E2 Pollution
As part of our commitment to address these negative impacts, we have used our double materiality assessment (DMA) process to further enhance our understanding of potential pollution-related impacts, risks, and opportunities. Detailed information about the DMA process can be found in the ESRS 2 section.
Impact, risk and opportunity management
Material impacts, risks and opportunities and their interaction with strategy and business model
The following material pollution-related impacts have been identified as part of our DMA:
Impacts, risks and opportunities (IROs)
| Location in the value chain | Time horizon | ||||||
| Upstream | Own operations | Downstream | Short-term | Medium-term | Long-term | ||
| Pollution of air | Actual negative impact | ⚫ | ⚫ | ⚫ | ⚫ | ⚫ | ⚫ |
| Pollution of water | Actual negative impact | ⚫ | ⚫ | ⚫ | ⚫ | ||
Pollution of Air
Impacts from Höegh Autoliners own operations
Pollutants, such as nitrogen oxides (NOx), sulphur oxides (SOx), non-methane volatile organic compounds (NMVOCs), and particulate matter (PM) are released into the atmosphere from the combustion of fossil fuels as part of vessel operations. These pollutants negatively impact both the environment and human health. The impact is systemic to the maritime sector, and it is relevant in the short, medium, and long term.
Impacts through Höegh Autoliners value chain activities
Both shipbuilding and ship recycling activities negatively impact the environment through air pollution. Höegh Autoliners’ twelve‑vessel newbuilding program, due for completion in early 2028, has already delivered seven vessels, with five still under construction at period end. These activities make the potential environmental impacts particularly relevant in the short to medium term. At the same time, the expected recycling of some existing vessels over the coming years underscores that the issue will remain equally significant in the medium to long term.
Pollution of water
Impacts from Höegh Autoliners own operations
Höegh Autoliners’ activities may cause marine pollution through oil spills during bunkering operations, discharges of wastewater such as bilge and sludge water, and vessel cleaning activities. Bilge water, which contains a mixture of substances including water, oil, grease, sludge, and other chemicals, could potentially cause negative impacts if untreated water is released into the ocean. As these impacts are systemic within the maritime sector, they remain relevant across the short, medium, and long term.
Policies related to pollution
Recognizing the severity of the mentioned impacts, the International Maritime Organization (IMO) has implemented strict regulations to limit the pollution within the sector through the IMO’s International Convention for the Prevention of Pollution from Ships (MARPOL). Höegh Autoliners has established policies and procedures that are aligned with applicable regulations for both own operations and, where relevant, across the value chain. Relevant policies are accessible to all employees via our internal platform.
Höegh Autoliners’ environmental actions, targets, and focus areas are outlined in its overarching Environmental Policy and Environmental Focus Plan, both detailed in disclosure requirement ESRS E1-2.
The policies “Sulphur emission control areas/ Emission control areas/ Nitrogen oxides emission control areas – MARPOL” , are describing the procedures in place to regulate emissions from our vessels to prevent, reduce, and control air pollution of NOx, SOx and particular matter (PM). This policy is applicable to Höegh Autoliners’ own shipping operations and is relevant in certain geographical areas.
The policy “MARPOL Protected Areas” provides operating guidelines to ensure all marine protected areas, special areas, emission control areas, and particularly sensitive areas are accurately identified and that all respective protective measures are strictly followed.
The “Sludge and Bilge Water Operation and Maintenance Policy” outlines required procedures for proper sludge and bilge water handling during vessel operations in compliance with international and national regulations. Among other things, the policy includes guidelines for processing, record-keeping, potential leakages, and maintenance of processing equipment.
Wastewater generated during vessel operations, such as sewage, is managed in accordance with our “Sewage Handling and Responsibility Policy” .This policy provides clear guidelines for proper handling and disposal of sewage to ensure compliance of MARPOL Annex IV.
All vessel-specific plans and policies are approved by class to ensure compliance with international regulations and are maintained in our internal document system, accessible to all employees, including seafarers. The policy defines treatment procedures and allocates responsibilities among crew members. To strengthen implementation, Höegh Autoliners equips seafarers with comprehensive training and upskilling, ensuring they are prepared to manage marine casualties and emergencies effectively.
