A. History and Development of the Company We are a Singapore public company limited by shares with company registration number (UEN) 202440137E and the legal name “Hafnia Limited”. We redomiciled from Bermuda to Singapore with effect from October 1, 2024 by way of a discontinuance from Bermuda and continuance into Singapore pursuant to Section 132G of the Bermuda Companies Act. Prior to the Redomiciliation, we were an exempted company limited by shares incorporated under the laws of Bermuda on April 29, 2014. We have operated under the name Hafnia Limited from January 16, 2019 to the date of this Annual Report, under the name BW Tankers Limited from February 13, 2018 to January 16, 2019, and under the name BW Pacific Limited from our incorporation on April 29, 2014 to February 13, 2018. We are a holding company, and all of our operations are performed through our subsidiaries. Our current corporate organisation is the result of a 2019 merger between Hafnia Tankers and BW Tankers. The merger, completed on January 16, 2019, was carried out by way of a triangular merger, where Hafnia Tankers first merged with BW Tankers Corporation (a wholly-owned subsidiary of BW Tankers) with BW Tankers Corporation being the surviving and continuing entity. Thereafter, on January 21, 2019, BW Tankers Corporation merged with BW Tankers (which changed its name to Hafnia Limited with effect from January 16, 2019) in a statutory parent and subsidiary short form merger with BW Tankers being the surviving and continuing entity. On November 8, 2019, our shares commenced trading on Oslo Axess under the ticker code “HAFNIA.” On April 30, 2020, we were transferred from Oslo Axess to Oslo Børs and began trading under the ticker code “HAFNI.” On February 28, 2023, we began trading on the OTCQX® Best Market, New York, under the ticker (OTCQX: HAFNF). On April 9, 2024, our shares ceased trading on the OTCQX® Best Market and were listed on the NYSE under the ticker symbol “HAFN”. Currently, our principal executive office is located at 10 Pasir Panjang Road, #18-01, Mapletree Business City, Singapore 117438. You can reach us in our Singapore office at +65 6434 3770. Our agent for service of process in the United States is Hafnia US, LLC and its address is c/o Corporation Service Company, 251 Little Falls Drive, Wilmington, New Castle County, Delaware, 19808, United States. We also have offices in Copenhagen (Denmark), Houston (United States), Mumbai (India), Dubai (United Arab Emirates) and Monaco. Our website is https://www.hafnia.com/. Information contained on our website does not constitute part of and is not incorporated by reference into this Annual Report. We have included our website address in this Annual Report solely as an inactive textual reference. The SEC maintains an Internet site (http://www.sec.gov) that contains reports, proxy and information statements, and other information regarding issuers that file electronically with the SEC. None of the information contained on, or that can be accessed through, these websites are incorporated into or forms a part of this Annual Report. Vessel acquisitions and divestments We are committed to a strategy of continuous fleet renewal and therefore complete divestments and acquisitions of vessels from time to time to ensure that our Hafnia Fleet is optimally structured. In the period from January 1, 2026 until the date of this Annual Report, we divested three LR1 vessels, two MR vessels, and one Handy vessel, and further committed to the sale of one LR1, two MRs, and three Handy vessels, all to external parties and pending delivery to the buyers. We have not acquired any vessels during the period but have taken delivery of one newbuild MR vessel in our Ecomar Joint Venture (as defined below) and ordered eight newbuild MR vessels. See “—Recent Developments”. In 2025, we divested four vessels and we did not acquire any vessels (excluding the acquisition of vessels by the utilisation of purchase options in our sale and lease-back arrangements). Our Ecomar joint venture took delivery of three newbuild MR vessels. In 2024, we divested two vessels and we did not acquire any vessels (excluding the acquisition of vessels by the utilisation of purchase options in our sale and lease-back arrangements). Our Vista Joint Venture (defined below) took delivery of one newbuild LR2 vessel. In 2023, we divested six vessels and acquired four vessels which were named Hafnia Atlantic, Hafnia Pacific, Hafnia Pioneer and Hafnia Valentino. Additionally, our Vista Joint Venture took delivery of three newbuild LR2 vessels. In 2022, we acquired 44 new vessels (through the acquisition of 12 product tankers from Scorpio Tankers Inc. (“Scorpio”) and the acquisition of the CTI Fleet in the CTI Transaction both as described below) and divested 18 vessels. Eight of the vessels divested in 2022 were stainless steel vessels acquired by us in connection with the CTI Transaction. We divested these non-core assets to Ace Tankers Management B.V. In addition to these eight vessels, we divested four LR1 and six Handy vessels in line with our ongoing fleet renewal strategy. 46 Table of Contents We note that the above does not include any vessel acquisition pursuant to purchase options or purchase obligations in our sale and lease-back arrangements. Our sale and lease-back arrangements are further described in “Item 5. Operating and Financial Review and Prospects – B. Liquidity and Capital Resources – Financing Arrangements”. Acquisition of Chemical Tankers Inc.’s fleet of vessels On January 27, 2022, we completed the acquisition of 32 modern-fuel efficient chemical and product tanker vessels (the “CTI Fleet”) through the acquisition of Chemical Tankers Inc. and its subsidiaries (“CTI”) (the “CTI Transaction”). Immediately after closing of the CTI Transaction, we transferred all shares in CTI to our wholly-owned subsidiary Hafnia Holding II Limited. As consideration for the acquisition, the shareholders of CTI received 99,199,394 shares in Hafnia. The consideration shares consisted of a combination of existing shares and newly issued shares. The vessels in the CTI Fleet were built between 