Taskforce on Nature-related Financial Disclosures (TNFD)

• Introduction
• Summary
• General Requirements

• 1. Governance
• 2. Strategy
• 3. Risk and Impact Management
• 4. Metrics and targets

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Introduction

Since it was founded, MOL Group has engaged in marine transport as its core business, supporting people's lives as it fulfills its social responsibility and contributing to international logistics. In recent years, we have expanded our business from transporting goods to various associated businesses originating from marine transport, and non-shipping businesses that contribute to improving people's well-being and lifestyle, such as community development.
We provide social value as infrastructure that supports people's lives and receive rewards for them. The pride we have in this business started by our forebears has remained unchanged and will continue to be the foundation of the value we create, both economically and socially, even as our business scope and scale expands globally.

The source of the value we create lies in the various strengths possessed by our Group, such as our diverse human resources (human capital), advanced maritime skills, technological capabilities, and project management expertise (intellectual capital), as well as our strong partnerships with customers and society (social and relationship capital). In addition, the stable operation of our business depends on and benefits from natural capital, such as the "climate" and the "ocean." Amid growing concerns over global environmental issues, including the intensification of climate change and the loss of biodiversity, the degradation of these natural capital resources poses a direct threat to the survival of our business.

In order to operate social infrastructure businesses, including the shipping industry, it is essential to respond flexibly to weather and oceanic conditions such as gusty winds, fog, high waves, and ocean currents. Therefore, among the various forms of natural capital, the stability of the "climate" and the "ocean" is particularly important. To maintain these, it is necessary to recognize and address a range of environmental issues, including climate change, biodiversity loss, and air pollution.

While shipping supports a large portion of global trade as an efficient means of transporting large volumes of cargo at once, maritime transport also contributes to significant greenhouse gas (GHG) emissions. Climate change is therefore one of the environmental issues most closely related to our business. Thus, we believe that reducing GHG emissions not only helps prevent the intensification of extreme weather and oceanic conditions, but also contributes to mitigating negative impacts on the marine environment, thereby ensuring stable business operations. These efforts embody our corporate Mission: "From the blue oceans, we sustain people's lives and ensure a prosperous future."

In order to define more concrete actions, we analyzed how our business interacts with nature, including the climate, and what risks and opportunities may arise, using the TNFD framework. As a result, we found that while there is a risk of increased compliance costs if regulations on air pollution and GHG emissions are strengthened, there are also opportunities to establish a competitive advantage by promoting the adoption of environmentally friendly technologies and low- or zero-carbon fuels, as well as to capture new business opportunities in emerging fields driven by global trends such as the energy transition.
To mitigate these risks and seize these opportunities, we are committed to further deepening and expanding our initiatives. In addition, we are actively engaged in the conservation and restoration of marine environments and ecosystems, such as mangroves and coral reefs. Going forward, we intend to strengthen collaboration with a wide range of stakeholders across society and to establish these efforts as sustainable practices.

We will continue to fulfill our responsibilities as a company connected to the sea by recognizing and addressing various environmental issues, including climate change. By doing so, we aim to protect the ocean, our source of value creation, while operating our business stably and growing as a sea-based social infrastructure company that supports people's lives.

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Summary

In this disclosure, we show the results of our analysis of dependencies, impacts, risks, and opportunities related to shipping, the group's core business, and its value chain, and measures and targets for the identified risks and opportunities, based on the Taskforce on Nature-related Financial Disclosures (TNFD). The summary of the company's initiatives to address the disclosure items in the TNFD is as follows.

[MOL's initiatives to TNFD disclosure items (external view)]

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General Requirements
(assumptions and basic perceptions common to the entire report)

The TNFD Proposal defines six general requirements for the four pillars of "governance," "strategy," "risk and impact management," and "metrics and targets," to ensure consistency in disclosure information. The general requirements for this disclosure are as follows.

