4.A.HISTORY AND DEVELOPMENT OF THE COMPANY General Corporate Information The Company’s legal name is “BW LPG Limited.” The Company is a public company limited by shares. The principal legislation under which the Company operates is the Singapore Companies Act and regulations made thereunder. The Company was incorporated in Bermuda on 21 August 2008 and redomiciled to Singapore on 1 July 2024, with its registered office at 10 Pasir Panjang Road, #17-02, Mapletree Business City, Singapore, 117438. The telephone number of the Company’s Singapore office is +65 6705 5588. The website of the Company is www.bwlpg.com. The information on the Company’s website does not form part of this annual report. The Shares are traded on the OSE under the ticker symbol “BWLPG.OL” and on the NYSE under the ticker symbol “BWLP.” BW LPG is a leading owner and operator of VLGCs based on the number of VLGCs as of December 2025 (source: Clarksons, January 2026). BW LPG currently operates two segments: Shipping and Product Services. See “Item 4. Information on the Company — 4.B. Business Overview — Operating Segments” for more detail. 39 Table of Contents The BW Group remains the largest shareholder of the Company as of 31 December 2025. Today, the BW Group is a global maritime company involved in shipping, floating infrastructure, deepwater oil & gas production, and new sustainable technologies. The BW Group controls a fleet of over 450 vessels that transport oil, gas and dry commodities, including approximately 200 LNG and LPG ships across its various affiliates. In the renewable energy space, the BW Group has investments in solar, wind, batteries and water treatment. Equiniti Trust Company, LLC, located at 6201 15th Avenue, Brooklyn, NY 11219, serves as the Company’s transfer agent and registrar. History and Development of the Group The origin of the Group dates back to 1935 when Mr. Sigval Bergesen d.y. established Sig. Bergesen d.y. & Co, a tanker business in Stavanger, Norway. In 1978, Sig. Bergesen d.y. & Co entered the gas transportation business with the acquisition of six LPG vessels. The company continued to grow in the 1980s to become a major operator of large LPG carriers, and in 1986, Bergesen d.y. ASA (“Bergesen”) became the holding company of the family’s various shipping businesses. In April 2003, Sohmen family interests acquired a majority of the shares of Bergesen. Bergesen, together with the Sohmen family’s World-Wide Shipping, reorganised to form Bergesen Worldwide in 2004, and in 2005, the business was rebranded as BW. In 2013, to prepare the LPG business of the BW Group for an IPO, the LPG business was reorganised with the Company becoming the parent company of the listed group. As part of the reorganisation, all assets and liabilities relevant to the continuing LPG business of the BW Group were transferred into subsidiaries of the Company. In November 2013, the Company was listed on the OSE. In 2016, BW LPG acquired Aurora LPG, and in 2017, BW LPG and Global United Shipping India Private Limited established a joint venture in India in which the parties each owned 50%. The purpose of the new joint venture (“BW India”) was to own and operate gas carriers for the transportation of LPG within Indian waters. BW LPG increased its equity share in BW India from 50% to 88% in 2021, which was subsequently reduced to 52.4% in 2022 when an external investor subscribed for new shares in BW India in an aggregate amount of 41.1% of the outstanding equity. By 2021, BW India had become India’s largest owner and operator of VLGCs by total fleet capacity, and remains such as of December 2025 (source: Sentosa Shipbrokers, “India LPG Monthly Synopsis” dated 23 December 2025). In 2019, BW LPG launched Product Services to offer customers a fully integrated product delivery service. See “Item 4. Information on the Company — 4.B. Business Overview — Product Services” for more detail on Product Services. In November 2022, BW LPG completed the acquisition of the LPG trading operations from Vilma Oil for a total consideration of US$53 million in order to expand Product Services. On 30 November 2023, the Group signed a joint venture agreement with Confidence Petroleum India Limited (“Confidence”) and committed to invest approximately US$40 million in Confidence and in an LPG onshore import terminal. On 20 May 2025, the Group announced the cessation of the investment due to the heightened market uncertainties from global trade protectionism, to strengthen its strategic focus on the company’s core value drivers—shipping and trading. On 23 April 2024, BW LPG obtained approval from the NYSE for the listing of the Company’s common shares, in addition to its existing listing on the OSE. The Company’s common shares commenced trading on the NYSE on 29 April 2024, under the ticker symbol “BWLP”. On 1 July 2024, BW LPG officially effected its discontinuance from Bermuda and continuance in Singapore after successfully completing the redomiciliation process. As a result of the redomiciliation, BW LPG’s common shares were converted into ordinary shares. 40 Table of Contents In August 2024, the Group entered into agreements to acquire 12 VLGCs from Avance Gas for a total consideration of US$1,050 million. All vessels were successfully delivered before the end of 2024. This acquisition has increased the Group’s owned fleet by more than 40%. By acquiring ships already on the water, the fleet expansion provided immediate commercial scale and operational leverage, contributing to revenue generation in a healthy rate environment. Additionally, this fleet acquisition contributes to fleet renewal and further solidifies the Group’s position as the world’s leading owner and operator of VLGCs, with the largest number of LPG dual-fuel powered vessels. 4.B.BUSINESS OVERVIEW Market Overview The VLGC market in 2025 experienced significant fluctuations, driven by both geopolitical events, regional price differences of LPG, low fleet growth and trade inefficiencies. Spot rates came under pressure in early 2025 as cold weather and fog negatively impacted VLGC loadings in the US Gulf. This is however a normal seasonal phenomenon, and its impact was less severe in 2025 compared to previous years. Towards the end of the first quarter, spot rates were improving again. VLGC spot rates, Middle East – Far East & US Gulf – Far East Source: Baltic Exchange, Internal analysis In early April, trade tensions between the US and China increased sharply as the two countries began imposing tariffs on each other. The rapid escalation of this trade war had a near immediate impact on LPG shipping, as the trade between the largest exporter (USA) and the biggest importer (China) nearly vanished. While the beginning of the trade war was a massive disruption to established trade routes, the market quickly began to adapt to the new reality. 41 Table of Contents A core dynamic with LPG shipping is that LPG is a byproduct of oil and gas production, and consequently any production not consumed or put into storage domestically, it is priced to clear in the international market. This remained the case even during the US – China trade war, with a few important caveats. Firstly, the US price for propane came down sharply. This allowed the product to be sold and exported. Secondly, with Chinese demand for US made LPG down, US volumes found other outlets, mainly in Japan and Southeast Asia, but also in more unconventional destination, like India. US LPG exports by destinations (VLGC only) Source: Vortexa ​ As 2025 progressed into the summer months, it became increasingly clear that not only did the rerouting of US volumes drive ton-mile demand, but Middle East exports also had to sail longer distances, to make up for the Chinese demand usually covered by US volumes. Middle East LPG exports by destinations (VLGC only) Source: Vortexa ​ During this period of rerouting spot earnings also saw periods of downwards pressure. This was particularly visible during the third quarter; where the Saudi Contract Price for LPG was lowered to a point where Far East prices also came down. This, in turn narrowed the US – Far East arbitrage, bringing down spot freight rates too. Further into the second half of 2025, various tariff truces came into effect, before many retaliatory tariffs were ultimately suspended in late 2025. 42 Table of Contents The Panama Canal plays an important role for VLGC shipping. This was also the case in 2025, as the canal saw periods of increased container traffic following both escalation and deescalation of trade hostilities between the US and China. Going forward, increased trade in LPG and other segments such as ethane, containers and LNG could increase demand for canal transits and consequently transit costs. This in turn could divert a higher share of VLGCs to sail around Cape of Good Hope, thus limiting the effective supply of LPG shipping capacity. Panama Canal, Neo-Panamax locks transits Source: Clarksons SIN ​ Growth in export volumes of LPG is expected to continue in the years ahead. Out of the main exporting regions, North America is expected to see the strongest nominal growth in 2026 – largely driven by new export infrastructure allowing for more LPG to be exported. Closer to 2030, it is expected that LPG export growth will largely be driven by new projects in the Middle East. The biggest offtake region for LPG is expected to be the Far East, but growth in imports into India and Southeast Asia is also expected. LPG export forecasts (VLGC only) Source: NGLS 43 Table of Contents LPG import forecasts (VLGC only) Source: NGLS Fleet overview The fleet continued its expansion, with 11 new VLGCs delivered in 2025, with the total fleet count at year end at 413. Over the next three years, the VLGC fleet will see additional vessels being delivered from shipyards, with 2027 expected to see a particularly high level of deliveries. Recently placed orders for newbuilds have seen estimated delivery times around mid-2028, reflecting long lead times for new ships. Nearly all VLGC new buildings can carry ammonia, often leading to their designation as VLACs (Very Large Ammonia Carriers). However, until the ammonia trade develops for VLGCs, the new ships are all expected to be employed in the LPG trade. 44 Table of Contents VLGC fleet summary Source: Internal analysis Key Highlights BW LPG is a leading owner and operator of VLGCs based on the number of VLGCs as of December 2025 (source: Clarksons, January 2026). As of 31 December 2025, the Group owned and/or operated a fleet of 54 vessels, including 28 owned VLGCs, 8 VLGCs owned by BW LPG India, 7 time charter/bareboat in VLGCs and 7 operated VLGCs and 4 operated LGCs/MGC. 22 out of 54 vessels have LPG dual-fuel propulsion technology onboard. As further described in “— Shipping — Fleet — Commercial Management of the Fleet,” the Group’s fleet operates a combination of spot voyages and time charters. For the year ended 31 December 2025, 69.3% of Revenue — Shipping totalling US$703.5 million was derived from spot voyages (including CoAs), and 30.7% totalling US$312.3 million was derived from time charters. BW LPG’s Product Services supports its core Shipping business. Product Services was established in February 2019, with the aim to diversify the Group’s business offerings. Product Services provides customers with integrated LPG delivery services, by purchasing LPG and delivering it directly to customers. For the year ended 31 December 2025, Revenue — Product Services was US$2,566.4 million. Strengths The Group believes that it has a number of competitive strengths which differentiate it from others and enable it to operate across the LPG value chain. 