Marine Protected Areas (MPAs) or adhering to IMO guidelines when passage is unavoidable, and a pilot project to study Underwater Radiated Noise (URN)[211] - No specific targets for biodiversity have been adopted, but Hafnia is exploring measurement methodologies[212] Resources Use and Circular Economy (E5) Hafnia identifies improper vessel scrapping as a potential negative impact, committing to responsible recycling at certified facilities and aiming for a 10% reduction in onboard plastic usage by 2028 - Improper vessel scrapping is identified as a potential negative impact due to hazardous substance mismanagement and pollution[213] - Hafnia's Ship Recycling Policy commits to responsible ship recycling at certified facilities compliant with the Hong Kong Convention 2009 or EU Regulation 1257/2013[214] - Actions include continuous commitment to recycling vessels at certified facilities and plans to establish guidelines for ship scrapping and material reuse[216] - No specific targets for vessel scrapping have been set, but a near-term target is a 10% reduction in onboard plastic usage by 2028 (2023 baseline)[217][218] Key Metrics on Waste (2024) | Metric | Value | | :--- | :--- | | Total Waste Generated | 35,405,442 kg | | Total Amount of hazardous waste | 0 | | Total amount of radioactive waste | 0 | | Non-Recycled Waste | 34,926,183 kg | | Percentage of non-recycled waste (% of total) | 98.6% | Waste by Treatment Type (2024) | Treatment Type | Hazardous/Non-Hazardous | Waste (kg) | | :--- | :--- | :--- | | Recycling | Non-hazardous waste | 479,259 | | Incineration | Non-hazardous waste | 34,028,209 | | Landfill | Non-hazardous waste | 897,974 | Social This section addresses Hafnia's social performance, covering its own workforce and workers in the value chain, detailing material impacts, risks, and opportunities related to employee well-being, diversity, human rights, and talent management Own Workforce (S1) Hafnia's reporting on its own workforce covers both onshore and seafarer employees, addressing material impacts such as challenging living conditions, alcohol consumption, incidents/injuries, and inappropriate behavior, alongside positive impacts like equal parental leave, maternity leave for female seafarers, and gender diversity Material Impacts, Risks and Opportunities for Employees (Selected Examples) | IRO Name | IRO Category | Impact Description | Target Group | | :--- | :--- | :--- | :--- | | Challenging living conditions on board | Potential Negative Impact | Poor ergonomic design can lead to injuries, fatigue, decreased performance | Hafnia's owned vessels and newbuilds | | Alcohol consumption on board | Potential Negative Impact | Uncontrolled alcohol consumption compromises safety | Hafnia's seafarers | | Incidents, injuries, and fatalities on board | Potential Negative Impact | Critical operations increase injury risk | Hafnia's seafarers | | Inappropriate behavior on board and cases of harassment | Potential Negative Impact | Hostile environment affects well-being and productivity | Hafnia's seafarers | | Equal parental leave for both parents for office employees | Actual Positive Impact | Boosts employee satisfaction, promotes gender equality | Hafnia's office employees | | Maternity leave for female seafarers | Actual Positive Impact | Supports women in maritime careers, enables diverse workforce | Hafnia's seafarers | | Gender Diversity on board above industry norms | Actual Positive Impact | Provides equal opportunities for female seafarers, broadens talent pool | Hafnia's seafarers | | Shortage of talent in the shipping industry | Actual Financial Opportunity | Investing in diverse talent pool drives growth, reduces hiring costs | Hafnia's overall company | - Hafnia's workforce includes shore-based employees and seafarers (internally and externally managed fleet)[228] - Policies to manage impacts include Vision, Purpose, Values; Human Rights; Anti-harassment and Anti-bullying; Diversity, Inclusion, Belonging & Equity (DIBE); Health, Safety, Environment and Quality Management; and Drug and Alcohol policies[235] - Engagement channels include regular dialogue, surveys, town halls, and specific forums for seafarers and shore-based employees[241][243] Number of Employees by Gender (Headcount at end of 2024) | | Seafarers Internally Managed Fleet | Seafarers - Externally Managed Fleet | Shore-based Employees | Total | | :--- | :--- | :--- | :--- | :--- | | Male | 2,159 | 2,054 | 173 | 4,386 | | Female | 199 | 273 | 101 | 573 | | Total | 2,358 | 2,327 | 274 | 4,959 | Employee Turnover (2024) | Employee Group | Employees Left | Turnover Rate (%) | | :--- | :--- | :--- | | Shore-based employees | 21 | 7.6% | | Seafarers (internally managed fleet) | 151 | 6.4% | | Seafarers (externally managed fleet) | 177 | 7.6% | | Total | 349 | 7% | - All seafarers are covered by a Collective Bargaining Agreement (CBA); shore-based employees are not[273] Gender Distribution of Management (Hafnia Top Management) | Gender | Number of Members | Percentage of Numbers | | :--- | :--- | :--- | | Male | 4 | 80% | | Female | 1 | 20% | | Total | 5 | 100% | Health and Safety Metrics (2024) | Metric | Value | | :--- | :--- | | Workers covered by health and safety management system | 100% | | Number of fatalities | 0 | | Number of recordable work-related accidents | 16 | | Lost Time Injury Frequency (LTIF) for the entire fleet | 0.13 | - Gender pay gap for seafarers is 62%, and for shore-based employees is 42.9%[278][280] - Number of incidents of discrimination: 10. Number of complaints filed through channels for workforce to raise concerns: 19[284] Workers In the Value Chain (S2) Hafnia identifies human rights breaches in its supply chain