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(1) The Application of Materiality

The MOL Group identifies "Safety & Value," "Environment," "Human & Community," "Innovation," and "Governance" as "Sustainability Issues (Materiality)" as key issues for sustainable growth with society through realization of the Group Vision. This was identified with an awareness of not only the impact of the environment and society on the group, but also the two aspects (double materiality) of the group's impact on the environment and society. With regard to "Environment," we have identified climate change countermeasures, preservation of marine environments, protection of biodiversity, and prevention of air pollution as themes for action, and we are striving to enhance the corporate value of the group by pursuing these initiatives.

Five Sustainability issues

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(2) Scope of disclosures

This disclosure covers the group's main business, the shipping industry. With regard to the upstream and downstream of the shipping industry, we covered the shipbuilding stage in the upstream and the ship recycling stage in the downstream, in light of the availability of data and the difficulty of replacing bases for shipbuilding and recycling.
On the other hand, in identifying risks and opportunities, we included not only the value chain of the shipping industry, but also business domains where we are expanding our business, to complement the broader set of risks and opportunities for the company. In identifying risks and opportunities, we analyzed the external environment using STEEP¹ so that we could also include social, technological, economic, environmental, and political perspectives in our assessment.

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(3) The location of nature-related issues

In line with the LEAP approach², the identification and assessment recommended by the TNFD, we analyzed the regions (priority locations) with nature-related issues in our business from the regions involved in the shipbuilding, ship operation, and ship recycling stages in terms of their business significance and ecological sensitivity. Details of the analysis method and assessment results are described in"3. Strategy."

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(4) Integration with other sustainability-related disclosures

We intend to further align our disclosures with other sustainability-related disclosures, including the TCFD.

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(5) The time horizons considered

We have set the year 2050, the same year as our Task Force on Climate-related Financial Disclosures (TCFD), as for the time frame in which risks and opportunities will materialize,

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(6) The engagement of Indigenous Peoples, Local Communities and affected stakeholders in the identification and assessment of the organization's nature-related issues.

The MOL Group established its human rights policy based on its Corporate Mission, Group Vision, and Rules of Conduct and conducts human rights due diligence. The group has also established several advisory and reporting service desks to promptly address human rights-related concerns. Details are described in "2. Governance."

*1: A framework for companies to assess their external environment. It considers social, technological, economic, environmental, and political factors.

*2: Developed as an integrated approach for assessing nature-related issues such as contact with nature, dependencies on nature, impacts, risks, and opportunities, and used to prepare for TNFD disclosure by steps of Locate (Discover), Evaluate (Diagnose), Assess (Evaluate), and Prepare, through scoping.

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1. Governance

(1) The role of the Board of Directors in relation to nature-related risks and opportunities

The MOL Group identifies sustainability issues, including significant environmental issues such as climate change countermeasures, as our key management issues, and established a system to address these issues with the president & CEO as the highest authority. The Chief Sustainability Officer (CSO) is responsible for environmental initiatives, including climate change and nature-related issues, which are deliberated primarily by the Sustainability Committee, subordinate to the Executive Committee. The Sustainability Committee is chaired by the Chief Strategy Officer (CSO) and vice-chaired by the Chief Sustainability Officer (CSuO). Matters deliberated by the committee are appropriately reported to the Executive Committee and Board of Directors, and especially critical decisions are implemented after deliberation and resolution by the Executive Committee and The Board of Directors.
This Committee held eight meetings in fiscal year (FY) 2022 and six in FY2023 to discuss key sustainability issues, with a focus on climate change. In particular, matters relating to important environmental policies, such as the establishment of the "MOL Group Environmental Vision 2.2," following deliberation by the committee, reports and resolutions were made at the Board of Directors meeting and Executive Committee, where decisions were made directly by the management team led by the representative director.