45 Table of Contents A leading owner and operator of VLGCs with over five decades of experience in LPG shipping According to Clarksons (January 2026), the Group is a leading owner and operator of VLGCs based on the number of VLGCs as of December 2025. In 2020, the Group retrofitted the world’s first VLGC powered by LPG, and as of 31 December 2025, 22 of the Group’s LPG vessels have LPG dual-fuel propulsion technology onboard, allowing the Group to serve customers with a low emissions profile. The Group believes that the size and composition of its LPG fleet, coupled with over 50 years of LPG shipping experience, provide the Group with the capacity and flexibility to offer timely and reliable services anywhere in the world. This positions the Group well to take advantage of the expected growth in demand for LPG shipping, through early recognition of market requirements, and strong brand recognition which provides access to relevant customer relationships. Additionally, the size of the fleet and the global coverage of its historical operations position the Group particularly well to take advantage of ongoing geographic trends in LPG export — in particular increasing US exports. For example, because VLGCs provide superior economies of scale compared to LGCs and MGCs on long haul voyages, the Group believes that it is particularly well positioned to take advantage of the expected growth in demand for long haul LPG transportation, such as deliveries between North America and Asia. According to Vortexa (February 2025), the Group lifted approximately 14%, 12% and 14% of the VLGC-sized cargoes exported from the United States, West Africa and the Middle East, respectively, during the period from 1 January 2025 to 31 December 2025. Strong utilisation potential through ability to provide flexible customer-oriented solutions Superior utilisation provides a competitive advantage in the immediate term, through improved profitability driven by higher earnings without a proportionate increase in operating expenses; and in the longer-term, driven by the potential to operate acquired assets at above market-average returns, enabling greater room to grow through value-accretive investments. The Group believes that the nature of the LPG transportation market, whereby LPG cargoes tend not to be stored for protracted periods at source but are delivered rapidly for transportation, lends itself to solutions other than long-term time charters which are more prevalent in other energy shipping sectors. Product Services provides customers with integrated LPG delivery services by purchasing LPG and delivering it directly to customers. Product Services enables end customers to secure LPG supply at the final point of consumption thereby eliminating the need to handle shipping and associated risks. Product Services facilitates utilisation of the BW LPG fleet by contracting to deliver LPG to end customers, allowing the Group to secure additional customers that do not otherwise engage in transportation in their supply chain. Strong brand and relationships within the shipping and energy industries The Group believes that, as a result of its history of more than 90 years in energy transportation, including over 50 years in LPG transportation, it has a long-standing reputation as a leading provider of safe, reliable, and efficient LPG transportation solutions. This reputation provides an important advantage in building and maintaining strong relationships with leading oil and gas companies, and is reflected in the Group’s existing customer base in LPG. These relationships are important not only in the VLGC market, but also in accessing LPG shipping and other related project opportunities available to experienced LPG transporters through energy majors. The Group intends to leverage the advantages afforded by the strength of the BW brand, by building close and cooperative relationships with existing customers and emerging participants in the LPG space. Additionally, the Group has long-standing customer relationships which support access to new and emerging opportunities with those customers. A strong customer relationship base in the United States and West Africa positions the Group to benefit by leveraging these pre-existing relationships to pursue the additional opportunities which the Group believes will emerge from these markets — the US market in particular — in the coming years. Experienced management team and employees, and international board of directors with strong credentials in governance and strategy The Group’s management team consists of seasoned executives with their own strong industry relationships, who have demonstrated their ability in managing the commercial, technical and financial areas of the Group’s business. These executives have deep experience in the shipping industry, including experience operating large and diverse fleets of energy transportation vessels, as well as other assets in the maritime energy space. The Group’s management have an extensive network of relationships with major oil and gas companies, shipyards, global financial institutions and other key participants in the shipping and industries. 46 Table of Contents In addition, to ensure the efficient, safe and reliable operation of our shipping assets, the Group’s management team is intensely focused on attracting and retaining the highest-caliber personnel at sea and on shore. Our management team, working with the BW Group, has access to a large pool of highly qualified employees with extensive experience in the industry. Our team’s proven ability to attract and retain exceptional professionals who have extensive industry experience, in many cases working within the BW Group, to serve as officers and crew, is a major competitive advantage in a market where charterers not only value, but in a number of the most important cases require, significant combined time in-company and in-industry among senior crew. The Group’s management is complemented by a board of directors with extensive collective international experience in shipping, energy and capital markets; as well as a broad range of complementary functional competencies. The Group believes that these competitive strengths have and will continue to collectively enhance its ability to develop and implement strategies to optimise shareholder returns, customer satisfaction, and to build and sustain recognised leadership as preferred suppliers of LPG transportation solution. Strategy The Group intends to be recognised as the leader in, and market-preferred provider of, maritime LPG transportation and related services and solutions. The Group’s strategic initiatives focus on ensuring environmental and customer-focused operational excellence and exploring investment opportunities along the LPG value chain. Ensuring environmental and customer-focused operational excellence The Group seeks to ensure environmental and customer-focused operational excellence by delivering LPG safely, sustainably and cost-effectively to world markets. The Group maintains its fleet to high standards to maximise commercial availability, and its network of offices ensures coverage across time zones for customers. The Group’s approach to vessel life cycle management is to maintain the LPG assets consistently to a high standard over their lives, without compromising on regular preventive maintenance for short-term gain, for example to access short-term positive charter rates. This approach increases reliability for customers, by avoiding unexpected ship repairs and reducing off-hire; optimises potential for extension of useful life (e.g. by applying well-maintained older vessels to end-of-life charters or storage projects); and potentially improves the residual value achievable on vessels’ disposal. The Group upgrades its assets to optimise commercial availability, reduce emissions to the environment and improve operational performance. A culture of innovation and prudent stewardship facilitated the decision to retrofit pioneering LPG propulsion technology onboard 15 vessels. With all LPG-powered vessels on water since 2022, the Group has been accumulating valuable knowledge on this front. Delivering an ambitious, multi-year retrofitting programme also provided valuable experience gained in managing large-scale technical projects. Explore investment opportunities across the broader energy value chain Given the increasing importance of LPG as an energy source, the Group is committed to investing further in the LPG value chain. The Group continues to monitor business opportunities across the broader energy value chain. The Group will remain selective in evaluating investment opportunities in markets with growing domestic LPG demand, including India, Africa and Southeast Asia. As part of this strategic approach, the Group expanded its Product Services team with the acquisition of Vilma Oil’s LPG trading operations in 2022, sold four of its pre-2011 built VLGCs at attractive prices, and expanded its presence in India through BW India. The Group’s Product Services segment facilitates the Group’s access to a wider range of investment opportunities across the broader energy value chain by enabling end-customers to secure LPG supply at the final point of consumption thereby eliminating the need to handle shipping and associated risks. 47 Table of Contents Leveraging our Established Shipping Platform in India We capitalize on our established shipping platform in the India market, which includes strategic relationships with Indian charterers to deploy a meaningful portion of our fleet in the time charter market to transport LPG to the India market; see “—BW India Fleet” and “—BW India”. We are a significant market participant and in 2025, BW India accounts for just under 20% of LPG imports into the Indian market. The strategic use of our India platform enables us to place certain of our older vessels—those that may be viewed as being in the mature years in more regulated international trades—into service in India, where the same vessels are considered relatively young assets. By redeploying these vessels, we are able to extend their revenue-generating lives, improve our overall utilization rates, and generate incremental returns on assets that might otherwise become less favorable in the international market. A core element of our BW India strategy is the disciplined use of time-charter contracts to fix and stabilize returns across the fleet used in the Indian market. We selectively enter into medium- term time charters typically one to three years with extension options, with mainly creditworthy Indian state-owned oil companies, locking in day rates that provide predictable cash flows and reduce exposure to the inherent volatility of the spot LPG freight market. These fixed-rate contracts are structured to cover operating expenses and debt service while delivering attractive margins, and they are complemented by a small number of spot-market fixtures that allow us to capture upside during periods of strong demand. Our BW India strategy—leveraging the India platform for older vessels and using time charters to obtain fixed returns—enhances the Group’s overall earnings visibility and the resilience of our business in turbulent markets. Increasing fixed-rate time charter-out coverage The Group intends to mitigate the financial risks in, while maintaining spot exposure to, the volatile but growing VLGC market by increasing coverage of its fleet to approximately 40% through either period charters or forward freight agreements (FFAs). Time charters and FFAs help to hedge risk through different approaches to physical access to transportation services and vessels, with period charters providing physical access while FFAs provide greater flexibility in trading. As recently as February 2026, the Group entered into three-year time charter-out contracts for two of its VLGCs, thereby reaching 36% fixed-rate time charter-out coverage. Operating Segments Shipping With over 50 years of operating experience in LPG shipping, including highly skilled and experienced seafarers and staff, BW LPG offers a flexible and reliable service to its customers. As further described in “— Shipping — Fleet — Commercial Management of the Fleet,” the Group’s fleet is operated through a mixture of spot voyages (including CoAs) and time charters. Product Services BW LPG’s Product Services supports the core shipping business. This division was established in February 2019, with the aim to diversify the Group’s business offerings. In November 2022, BW LPG completed the acquisition of the LPG trading operations from Vilma Oil for total consideration of US$53 million in order to expand BW LPG’s Product Services. Product Services provides customers with integrated LPG delivery services, by purchasing LPG and delivering it directly to customers. It enables end customers to secure LPG supply at the final point of consumption thereby eliminating the need to handle shipping and associated risks. Shipping Fleet As of 31 December 2025, the Group owned and/or operated a fleet of 54 vessels, including 28 owned VLGCs, 8 VLGCs owned by BW LPG India, 7 time charter/bareboat in VLGCs and 7 operated VLGCs and 4 operated LGCs/MGCs. 22 out of 54 vessels have LPG dual-fuel propulsion technology onboard. As of 31 December 2025, the Group was ranked as the leading owner and operator of VLGCs based on the number of VLGCs owned (source: Clarksons, January 2026). 48 Table of Contents The operation of the Group’s fleet of VLGCs has historically been the Group’s core activity. By operating a vessel, the Group is responsible for the commercial management of the vessel either through its ownership of the vessel or pursuant to a charter or pool arrangement. The majority of the VLGCs the Group operates are commercially managed by the Group under a pool arrangement. For more information on the pool arrangement, see “— Pool Arrangement” below. The following table presents certain information with respect to the owned and/or operated vessels in the Group’s fleet as of 31 December 2025. 