2015 and 2017. As described above, we divested eight of the vessels acquired in the CTI Transaction. The remaining 24 vessels were included in our Hafnia Fleet and now operate in our Chemical-MR Pool and Chemical-Handy Pool. Acquisition of 12 LR1 product tankers from Scorpio Tankers Inc. On January 27, 2022, we announced our acquisition of a fleet of 12 LR1 product tankers from Scorpio. The total consideration paid to Scorpio for the vessels was $413.8 million. The vessels were built in 2015 (1) and 2016 (11) in South Korea. On February 24, 2022, we (as guarantor) and our subsidiary, Hafnia Pools Pte. Ltd. (as charterer), entered into a sale and lease-back agreement with ICBC Financial Leasing Co., Ltd. (“ICBCL”) for the financing of these vessels. See “Item 5. Operating and Financial Review and Prospects – B. Liquidity and Capital Resources” for additional information on this financing arrangement. We have delivered all vessels to ICBCL and all vessels have been bareboat chartered back to our subsidiary Hafnia Pools Pte. Ltd. Joint Ventures Vista Joint Venture We are joint venture partners with CSSC (Hong Kong) Shipping Company Limited (“CSSC”) in Vista Shipping Pte. Ltd. (“Vista Shipping”) (the “Vista Joint Venture”). The Vista Joint Venture builds and operates LR1 and LR2 product tanker vessels. Vista Shipping and several of the subsidiaries of Vista Shipping were initially incorporated in Marshall Islands; however, these companies have been redomiciled to Singapore. We and CSSC have joint control over the Vista Joint Venture and each have 50% ownership interest. In accordance with the agreement under which the Vista Joint Venture was established, we and CSSC have agreed to provide shareholder loans in proportion to our interest to finance the newbuild program in the Vista Joint Venture. As at the date of this Annual Report, the fleet of the Vista Joint Venture comprises six LR1 vessels and four LR2 vessels. The LR1 vessels are trading in the Hafnia LR1 Pool. The LR2 vessels are chartered to Total or Equinor on long-term time charters. Andromeda Joint Venture We are joint venture partners with Andromeda Shipholdings Ltd. (“Andromeda Shipholdings”) in H&A Shipping Pte. Ltd. (“H&A Shipping”) (the “Andromeda Joint Venture”). We and Andromeda Shipholdings have joint control over the Andromeda Joint Venture and each have 50% ownership interest. H&A Shipping and its subsidiaries Green Stars Shipping Pte. Ltd. and Yellow Star Shipping Pte. Ltd. were initially incorporated in Marshall Islands, but were redomiciled to Singapore in 2024. In accordance with the agreement under which the Andromeda Joint Venture was established, we and Andromeda Shipholdings have agreed to provide shareholder loans in proportion to our interest to finance the newbuild program in the Andromeda Joint Venture. The fleet of the Andromeda Joint Venture comprises two MR vessels; Yellow Stars and PS Stars. Both vessels are time chartered to Clearlake on long-term time charters. Ecomar Joint Venture We are joint venture partners with Socatra in Ecomar Shipholding SAS (the “Ecomar Joint Venture”). We and Socatra each have 50% ownership interest. The Ecomar Joint Venture is managed in France and controlled by a Management Committee primarily comprising persons living in France. Ecomar Shipholding SAS has four wholly-owned subsidiaries; Ecomar Alpha SAS, Ecomar Bravo SAS, Ecomar Charlie SAS and Ecomar Delta SAS, all of which are incorporated in France. In connection with the Ecomar Joint Venture, we ordered four newbuild MR vessels from GSI (as defined below). The shipbuilding contracts relating to these vessels were originally entered into between Hafnia SG Pte. Ltd. and the yard but were novated to the Ecomar Joint Venture in October 2023 and subsequently novated from Ecomar Shipholding SAS to each of Ecomar Alpha SAS, Ecomar Bravo SAS, Ecomar Charlie SAS and Ecomar Delta SAS in June 2024. In accordance with the agreement under which the Ecomar Joint Venture was established, we and Socatra have agreed to provide shareholder loans in proportion to our interest to finance the newbuild program in the Ecomar Joint Venture. Each of the four vessels in the Ecomar Joint Venture are to be time chartered to Total on long-term time charters. The Ecomar Joint Venture fleet consists of four MR vessels, with the final vessel delivered in January 2026. 47 Table of Contents Seascale Energy Joint Venture We are joint venture partners with Cargill in Seascale Energy Pte. Ltd. (the “Seascale Energy Joint Venture”), which combined the business of the Hafnia Bunkers Alliance with Cargill’s Pure Marine Fuels business and commenced operations in May 2025. We and Cargill each have 50% of the outstanding equity in the Seascale Energy Joint Venture. The Seascale Energy Joint Venture is incorporated in Singapore and is controlled under a dual-CEO structure where both we and Cargill are represented. Over 25 team members from Cargill and Hafnia operate the Seascale Energy Joint Venture from offices in Singapore, Geneva, Copenhagen and Houston. The Hafnia team members previously worked within the Hafnia Bunkers Alliance, where they assisted with the purchase of bunkers for all Pool Vessels and for vessels operated by third parties. The Hafnia Bunkers Alliance offered a best-in-class bunker management service by utilising our large buying power, economies of scale and full transparency on our procurement processes. By combining the businesses of the Hafnia Bunkers Alliance and Cargill’s Pure Marine Fuels, the Seascale Energy Joint Venture significantly improves such economies of scale and transparency and is now one of the ten largest bunker procurement companies. Since commencing operations in May 2025, the Seascale Energy Joint Venture serviced approximately 2,400 vessels during the year. Investments Investment in TORM PLC On September 11, 2025, we entered into a sale and purchase agreement with OCM Njord Holdings S.ar.l. to purchase 14,156,061 Class A Shares of TORM plc (the “TORM Class A Shares”) corresponding to, as of the date of this Annual Report, approximately 13.97% of TORM plc’s issued share capital (the “Investment