In FY2024, we held a total of 10 committee meetings and established a new "Sustainability Discussion" separate from the general resolutions and reports at the Board of Directors' meeting to strengthen the Board's involvement in the establishment and review of sustainability management policies and strategies.
We established the Environment & Sustainability Strategy Division (Currently called Corporate Sustainability Division). responsible for implementing integrated measures to address the sustainability issues faced by our group, in FY2021 and integrated our sustainability initiatives into our management plan, "BLUE ACTION 2035," working to incorporate our initiatives to address environmental issues, with a focus on climate change countermeasures, into our business strategy. We have also established the "MOL Group Environmental Vision" to promote comprehensive initiatives addressing environmental issues in general. With regard to this vision, the Sustainability Committee regularly monitors the status of response to environmental issues. We will also promote internal cooperation to ensure that each initiative corresponds with our financial plan.
The MOL Group sets GHG emissions intensity reduction targets as a core KPI in the "BLUE ACTION 2035" management plan, and incorporates progress on this issue into our Directors' Remuneration System, creating a mechanism whereby the progress of sustainability-related initiatives is reflected in their remuneration.

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(2) Engagement with stakeholders

The MOL Group stipulates that it shall engage in transparent dialogue with all stakeholders, including local communities. In the "MOL Group's Three Basic Principles of Corporate Governance" and the "MOL Group Corporate Governance Policy (Article 3).
In addition, the "MOL Group Human Rights Policy," expresses our respect for the human rights of all people involved in our business activities, striving to identify and mitigate human rights risks, including human rights violations against indigenous peoples and local communities, through our initiatives on human rights due diligence. Furthermore, we have established several advisory and reporting service desks that can be used when specific concerns arise. All of these desks ensure the anonymity of the person seeking consultation and the confidentiality of the reported information, and guarantee that no disadvantageous treatment will result from submitting a report. For external stakeholders, we have built a system to respond appropriately while ensuring fairness and transparency by establishing a multilingual external service desk and Iaccepting consultations through impartial third parties.

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2. Strategy

(1) Dependence and impact

We conducted an analysis using ENCORE, a tool developed by the United Nations Environment Programme World Conservation Monitoring Centre (UNEP-WCMC) and others to grasp the dependence of our business on nature and its impact. The analysis covers the group's main business, the shipping industry. With regard to the upstream and downstream of the shipping industry, we covered the shipbuilding stage in the upstream and the ship recycling stage in the downstream, in consideration of the availability of data and the difficulty of replacing bases for shipbuilding and recycling.
Based on the analysis, it has been demonstrated that the direct operations of the shipping industry rely on climate regulation services (the function of stabilizing and adjusting weather and waves through the natural force of restoration), the stable supply of surface water (the function of assisting in maintaining water levels in canals and ports through the stable supply of natural water resources), and at upstream and downstream stages, the mitigation of natural disasters and noise reduction functions (the functions provided by forests and other natural features in the vicinity of our activity bases, such as preventing or mitigating landslides and absorbing noise).
Regarding impact, the emission of GHGs and the leakage of oil and hazardous substances have been identified throughout the value chain.

[Chart 2-1: Dependance/Impact on Nature in MOL Value Chain]

While we recognize that all these dependencies and impacts are significant, analyses such as "ENCORE" have revealed that the impact of GHG emissions is relatively greater compared to other dependencies and impacts.

To mitigate this impact and reduce the adverse effects on the natural systems we depend on, it is important to understand the relationship between the ocean and climate.
As shown in Figure 2-1, it has become evident that in the relationship between our business operations and nature, the impact of GHG emissions and our reliance on a stable marine environment through climate regulation services and the maintenance of water quantity and quality are significant.
Figure 2-2 illustrates the sequence of impacts whereby reducing GHG emissions not only contributes to climate mitigation-such as stabilizing weather and wave conditions-but also helps mitigate ocean acidification and sea level rise, supports the maintenance of water levels in canals and straits, and ultimately contributes to the preservation of marine environments and ecosystems. This overview was organized by our company with reference to the Sixth Assessment Report published by the Intergovernmental Panel on Climate Change (IPCC).
By accurately understanding these interrelationships, we believe we can implement more effective and efficient countermeasures, which will in turn contribute to the health of the oceans-our primary field of business.

*1: Please refer to this web page (link) for details on the international conventions our company complies with.