100%-owned VLGCs ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ Year ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ Capacity ​ ​ ​ ​ ​ ​ ​ Classification Name ​ Built ​ Shipyard ​ Propulsion(1) ​ (CBM) ​ Flag ​ Society BW Avior 2023 DSME LPG dual-fuel 91,344 Marshall Islands (Majuro) Lloyds Register BW Rigel 2023 DSME LPG dual-fuel 91,344 Marshall Islands (Majuro) Lloyds Register BW Messina 2017 DSME Compliant fuel 84,177 Panama Nippon Kaiji Kyokai BW Mindoro 2017 DSME LPG dual-fuel 84,180 Isle of Man (IOM) DNV BW Balder 2016 Hyundai H.I. LPG dual-fuel 84,142 Marshall Islands (Majuro) DNV BW Brage 2016 Hyundai H.I. LPG dual-fuel 84,114 Marshall Islands (Majuro) DNV BW Freyja 2016 Hyundai H.I. LPG dual-fuel 84,143 Marshall Islands (Majuro) DNV BW Frigg(2) 2016 Hyundai H.I. LPG dual-fuel 84,136 Marshall Islands (Majuro) DNV BW Magellan 2016 DSME LPG dual-fuel 84,171 Isle of Man (IOM) DNV BW Malacca 2016 DSME LPG dual-fuel 84,105 Isle of Man (IOM) DNV BW Njord(2) 2016 Hyundai H.I. LPG dual-fuel 84,107 Marshall Islands (Majuro) DNV BW Tucana(2) 2016 Hyundai H.I. LPG dual-fuel 84,113 Isle of Man (IOM) DNV BW Var(2) 2016 Hyundai H.I. LPG dual-fuel 83,839 Marshall Islands DNV BW Volans 2016 Hyundai H.I. LPG dual-fuel 84,134 Isle of Man (IOM) DNV BW Breeze(2) 2015 Jiangnan Scrubber 83,121 Marshall Islands (Majuro) Lloyds Register BW Carina(2) 2015 Hyundai H.I. Scrubber 84,154 Isle of Man (IOM) DNV BW Gemini(2) 2015 Hyundai H.I. LPG dual-fuel 84,134 Isle of Man (IOM) DNV BW Leo(2) 2015 Hyundai H.I. LPG dual-fuel 84,161 Isle of Man (IOM) DNV BW Levant(2) 2015 Jiangnan Scrubber 83,114 Malta (Valletta) Lloyds Register BW Libra(2) 2015 Hyundai H.I. LPG dual-fuel 84,196 Isle of Man (IOM) DNV BW Mistral(2) 2015 Jiangnan Scrubber 83,134 Marshall Islands (Majuro) Lloyds Register BW Monsoon(2) 2015 Jiangnan Scrubber 83,129 Marshall Islands (Majuro) Lloyds Register BW Orion(2) 2015 Hyundai H.I. LPG dual-fuel 84,196 Isle of Man (IOM) DNV BW Passat(2) 2015 Jiangnan Scrubber 83,115 Marshall Islands (Majuro) Lloyds Register BW Sirocco 2015 Jiangnan Scrubber 83,114 Marshall Islands (Majuro) Lloyds Register BW Aries(2) 2014 Hyundai H.I. Scrubber 84,196 Isle of Man (IOM) DNV BW Yushi 2020 Mitsubishi H.I. Scrubber 83,315 Singapore Nippon Kaiji Kyokai BW Kizoku ​ 2019 ​ Mitsubishi H.I. ​ Scrubber ​ 83,325 ​ Singapore ​ Nippon Kaiji Kyokai Total: 28 vessels ​ ​ ​ ​ ​ ​ ​ (1) “Compliant fuel” propulsion uses fuel compliant with emissions regulations in different sea areas; “LPG dual-fuel” propulsion uses both compliant fuel and LPG; “scrubber” propulsion uses exhaust gas cleaning systems. (2) Used as collateral under the Group’s loan agreements. ​ 49 Table of Contents Operated VLGCs/LGCs/MGC ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ Year ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ Capacity ​ ​ ​ ​ ​ ​ ​ Classification Name ​ Built ​ Shipyard ​ Propulsion ​ (CBM) ​ Flag ​ Society Denver(1)(2) 2009 Hyundai H.I. Compliant fuel 60,291 Liberia DNV Helsinki(1)(2) 2009 Hyundai H.I. Compliant fuel 60,276 Liberia DNV Kaede(3) 2023 Hyundai H.I. LPG dual-fuel 84,000 Marshall Islands American Bureau of Shipping Gas Gabriela(1) 2021 Hyundai H.I. Scrubber 80,421 Panama Korea Register Gas Venus 2021 Jiangnan LPG dual-fuel 86,045 Singapore Lloyd’s Register Gas Jupiter 2023 Jiangnan LPG dual-fuel 93,076 Hong Kong BV Vega Sea(1) ​ 2017 ​ Hyundai H.I. ​ Compliant fuel ​ 78,000 ​ Liberia ​ DNV Vega Star(1) ​ 2017 ​ Hyundai H.I. ​ Compliant fuel ​ 78,000 ​ Liberia ​ DNV Clipper Wilma(1) 2019 Hyundai H.I. Scrubber 80,032 Norway DNV Tokyo(1)(2) 2009 Mitsubishi H.I. Compliant fuel 83,271 Liberia DNV Oceanic Moon(4) ​ 2011 ​ Hyundai H.I. ​ Compliant fuel ​ 22,978 ​ Liberia ​ RINA Total: 11 vessels ​ ​ ​ ​ ​ ​ ​ (1) Directly managed by Product Services. (2) LGC (Large Gas Carrier). The other vessels are VLGCs. (3) Placed to the pool by Product Services. (4) MGC (Medium Gas Carrier) ​ Time chartered-in / Bareboat in VLGCs ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ Year ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ Capacity ​ ​ ​ ​ ​ ​ ​ Classification Name ​ Built ​ Shipyard ​ Propulsion ​ (CBM) ​ Flag ​ Society BW Capella(1)(2) 2022 DSME LPG dual-fuel 91,286 Marshall Islands (Majuro) Lloyds Register BW Polaris(1)(2) 2022 DSME LPG dual-fuel 91,285 Marshall Islands (Majuro) Lloyds Register Doraji Gas 2017 Mitsubishi H.I. Compliant fuel 83,319 Panama Nippon Kaiji Kyokai Oriental King 2017 Hyundai H.I. Compliant fuel 84,099 Hong Kong DNV Berge Nantong 2006 Hyundai H.I. Compliant fuel 82,244 Hong Kong DNV Berge Ningbo 2006 Hyundai H.I. Compliant fuel 82,252 Hong Kong DNV BW Kyoto(1)(2) ​ 2010 ​ Mitsubishi H.I. ​ Scrubber ​ 83,299 ​ Singapore ​ Nippon Kaiji Kyokai Total: 7 vessels ​ ​ ​ ​ ​ ​ ​ (1) Financed via lease financing agreements (2) Bareboat charter VLGCs owned by BW LPG India(1) ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ Year ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ Capacity ​ ​ ​ ​ ​ ​ ​ Classification Name ​ Built ​ Shipyard ​ Propulsion ​ (CBM) ​ Flag ​ Society BW Chinook ​ 2015 ​ Jiangnan ​ Compliant fuel ​ 83,106 ​ India ​ Lloyds Register BW Pampero ​ 2015 ​ Jiangnan ​ Compliant fuel ​ 83,131 ​ India ​ Lloyds Register BW Pine 2011 Kawasaki S.C. Compliant fuel 80,156 India Lloyds Register BW Loyalty 2008 DSME Scrubber 84,601 India Lloyds Register BW Oak 2008 Hyundai H.I. Compliant fuel 82,253 India Lloyds Register BW Tyr 2008 Hyundai H.I. Compliant fuel 82,303 India Lloyds Register BW Birch 2007 Hyundai H.I. Compliant fuel 82,303 India Indian Register of Shipping BW Elm 2007 Hyundai H.I. Compliant fuel 82,291 India Lloyds Register Total: 8 vessels ​ ​ ​ ​ ​ ​ ​ 50 Table of Contents The Group invests significant resources in R&D and technology to drive energy efficiency and reduce emissions. One of the Group’s most significant initiatives was to pioneer the use of LPG dual-fuel propulsion engines. Seventeen of the Group’s LPG vessels have LPG dual-fuel propulsion technology onboard, allowing the Group to serve customers with a low emissions profile. The Group also offers vessels that are equipped with scrubber technology that reduces harmful elements in exhaust gases. Technical Management of the Fleet Technical ship management involves the comprehensive operation and maintenance of vessels in all aspect on behalf of the owner. It encompasses key services such as vessel registration, technical expertise, ship maintenance, crew management, compliance, budgeting, procurement, environmental and safety management. Dedicated technical teams ensure efficient operations by managing inspections, certifications, safety systems, and drydocking in alignment with international standards. Ship management companies optimize operations by capitalizing on their extensive networks, advanced systems like Planned Maintenance Systems (PMS), and Safety Management Systems (SMS) to reduce costs and enhance safety and efficiency. They coordinate complex logistics, ensure timely procurement of spares and consumables, and maintain regulatory compliance to prevent delays and detentions. The Group prioritizes having its inhouse technical team (BW LPG Fleet Management AS, a Group subsidiary) provide technical management for its dual fuel vessels. Some vessels are managed by third-party technical managers pursuant to technical management agreements. The Group does not technically manage vessels that the Group does not own, including time chartered-in vessels and pooled-in vessels, i.e. vessels that are commercially operated by BW LPG through a pooling arrangement where vessel owners place their vessels with BW LPG, which acts as the commercial manager to secure vessels deployment. The Group believes that the quality of its vessels is one of the main reasons why the Group has been able to retain many of the world’s largest oil and gas companies among its customers. The Group uses its resources to furnish its vessels with the most reliable equipment available at the time of building, and continues to maintain them and, when required, upgrade them to keep them competitive in the market. The Group has in place a maintenance programme designed to ensure a high standard of maintenance throughout a vessel’s lifetime. Commercial Management of the Fleet Commercial management of the fleet involves deployment in the market through a number of different arrangements. The Group typically enters into voyage charters, time charters and CoAs. The Group’s Commercial department operates the pool arrangement described below, including the scheduling of vessels, budgeting and accounting for pool participants. The department is responsible for the development and marketing of the LPG vessels the Group operates, negotiating contracts directly with the Group’s clients as well as through shipbrokers. Contracts are negotiated and concluded by the Group’s chartering and commercial development department under instructions and authority from the Chief Executive Officer. The department is also responsible for chartering in tonnage for arbitrage profit as well as actively seeking opportunities to enlarge the fleet by acquiring tonnage, bringing in pool participants, placing newbuild orders, or through other commercial arrangements. Pool Arrangement BW LPG operates a pooling arrangement where vessels are in a pool operated by BW LPG to secure vessel deployment and facilitate the operation and utilisation of the fleet. As commercial manager of the pool, the Group receives a fee for all vessels that participate in the pool. The pool includes vessels owned and/or operated by the Group, except that time chartered-out vessels with time charter durations longer than one year are currently excluded from the pool. BW India’s vessels do not participate in the pooling arrangements. External pool participants include Exmar and Sinogas Maritime. 51 Table of Contents Under a typical pool arrangement, the manager of the pool markets the vessels as a single, cohesive fleet, operating them on spot voyages. The pools the Group participates in are marketing and revenue sharing arrangements under which each participating vessel receives “pool points.” Earnings from the pool are distributed among the pool participants according to these pool points. The pool points are calculated based on a pre-agreed template and allocated to the vessels participating in the relevant pool and are revised from time to time based on each vessel’s speed, fuel consumption and other technical and operational parameters. A shipping pool thus acts as a single entity in the allocation of its vessels to meet the various contracts that it has entered into. The pool manager is responsible for all the voyage expenses for pool activities, such as bunker fuel costs, port charges and canal dues. Such costs are deducted from pool revenue prior to distribution to pool members. All other operating costs, such as manning, insurance, loan repayments and maintenance are paid for by the respective pool participant. The pool manager prepares and distributes reports to the other participants monthly and/or quarterly and at the end of the year. These reports contain information regarding the pool’s revenue, costs, any off-hire days and cash to be distributed to the participants. Payment is normally made monthly to each owner. Participants can remove vessels from the pool, subject to a reasonable amount of notice period by providing prior written notice to the other participants, or upon expiry of an employment contract of the vessel, if entered into prior to such notice. The pool income is divided on the basis of the respective vessel’s pool points reflecting each vessel’s relative earnings potential. Pool income is distributed on a monthly basis to the respective pool participant. Time Chartered-ins The following table presents certain information with respect to the chartered-in VLGCs in the Group’s fleet as of the date of this annual report. ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ ​ Chartered- ​ ​ ​ ​ ​ ​ ​ ​ ​ in ​ ​ ​ Extension ​ ​ ​ ​ ​ (US$’000 ​ ​ ​ option ​ Purchase ​ Name ​ ​ ​ per month) ​ ​ ​ Expiry date ​ ​ ​ period ​ ​ ​ option ​ ​ ​ Berge Nantong Index-linked 31/12/2026 ​ N/A Berge Ningbo Index-linked 31/12/2026 ​ N/A Oriental King 1,125 1/2/2027 ​ N/A Doraji Gas 1,040 17/1/2026 ​ N/A ​ BW India Fleet The BW India fleet consists of eight vessels, with seven deployed on time charters to Indian oil majors and one vessel operated in the spot market. BW India’s vessels do not participate in the pooling arrangements. The eight vessels are technically and commercially managed by BW Global United LPG India. Operations The Group’s Operations department is responsible for monitoring the performance of the vessels the Group operates and that these vessels are deployed in compliance with the terms and conditions of the applicable charter contracts. Each vessel that the Group operates is assigned a designated operator and demurrage claims analyst to ensure that voyage orders, cargo documentation, freight and demurrage payments are as agreed and settled in a timely manner. The designated operators are responsible for communicating on a daily basis with agents, charterers and vessels as well as monitoring the vessels’ bunker situation and obtaining bunker fuel. While operational and technical quality is an integral part of the Group’s operations, the Marine department is responsible for overseeing the vetting and inspection programme for the Group’s owned vessels (except vessels that are technically managed by third parties), which the Group operates in a manner intended to protect the safety and health of its employees, the general public and the environment. The Group actively manages the risks inherent in its business and is committed to eliminating incidents that threaten safety, such as groundings, fires, collisions and petroleum spills. The Group’s total quality management system has been fully electronically operated onboard all vessels since over ten years ago. The Operations department works hand in hand with the Marine department to ensure validity of ship’s trading certificates and approvals. 52 Table of Contents Customers/Charterers The Group’s assessment of a customer’s financial condition and reliability is a key factor in negotiating employment for the Group’s vessels. Counterparties are revalidated on a quarterly basis, with new customers appraised before embarking upon commercial relations. The Group seeks to charter its vessels to international oil companies and national oil companies, as well as trading and utility companies. In 2025, the Group’s top five Shipping customers by revenue included Aramco Trading, P66, Abu Dhabi Marine International Chartering, BGN International and Hindustan Petroleum Corporation Limited, representing an aggregate of 40% of the Group’s Revenue — Shipping. Competition The Group’s business performance fluctuates in line with the main patterns of trade of LPG cargo and varies according to changes in the supply of and demand for transportation of this cargo. The LPG market is highly competitive and based primarily on supply of cargo and vessel availability. The Group competes for charters on the basis of price, vessel location, size, age and condition of the vessel, as well as on its reputation as an owner and operator. The Group’s main competitors in 2025 included Dorian LPG, Petredec and Neptune Pool. BW India Since its establishment in 2017, BW India has grown to become India’s largest owner and operator of VLGCs by total fleet capacity as of 31 December 2025. As of 31 December 2025, BW India had eight LPG vessels. BW India’s fleet is Indian-flagged and Indian-operated to facilitate business transactions in alignment with the Padmanabha Bharat scheme (translated as domestic self-reliance). According to data from Vortexa, BW India’s fleet comprised approximately 19% of LPG imports carried on VLGCs into India from January 2025 to December 2025, and had approximately a 25% share of the time-charter market by the end of 2025, according to Sentosa Shipbrokers, based on number of time chartered VLGC vessels. Product Services Product Services provides customers with integrated LPG delivery services by purchasing LPG and delivering it directly to customers. Product Services enables end-customers to secure LPG supply at the final point of consumption thereby eliminating the need to handle shipping and associated risks. This allows customers to avoid the need to purchase LPG on a FOB basis (Free on Board), if preferred, charter a vessel and manage associated transport operations. Product Services can provide tailor-made pricing depending on customers’ specific consumption needs. For example, it can offer its petrochemical customers a price for LPG fixed as a percentage of an index price for Naphtha, which allows customers to easily compare the LPG price with the price of their alternative feedstock. Furthermore, as Product Services’ prices are fixed by reference to the time of delivery, rather than to the time of loading (with a typical gap of 35 days between the two for customers in Asia), customers can benefit from prices that are much closer to the actual consumption period. Following the acquisition of Vilma Oil Trading in November 2022, Product Services has operated under a trading mandate where the trading activities are assessed and monitored based on risk limits such as value-at-risk levels, margin and working capital requirements. Product Services is able to generate margins by taking advantage of arbitrage opportunities in the global LPG market. It is able to take advantage of time differences, as well as differences between cost pricing indexes at source and freight and operations costs on the one hand and sales pricing indexes at the discharge location on the other hand. Currently, approximately 90% of Product Services’ traded volume is sourced from North America, with the majority being shipped to Asia and the balance to Europe, the Mediterranean and South America. Its traded volume is also sourced from North and West Africa and the Middle East and shipped to India and Asia. Product Services uses derivatives quoted on the main commodity exchanges to both hedge the underlying risks and extract and enhance margins between the physical product and freight indexes. Its activities are also supported by the use of proprietary developed software with sophisticated algorithms that analyses vessel/ cargo movements, supply and demand volumes, as well as other market variables. 53 Table of Contents Product Services’ sales are managed by an experienced and skilled team that continuously engages with customers through calls, message applications, face-to-face meetings and industry events. It aims to identify new clients who recognise the value-added services provided by Product Services. Product Services enters into the following types of contracts with customers: ● Long-term supply contracts, whereby a specified number of cargo deliveries is made over an agreed timeframe. These contracts may be concluded by direct negotiations with the counterparty, via a broker or a tender initiated by the counterparty. Long-term contracts are based on an industry published index plus/minus a pre-agreed premium/discount. ● Spot sales contracts, whereby a single cargo is delivered in a specified date range. These contracts are concluded by direct negotiations with the counterparty, via a broker or standardised contracts Product Services has CoAs with Shipping, pursuant to which Product Services commits to utilise the fleet for a minimum number of voyages or voyage hours over an agreed time frame. Such CoAs form the foundation of Product Services’ fleet utilisation. Product Services may also use time chartered-in vessels from third parties. Customers In 2025, the top five customers of Product Services by revenue were Unipec Singapore, SK Gas International, Shandong Port Group, Itochu Corp., Eneos Globe Corp., which together represented 47.5% of the Group’s Revenue – Product Services. Competition The principal competitors of Product Services are traditional trading companies, including Vitol, Trafigura, Mercuria, Gunvor, Glencore, Swisschem, Petredec and Bayegan. Seasonality See “Item 5. Operating and Financial Review and Prospects — 5.A. Operating Results — Key Factors Affecting the Group’s Results of Operations and Financial Position — Seasonality.” Insurance The operation of any ocean-going vessel represents a potential risk of major losses and liabilities, death or injury of persons, as well as property damage caused by adverse weather conditions, mechanical failures, human error, war, terrorism, piracy and other circumstances or events. In addition, the transportation of gas is subject to the risk of pollution and to business interruptions due to political unrest, hostilities, labour strikes and boycotts. The occurrence of any of these events may result in loss of revenue or increased costs. See also “Item 3. Key Information — 3.D. Risk Factors — Risks Related to the Group’s Business — Shipping is a business with inherent risks and the Group’s insurance may cover certain loss events and, where insurance does cover a loss event, may not be adequate to cover the Group’s losses.” As an integral part of operating the Group’s gas carriers, the Group maintains “Hull Insurance” under an All Risk Policy on Nordic Conditions with first class international insurance carriers and “Protection and Indemnity” (“P&I”) insurance with P&I Associations who are members of the International Group of P&I Clubs. Hull insurance covers, among other things, loss of or damage to a vessel, its machinery and equipment where the loss is caused by a marine peril which includes grounding, collision, crew negligence and adverse weather conditions. The typical average deductible is US$150,000 and applies to non-total loss claims. All vessels are covered against total loss, with each vessel insured at no less than fair market value. P&I insurance indemnifies the ship owner against third-party liability exposures which arise out of the operation of its vessels. P&I liabilities include injury to the Group’s crew or third parties, cargo loss, wreck removal and pollution. Collision and fixed and floating liabilities such as dock damage are covered under the Hull policy with excess risks defaulting to P&I where a claim exceeds the hull value of the ship. The current limit for pollution cover is US$1 billion per vessel per incident. The Group also carries insurances covering war risks, including piracy and terrorism and cyber buyback. 54 Table of Contents The Group believes that its current insurance programme, as described above, is adequate to protect the Group against the majority of accident-related risks involved in the conduct of its business, including pollution liability and environmental damage. However, there can be no assurance that the range of risks the Group is exposed to is adequately insured against, that any particular claim will be paid or that the Group in the future will be able to procure similar adequate insurance coverage at the terms and conditions equal to those the Group currently has. More stringent environmental and passenger liability regulations have resulted in increased exposures and insurance costs and may in certain circumstances be difficult to insure or even become uninsurable. The Group’s goal is to maintain an adequate insurance coverage required by its marine operations and to actively monitor any new regulations and threats that may require the Group to revise its coverage. Environmental, Health and Safety Matters The Group’s corporate values and ethical guidelines make health, safety and environment responsibility an integral facet of its business. The Group aspires to Zero Harm to people, environment, cargo and vessel and works continuously to raise both personal safety and process safety awareness. The Group’s Quality Management System’s approach is therefore to safeguard people, environment, cargo and vessel through implementation of the Group’s values, policies, processes and procedures. The Quality Management System shall be in accordance with applicable laws and regulations in addition to industry and the Group’s own best practices. As applicable laws, regulations and best practices will change and develop; the Group’s Management System is therefore dynamic and will be continually improved. The Group emphasises that safety is a corporate priority. To achieve the Group’s aspiration of Zero Harm and to ensure continual improvement, the Group will motivate each individual to maintain and further develop their professional skills and continue to focus on programmes to develop competence. The Group has established a set of HSEQ performance indicators with targets which are regularly monitored and followed up. See also “Item 3. Key Information — 3.D. Risk Factors — Risks Related to the Industry in which the Group Operates — Compliance with environmental laws or regulations may have an adverse effect on the Group’s results of operations.” Regulatory Overview General The Group’s business and the operation of the Group’s vessels are subject to extensive environmental, health and