in TORM”), at a price of $22.0 per share, representing $311.4 million in aggregate consideration. The purchase was completed on December 22, 2025. The sale and purchase agreement has been filed as Exhibit 4.2 to this Annual Report. We acquired and hold the TORM Class A Shares for investment purposes. We believe consolidation is positive for the tanker industry generally and are evaluating potential strategic opportunities involving the Investment in TORM, including a range of potential options for a combination of the two businesses. There can be no assurance as to whether any such actions will occur, or as to the timing or outcome of any such actions. See “Item 3. Key Information – D. Risk Factors – We have purchased approximately 13.97% of TORM plc for investment purposes and are evaluating potential strategic purposes. There can be no assurance that we and TORM will pursue, enter or consummate a potential transaction and there are several risks associated with the negotiation, completion and timing of any potential transaction” for more information. Alternative Investments In addition to investments in vessels, we have made and will from time to time make alternative investments, such as investments in start-ups or investments in certain projects or companies. In the past, we have invested in projects relating to the production of green energy and projects regarding development of technologies which can possibly be used in our business in a short, medium, or long term perspective. There can be no assurance as to whether any such actions will occur, or as to the timing or outcome of any such actions. Pools For information regarding our Pools, see “Item 4. Information on the Company – B. Business Overview – Our Business.” Our Hafnia Fleet For information regarding our Hafnia fleet, including the development of our Hafnia fleet, see “Item 4. Information on the Company – B. Business Overview – Our Business.” Recent Developments On January 12, 2026, we sold and delivered a MR vessel, Hafnia Libra, to an external party. 48 Table of Contents On January 26, 2026, we sold and delivered a MR vessel, Hafnia Phoenix, to an external party. On January 27, 2026, we took delivery of an IMO-II MR vessel, Ecomar Gironde, through its ECOMAR joint venture. On February 18, 2026, we committed to the sale of Hafnia Leo and Hafnia Crux to external parties, pending delivery. On February 25, 2026, we committed to the sale of Hafnia Torres to an external party, pending delivery. On February 27, 2026, we entered into a US$100 million unsecured revolving credit facility with China Merchants Bank, with a final maturity date of February 27, 2029. On February 27, 2026, we entered into a US$100 million unsecured revolving credit facility with ICBC Bank, with a final maturity date of March 5, 2027. On March 16, 2026, we sold and delivered an LR1 vessel, Hafnia Zambesi, to an external party. On March 17, 2026, the Company granted a total of 2,489,948 share options to key management and senior employees under the LTIP 2026 share option program. On March 20, 2026, we sold and delivered an LR1 vessel, Hafnia Yangtze, to an external party. On March 27, 2026, we sold and delivered a Handy vessel, Hafnia Malacca, to an external party. On March 27, 2026, the Company cancelled 12,721,253 treasury shares. On March 31, 2026, we sold and delivered an LR1 vessel, Hafnia Seine, to an external party. On March 31, 2026, we cancelled our US$473 million facility and fully repaid the outstanding term loan. On April 3, 2026, we announced that we had signed a contract for the construction of eight MR newbuild product tankers from a South Korean shipyard, with a total purchase price of approximately US$405 million, with deliveries expected between the third quarter of 2028 and the second quarter of 2029. On April 9, 2026, we sold and delivered two Handy vessels, Hafnia Sunda and Hafnia Magellan, to an external party. On April 13, 2026, we sold and delivered an LR1 vessel, Hafnia Shinano, to an external party. We intend to wind down our Handy and LR2 pool operations in the upcoming financial year. We will exit the Handy segment upon the completion of the sale of our Handy vessels, while the majority of its owned LR2 vessels will be employed via time charters. B. Business Overview We are one of the world’s largest operators of chemical and product tankers and provide transportation of oil and oil products to leading international oil companies and national oil companies, major chemical companies, as well as trading and utility companies. The vessels in our Combined Fleet primarily transport petroleum products and chemicals and operate globally and throughout the whole year. See below for additional information on our Combined Fleet. Competitive Landscape We operate in markets that are highly competitive and highly influenced by supply and demand. We compete against other owners and operators of chemical and product tankers in a market where ownership is highly fragmented and our competitors include other publicly listed companies, major oil companies, state-controlled entities and private shipowners. We compete for charters on the basis of price, vessel location, size, age and condition of the product tankers as well as our reputation as an operator. Competition is also affected by the availability of other vessels which can compete in the trades in which we engage. Seasonality We operate the vessels in our Combined Fleet in markets that have historically had seasonal variations in demand, and as a result thereof, variations in charter rates. Seasonal peaks in demand for oil and products we transport can broadly be classified into two main categories; (i) increased demand prior to the winters in the northern hemisphere due to increases in heating oil consumption and (ii) increased demand for gasoline prior to the summer driving season in the United States. Unpredictable weather conditions and variations in oil supply may disrupt our scheduling. These seasonal variations may result in quarter-to-quarter volatility in our operating results as many of the vessels in our Combined Fleet operate in the spot market. 