EXMAR report 2025
3.5 APPENDIX 130 DISCLOSURE REQUIREMENTS HEADLINE OBJECTIVE 3.5.2 Appendix 2: Overview of EXMAR policies and alignment with ESRS 2 MDR-P Disclosure Requirements The table below demonstrates how EXMAR’ policies referred to in the sustainability statement, comply with the Minimal Disclosure Requirements for Policies from ESRS 2 – General Disclosures. The policies concerned are the following: GENERAL ESG ENVIRONMENT SOCIAL GOVERNANCE Sustainability policy HSEQ policy Car policy Internal & external privacy policy Anti-harassment & non-discrimination Policy Whistleblowing policy (incl. Grievance mechanism) Home Office Arrangement Anti-fraud & anti-corruption policy Antitrust and competition policy Anti-money laundering policy Sanctions policy Acceptable use policy Intellectual property policy ESRS 2 MDR-P-63 The undertaking shall apply the minimum disclosure requirements defined in this provision when it discloses the policies it has in place regarding each sustainability matter identified as material. ESRS 2 MDR-P-64 The objective of this Minimum Disclosure Requirement is to provide an understanding of the policies that the undertaking has in place to prevent, mitigate and remediate actual and potential impacts, to address risks and to pursue opportunities. ESRS 2 MDR-P-65a The undertaking shall disclose information about policies adopted to manage material sustainability matters. The disclosure shall include the following information: (a) the description of the key contents of the policy, including its general objectives and which material impacts, risks or opportunities the policy relates to and the process for monitoring ■ The information for the sustainability policy, HSEQ policy, anti-harassment & non-discrimination policy, whistleblowing policy, home office arrangement, and anti- fraud & anti-corruption policy is provided in the social & governance chapters. ■ Privacy policy: Description of data processing of employees/ any other person using the services of or having business relationships with an EXMAR entity. In addition, the policies describe the data rights of employees/any other person using the services of or having business relationships with an EXMAR entity. ■ Antitrust & competition policy: Basic principles contained in most antitrust and competition law regimes worldwide. The intention is to provide information on related rules, enabling personnel to spot and seek advice on potential issues. The information contains specifics on the consequences of non-compliance, sanctions, anti- competition agreements, prohibited actions, abuse of dominance, and procedures. ■ Anti-money laundering: The policy deals with the requirements of anti-money laundering laws and regulations I the day-to-day operation of the business. It elaborates on target personnel and each employee’s responsibility to raise concerns in case of suspicion. In addition, it includes a non-exhaustive guidance of areas that may be cause for concern. ■ Sanctions policy: Information related to comply with sanctions, referred to as tools used by governments, international organisations and supranational bodies to encourage a change in the behaviour or a government or regime or to prevent financing of terrorism. The policy outlines responsibilities of EXMAR personnel to check that no contracts nor projects violate any sanctions. ■ Acceptable use policy: This policy aims to secure our resources and data and places this responsibility with each employee. It summarizes the main information security guidelines and explains the expectations to EXMAR employees on the use of available IT resources and systems, referring to behaviour and best practices for information security. ■ Intellectual property policy: Aims to protect the intellectual property rights, including inventions, ideas, discoveries and authored works. It elaborates on patents, trade secrets and confidential information, trademarks and copyright and outlines rights and responsibilities.
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