safety regulations, including various international treaties and conventions and the applicable local, national and subnational laws and regulations of the countries in which its vessels operate or are registered. Such laws and regulations cover a variety of topics, including, but not limited to, the discharge of pollutants into the air and water, waste management, the generation, use, storage, transportation, treatment and disposal of hazardous materials and wastes, protection of natural resources, the cleanup of contaminated sites, the cleanup of the environment from oil spills and protection of worker health and safety, and might require the Group to obtain governmental or quasi-governmental permits, licenses and certificates before the Group may operate its vessels or conduct certain activities. Failure to comply with these laws or to obtain the necessary business and technical permits, licenses and certificates could result in sanctions including suspension and/or freezing of the business and responsibility for all damages arising from any violation. Governments may also periodically revise their environmental laws and regulations or adopt new ones, and the effects of new or revised laws and regulations on the Group’s operations often cannot be predicted. In particular, as further discussed in this “—Regulatory Overview”, the Trump administration in the United States has moved toward rapid degregulation and withdrawal from numerous international organizations and treaties. Although the Group believes that it is substantially in compliance with applicable environmental laws and regulations and has all permits, licenses and certificates required for its vessels, future noncompliance or failure to maintain necessary permits or approvals could require the Group to incur substantial costs or temporarily suspend the operation of one or more of the Group’s vessels. There can be no assurance that additional significant costs and liabilities will not be incurred to comply with such current and future laws and regulations, or that such laws and regulations will not have a material effect on the Group’s operations. Similar or more stringent laws may also apply to the Group’s customers, including oil & gas exploration and production companies, which may impact demand for the Group’s services. Key international environmental treaties and conventions as well as US environmental laws and regulations that apply to the operation of the Group’s vessels are described below. Other countries, including member countries of the EU, in which the Group operates or in which the Group’s vessels are registered, have or may in the future have laws and regulations that are similar to, or more stringent than, the US laws referenced below. 55 Table of Contents International maritime regulations of vessels A particularly significant organisation in the shipping industry is the IMO, the United Nations agency for maritime safety and the prevention of pollution by vessels. The IMO has adopted a number of regulations relating to the prevention of pollution by vessels, including the International Convention for the Prevention of Pollution from Ships 1973, as modified by the Protocol of 1978 relating thereto and by the Protocol of 1997 (collectively, “MARPOL”) which is the main international convention covering prevention of pollution of the marine environment by ships from operational or accidental causes and establishes environmental standards relating to oil leakage and oil spills, garbage management, sewage, air emissions, and handling and disposal of noxious liquids and the handling of harmful substances in packaged forms. MARPOL is applicable to drybulk, tanker and LNG carriers, among other vessels. Additionally, IMO has adopted the International Convention for the Safety of Life at Sea 1974, as amended (“SOLAS”) which is intended to specify minimum standards for the construction, equipment, and operations of ships, compatible with their safety. The SOLAS Convention was amended to address the safe manning of vessels and emergency training drills. The Convention of Limitation of Liability for Maritime Claims sets limitations of liability for loss of life or personal injury claims or property claims against ship owners. An important entity within IMO is the Marine Environment Protection Committee (“MEPC”) which is the entity addressing environmental issues under IMO. MEPC holds two sessions a year and a reference to, for example, MEPC 80 is a reference to MEPC’s 80th session. Among other requirements, the International Management Code for the Safe Operation of Ships and for Pollution Prevention (the “ISM Code”) requires the owner and the party with operational control of a vessel to develop an extensive safety management system and the adoption of a policy for safety and environmental protection setting forth instructions and procedures for operating its vessels safely and also describing procedures for responding to emergencies. In 2012, the MEPC adopted a resolution amending the International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk (the “IBC Code”), which entered into force on 1 June 2014. The provisions of the IBC Code are mandatory under MARPOL and the SOLAS Convention. Later amendments adopted in 2019 entered into force on 1 January 2021, and introduced among other changes, a revised format for the international certificates of fitness for the carriage of dangerous chemicals in bulk and updates to the products identified as falling under the IBC Code. In 2013, the MEPC adopted a resolution amending MARPOL Annex I Condition Assessment Scheme. These amendments became effective on 1 October 2014, and require compliance with the 2011 International Code on the Enhanced Programme of Inspections during Surveys of Bulk Carriers and Oil Tankers, or “ESP Code,” which provides for enhanced inspection programmes. The IMO continues to review and introduce new regulations. It is impossible to predict what additional regulations, if any, may be passed by the IMO and what effect, if any, such regulation may have on the Group’s operations. Noncompliance with the ISM Code or other applicable IMO regulations may subject a shipowner or a bareboat charterer to increased liability or penalties, may lead to decreases in available insurance coverage for affected vessels and may result in the denial of access to, or detention in, some ports. Emissions The IMO’s MARPOL imposes environmental standards on the shipping industry relating to marine pollution, including oil spills, management of garbage, the handling and disposal of noxious liquids, sewage and air emissions. Regulation 12A of Annex I relating to oil leakage or spilling applies to various vessels delivered on or after 1 August 2010 with an aggregate oil fuel capacity of 600 CBM and above. It includes requirements for the protected location of the fuel tanks, performance standards for accidental oil fuel outflow, a tank capacity limit and certain other maintenance, inspection and engineering standards. IMO regulations also require owners and operators of vessels to adopt Shipboard Oil Pollution Emergency Plans. Periodic training and drills for response personnel and for vessels and their crews are required. MARPOL 73/78 Annex VI regulations for the “Prevention of Air Pollution from Ships” apply to all vessels, fixed and floating drilling rigs and other floating platforms. Annex VI sets limits on sulphur oxide and nitrogen oxide emissions from vessel exhausts, emissions of volatile compounds from cargo tanks, shipboard incineration of specific substances (such as polychlorinated biphenyls), and prohibits deliberate emissions of ozone depleting substances (such as certain halons and chlorofluorocarbons). Annex VI also includes a global cap on sulphur content of fuel oil and allows for special areas to be established with more stringent controls on sulphur emissions. Regarding the Group’s vessels, International Air Pollution Prevention Certificates have been issued to vessels of 400 gross tonnes and above and engaged in international voyages involving countries that have ratified the conventions, or vessels flying the flag of those countries. 56 Table of Contents The MEPC adopted amendments to Annex VI regarding emissions of sulfur oxide, nitrogen oxide, particulate matter and ozone depleting substances, which entered into force on 1 July 2010. The amended Annex VI seeks to further reduce air pollution by, among other things, implementing a progressive reduction of the amount of sulfur contained in any fuel oil used on board ships. As of 1 January 2020, an upper limit of sulfur content of ship’s fuel oil was reduced to 0.5% from a previous 3.5% under the so-called IMO2020 regulation prescribed in MARPOL. Ships may limit their air pollutants by using compliant fuels such as VLSFO or marine gas oil, by installing exhaust gas cleaning systems (scrubbers), or by using alternative fuels with low or zero sulfur contents such as liquified natural gas or biofuels. In certain areas, so called emission control areas (“ECAs”), the upper limit of sulfur content is reduced to 0.1%. ECAs include certain coastal areas of North America, the United States Caribbean Sea, the Baltic Sea and the North Sea. With effect from 1 May 2025, the Mediterranean Sea has been designated as an ECA. With effect from 1 March 2027, the upper limit of sulfur content is reduced to 0.10% in Canadian Arctic ECA and the Norwegian sea ECA. Amended Annex VI also establishes new tiers of stringent nitrogen oxide emissions standards for marine diesel engines, depending on their date of installation. At the MEPC meeting held from 31 March to 4 April 2014, amendments to Annex VI were adopted which address the date on which Tier III Nitrogen Oxide (“NOx”) standards in ECAs will go into effect. Under the amendments, Tier III NOx standards apply to ships that operate in the North American and US Caribbean Sea ECAs designed for the control of NOx produced by vessels with a marine diesel engine installed and constructed on or after 1 January 2016. Tier III requirements could apply to areas that will be designated for Tier III NOx in the future. At MEPC 70 and MEPC 71, the MEPC approved the North Sea and Baltic Sea as ECAs for nitrogen oxide for ships built on or after 1 January 2021. The EPA promulgated equivalent (and in some senses stricter) emissions standards in 2010. Additionally, the IMO adopted amendments to MARPOL Annex I to, with effect from 1 July 2024, prohibiting the use, or carrying for use, HFO in Arctic waters. IMO’s MEPC 77 adopted a non-binding resolution which urged EU Member States and ship operators to voluntarily use distillate or other cleaner alternative fuels or methods of propulsion that are safe for ships and could contribute to the reduction of Black Carbon emissions from ships when operating in or near the Arctic. The Group’s LPG vessels have achieved compliance with sulfur emission standards, where necessary, by being modified to burn low sulfur gas oil in their boilers when alongside a berth. US air emissions standards are broadly aligned with the amended Annex VI requirements. Additional or new conventions, laws and regulations may be adopted that could require the installation of expensive emission control systems. Because the Group’s LPG vessels are largely powered by means other than high sulphur fuel oil, the Group does not anticipate that any emission limits that may be promulgated will require it to incur any material costs for the operation of its vessels, but that possibility cannot be eliminated. Clean Air Act The US Clean Air Act of 1970 (including its amendments of 1977 and 1990) (the “CAA”) requires the Environmental Protection Agency (the “EPA”) to promulgate standards applicable to emissions of volatile organic compounds and other air contaminants. The Group’s LPG vessels may be subject to vapor control and recovery requirements for certain cargos when loading, unloading, ballasting, cleaning and conducting other operations in regulated port areas and emission standards for so-called “Category 3” marine diesel engines operating in US waters. Previous marine diesel engine emission standards for Category 3 engines were adopted in 2003. These Tier 1 standards are generally equivalent to MARPOL Annex VI NOx limits and were limited to new engines beginning with the 2004 model year. On 30 April 2010, the EPA promulgated final emission standards for Category 3 marine diesel engines equivalent to those adopted in the amendments to Annex VI to MARPOL. The emission standards were applied in two stages: near-term standards for newly built engines apply from 2011, and long-term standards requiring an 80% reduction in nitrogen dioxides, or NOx, apply from 2016. A further stage of reductions, known as “Tier 4” standards, has also been developed and implemented. Separately, in December 2019, the EPA published a final rule concerning national diesel fuel regulations that allow fuel suppliers to distribute distillate diesel fuel that complies with the 0.5% international sulphur cap instead of fuel standards that otherwise apply to distillate diesel fuel in the United States. Fuel that does not meet the 0.5% sulphur cap cannot be used in ECA boundaries. 