49 Table of Contents Our Business As at December 31, 2025, we operated a Combined Fleet of 187 vessels (including the Hafnia Fleet (Hafnia Vessels, TC Vessels and JV Vessels), Pool Vessels and other commercially managed third-party vessels) of which 99 are Hafnia Vessels; 9 are TC Vessels and 16 are JV Vessels (including one newbuild in our Ecomar Joint Venture). All Hafnia Vessels and TC Vessels are owned, leased (sale and lease-back arrangement) or time chartered-in by our subsidiaries. We have three vessel-owning joint ventures which as at December 31, 2025 operated 15 JV Vessels and had one newbuild on order. In addition to our Hafnia Fleet, as at December 31, 2025, we operated 61 Pool Vessels owned by third parties through our Pools and from time to time commercially manage additional vessels for third parties. We have in-house commercial and technical vessel management operations. We provide in-house commercial management to all of the vessels in our Combined Fleet apart from the vessels in the Andromeda Joint Venture and, as at December 31, 2025, provided in-house technical management for 57 of our Hafnia Vessels and JV Vessels with the remaining 57 Hafnia Vessels and JV Vessels being managed by third-party technical managers. The vessels in our Hafnia Fleet primarily trade through our Pools; however, we charter certain Hafnia Vessels, JV Vessels and TC Vessels directly to customers on time charters or voyage charters. Our Combined Fleet operates globally, with a total carrying capacity of 10.3 million dwt as at December 31, 2025, and when compared to worldwide dwt as at March 1, 2026 as further detailed in the subsection “Industry” below, has a current market share of 4.3% of operated product tankers worldwide within the segments in which we operate. As at December 31, 2025, the vessels in our Hafnia Fleet had an average age of approximately 4.9 years (LR2), 10.2 years (LR1), 9.3 years (MR) and 10.5 years (Handy), compared to the world LR2, LR1, MR, and Handy fleets’ average age as at March 1, 2026 of approximately 10.6, 15.8, 13.4 and 18.2 years, respectively. The vessels in our Hafnia Fleet are divided into four main operating segments which are based on the size and type of the vessels: • Long Range II (“LR2”) (85,000 – 124,999 dwt) • Long Range I (“LR1”) (55,000 – 84,999 dwt) • Medium Range (“MR”) (40,000 – 54,999 dwt) • Handy size (“Handy”) (25,000 – 39,999 dwt) Additionally, we have in recent years from time to time, including through our Pools, operated vessels in two additional smaller segments: • Stainless steel 25k (“Stainless” or “Chemical-Stainless”) (25,000 dwt) • Small and City tankers, all of which we jointly refer to as “Specialised” size (5,000-19,999 dwt). The vessels in the Hafnia Fleet operate in all of the above-mentioned main operating segments (i.e., not in the Stainless and Specialised segments). As at December 31, 2025, our Combined Fleet consists of the following vessels: Combined Fleet Hafnia Fleet ​ Hafnia Vessels (Owned) ​ Hafnia Vessels (Sale and lease-back) ​ TC Vessels ​ JV Vessels ​ Total ​ Commercial management (including Pool Vessels) ​ Total Fleet NB* Total ​ Fleet ​ NB* ​ Total ​ Fleet ​ NB* ​ Total ​ Fleet ​ NB* ​ Total ​ Fleet ​ NB* ​ Total ​ Fleet ​ NB* ​ Total ​ Fleet ​ NB* Total Specialised - - - ​ - ​ - ​ - ​ - ​ - ​ - ​ - ​ - ​ - ​ - ​ - ​ - ​ 10 ​ - ​ 10 ​ 10 ​ - 10 Handy 23 - 23 ​ 1 ​ - ​ 1 ​ - ​ - ​ - ​ - ​ - ​ - ​ 24 ​ - ​ 24 ​ 8(1) ​ - ​ 8 ​ 32 ​ - 32 MR 45 - 45 ​ - ​ - ​ - ​ 7 ​ - ​ 7 ​ 5(4) ​ 1(5) ​ 6 ​ 57 ​ 1 ​ 58 ​ 31(2) ​ - ​ 31 ​ 88 ​ 1 89 LR1 22 - 22 ​ 2 ​ - ​ 2 ​ 2 ​ - ​ 2 ​ 6(6) ​ - ​ 6 ​ 32 ​ - ​ 32 ​ 10(3) ​ - ​ 10 ​ 42 ​ - 42 LR2 6 - 6 - - - - - - 4(6) - 4 10 - 10 4 - 4 14 - 14 Total 96 - 96 3 - 3 9 - 9 15 1 16 123 1 124 63 - 63 186 1 187 * Newbuilds (1) Inclusive of vessels in Handy and Chemical-Handy Pool. (2) Inclusive of vessels in MR and Chemical-MR Pool. (3) Inclusive of vessels in LR1 and Panamax Pool. (4) Two owned through 50% ownership in the Andromeda Joint Venture and three owned through 50% ownership in the Ecomar Joint Venture. (5) Owned through 50% ownership in the Ecomar Joint Venture. (6) Owned through 50% ownership in the Vista Joint Venture. 50 Table of Contents Our Hafnia Fleet See below for additional information on the vessels in our Hafnia Fleet: Long range tankers (LR2) As at December 31, 2025, our Hafnia Fleet comprised 10 LR2 vessels: six Hafnia Vessels and four JV Vessels. The LR2s can carry a wide range of oils and oil products, including gasoline, diesel, naphtha, kerosene, fuel oil, and crude oil. The following table presents certain key information with respect to the LR2s in our Hafnia Fleet: Vessel Name Month/ Year built Shipyard(*) Cargo Capacity (dwt) Flag Ownership % Classification Society(**) Employment Type Hafnia Despina Jan-19 Daehan 109,990 Singapore 100% LR LR2 Pool Hafnia Galatea Mar-19 Daehan 109,990 Singapore 100% LR Time Charter Hafnia Languedoc Mar-23 GSI 109,999 Singapore 50%(1) DNV Time Charter Hafnia Larissa Apr-19 Daehan 109,990 Singapore 100% LR LR2 Pool Hafnia Larvik Oct-23 GSI 109,999 Singapore 50%(1) DNV Time Charter Hafnia Lillesand Feb-24 GSI 109,999 Singapore 50%(1) DNV Time Charter Hafnia Loire May-23 GSI 109,999 Singapore 50%(1) DNV Time Charter Hafnia Neso Jul-19 Daehan 109,990 Singapore 100% LR Time Charter Hafnia Thalassa Sep-19 Daehan 109,990 Singapore 100% LR Time Charter Hafnia Triton Oct-19 Daehan 109,990 Singapore 100% LR Time Charter Total (10 vessels) 1,099,936 (*) In the above table, Daehan refers to Daehan Shipbuilding Co., Ltd. and GSI refers to Guangzhou Shipyard International Co. Ltd. (**) For a discussion regarding Classification Society, see the section below “– Classification Societies”. (1) Owned through the Vista Joint Venture. Long range tankers (LR1) As at December 31, 2025, our Hafnia Fleet comprised 32 LR1 vessels: 24 Hafnia Vessels, two TC Vessels, and six JV Vessels. The LR1s can carry a wide range of oils and oil products, including gasoline, diesel, naphtha, kerosene, fuel oil, and crude oil. The following table presents certain key information with respect to the LR1s in our Hafnia Fleet. Vessel Name Month/ Year