and shipyards as potential negative impacts on value chain workers, with plans to strengthen engagement and due diligence in 2025 Material Impacts, Risks and Opportunities on Value Chain Workers | IRO Name | IRO Category | Impact Description | Target Group | | :--- | :--- | :--- | :--- | | Human Rights breaches in supply chain | Potential Negative Impact | Suppliers in regions with weak human rights protections may engage in poor practices | Workers of our suppliers | | Human Rights breaches in shipyards | Potential Negative Impact | Shipyards in regions with documented human rights violations may expose workers to exploitation | Workers in the shipyards | - Hafnia's Human Rights Policy and Supplier Code of Conduct extend commitments to human rights to all workers across its value chain[290] - All measures for addressing human rights impacts, including access to the whistleblowing platform, are available to workers in Hafnia's value chain[292] - In 2024, no breaches of the Supplier Code of Conduct or human rights violations were identified in the supply chain through audits[293] - Hafnia plans to strengthen supply chain engagement in 2025 by mapping its supply chain, conducting due diligence, and enhancing supplier engagement through annual questionnaires[293][295][302][309] Governance This section outlines Hafnia's governance framework, focusing on business conduct, ethical principles, and compliance, detailing the roles of administrative and supervisory bodies, material impacts, and policies for anti-bribery, anti-corruption, and supplier management Business Conduct (G1) Hafnia's Board and Executive Management oversee business conduct, aligning with ethical principles and regulatory expectations, mitigating financial risks from compliance breaches and corruption - Hafnia's Board of Directors and Executive Management oversee business conduct, with the CEO and CFO accountable for governance initiatives[313] Material Impacts, Risks and Opportunities (IROs) for Business Conduct (Selected Examples) | IRO Name | IRO Category | Impact Description | Target Group | | :--- | :--- | :--- | :--- | | Healthy corporate culture driving the company towards shared goals | Actual Positive Impact | Fosters a collaborative and motivating work environment | Employees | | Ethical behavior and governance | Actual Positive Impact | Implements strong policies and training programs, ensuring ethical behavior | Employees and External Stakeholders | | Reputable trades | Actual Positive Impact | Upholds strong compliance practices, safeguarding against financial penalties | Employees and External Stakeholders | | Protection of whistle-blower through anti-retaliation policies and procedures | Actual Positive Impact | Ensures protection for whistleblowing for employees and third parties | Employees and External Stakeholders | | Legal liabilities due to compliance breach | Financial Risk | Illegal conduct results in reputational damage and significant financial losses | Hafnia's Overall Company | | Reputational effects from Corruption and bribery | Financial Risk | High levels of bribery/corruption disrupt operations, cause legal/financial damage | Hafnia's Overall Company | - Key policies include Anti-bribery and Anti-corruption, Supplier Code of Conduct, Corporate Governance, Anti-Trust, Anti-Money Laundering (AML), Whistleblowing, Human Rights, and Code of Conduct[318][319] - Hafnia promotes a 'speak-up culture' through a 24/7 whistleblowing platform (allowing anonymous reporting) and an open-door policy, prohibiting retaliation[321][322] - All onshore Hafnia employees receive annual mandatory training covering Anti-Bribery and Anti-Corruption, Anti-Trust, Sanctions, and GDPR[325] - High-risk functions for corruption and bribery include Vessel Operations, Procurement & Vendor Management, Commercial Activities, Government & Regulatory Affairs, and Finance & Accounts Payable[333][339][340] Anti-Corruption and Bribery Training Coverage (2024) | Group | Training Coverage (%) | Total Number Covered | Total Receiving Training | | :--- | :--- | :--- | :--- | | At-risk Functions - Shore based employees | 100% | 64 | 64 | | At-risk Functions - All Seafarers | 100% | 2,358 | 2,358 | | Managers | 100% | 76 | 76 | | Board of Directors | 0% | 5 | 0 | - No convictions for anti-corruption/bribery law violations and no fines were incurred in 2024[338] - No outstanding legal proceedings for late payments were registered in 2024[344] Limited Assurance Report KPMG AS provided a limited assurance conclusion on Hafnia's consolidated sustainability statement for 2024, stating that nothing came to their attention suggesting the statement was not prepared in all material respects according to the Norwegian Accounting Act and ESRS, including the EU Taxonomy reporting - KPMG AS issued a limited assurance report on Hafnia's 2024 consolidated sustainability statement[349] - The assurance engagement was conducted in accordance with International Standard on Assurance Engagements (ISAE) 3000 (Revised)[350] - The conclusion states that nothing came to their attention suggesting the Sustainability Statement is not prepared, in all material respects, in accordance with the Norwegian Accounting Act section 2-3 and European Sustainability Reporting Standards (ESRS), including EU Taxonomy reporting[349][354] - Management is responsible for designing and implementing the process to identify and assess material impacts, risks, and opportunities, and for preparing the Sustainability Statement[352][355] - The auditor's responsibility is to plan and perform the assurance engagement to obtain limited assurance about whether the Sustainability Statement is free from material misstatement[356]