57 Table of Contents Anti-Fouling Systems Anti-fouling Systems (“AFS”), such as paint or surface treatment, are used to coat the bottom of vessels to prevent the attachment of molluscs and other sea life to the hulls of vessels. The Group’s LPG vessels are subject to the IMO’s International Convention on the Control of Harmful Anti-fouling Systems (“Anti-fouling Convention”), which prohibits the use of harmful organotin compounds in anti-fouling coating systems. Vessels of over 400 gross tonnes (excluding fixed and floating platforms, FSUs and FPSOs) engaged in international voyages must obtain an International AFS Certificate and undergo an initial survey before the vessel is put into service or when the AFS are altered or replaced. In June 2021, the MEPC formally adopted amendments to the Anti-fouling Convention to prohibit AFS containing cybutryne for all vessels. From 1 January 2023, for all vessels of over 400 gross tonnes engaged in international voyages (subject to certain exclusions) already bearing such AFS shall either remove the AFS or apply a coating that forms a barrier to this substance leaching from the underlying noncompliant AFS, at the next scheduled renewal of the systems after that date, but no later than 60 months following the last application to the vessels of AFS containing cybutryne. The Group has obtained AFS Certificates for all of its vessels, and the Group does not believe that maintaining such certificates will have an adverse financial impact on the operation of its vessels. Biofouling The IMO’s MEPC has adopted guidelines for the control and management of ships’ biofouling to minimise the transfer of invasive aquatic species, the most recent update being in July 2023. The 2023 guidelines focused on operational considerations such as the selection and installation of AFS and the re- installation, re-application or repair of the AFS, as well as guidance on maritime growth prevention systems (“MGPS”). The guidelines include recommendations as to the frequency of biofouling inspections or inspection dates (or date ranges) for in-water inspections by organisations, crew or personnel who are competent during the in-service period of the vessel. The guidelines recommend that the inspections be based on the ship-specific biofouling risk profile, including inspection as a contingency action, and specified in the Biofouling Management Plan (“BFMP”) under the responsibility of shipowners, ship operators and shipmasters. The 2023 guidelines also provide updates to the recommended information to be included in a BFMP and biofouling management record book. A biofouling assessment may be carried out during each biofouling inspection, taking into account the type and extent of biofouling, the condition of the AFS and the performance of any MGPS. The findings may be recorded using a rating system and used to determine whether cleaning or other remedial measures are appropriate. Oil Pollution Act and The Comprehensive Environmental Response Compensation and Liability Act The US Oil Pollution Act of 1990 (“OPA”) established an extensive regulatory and liability regime for the protection and cleanup of the environment from oil spills. OPA affects all owners and operators whose vessels trade or operate within the United States, its territories and possessions, or whose vessels operate in the waters of the United States, which includes the US territorial seas and its 200 nautical mile exclusive economic zone around the United States. The Comprehensive Environmental Response, Compensation, and Liability Act (“CERCLA”) applies to the discharge of hazardous substances whether on land or at sea. OPA and CERCLA both define “owner and operator” in the case of a vessel as any person owning, operating or chartering by demise, the vessel. Both OPA and CERCLA impact the Group’s operations. Under OPA, vessel owners and operators, are “responsible parties” and are jointly, severally and strictly liable (unless the spill results solely from the act or omission of a third party, an act of God or an act of war) for all containment and clean-up costs and other damages arising from discharges or threatened discharges of oil from their vessels, including bunkers (fuel). An oil spill could result in significant liability, including fines, penalties, criminal liability and remediation costs for natural resource damages as well as third-party damages. 58 Table of Contents The limits of OPA liability are the greater of US$2,500 per gross tonne or US$21,521,000 for any tanker, other than single-hull tank vessels, over 3,000 gross tonnes (subject to adjustments for inflation). These limits of liability do not apply, however, where the incident is caused by violation of applicable US federal safety, construction or operating regulations, or by the responsible party’s gross negligence or wilful misconduct. These limits likewise do not apply if the responsible party fails or refuses to report the incident or to cooperate and assist in connection with the substance removal activities. OPA specifically permits individual states to impose their own liability regimes with regard to oil pollution incidents occurring within their boundaries, and some states have enacted legislation providing for unlimited liability for discharge of pollutants within their waters. CERCLA, which also applies to owners and operators of vessels, contains a similar liability regime and provides for recovery of clean up and removal costs and the imposition of natural resource damages for releases of “hazardous substances,” which, as defined in CERCLA, excludes petroleum, including crude oil or any fraction thereof. Liability under CERCLA is limited to the greater of US$300 per gross tonne or US$0.5 million for each release from vessels not carrying hazardous substances as cargo or residue, and the greater of US$300 per gross tonne or US$5 million for each release from vessels carrying hazardous substances as cargo or residue (subject to adjustments for inflation). As with OPA, these limits of liability do not apply where the incident is caused by violation of applicable US federal safety, construction or operating regulations, or by the responsible party’s gross negligence or wilful misconduct or if the responsible party fails or refuses to report the incident or to cooperate and assist in connection with the substance removal activities. OPA and CERCLA each preserve the right to recover damages under existing law, including state and maritime tort law. The Group believes that it is in substantial compliance with OPA, CERCLA and all applicable state regulations in the ports where the Group’s vessels call. OPA and CERCLA both require owners and operators of vessels to establish and maintain with the US Coast Guard (the “USCG”) evidence of financial responsibility sufficient to meet the maximum amount of liability to which the particular responsible person may be subject. Under OPA regulations, an owner or operator of more than one vessel is required to demonstrate evidence of financial responsibility for the entire fleet in an amount equal only to the financial responsibility requirement of the vessel having the greatest maximum liability under OPA/CERCLA. Each of the Group’s ship owning subsidiaries that has vessels trading in US waters has applied for and obtained from the US Coast Guard National Pollution Funds Center three-year certificates of financial responsibility (“COFRs”), supported by guarantees purchased from an insurance-based provider. The Group believes that it will be able to continue to obtain the requisite guarantees and that it will continue to be granted COFRs from the USCG for each of its vessels that is required to have one. Compliance with any new requirements of OPA and future legislation or regulations applicable to the operation of the Group’s vessels could impact the cost of the Group’s operations and adversely affect its business and ability to make distributions to its shareholders. The Group currently maintains pollution liability coverage insurance in the amount of US$1 billion per incident for each of its vessels. If the damages from a catastrophic spill were to exceed the Group’s insurance coverage, it could have an adverse effect on the Group’s business and results of operation. CLC/Bunker Convention/CLC State Certificate The IMO adopted the International Convention on Civil Liability for Oil Pollution Damage of 1969, as amended by different Protocols in 1976, and 1992, and amended in 2000 (the “CLC”). Under the CLC and depending on whether the country in which the damage results is a party to the 1992 Protocol to the CLC, a vessel’s registered owner may be strictly liable, for pollution damage caused in the territorial waters of a contracting state by discharge of persistent oil, subject to certain exceptions. The 1992 Protocol changed certain limits on liability, expressed using the International Monetary Fund currency unit, the Special Drawing Rights. The limits on liability have since been amended so that the compensation limits on liability were raised. The right to limit liability is forfeited under the CLC where the spill is caused by the shipowner’s actual fault and under the 1992 Protocol where the spill is caused by the shipowner’s intentional or reckless act or omission where the shipowner knew pollution damage would probably result. The CLC requires ships carrying more than 2,000 tons of oil cargo to maintain insurance covering the liability of the owner in a sum equivalent to an owner’s liability for a single incident. 59 Table of Contents IMO also adopted the International Convention on Civil Liability for Bunker Oil Pollution Damage 2001 (the “Bunker Convention”), which establishes a liability, compensation and compulsory insurance regime for the victims of oil pollution damage caused by spills of bunker oil. The Bunker Convention imposes strict liability on the registered owner for pollution damage caused by discharges of bunker oil in the territorial sea and exclusive economic zone (or equivalent area) of a state party. Registered owners of any sea going vessel and seaborne craft over 1,000 gross tonnage, of any type whatsoever, and registered in a state party, or entering or leaving a port in the territory of a state party, are required to maintain insurance which meets the requirements of the Bunker Convention and to obtain a certificate issued by a state party attesting that such insurance is in force. The state party-issued certificate must be carried on board at all times. P&I Clubs in the International Group issue the required Bunker Convention “Blue Cards” to provide evidence that there is insurance in place that meets the Bunker Convention requirements and thereby enable signatory states to issue certificates. The Group’s LPG vessels have received “Blue Cards” from their P&I Club and are in possession of a CLC State-issued certificate attesting that the required insurance cover is in force. Ballast Water Management Convention, Clean Water Act and National Invasive Species Act The IMO has negotiated international conventions that impose liability for pollution in international waters and the territorial waters of the signatories to such conventions. The EPA and the USCG, have also enacted rules relating to ballast water discharge for all vessels entering or operating in US waters. Compliance requires the installation of equipment on the Group’s vessels to treat ballast water before it is discharged or the implementation of other port facility disposal arrangements or procedures at potentially substantial cost, and/or otherwise restrict the Group’s vessels from entering US waters. Ballast Water Management Convention IMO adopted the International Convention for the Control and Management of Ships’ Ballast Water and Sediments (the “BWM Convention”) in 2004. The BWM Convention entered into force on 8 September 2017. The BWM Convention requires ships to manage their ballast water to remove, render harmless or avoid the uptake or discharge of new or invasive aquatic organisms and pathogens within ballast water and sediments. The BWM Convention’s implementing regulations call for a phased introduction of mandatory ballast water exchange requirements to be