built Shipyard(*) Cargo Capacity (dwt) Flag Ownership % Classification Society(**) Employment Type Hafnia Africa May-10 STX 74,539 Singapore SLB(1) DNV Panamax Pool Hafnia Asia Jun-10 STX 74,490 Malta 100% DNV Panamax Pool Hafnia Australia May-10 STX 74,539 Singapore SLB(1) DNV Panamax Pool Hafnia Beijing Oct-19 GSI 74,999 Malta 50%(2) DNV LR1 Pool Hafnia Exceed Feb-16 STX 74,664 Singapore 100% DNV LR1 Pool Hafnia Excel Nov-15 STX 74,547 Singapore 100% DNV LR1 Pool Hafnia Excellence May-16 STX 74,613 Singapore 100% DNV LR1 Pool Hafnia Excelsior Jan-16 STX 74,665 Singapore 100% ABS LR1 Pool Hafnia Executive May-16 STX 74,319 Singapore 100% DNV LR1 Pool Hafnia Expedite Jan-16 STX 74,634 Singapore 100% ABS LR1 Pool Hafnia Experience Mar-16 STX 74,669 Singapore 100% DNV LR1 Pool Hafnia Express May-16 STX 74,663 Singapore 100% DNV LR1 Pool Hafnia Guangzhou Jul-19 GSI 74,999 Malta 50%(2) DNV LR1 Pool Hafnia Hong Kong Jan-19 GSI 74,999 Malta 50%(2) DNV LR1 Pool Hafnia Kallang Jan-17 STX 74,189 Singapore 100% LR LR1 Pool Hafnia Nanjing Jan-21 GSI 74,999 Singapore 50%(2) DNV LR1 Pool Hafnia Shannon Aug-17 STX 74,189 Singapore 100% LR LR1 Pool Hafnia Pioneer Jun-13 DSME 81,305 Singapore 100% LR LR1 Pool Hafnia Precision Oct-16 SPP 74,996 Singapore 100% DNV LR1 Pool Hafnia Prestige Nov-16 SPP 74,996 Singapore 100% DNV LR1 Pool Hafnia Pride Jul-16 SPP 74,997 Singapore 100% DNV LR1 Pool 51 Table of Contents Hafnia Providence Aug-16 SPP 74,996 Singapore 100% DNV LR1 Pool Hafnia Seine(4) May-08 Dalian 74,998 Singapore 100% ABS Panamax Pool Hafnia Shanghai Jan-19 GSI 74,999 Malta 50%(2) DNV LR1 Pool Hafnia Shenzhen Aug-20 GSI 74,999 Singapore 50%(2) DNV LR1 Pool Hafnia Shinano(4) Oct-08 Dalian 74,998 Singapore 100% DNV Time Charter Hafnia Tagus Mar-17 STX 74,151 Singapore 100% LR Time Charter Hafnia Yangtze(4) Jan-09 Dalian 74,996 Singapore 100% ABS Time Charter Hafnia Yarra Jul-17 STX 74,189 Singapore 100% LR Time Charter Hafnia Zambesi(4) Jan-10 Dalian 74,995 Singapore 100% ABS Panamax Pool Karimata Aug-19 Onomichi 79,885 Panama TC-in(3) ABS LR1 Pool Sunda Jul-19 Onomichi 79,902 Panama TC-in(3) ABS LR1 Pool Total (32 vessels) 2,408,118 (*) In the above table, STX refers to K Shipbuilding Co. Ltd. (formerly “STX Offshore and Shipbuilding Co. Ltd.”); GSI refers to Guangzhou Shipyard International Co. Ltd.; DSME refers to Daewoo Shipbuilding & Marine Engineering Co., Ltd., Dalian refers to Dalian Shipbuilding Industry; Tsuneishi refers to Tsuneishi Group (Zhoushan) Shipbuilding Inc.; Onomichi refers to Onomichi Dockyard Co. Ltd., and SPP refers to SPP Shipbuilding Co. Ltd. (**) For a discussion regarding Classification Society, see the below section “– Classification Societies”. (1) SLB = Sale and lease-back. (2) Owned through our Vista Joint Venture. (3) TC-in = Time charter in. (4) Vessel was sold or committed to sale after December 31, 2025. Medium range tankers (MR) As at December 31, 2025, our Hafnia Fleet comprised 57 MR vessels: 45 Hafnia Vessels, seven TC Vessels and five JV Vessels. The MRs carry a wide range of oil and oil products which include gasoline, diesel, naphtha, kerosene, vegetable oil, fuel, crude oil, easy chemicals, etc. The following table presents certain key information with respect to the MRs in our Hafnia Fleet. Vessel Name Month/ Year built Shipyard(*) Cargo Capacity (dwt) Flag Ownership % Classification Society(**) Employment Type Basset Nov-19 JMU 49,875 Singapore TC-in(1) ClassNK MR Pool Beagle Mar-19 JMU 49,850 Panama TC-in(1) ClassNK MR Pool Boxer Jun-19 JMU 49,852 Singapore TC-in(1) ClassNK MR Pool Bulldog Feb-20 JMU 49,856 Singapore TC-in(1) ClassNK MR Pool BW Wren Mar-16 SPP 49,999 Singapore 100% DNV MR Pool Ecomar Garonne Jul-25 GSI 49,696 France 50%(2) BV Time Charter Ecomar Gascogne Jan-25 GSI 49,776 France 50%(2) BV Time Charter Ecomar Guyenne May-25 GSI 49,763 France 50%(2) BV Time Charter Hafnia Andrea Jun-15 HMD 49,999 Singapore 100% ABS MR Pool Hafnia Ane Nov-15 GSI 49,999 Malta 100% DNV MR Pool Hafnia Atlantic Dec-17 GSI 49,641 Singapore 100% LR Chemical-MR Pool Hafnia Bobcat Aug-14 SPP 49,999 Singapore 100% LR Time Charter Hafnia Caterina Aug-15 HMD 49,999 Singapore 100% ABS MR Pool Hafnia Cheetah Feb-14 SPP 49,999 Singapore 100% ABS Time Charter Hafnia Cougar Jan-14 SPP 49,999 Singapore 100% LR Time Charter Hafnia Crux(4) Feb-12 GSI 49,999 Denmark 100% LR Time Charter Hafnia Daisy Aug-16 GSI 49,999 Malta 100% DNV Time Charter Hafnia Eagle Jul-15 SPP 49,999 Singapore 100% LR MR Pool Hafnia Egret Nov-14 SPP 49,999 Singapore 100% ABS MR Pool Hafnia Falcon Feb-15 SPP 49,999 Singapore 100% ABS Time Charter Hafnia Hawk Jun-15 SPP 49,999 Singapore 100% ABS MR Pool Hafnia Henriette Jun-16 GSI 49,999 Malta 100% DNV MR Pool Hafnia Jaguar Mar-14 SPP 49,999 Singapore 100% LR MR Pool Hafnia Kestrel Aug-15 SPP 49,999 Singapore 100% ABS Time Charter Hafnia Kirsten Jan-17 GSI 49,999 Malta 100% DNV MR Pool Hafnia Lene Jul-15 GSI 49,999 Malta 100% DNV MR Pool Hafnia Leo(4) Nov-13 GSI 49,999 Malta 100% LR MR Pool(5) Hafnia Leopard Jan-14 SPP 49,999 Singapore 100% LR MR Pool Hafnia Libra(4) May-13 GSI 49,999 Denmark 100% LR MR Pool Hafnia Lioness Jan-14 SPP 49,999 Singapore 100% LR Time Charter 52 Table of Contents Hafnia Lise Sep-16 GSI 49,875 Malta 100% DNV Time Charter Hafnia Lotte Jan-17 GSI 49,999 Malta 100% DNV MR Pool Hafnia Lynx Nov-13 SPP 49,999 Singapore 100% LR MR Pool Hafnia Merlin Sep-15 SPP 49,999 Singapore 100% DNV Time Charter Hafnia Mikala May-17 GSI 49,999 Malta 100% DNV MR Pool Hafnia Myna Oct-15 SPP 49,999 Singapore 100% LR Time Charter Hafnia Osprey Oct-15 SPP 49,999 Singapore 100% DNV MR Pool Hafnia Pacific Dec-17 GSI 49,686 Singapore 100% LR Chemical-MR Pool Hafnia Panther Jun-14 SPP 49,999 Singapore 100% LR MR Pool Hafnia Petrel Jan-16 SPP 49,999 Singapore 100% DNV Time Charter Hafnia Phoenix(4) Jul-13 GSI 49,999 Denmark 100% LR MR Pool Hafnia Puma Nov-13 SPP 49,999 Singapore 100% ABS MR Pool Hafnia Raven Nov-15 SPP 49,999 Singapore 100% DNV MR Pool Hafnia Swift Jan-16 SPP 49,999 Singapore 100% DNV MR Pool Hafnia Tanzanite Nov-16 STX 49,478 Marshall Islands 100% ABS Chemical-MR Pool Hafnia Tiger Mar-14 SPP 49,999 Singapore 