Implementation and oversight of the above-mentioned policies fall under the responsibility of the Chief Operating Officer.
Actions and resources related to pollution
Actions related to pollution of air
Executing fleet transition plan and energy efficiency measures
Pollution management is closely linked to energy efficiency, and Höegh Autoliners has consistently improved fleet performance through technical upgrades and operational measures for several years. The ongoing fleet transition and adoption of alternative fuels will further advance our decarbonisation targets while also reducing non‑GHG emissions such as SOx and NOx. Because air pollution is directly tied to fuel consumption, the decarbonisation measures outlined in ESRS E1-3 are expected to deliver corresponding reductions in non‑GHG pollutants. Progress on these measures are also detailed in ESRS E1-3.
The Company has not established specific actions addressing air pollution at ship yards, but will assess the relevance of introducing additional expectations for future newbuilding cycles. Further, as no vessels were recycled during the reporting year, Höegh Autoliners has not implemented specific downstream air‑pollution measures. Future assessment of relevant recycling yards will incorporate such measures, conducted in line with international recycling regulations and our “Green Recycling Policy” , covering sustainability topics such as air pollution.
Höegh Autoliners is committed to using fuels that comply with the IMO Global Sulphur Cap 2020. To meet the stricter requirements of designated emission control areas (ECAs and SECAs) aiming to reduce airborne emissions, we have established rigorous fuel‑switching procedures to ensure compliance across all operational areas.
Actions related to pollution of water
Bilge water and oil spill management
All Höegh Autoliners vessels are equipped with Oily Water Systems (OWS), enabling continuous monitoring of bilge water through oil content meters. If bilge water cannot be processed via the OWS, it is safely collected and retained onboard until discharged at an approved shore reception facility. This process ensures proper handling and disposal of bilge and oily water, preventing oil spills and the release of untreated water into the sea. Strict adherence to company policies in operating the OWS helps minimize environmental impacts and supports effective water pollution control.
To prevent spills into the sea, Höegh Autoliners enforces strict procedures for handling sewage, greywater, and bunkering operations. Effective wastewater and pollution management is supported by crew awareness programs, targeted spill‑response training, and comprehensive emergency response plans with checklists. All accidental or operational spills, regardless of type or quantity, must be reported immediately, and any malfunctions in approved sewage treatment plants are promptly escalated to the vessel manager. Proper operation of treatment units and bunkering systems is ensured through engine crew training, adequate spare parts, and maintenance carried out in line with the Planned Maintenance System (PMS) and manufacturer recommendations. Regular preventive maintenance and diligent equipment upkeep further strengthen preparedness, ensuring our crews are fully equipped to respond effectively and minimize environmental impacts.
In 2025, the actions mentioned above have continued as part of the vessels’ daily operations, conducted in accordance with company policies and international requirements, without any significant challenges.
Metrics and targets
Targets related to pollution
Based on regulatory requirements and stakeholder expectations, Höegh Autoliners has established pollution-related targets to reduce its environmental footprint and strengthen business resilience. Although not based on conclusive scientific evidence, they support our policies and procedures, and address pollution-related impacts from our operations as identified in the DMA. The target presented below, applies across the entire Höegh Autoliners fleet.
This target aims to minimize operational oil spills from vessel operations.
In 2025 there were no major oil spills recorded, consistent with the 2024’s results. Höegh Autoliners remains committed to preventing future incidents by focusing on operational controls, maintaining strict spill‑prevention procedures, and equipping crew with detailed checklists to be used in emergency situations.
This target is designed to minimize potential financial impacts from oil spills. By ensuring prompt reporting of all spill incidents and closely monitoring HIS reports, we reduce the risk of oil spill‑related fines.
In 2025 we have not reported any major operational oil spill to the environment, in line with 2024’s result. As such, no fines related to oil spill were received.
Accounting policies - Metrics and targets
Our pollution-related targets are absolute targets without a relative measurement towards a baseline. Metrics disclosed in this section are used to monitor IROs related to pollution. These metrics are not validated by an external body other than the assurance provider of the Sustainability Statements.
