ESG Disclosure 2024 | Reporting Year 2023

EU ETS: Readiness and Implementation As part of the European Union’s Fit for 55 legislative package, several new regulations have been introduced for the shipping industry, including the EU Emissions Trading System (EU ETS). This cap-and-trade system is designed to reduce greenhouse gas (GHG) emissions by setting a sector-wide emissions cap.

Readying for FuelEU FuelEU is part of the broader “Fit for 55” legislative package aimed at reducing the European Union’s greenhouse gas emissions by 55% by 2030. Scheduled to take effect in 2025, FuelEU specifically targets the maritime industry, mandating that vessels operating within EU waters must adhere to specific carbon intensity limits. Vessels exceeding these limits face penalties unless they can pool with lower-emission vessels to meet the overall compliance threshold. This pooling mechanism allows ships with lower carbon emissions to sell their excess capacity to higher-emitting vessels, creating a market incentive for investment in low-carbon and alternative fuel technologies. Over time, these carbon intensity limits will become stricter, further accelerating the shift towards sustainable maritime technologies. A key distinction of FuelEU, compared to the EU Emissions Trading System (ETS), is the allocation of compliance responsibilities. Under FuelEU, the responsibility shifts

3. Submission of Emissions Data V. Group can act as a nominated user within the THETIS- MRV system, enabling us to submit verified emissions data to the relevant authority on behalf of our clients. 4. Emissions Allowance Trading We offer an optional service for trading emissions allowances through our partnership with the Marcas association and Aither, a seasoned carbon trading solutions provider. This partnership ensures optimal pricing for emissions allowances. Aither also assists with the setup of Maritime Operating and Holding Accounts (MOHAs) and manages the surrendering procedures. We coordinate closely with Aither to upload emissions data, calculate necessary allowances, and facilitate allowance trading, thus removing administrative burdens for our clients. 5. Surrender of Allowances We are developing a service where V. Group could manage the surrender of emissions allowances and perform related accounting as an authorized representative in our clients’ MOHAs, tailored specifically to our clients’ needs. Our comprehensive EU ETS service ensures that our clients receive accurate, real-time data, allowing them to comply effortlessly with the EU ETS and deliver premium services to their charterers.

from ship owners to ISM (ship) managers. This shift not only introduces new risks but also opens up various opportunities. As ISM managers are directly responsible for operational compliance, they play a crucial role in navigating these regulations, potentially guiding investments and operational decisions that align with FuelEU requirements. At V., recognising the implications of this regulatory shift, we are actively exploring opportunities to position ourselves as a leading provider of FuelEU services. Our planned offerings include consultancy for compliance strategies and pooling arrangements, as well as technical services aimed at integrating shore power solutions and facilitating the use of low-carbon fuels in maritime operations. Over the next year, we will delve into these possibilities to ensure we can offer our clients comprehensive, high- quality FuelEU-related services.

To help our clients comply with these regulations, we have developed a new service that significantly eases the burden of data collection and verification. Our EU ETS service comprises a five-step process: 1. Emissions Data Collection and Validation We collect emissions data through daily vessel voyage reporting. Utilising our in-house data analytics tool, ShipSure, we have enhanced our capabilities for automatic digital data verification using inputs like vessel performance models, behaviour mapping, AIS positional data, and weather information. This integration allows for the automated validation of our clients’ emissions data. 2. Third-Party Verification We partner with the Classification Society (Lloyd’s Register) to verify voyage and emissions data at the end of each voyage. We have established a seamless data transfer between our ShipSure platform and the third- party verifier’s system, ensuring smooth data flows. The Classification Society then produces verified emissions statements, including the calculation of required EU Allowances (EUAs), which are shared with our clients.

Client buys, holds and surrenders carbon credits to maintain compliance with EU ETS scheme (through Aither or another EUA provider)

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V. introduces Client to Aither including EU ETS support service and platform

Aither & Client Relationship

Verified Emissions Package

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Data Collection, Verification & Reporting

EU Allowance Procurement

EU Allowance Surrender

Client takes decision on whetehr to use Aither’s carbon trading support service and platform

V. shares verified emissions certification and data package to Client

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Emissions data collection from Vessel Daily Voyage Reporting

Automatic validation of emissions data

Verification of Voyage Reporting Data with Classification Society (Lloyd’s Register)

Submission of emissions data to required administrative authorities. (EU THESIS)

Client introduced to Emission Allowance Trader

Provides free consultancy service; to support Clients with EU ETS

Procures required EUAs and deposits into client account (trading / operator)

Monitor & Management of EUAs

Surrender of EUAs

through Enhanced Digital Verification Check

V. EU ETS Service

Client/Charter Responsibilities (Partnered with Aither)

Client’s Responsibilities (Optional V. Service)

26 | EU ETS: Readiness and Implementation & Readying for FuelEU

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