100% LR MR Pool Hafnia Topaz Jul-16 STX 49,561 Marshall Islands 100% ABS Chemical-MR Pool Hafnia Tourmaline Oct-16 STX 49,513 Marshall Islands 100% ABS Chemical-MR Pool Hafnia Turquoise Apr-16 STX 49,516 Marshall Islands 100% ABS Chemical-MR Pool Hafnia Valentino May-15 HVS 49,126 Singapore 100% DNV Chemical-MR Pool Hafnia Violette Mar-15 HVS 49,126 Marshall Islands 100% ABS Chemical-MR Pool Hafnia Viridian Jan-15 HVS 49,126 Marshall Islands 100% ABS Chemical-MR Pool Hokkaido Oct-25 HMD 49,804 Panama TC-in(1) ClassNK MR Pool Orient Challenge Jun-17 HVS 49,972 Singapore TC-in(1) ClassNK MR Pool Orient Innovation Jul-17 HVS 49,997 Singapore TC-in(1) ClassNK MR Pool PS Stars Jan-22 HMD 49,999 Marshall Islands 50%(3) LR Time Charter Yellow Stars Jul-21 HMD 49,999 Marshall Islands 50%(3) LR Time Charter Total (57 vessels) 2,843,052 (*) In the above table, JMU refers to Japan Marine United Corporation; SPP refers to SPP Shipbuilding Co. Ltd.; GSI refers to Guangzhou Shipyard International Co. Ltd.; SKDY refers to Shin Kurushima Dockyard Co. Ltd.; STX refers to K Shipbuilding Co. Ltd. (formerly “STX Offshore and Shipbuilding Co. Ltd”); HVS refers to Hyundai-Vietnam Shipbuilding Co. Ltd. (formerly “Hyundai Vinashin Shipyard Co. Ltd.”); and HMD refers to Hyundai Mipo Dockyard Co. Ltd. (**) For a discussion regarding Classification Society, see the below section “Classification Societies”. (1) TC-in = Time charter-in. (2) Owned through the Ecomar Joint Venture. (3) Owned through the Andromeda Joint Venture. (4) Vessel was sold or committed to sale after December 31, 2025. (5) Vessel joined the pool on January 1, 2026. Handy tankers (Handy) As at December 31, 2025, our Hafnia Fleet comprised 24 Handy vessels, all of which are Hafnia Vessels. Our Handy vessels carry a wide range of oil and oil products which include gasoline, diesel, naphtha, kerosene, vegetable oil, fuel, crude oil, easy chemicals, etc. The following table presents certain key information with respect to the Handy vessels in our Hafnia Fleet. Vessel Name Month/ Year built Shipyard(*) Cargo Capacity (dwt) Flag Ownership % Classification Society(**) Employment Type Hafnia Achroite Jan-16 HMD 38,506 Marshall Islands 100% ABS Chemical-Handy Pool Hafnia Adamite Sep-15 HMD 38,506 Marshall Islands 100% ABS Chemical-Handy Pool Hafnia Alabaster Nov-15 HMD 38,506 Marshall Islands 100% ABS Time Charter Hafnia Almandine Feb-15 HMD 38,506 Marshall Islands 100% ABS Chemical-Handy Pool Hafnia Amazonite May-15 HMD 38,506 Marshall Islands 100% ABS Chemical-Handy Pool 53 Table of Contents Hafnia Amber Feb-15 HMD 38,506 Marshall Islands 100% ABS Chemical-Handy Pool Hafnia Amessi Jul-15 HMD 38,506 Singapore 100% ABS Chemical-Handy Pool Hafnia Amethyst Mar-15 HMD 38,506 Marshall Islands 100% ABS Chemical-Handy Pool Hafnia Ametrine Apr-15 HMD 38,506 Marshall Islands 100% ABS Chemical-Handy Pool Hafnia Ammolite Aug-15 HMD 38,506 Singapore SLB(1) ABS Chemical-Handy Pool Hafnia Andesine May-15 HMD 38,506 Marshall Islands 100% ABS Chemical-Handy Pool Hafnia Aquamarine Jun-15 HMD 38,506 Singapore 100% ABS Chemical-Handy Pool Hafnia Aragonite Oct-15 HMD 38,506 Marshall Islands 100% ABS Chemical-Handy Pool Hafnia Aronaldo Jun-15 HMD 38,506 Marshall Islands 100% ABS Chemical-Handy Pool Hafnia Aventurine Apr-15 HMD 38,506 Marshall Islands 100% ABS Chemical-Handy Pool Hafnia Axinite Jul-15 HMD 38,506 Singapore 100% ABS Chemical-Handy Pool Hafnia Azotic Sep-15 HMD 38,506 Marshall Islands 100% ABS Chemical-Handy Pool Hafnia Azurite Aug-15 HMD 38,506 Singapore 100% ABS Chemical-Handy Pool Hafnia Bering Apr-15 HMD 39,067 Singapore 100% LR Time Charter Hafnia Magellan(2) May-15 HMD 39,067 Singapore 100% LR Handy Pool Hafnia Malacca(2) Jul-15 HMD 39,067 Singapore 100% LR Handy Pool Hafnia Soya Nov-15 HMD 39,067 Singapore 100% LR Time Charter Hafnia Sunda(2) Sep-15 HMD 39,067 Singapore 100% LR Handy Pool Hafnia Torres(2) May-16 HMD 39,067 Singapore 100% LR Handy Pool Total (24 vessels) 927,510 (*) In the above table, HMD refers to Hyundai Mipo Dockyard Co. Ltd. (**) For a discussion regarding Classification Society, see the below section “Classification Societies”. (1) SLB = Sale and lease-back. (2) Vessel was sold or committed to sale after December 31, 2025. Newbuilds As at December 31, 2025, our Ecomar Joint Venture had one newbuild on order. The vessel was delivered in January 2026. The following table presents certain key information with respect to the newbuild that our Ecomar Joint Venture had on order as at December 31, 2025: Vessel Name Type of vessel Month/ Year built Shipyard(*) Cargo Capacity (dwt) Flag Ownership % Classification Society(**) Ecomar Gironde(1) MR Jan-26 GSI 49,800 France 50%(2) BV Total (1 newbuild) 49,800 (*) GSI refers to Guangzhou Shipyard International Co. Ltd. (**) For a discussion regarding Classification Society, see the below section “Classification Societies”. (1) Vessel delivered in January 2026. (2) Owned through the Ecomar Joint Venture. All the shipbuilding contracts are subject to customary cancellation provisions. Any newbuilds may be cancelled by us, inter alia, in the event of default by the shipbuilder due to bankruptcy or liquidation, in which case the newbuild(s) will be cancelled against a full refund amount (including interest) which is guaranteed by a bank, and in the event of excessive delay or vessel specification issues, in which case we will be entitled to a customary contract price reduction by way of liquidated damages or to cancel with a refund of pre-delivery instalments together with interest depending on the circumstances. The shipbuilder will be entitled to cancel any newbuilds, inter alia, in the event of payment default by us. 54 Table of Contents The Pools As at December 31, 2025, we operated as a pool manager for nine commercial tanker pools: (i) the Small pool, (ii) the City pool ((i) and (ii) together, the “Specialised Pool”), (iii) the Handy pool for Handy vessels (the “Handy Pool”), (iv) the Chemical-Handy pool for certain Handy vessels capable of carrying chemical products (the “Chemical-Handy Pool”), (v) the MR pool for MR vessels (the “MR Pool”), (vi) the Chemical-MR pool for