replaced in time with mandatory concentration limits. As of 31 December 2023, the Group’s LPG vessels had installed ballast water treatment systems. Clean Water Act The US Clean Water Act (the “CWA”) prohibits the discharge of oil, hazardous substances and ballast water in US navigable waters unless authorised by a duly issued permit or exemption and imposes strict liability in the form of penalties for any unauthorised discharges. The CWA also imposes substantial liability for the costs of removal, remediation and damages and complements the remedies available under OPA and CERCLA. In addition, many US states that border a navigable waterway have enacted environmental pollution laws that impose strict liability on a person for removal costs and damages resulting from a discharge of oil or a release of a hazardous substance. These laws may be more stringent than US federal law. The EPA regulates the discharge of ballast and bilge water and other substances in US waters under the CWA. The EPA regulations historically have required vessels 79 feet in length or longer (other than commercial fishing vessels and recreational vessels) to obtain and comply with a permit that regulates ballast water discharges and other discharges incidental to the normal operation of certain vessels within US waters. In March 2013, the EPA issued the Vessel General Permit for Discharges Incidental to the Normal Operation of Vessels (“VGP”). The 2013 VGP focuses on authorizing discharges incidental to operations of commercial vessels and contains ballast water discharge limits for most vessels to reduce the risk of invasive species in US waters, more stringent requirements for exhaust gas scrubbers and the use of environmentally acceptable lubricants. In December 2018, the Vessel Incidental Discharge Act (“VIDA”) amended the CWA Section 312(p) and restructured how the EPA and the USCG regulated incidental discharges from commercial vessels into US waters. Specifically, VIDA gave the EPA responsibility for establishing standards for the discharge of pollutants from vessels and the USCG responsibility for prescribing, administering, and enforcing the standards. VIDA defines specific roles for the EPA, the U.S. Coast Guard and states. The EPA’s primary responsibility is to develop national standards of performance for the incidental discharges from these vessels, while the USCG is to develop corresponding implementation, compliance and enforcement regulations for those standards, including any requirements governing the design, construction, testing, approval, installation and use of devices necessary to achieve the EPA standards. 60 Table of Contents In October 2024, the EPA published a final rule, the Vessel Incidental Discharge National Standards of Performance, in the Federal Register. The USCG has two years after issuance of the EPA’s rule to finalize the corresponding implementing regulations. The EPA’s rule included three general discharge standards – General Operation and Maintenance, Oil Management, and Biofouling Management – as well as specific standards for 20 different equipment and systems onboard vessels. Once both the EPA and USCG regulations are final, effective and enforceable, states will be preempted from establishing more stringent discharge standards. VIDA, however, includes provisions for states to pursue additional requirements through various petition processes. VIDA also specified that the EPA, the USCG and the states all have responsibilities related to enforcement. The USCG is authorized to inspect vessels, establish procedures for investigating and reporting violations, and monitor vessels, as well as detain vessels, as appropriate, for noncompliance with the requirements. The EPA is authorized to take civil actions or pursue criminal penalties against any person that is in violation of the requirements. Finally, the requirements may also be enforced by states or political subdivisions of states. Vessels operating in multiple jurisdictions could face potentially conflicting conditions specific to each jurisdiction that they travel through. National Invasive Species Act The USCG regulations adopted under the US National Invasive Species Act require the USCG’s approval of any technology before it is placed on a vessel. As a result, the USCG has provided waivers to vessels which could not install the then unapproved technology. Under the USCG rule on the Coast Guard’s ballast water management record-keeping requirements, vessels with ballast tanks operating exclusively on voyages between ports or places within a single Captain of the Port zone are required to submit an annual report of their ballast water management practices. Vessels may submit their reports after arrival at the port of destination instead of prior to arrival. As discussed above, under VIDA, existing USCG ballast water management regulations will be phased out and replaced with national standards of performance to be developed by EPA and implemented and enforced by the USCG (anticipated in 2026). EU regulations In October 2009, the EU amended a directive to impose criminal sanctions for illicit ship-source discharges of polluting substances, including minor discharges, if committed with intent, recklessly or with serious negligence and the discharges individually or in the aggregate result in deterioration of the quality of water. Aiding and abetting the discharge of a polluting substance may also lead to criminal penalties. The directive applies to all types of vessels, irrespective of their flag, but certain exceptions apply to warships or where human safety or that of the ship is in danger. Criminal liability for pollution may result in substantial penalties or fines and may result in increased civil liability claims. In June 2023, the EU Commission presented legislative proposals to modernize EU rules on maritime safety and prevention of water pollution; including extension of port state controls, proposals to prevent illegal discharges into European seas, including by extending the scope of prohibitions to cover a wider range of polluting substances, and to strengthen the legal framework for penalties and their application. The proposals have not yet been adopted but these, or other new regulations regarding water pollution, may have an effect on the Group’s business in the future. International Labour Organisation The ILO is a specialised agency of the United Nations that has adopted the Maritime Labour Convention, 2006 as amended (“MLC 2006”). The MLC 2006 establishes minimum standards for seafarers’ working and living conditions and requires that compliant ships carry a Maritime Labour Certificate and a Declaration of Maritime Labour Compliance These certificates are mandatory for ships of 500 gross tonnage or above engaged in international voyages or flying the flag of a member and operating from a port, or between ports, in another country. The MLC 2006 imposes obligations on owners, including requirements relating to seafarers’ health protection, medical care, repatriation and other welfare measures that have been applied in the context of the COVID-19 pandemic to safeguard seafarers’ rights and working conditions under MLC 2006 standards. The Group believes that all its vessels are in substantial compliance with and are certified to meet the MLC 2006. 61 Table of Contents GHG regulations Greenhouse Gasses In 2009, the EPA issued a finding that GHGs endanger public health and safety and has adopted regulations that regulate the emission of GHGs from certain sources. These regulations may include restrictions on certain oil and gas production or stimulation techniques, standards to control methane and volatile organic compound emissions from new oil and gas facilities, requirements for the installation and use of certain emissions control technologies, and other regulations that may adversely impact the operations of the fossil fuel companies to whom the Group provides services, which may ultimately reduce demand for the Group’s services. Regarding the Group’s own operations, the EPA has historically enforced the CAA and US regulations to implement the international standards found in Annex VI of MARPOL concerning marine diesel emissions, and the sulphur content found in marine fuel. Other federal and state regulations relating to the control of GHG emissions may follow, including climate change initiatives that have been considered in the US Congress. However, in February 2026, the Trump administration revoked the 2009 EPA GHGs endangerment finding and, subsequently, the EPA announced that the CAA does not give it the legal authority to regulate GHGs. Public health and environmental groups swiftly filed legal challenges against the recission of the 2009 endangerment finding, arguing that the EPA is legally required to limit such emissions. The outcome of these legal challenges is uncertain. The EU has imposed a 0.1% maximum sulfur requirement for fuel used by ships at berth in the Baltic, the North Sea and the English Channel (“SOx-Emission Control Area”) under Annex VI to MARPOL. As of January 2020, EU member states must also ensure that ships in all EU waters, except the SOx-Emission Control Area, use fuels with a 0.5% maximum sulfur content. In 2019, a consortium of shipping financiers launched the Poseidon Principles, a framework to assess and disclose the alignment of ship finance portfolios with the climate-related goals of the IMO. While voluntary, signatories commit to implementing the Poseidon Principles in their internal policies. Similarly, at the 26th Conference to the Parties of the United Nations Framework Convention on Climate Change (“COP 26”), the Glasgow Financial Alliance for Net Zero (“GFANZ”) announced commitments from a global coalition of leading financial institutions to accelerate decarbonisation of the economy. The various suballiances of GFANZ, including the Net- Zero Banking Alliance of leading global banks, generally require participants to set targets to transition their financing, investing, and/or underwriting activities to net zero emissions by 2050. Changes in U.S. presidential administrations have led to rapid, contradictory changes in policy. In late 2020, the U.S. Federal Reserve Board announced that it had joined, and in January 2025 the U.S. Federal Reserve Board announced that it had withdrawn from, the Network for Greening the Financial System, a consortium of financial regulators focused on addressing climate-related risks in the financial sector. In March 2024, the SEC adopted rules requiring US-listed companies to disclose extensive climate-related information, although in April 2024, the SEC issued an order voluntarily staying these new climate-related disclosure rules following a number of legal challenges, and the outcome of these legal challenges remains uncertain. In February 2025, the acting Chairman of the SEC asked the relevant court to pause the ongoing litigation over the climate-related disclosure rules to provide the SEC with time to deliberate and determine the appropriate next steps. On March 27, 2025, the SEC voted to end its defense of the climate-related disclosure rules. It is unlikely that the proposed rules in any form will become effective. However, if climate-related disclosure rules do become effective in the future, although the ultimate form and substance of these requirements is not yet known, they may result in additional costs to comply with any such disclosure requirements. At the international level, at COP 26, the United States and EU jointly announced the launch of the Global Methane Pledge, an initiative committing to a collective goal of reducing global methane emissions by at least 30% from 2020 levels by 2030, including “all feasible reductions” in the energy sector. Conversely, in October 2025, the IMO postponed the vote to adopt the Net Zero Framework following pressure from the Trump administration. 