Air pollution is closely linked with Climate Change. Therefore, Höegh Autoliners has not set specific targets for air pollution, as these are implicitly included in the targets outlined in ESRS E1-4. Consequently, the effectiveness of policies and actions related to air pollution are tracked with the same level of ambition as established for climate change.
Pollution of air, water, and soil
Höegh Autoliners continues to disclose key environmental performance metrics, offering transparency on progress toward our pollution‑related targets. These disclosures also explain the methodologies and assumptions applied in setting the targets.
Air pollution reporting
| Unit | 2025 | 2024 1 | |
| Nitrogen Oxides (NOx) | MT | 28 861 | 28 664 |
| Sulphur Oxides (SOx) | MT | 2 765 | 2 870 |
| Black Carbon (BC) | MT | 29 | 29 |
| Carbon Monoxide (CO) | MT | 1 133 | 971 |
| Particular Matter (PM) | MT | 1 398 | 1 594 |
| Volatile Organic Compouts (VOC) | MT | 1 368 | 1 277 |
| 1 2024 numbers have been restated due to updated calculation methodology. | |||
|---|---|---|---|
Accounting policies - Air pollution reporting
Air pollution: Consists of the amount of air pollutants emitted by Höegh Autoliners’ operations that are not included in the GHG emissions reported under E1 – Climate Change.
The calculation and consolidation follow the same methodology as applied for scope 1 emissions, by using actual fuel consumption data combined with the relevant emission factors to quantify the associated air pollutant outputs.
Entity-specific metrics
| Unit | 2025 | 2024 | |
| Number of major oil spills | # | 0 | 0 |
| Fines related to oil spills | $ | 0 | 0 |
| Days in ECA/SECA (MARPOL) | # | 1 741 | 1 784 |
| Non-compliance with environmental laws and regulations | # | 1 | 1 |
| Sludge water | m3 | 6 456 | 5 884 |
| Bilge water | m3 | 6 340 | 5 892 |
In 2025, the company reports one minor regulatory finding related to air‑emissions compliance. The issue was promptly addressed, and corrective measures were implemented to prevent recurrence. No significant environmental impact was associated with the incident.
Generation of sludge and bilge water
Höegh Autoliners continuously monitors the generation of sludge and bilge water, in line with our policies. These entity-specific metrics support our goal of preventing oil spills.
During the year, about 96% of sludge generated was disposed of at designated shore facilities. In relation to bilge water, 83% was either discharged to sea following proper processing through OWS or disposed of at shore facilities.
Accounting policies - Entity-specific metrics
Oil spills: Oil spills are reported based on their size: 700 tons categorized major oil spills. Vessels report all spills monthly.
Days in ECA/SECA (MARPOL): Number of days vessels navigate through areas with stricter emission controls, as per IMO guidelines. The calculation is performed manually using the date and time of entry and exit. The results are aggregated monthly and then reported manually at the end of each month through the EFP survey form.
Environmental laws and regulations: Primarily refer to MARPOL 73/78 under the IMO, as well as local regulations applicable to vessels calling at ports in different port states.
Water pollution: Includes oil leakage, sludge, and untreated bilge water released into the ocean. These entity-specific metrics support our goal of preventing oil spills.
Total sludge generated: Total sludge generated is the sum of all sludge generated during the year. Total sludge generated is measured and reported through the Environmental Aspect Log.
Total bilge water generated: Total bilge water generated is the sum of all bilge water generated during the year. Data is measured and reported through the Environmental Aspect Log.
Technically managed vessels refer to the vessels for which the Höegh Autoliners Group holds responsibility under the IMO's International Safety Management (ISM) Code. All entity-specific metrics referred to above cover all vessels technically managed by the Höegh Autoliners Group.
Anticipated financial effects from pollution-related risks and opportunities
Following the reassessment of DMA, Höegh Autoliners has concluded that there are no material risks and opportunities related to pollution. Consequently, no significant financial impacts are anticipated in short, medium, or long term in relation to this topic.