certain MR vessels capable of carrying chemical products (the “Chemical-MR Pool”), (vii) the LR1 pool for LR1 vessels (the “LR1 Pool”), (viii) the Panamax pool for Panamax vessels (the “Panamax Pool”) and (ix) the LR2 pool for LR2 vessels (the “LR2 Pool”) (each of the Specialised Pool, the Handy Pool, the Chemical-Handy Pool, the MR Pool, the Chemical-MR Pool, the LR1 Pool, the LR2 Pool and the Panamax Pool, a “Pool”, and together collectively known as the “Pools”). In the Pools, we commercially manage Pool Vessels (i.e., vessels owned and/or operated by third parties which are commercially managed through our Pools) in addition to vessels from the Hafnia Fleet. As at December 31, 2025, the Specialised Pool comprised 10 vessels, all of which were Pool Vessels; the Handy Pool comprised 10 vessels of which six were Pool Vessels; the Chemical-Handy Pool comprised 18 vessels of which one was a Pool Vessel; the MR Pool comprised 62 vessels of which 31 were Pool Vessels; the Chemical-MR Pool comprised nine vessels, all of which were Hafnia Vessels; the LR1 Pool comprised 27 vessels of which four were Pool Vessels; the Panamax Pool comprised ten vessels of which five were Pool Vessels; and the LR2 Pool comprised six vessels of which four were Pool Vessels. We have Hafnia Vessels operating in each of the Pools except the Specialised Pool. Pool Agreements We operate the Pools through our pool managing entities, Hafnia Pools Pte. Ltd. and Hafnia Chemical Tankers Pte. Ltd., both of which are wholly-owned subsidiaries of ours (each a “Pool Manager”). The Pools are operated on the basis of eight separate pool agreements, which are amended from time to time (the “Pool Agreements”). These Pool Agreements are entered into between the respective Pool Manager and the relevant pool participants. With respect to our Hafnia Vessels and TC Vessels, the relevant Hafnia entities with ownership (or disponent ownership) of such vessels may also constitute pool participants. Until February 2023, we operated all the Pools as ‘agent-to-owner’ pools, where the Pool Manager entered into contracts for the employment of the vessels as an agent to the vessels’ respective owners. In February 2023, we changed the Handy Pool, MR Pool, LR1 Pool and the LR2 Pool to a ‘disponent-owner’ model as we believed it would lead to an increase in efficiency and in our access to working capital facilities. In May 2025, we changed the Chemical-Handy Pool and the Chemical-MR Pool to the ‘disponent-owner’-model. In connection with the transition of these two Pools to the ‘disponent-owner’ model, Hafnia Chemical Tankers Pte. Ltd. replaced Hafnia Middle East DMCC as pool manager for the Chemical-Handy and Chemical-MR Pools. We are not currently planning to transition the Specialised Pool from the ‘agent-to-owner’ model to the ‘disponent-owner’ model. We refer to such Pools as “Disponent-Owner Pools”. The Panamax Pool was a Disponent-Owner Pool from its establishment. The ‘disponent owner’ of a vessel is the person who contractually has the right to use and possession of the vessel, either as owner or charterer of the vessel. Most of the Pools are, as stated above, structured as ‘disponent-owner’-pools where the Pool Manager is the time charterer of the vessels in the pool. Therefore, in addition to the relevant Pool Agreement, each pool participant enters into a time charter with the relevant Pool Manager when entering their vessel in a ‘disponent-owner’-model Pool. On this basis, the relevant Pool Manager contractually becomes the disponent owner of each of the vessels in the ‘disponent-owner’ model pools and enters into contracts for the employment of the vessels in a Pool in its own name. Pursuant to the Pool Agreements, each vessel is allocated a number of ‘pool points’. A vessel’s pool points are based on its earning capabilities (which are largely defined by its fuel consumption) and may be adjusted in accordance with the terms of the Pool Agreements if, for example, the earning capacity of the vessel changes. In each pool, aggregated earnings of all vessels are, as a general rule, distributed between all participating vessels pro rata to their pool points. Certain exceptions apply, for example, in respect of time charters exceeding 12 months, where each pool participant can elect whether to opt-in or opt-out of earnings (and losses) relating to that time charter. Though a Pool Manager of a Pool under the ‘disponent-owner’ model has certain rights as time charterer with regard to employment and potential liabilities in connection with such role, the Pool Manager does not recognise TCE income from any Pool Vessel or JV Vessel operating in the Pools, where the relevant pool participant that is a third party owner or joint venture company, respectively, recognises the relevant TCE income. None of the Pool Managers benefit directly from gains or losses of revenue generated by use of the Pool Vessels or JV Vessels, receiving only management fees. Such fees are only a small percentage of the earnings generated by vessels in the Pool. A pool participant may only withdraw from the pool under certain conditions and shall give notice to the relevant Pool Manager of such withdrawal in accordance with the terms of the relevant Pool Agreement. Pool participants are fully responsible for the financing, insurance (except insurance related to procurement of bunkers), maintenance, and technical management, including manning, of their vessels. 