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(2) Identification of priority locations

TNFD recommends the identification and disclosure of priority locations concerning direct operations and sites involved in the value chain. Priority locations refer to areas or sites that a company should particularly focus on when assessing its relationship with nature. In this disclosure, we have targeted the upstream, direct operations, and downstream aspects of the shipping industry. We have used criteria such as "business significance" and "ecologically sensitive locations with respect to biodiversity importance" to identify sites. Locations that were deemed high in either criterion have been extracted.

<Examples of locations that are important for business significance^*3 or ecologically sensitive^*4>

Upstream:Shipyards mainly located in Asia
Direct operation:Straits and canals (Suez Canal, Panama Canal, etc.)
Downstream:Ship recycling yards mainly located in India, etc.

*3: Locations deemed to be of high importance in business operations (e.g., difficulty of substitution, port call duration, etc.)

*4: Locations situated in areas that have been assessed as having a very high ecological sensitivity (e.g., refer to the dataset indicated by TNFD / Table 2-2). It should be noted that for maritime transport routes, further scientific knowledge and research outcomes are necessary to measure and evaluate specific dependencies and impacts in order to analyze risks and opportunities. Therefore, these routes were not included as candidates for locations.

When we cross-referenced the sites identified above with the results of (1) dependence and impact, we found that, for climate regulation services and GHG emissions-which showed high levels of dependence and impact-it is necessary to consider these factors across all regions relevant to our business. Additionally, since there were no significant differences in ecological sensitivity among the identified sites, it was concluded that further examination is required to determine the priority sites for our shipping business. We will continue to closely monitor the situation and conduct reviews as necessary.

[Table 2-2: External databases on the importance of biodiversity used in the evaluation]

*5: We comprehensively selected evaluation criteria based on the availability of data from the data sets listed in the TNFD LEAP Guidance, the natural capital subject to evaluation, etc.

*6: Ecosystem integrity : The IUCN defines it as the existence of viable and ecologically functioning populations of species within habitats of sufficient quality and extent.

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(3) Risks and Opportunities

1. Assumptions for Analysis

In order to comprehensively identify nature-related risks and opportunities that may affect our business, we utilized the analysis results regarding our business's dependence on and impact on nature described in the previous sections, and, in addition, conducted a STEEP analysis to identify potential events from social, technological, economic, environmental, and political perspectives that may arise now or in the future.

[Risk evaluation axis]

• Financial impact: Decreased revenue and increased costs.
• Probability of occurrence: The likelihood of risk materialization (with a time horizon up to 2050), based on the occurrence of similar risk events over the past ten years and publicly available information on various regulations.

[Opportunity evaluation axis]

• Financial impact: Effects of increased revenue and reduced costs
• Potential to utilize our company's strengths.: Status of management resources that give our group a competitive advantage and proximity to existing businesses

2. Evaluation Results (Risks and their mitigation strategies, opportunities and their acquisition strategies)

[Risk]
Among the derived risks, Table 2-3 shows the types of risks evaluated as having a relatively significant impact from the perspectives of financial impact and likelihood of occurrence, as well as related measures to avoid or mitigate them.
As a result of our evaluation, the risks identified as having particularly high financial impact and likelihood of occurrence were those related to GHG emissions arising from climate change. These risks are already covered by TCFD analysis, and necessary measures are being implemented. In implementing such measures, we believe it is important not only to avoid and mitigate risks, but also to create and seize opportunities. For example, GHG emission reduction measures are risk avoidance and mitigation measures, we expect to achieve an increase in market share by quickly responding to the needs of shippers who prefer low-carbon transportation.
In addition, as mentioned in the previous section, climate change measures not only reduce GHG emissions but also contribute to the conservation and restoration of natural environments, including the oceans. For example, the mangrove restoration and conservation project in Indonesia, which we have participated in since 2022, not only removes and absorbs CO₂ through mangrove planting, but also enhances the biodiversity of mangrove habitats and protects the lives of people living on the coast from high waves, creating co-benefits^*7 for nature and local communities. In addition, we are involved in initiatives that offer multiple benefits, such as reducing GHG emissions, preventing collisions with marine life and minimizing underwater noise, by cooperating with slow steaming.
In addition to climate change, we also recognize risks arising from issues such as water and air pollution. Accordingly, we not only comply with existing international conventions such as the MARPOL Convention and regional regulations^*8, but have also already implemented a variety of our own initiatives. For details, please refer to the "Preservation of marine environment/Protection of biodiversity" and "Prevention of Air Pollution" pages on our website. In addition, we minimize our impact on the environment through our own initiatives, such as establishing the "Superior Ship recycling Standards (SSS) ^*9 and maintaining, implementing, and establishing the safety operation management system^*10.

