EXMAR report 2025

3.5 APPENDIX 131 DISCLOSURE REQUIREMENTS ESRS 2 MDR-P-65b The undertaking shall disclose information about policies adopted to manage material sustainability matters. The disclosure shall include the following information: (b) a description of the scope of the policy, or of its exclusions, in terms of activities, upstream and/or downstream value chain, geographies and, if relevant, affected stakeholder groups ■  All policies are developed on group level and are applicable to both office employees and seafarers. We do apply a pragmatic approach, tailoring policies to the nature of employment. Hence, there may exist several versions of policies, dedicated for office employees versus seafarers (e.g., related to topics such as health & safety). In addition, the car policy & home office arrangement are currently applied at the headquarters office in Antwerp with the ambition to broaden the application to the regional offices. ■  Anti-fraud & anti-corruption policy: Applicable to both EXMAR personnel and all Third Parties. ■  Internal privacy policy: Applicable to both EXMAR personnel and other seafarers on vessels owned or chartered by EXMAR Group. ■ Whistleblowing policy: Applicable to EXMAR personnel, third parties and other seafarers on vessels owned or chartered by EXMAR Group. ■  Acceptable use policy: Applicable to EXMAR personnel, consultants and third-party contractors with access to EXMAR resources, data and information. ESRS 2 MDR-P-65c The undertaking shall disclose information about policies adopted to manage material sustainability matters. The disclosure shall include the following information: (c) the most senior level in the undertaking’s organisation that is accountable for the implementation of the policy The Board of Directors is responsible for defining and reviewing key policies. The Executive Committee is accountable for our day-to-day management and policy, hence, the proper implementation of each policy. ESRS 2 MDR-P-65d The undertaking shall disclose information about policies adopted to manage material sustainability matters. The disclosure shall include the following information: (d) a reference, if relevant, to the third-party standards or initiatives the undertaking commits to respect through the implementation of the policy. References to applicable regulations per policy/domain. No references to third-party standards or initiatives. ESRS 2 MDR-P-65e The undertaking shall disclose information about policies adopted to manage material sustainability matters. The disclosure shall include the following information: (e) if relevant, a description of the consideration given to the interests of key stakeholders in setting the policy Described in the social & governance chapter. ESRS 2 MDR-P-65f The undertaking shall disclose information about policies adopted to manage material sustainability matters. The disclosure shall include the following information: (f) if relevant, whether and how the undertaking makes the policy available to potentially affected stakeholders, and stakeholders who need to help implement it ■  The overarching framework for all policies is described in EXMAR’s Compliance Model, which is available on the website. ■  All policies for internal use are available on EXMAR’s intranet. ■  Policies also applicable to external shareholders (external privacy policy & whistleblowing policy) are published on EXMAR’s website. ■  Each new employee receives an onboarding package, including all policies. He/she is expected to acknowledge the receipt and confirm all policies have been read.