62 Table of Contents EEDI & EEXI EEXI determines energy efficiency and CO2 emissions from the vessel’s operations based on its design parameters. From 1 January 2023, it became a requirement that vessels subject to the EEXI framework must have an attained EEXI value falling below an allowable maximum value (the required EEXI). If a vessel’s EEXI does not satisfy the required EEXI, it is necessary to implement countermeasures. EEXI supplements the Energy Efficiency Design Index (“EEDI”) which has been in force since 2013. EEDI applies to newbuilds while EEXI applies to existing vessels. Certification of EEXI takes place at the first annual, intermediate, or special survey on or after 1 January 2023. Compliance with EEXI must be documented by the issuance of the IEE certificate. Shaft Power Limitation Systems have been deployed for the Group’s LPG vessels requiring main engine power reduction to attain EEXI compliance. SEEMP As of 1 January 2013, certain measures relating to energy efficiency for ships were made mandatory under MARPOL. All ships became required to develop and implement a Ship Energy Efficiency Management Plan (“SEEMP”). SEEMP was developed by the IMO to support ships’ energy performance and efficiency objectives. SEEMP is split into three different parts, each of which includes different requirements on vessel owners and vessel operators. The Group has completed and verified its SEEMP III plans for all vessels. CII The CII requires vessels over 5,000 gross tonnes to quantify and report their carbon emissions from ongoing operations. CII determines the annual reduction factor needed to improve the vessel’s operational carbon intensity. Based on the collected data, the vessel is rated on a scale from A – E, where A is best. If a vessel is rated D for three consecutive years or E for one year, a corrective action plan must be provided to indicate how an index of C or above will be reached. As of 31 December 2025, the Group’s LPG vessels were all in compliance with the CII requirements. EU Regulation on monitoring, reporting and verification of CO2 emissions In April 2015, Regulation (EU) 2015/757 of the European Parliament and of the EU Council on the monitoring, reporting and verification of carbon dioxide emissions (“EU MRV”) from maritime transport and amending Directive 2009/16/EC was adopted. EU MRV requires large vessels calling at EU ports to collect and publish data on CO2 emissions and other information and requires owners or operators (as applicable) of vessels over 5,000 gross tonnes to monitor emissions for each ship on a per-voyage and annual basis from 1 January 2018. Further, since 2019, all ships above 5,000 gross tonnes, regardless of flag state, calling at EU ports must submit a verified emissions report to the responsible administering authority by 30 April of each year, and by 30 June of each year vessels must carry a valid document of compliance confirming compliance with Regulation (EU) 2015/757 for the prior reporting period. EU Emissions Trading System From 1 January 2024, the EU Emissions Trading System (“EU ETS”) has been extended to cover emissions from ships of 5,000 gross tonnes and above calling at EU ports, including emissions from voyages within the EU, a portion of emissions from voyages to or from non-EU ports, and emissions at berth, regardless of flag state. The EU ETS is a “cap” and “trade” system providing for an absolute, gradually decreasing, “cap” on total emissions. Under the EU ETS, shipowners (or the ISM company if mandated) will be required to submit 1 EU allowance (“EUA”) for each ton of CO2 (or CO2-equivalent) they emit. The EU ETS is gradually phased in and as such, shipping companies will be obligated to surrender EUAs in 2025 for 40% of their emissions reported in 2024, in 2026 for 70% of their emissions reported in 2025 and from 2027 for 100% of their reported emissions in the previous year. The obligation to surrender EUAs will generally rest with the vessel’s registered owner, however the obligation can be delegated contractually. If a shipping company does not surrender the required EUAs, they will be liable to pay a penalty and may be published as a non-complying shipping company. 63 Table of Contents FuelEU Maritime Regulation The European Parliament and the Council of the European Union have adopted Regulation (EU) 2023/1805 on the use of renewable and low-carbon fuels in maritime transport, and amending Directive 2009/16/EC (“FuelEU Maritime Regulation”). This Regulation was adopted on 13 September 2023 and became effective on 12 October 2023. Shipping companies must submit a standardized emissions monitoring plan for each of their vessels by 31 August 2024, and from 1 January 2025, must collect information in accordance with this plan. From 2026, shipping companies must submit the relevant information for the first reporting period (2025) to a verifier and thereafter to a compliance database to be established by the EU. Each year, the verifier will issue to the shipping company a FuelEU document of compliance which must be kept onboard all ships calling at an EU port of call. If a ship is non-compliant, penalties must be paid in order for the ship to receive the document of compliance from the verifier. A ship that is non-compliant for two or more consecutive years may be issued an expulsion order. Wreck Removal The Nairobi Convention on the Removal of Wrecks (“Wreck Removal Convention”), entered into force on 14 April 2015, and contains obligations for shipowners to effectively remove wrecks located in a member state’s exclusive economic zone or equivalent 200 nautical miles zone. The Wreck Removal Convention places strict liability, subject to certain exceptions, on a vessel owner for locating, marking, and removing the wreck of any owned vessel deemed to be a hazard due to factors such as its proximity to shipping routes, traffic density and frequency, type of traffic and vulnerability of port facilities as well as environmental damage. It also makes government certification of insurance, or other form of financial security for such liability, compulsory for ships of 300 gross tonnes and above. Should one of the Group’s LPG vessels become a wreck subject to the Wreck Removal Convention, substantial costs may be incurred in addition to any losses suffered as a result of the loss of the vessel, although such risk may be insured. HNS Convention In 1996, the IMO adopted the International Convention on Liability and Compensation for Damage in Connection with the Carriage of Hazardous and Noxious substances by Sea (“HNS Convention”). The aim of the HNS Convention is to ensure adequate, prompt and effective compensation for damage resulting from shipping accidents involving hazardous and noxious substances. By 2009, the 1996 HNS convention had still not entered into force, due to an insufficient number of ratifications. A second international conference, held in April 2010, adopted a Protocol to the HNS convention (the “2010 HNS Protocol”) that was designed to address practical problems that had prevented many States from ratifying the original HNS Convention. If the 2010 HNS Protocol is ratified and enters into force, the Group may incur additional costs or capital expenses to be compliant. Hong Kong International Convention and EU Ship Recycling Regulation The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (“Hong Kong Convention”) aims to ensure that when vessels are being recycled at the end of their operational lives, they do not pose any unnecessary risks to the environment, human health and safety. The ratification conditions for the Hong Kong Convention were met on 26 June 2023, and the Hong Kong Convention will enter into force on 26 June 2025. The Hong Kong Convention applies to all vessels larger than 500 gross tonnes that fly the flag of, or enter the waters of, a party to the Hong Kong Convention. Upon the Hong Kong Convention’s entry into force, each vessel will have to carry an inventory of its hazardous materials, ship recycling facilities authorized by the competent authorities must provide a ship recycling plan specific for each vessel to be recycled, and governments will be required to ensure that recycling facilities under their jurisdiction comply with the Hong Kong Convention. The hazardous materials, whose use or installation are prohibited in certain circumstances, are listed in an appendix to the Hong Kong Convention. Vessels will be required to have surveys to verify their inventory of hazardous materials initially, throughout their lives and prior to being recycled. 64 Table of Contents The EU Ship Recycling Regulation, although only applicable on a regional level, has prepared the industry for compliance with the Hong Kong Convention requirements. Regulation (EU) 2013/1257 applies to all EU-flagged vessels going for dismantling, all new EU ships and to vessels with non-EU flags that call at an EU port or anchorage (with certain exceptions). The legislation aims to prevent, reduce and minimise accidents, injuries and other negative effects on human health and the environment when ships are recycled and the hazardous waste they contain is removed. Every new ship has to have on board an inventory of hazardous materials (such as asbestos, lead or mercury) it contains in either its structure or equipment and must specify the location and approximate quantities of those materials. The use of certain hazardous materials is forbidden. Before a ship is recycled, its owner must provide the recycling facility with specific information about the vessel in order to prepare a ship recycling plan. Recycling may only take place at facilities listed on the EU list of facilities, which was launched by Commission Implementing Decision (EU) 2016/2323. The facilities may be located in the EU or in non-EU countries. They must comply with a series of requirements related to workers’ safety and environmental protection. Vessel Security Regulation Chapter XI-2 of SOLAS imposes detailed security obligations on vessels and port authorities and mandates compliance with the International Ship and Port Facility Security Code (“ISPS Code”), which came into effect on 1 July 2004, and is applicable to passenger ships and cargo vessels over 500 gross tonnes operating on international trades, to detect security threats and take preventive measures against security incidents affecting vessels or port facilities. To trade internationally, a vessel must attain an International Ship Security Certificate (“ISSC”) issued by the vessel’s flag state or by a recognized security organisation approved by the vessel’s flag state. Ships operating without a valid certificate may be detained, expelled from, or refused entry at port until they obtain an ISSC. US Maritime Transportation Security Act (“MTSA”) was adopted in 2002. To implement certain portions of the MTSA, the USCG issued regulations requiring the implementation of certain security requirements aboard vessels operating in waters, subject to the jurisdiction of the United States and at certain ports and facilities, some of which are regulated by the EPA. The USCG regulations, intended to align with international maritime security standards, exempt non-US vessels from MTSA vessel security measures, provided such vessels have on board a valid ISSC that attests to the vessel’s compliance with SOLAS security requirements and the ISPS Code. All of the Group’s LPG vessels have been certified to meet the ISPS Code and the security requirements of the SOLAS and MTSA. The cost of vessel security measures has also been affected by the escalation in the frequency of acts of piracy against ships, notably off the coast of West Africa and Somalia, including the Gulf of Aden and Arabian Sea area. Substantial loss of revenue and other costs may be incurred as a result of detention of a vessel or additional security measures, and the risk of uninsured losses could significantly affect the Group’s business. Costs are incurred in taking additional security measures in accordance with Best Management Practices to Deter Piracy, notably those contained in the BMP WAF and BMP5 industry standard. Cybersecurity Recent action by the IMO’s Maritime Safety Committee and US agencies indicate that cybersecurity regulations for the maritime industry are likely to be further developed in the near future in an attempt to combat cybersecurity threats. By IMO resolution, administrations are encouraged to ensure that cyber-risk management systems are incorporated by shipowners and managers by their first annual Document of Compliance audit after 1 January 2021. In February 2021, the USCG published guidance on addressing cyber risks in a vessel’s safety management system. This might cause companies to cultivate additional procedures for monitoring cybersecurity, which could require additional expenses and/or capital expenditures. In January 2025, the USCG published a final rule, Cybersecurity in the Marine Transportation System, which became effective July 16, 2025 for U.S.-flagged vessels, outer continental shelf facilities and facilities subject to the MTSA. 4.C.ORGANIZATIONAL STRUCTURE The Group operates through various subsidiaries. A list of significant subsidiaries of the Group is included in Exhibit 8.1 to this annual report. ​ ​ 65 Table of Contents 4.D.PROPERTY, PLANT AND EQUIPMENT Other than its vessels, the Group does not own any material property. For information on the Group’s fleet, see “Item 4. Information on the Company — 4.B. Business Overview — Shipping — Fleet.”