[Table 2-3: Nature-related risks]

*7: Secondary benefits: This refers to the positive effects that a particular measure taken for one aspect of nature can also have on other aspects of nature.

*8: Compliance with relevant international treaties, regional regulations, etc.
The MARPOL Convention, officially known as the 1978 Protocol to the 1973 International Convention for the Prevention of Pollution from Ships, is a treaty designed to prevent marine pollution caused by ship operations and accidents. It currently includes six annexes that stipulate methods for discharging SOx and NOx from ships, as well as oil, hazardous liquid substances, hazardous materials, sewage, etc., and we comply with these regulations. For information on other relevant international treaties, etc., please refer to "Regulations."

[Table 2-4: Examples of Relevant Environmental Regulations]

*9: Establishment of the Superior Ship recycling Standards (SSS)
Recycled steel from ship recycling supports the demand for steel in various countries and regions, and demand is also increasing in response to growing environmental awareness to reduce the burden on the environment.
On the other hand, challenges related to the management and disposal of hazardous substances during ship dismantling, environmental impacts, and worker health and safety have been internationally recognized. In response, the International Maritime Organization (IMO) adopted the "Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships" in 2009, which came into force in 2025.
In addition to complying with this convention, we have newly established and implemented the Superior Ship recycling Standards (SSS)-our own ship recycling yard selection criteria-in fiscal year 2023 to promote sustainable ship recycling in line with the above background.
For details on SSS, please refer to "Initiatives for ship recycling" under "Responsible Procurement."

*10: Maintaining, implementing, and establishing a Safe Operation Management System.
Among measures to avoid and reduce risks, maintaining, implementing, and improving safe operation systems are important initiatives from the perspective of protecting the sea.
We see safety as one of our fundamental missions and as the basis for taking on new challenges. Driven by this belief, we established the "MOL Group Safety Vision" in January 2024 to serve as a blueprint for safety within the Group's operations.
In February 2007, we established the Safety Operation Supporting Center (SOSC) as an organization that provides 24/7 support and help desk functions from land to vessels, with the motto of "Never leave the captain alone." Currently, our staff, including two experienced captains, are on duty 24/7 and monitor the latest bases and weather and sea conditions of all operating vessels in real time and provide that information to the vessel. We are fully committed to preventing the occurrence of major accidents and aim to achieve "the world's highest level of safe operation."

[Opportunity]
Table 2-5 shows the types of risks that were evaluated as having a relatively large impact in terms of financial impact and the company's strengths, as well as measures to avoid or mitigate them. As a result of the evaluation, opportunities related to climate change were recognized, as were risks.

[Table 2-5: Nature-related opportunities]

We also consider the following ongoing initiatives to be leading to the acquisition of nature-related opportunities.

Contributing to the development of marine science and technology through cooperation in research and surveys

We gather, share, and cooperate in the use of data and expertise obtained through our business activities regarding the ocean, which is considered to lack environmental data compared to land.
For example, meteorological agencies around the world, including the Japan Meteorological Agency, create weather data such as weather maps based on meteorological observation data provided by vessels underway, as it is difficult to collect data from meteorological observations at sea. This data is not only used to provide daily weather forecasts and marine forecasts but is also widely used on a global scale for monitoring and researching global warming and climate change. We contribute to the development of meteorological services, as well as to marine safety and the preservation of the global environment, through the continuous provision of marine weather data.
We also dispatch outfitting personnel (who are assigned to shipyards to confirm compliance with shipbuilding specifications and quality standards and identify defects) and operation services for the Arctic research vessel Mirai Ⅱ, which is currently under construction by the Japan Agency for Marine-Earth Science and Technology (JAMSTEC) ^*11. The Mirai Ⅱ will conduct comprehensive observations of the atmosphere, weather, oceans, sea ice, and other phenomena in the Arctic region, contribute to the sustainable development, utilization, and conservation of the Arctic region by enriching observational data and scientific knowledge, and aims to contribute to the development of personnel such as researchers and engineers. We will contribute to a better future for the planet by leveraging the expertise and human resources that the group has accumulated in operation on the Arctic route and handling of LNG fuel for the operation of Mirai Ⅱ.
In addition, we cooperate in the transport of loggerhead turtles for migration pattern surveys and provide marine data collected by vessels to the Japan Coast Guard. We believe these activities will contribute to the development of marine science and technology, and ultimately to the sustainability of the oceans, which are the arena for our business.

*11: To be implemented by MOL and its wholly owned subsidiary, MOL Maritex Co., Ltd.

Natural Environment Restoration and Conservation Project and Contribution to Local Communities in Mauritius

In response to running aground off the island of Mauritius and leaking bunker oil in 2020, a fund was established with the aim of supporting environmental restoration and conservation, as well as providing assistance to the local community. This fund supports various projects led by local NGOs and Japanese academic institutions. In 2024, employees from our group worldwide will participate in on-site training in Mauritius to deepen their understanding of marine pollution prevention and natural environment protection, reaffirming the importance of contributing to local communities through our business activities. Moving forward, we aim to expand the scope of these activities to other regions closely connected to our business, thereby further supporting and promoting solutions to social issues.
Additionally, we are conducting campaigns at our global locations to focus on various social contribution activities, including environmental conservation. We are collaborating on research into the migratory routes of loggerhead turtles using our operated vessels and organizing survey and research events supervised by coral experts. Furthermore, to promote the regeneration of seaweed beds, our employee cafeteria offers menus that effectively utilize fish that consume seaweed. These initiatives aim to foster awareness among our staff and contribute to nature through cooperation in research activities with high scientific and social significance, while also enhancing corporate value through building relationships with local communities.

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3．Risk and Impact Management

Handling of nature-related risks in risk management systems

Nature-related risks are managed within the risk management processes of our Group. Executive officers in charge of each management division within the corporate organization supervise the risk management status of each business division belonging to the sales and regional organizations, providing necessary advice as appropriate. In addition, major risks are centrally managed through regular reports to management meetings and their subordinate committees, with priority given to addressing risks deemed particularly significant.
For important decision-making, potential risks are identified in advance by a dedicated internal review department. Where necessary, assessments are conducted by the relevant departments proposing the matter, after which the decision-making process proceeds. Depending on the content and significance of the decision, six committees have been established under the management meeting to conduct preliminary deliberations, thereby facilitating in-depth examination of risks and clarification of key issues. Furthermore, for the most critical matters, careful deliberation is conducted at the management meeting before submission to the Board of Directors, ensuring decisions are made with a strong emphasis on risk management.
For further details, please refer to "Risk Management."

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4．Metrics and targets

We disclose the TNFD Global Core Disclosure Indicators as shown in Table 4-1 below. The Global Core Disclosure Indicators are aligned with global policy goals such as the Global Biodiversity Framework (GBF).

[Table 4-1: Core global disclosure metrics]

As shown in Table 4-2 below, we will disclose additional indicators for measuring the progress of risk reduction measures.
For example, with regard to the "risk of increased costs due to the adoption of GHG regulation-compliant equipment and carbon taxes," we disclose "the "zero-emission fuel usage ratio" as an indicator to measure progress in the adoption of next-generation fuels, which is a measure to reduce this risk.

[Table 4-2: Additional global disclosure metrics]

*12: The total number of vessels already in service and those for which a construction decision has been made.

Among the core indicators and additional indicators, we have set targets for those indicators that are closely tied to our environmental strategy and the reduction of nature-related risks and the acquisition of opportunities, as shown in Table 4-3 below.

[Table 4-3: Target and milestone]

*13: The total number of vessels already in service and those for which a construction decision has been made.