55 Table of Contents When the Pool Manager is acting as disponent owner of the Pool Vessels in the Pools structured as ‘disponent-owner’ pools, the Pool Manager is contractually exposed to certain claims, including technical, operational, freight, demurrage and charterer’s liabilities as well as credit risks in relation to the pool participants, its customers, and in relation to letters of indemnity received by the relevant Pool Manager on the discharge of cargo. Some of these risks may be substantial, including, but not limited to, claims on bills of lading if a customer defaults or if a customer is sanctioned while the customer has cargo on board a vessel, in which case the vessel may not earn income until the issues are resolved. The Pool Agreements for the Disponent-Owner Pools include provisions to mitigate these risks; however, there can be no assurance that the risks are or can be fully mitigated. See “Item 3. Key Information – D. Risk Factors – We are subject to certain risks with respect to our counterparties on contracts, and failure of such counterparties to meet their obligations could cause us to suffer losses or negatively impact our results of operations, financial condition, and cash flows.” In addition, as discussed above, the Pool Manager of a Disponent-Owner Pool contractually passes all TCE income/losses on Pool Vessels and JV Vessels to the pool participants. In our LR1 Pool, the vessels are separated into an A-pool and a B-pool. The B-pool comprises vessels which are 15 years or older with or without ballast water treatment systems or which are under 15 years and do not have ballast water treatment systems. The A-pool and B-pool are not separate pools but rather notional constructs which exist in order to separate the vessels in the LR1 Pool for the purpose of sharing of revenue, expenses, income and claims arising solely in relation to the vessels in the ‘B-pool’ in the LR1 Pool. Management of vessels in the Pools The Pools comprise Pool Vessels, Hafnia Vessels, JV Vessels, and TC Vessels. The vessels in the Pools are employed through a variety of maritime transportation arrangements based on the needs of our customers including, inter alia, contracts of affreightment, time charters and voyage charters. These types of contracts are further described below in the section “Commercial Trading of the Combined Fleet.” Management of the Pools Each Pool is managed by a pool board, comprising up to two representatives from each pool participant (the “Pool Board”). The Pool Board is the governing body for the Pool, managing the responsibility for the overall strategic direction of the Pools. All decisions and resolutions of the respective Pool Boards must be approved by at least 2/3 of the pool participants and no less than a 2/3 majority of votes cast. Each pool participant has one vote per vessel in the relevant Pool. The Pool Board meets approximately every six months and can hold extraordinary meetings if any pool participant so requests. The Pool Board can decide on all matters relating to the Pool Agreement and can additionally give guidelines to the Pool Manager as to how the Pool Manager shall perform its duties. Certain decisions cannot be taken by the Pool Manager without the prior approval of the Pool Board, including, but not limited to, the committal of a vessel in the Pool on time charters or consecutive voyage charter which will or may at the option of the charterer exceed 12 months (plus 30 days option) or the Pool Manager entering into contracts of affreightment for periods longer than 12 months, any changes to the pool points of a vessel in the Pool, and/or the approval of new pool participants and new pool vessels. The Pool Board is complemented by the relevant Pool Manager, who, as pool manager, represents the Pools in external relations and oversees the day-to-day commercial operation under the authority of the Pool Board. The Pool Manager has the authority to enter into employment and other material agreements for the vessels in the relevant Pool, including forward freight agreements and bunker hedging agreements transactions on behalf of pool participants in accordance with the terms of the relevant Pool Agreement. Additionally, the Pool Manager performs marketing, bunker purchasing, and commercial operation of the vessels in accordance with the terms of the relevant Pool Agreement. Third-party vessels in the Pools The following table presents certain key information with respect to the third-party vessels in the Pools as at December 31, 2025 and does not reflect events such as name changes, ownership changes, and Pool entries which have occurred after December 31, 2025: Pool Vessel name Year Built ​ Capacity (dwt) Pool entry ​ Registered Owner Flag LR2 Pool Eagle Le Havre 2017 109,999 Jul-25 AET Bermuda One Pte. Ltd. Singapore LR2 Pool Eagle Lyon 2017 99,999 Jun-25 AET Bermuda One Pte. Ltd Singapore LR2 Pool Norddolphin(1) 2017 113,955 Sep-22 MT Norddolphin Shipping Management B.V. Portugal LR2 Pool Nordmarlin 2017 113,959 Nov-22 MT Nordmarlin Shipping Management B.V. Portugal Panamax Pool Advantage Pioneer 2011 74,552 Nov-24 Syntrend Limited Marshall Islands Panamax Pool Amazon Falcon(1) 2017 72,202 May-24 Meridian Marine Co. Ltd. Greece Panamax Pool Hafnia Shinano 2008 74,998 Aug-24 BW Aldrich Pte. Ltd. Singapore Panamax Pool Hafnia Yangtze(1) 2009 74,996 Nov-24 BW Aldrich Pte. Ltd. Singapore Panamax Pool Jag Aanchal 2008 74,811 Jul-25 The Great Eastern Shipping Co. Ltd. India LR1 Pool Jag Amisha 2009 74,889 Apr-25 The Great Eastern Shipping Co. Ltd. India 56 Table of Contents LR1 Pool Bluebird 2016 64,994 Feb-17 Larine Tankers Pte. Ltd. Singapore LR1 Pool Kamome Victoria 2011 74,908 Nov-24 Shintoku Panama S.A. Panama LR1 Pool Starling 2016 74,033 Feb-17 Larine Tankers Pte. Ltd. Singapore MR Pool Aegean Star 2019 44,999 Jun-19 Saltini Shipping Corporation Marshall Islands MR Pool Allied Atlantic 2018 49,995 Oct-25 Fed Ship III LLC Marshall Islands MR Pool Alpine Marina 2010 46,162 Jul-23 Tornado Navigation Inc. Marshall Islands MR Pool Angel Star 2006 48,635 Dec-21 Selitsa Shipping Corporation Marshall Islands MR Pool Atalanta T 2010 44,999 Jul-24 Atalanta Tankers Ltd Marshall Islands MR Pool Atlantic Infinity 2017 49,999 Jan-25 Mothallah Corp Marshall Islands MR Pool Atlantic Rainbow 2024 49,999 Oct-25 Brilliant Aria Corporation Marshall Islands MR Pool Atlantic Rosa 2025 49,999 Feb-25 Brilliant Crescendo Corporation Marshall Islands MR Pool Atlantic Sunflower 2025 49,999 Apr-25 Brilliant Etude Corporation Marshall Islands MR Pool Atlantic Sunshine 2025 49,954 Jan-25 Brilliant Bolero Corporation Marshall Islands MR Pool Bantry Bay 2023 49,999 Dec-23 AL Tanker I Shipping Pte. Ltd. Singapore MR Pool Cape Bilbao 2025 49,998 Jul-25 Cape Bilbao Navigation Limited Marshall Islands MR Pool Cepolis 2011 48,020 Dec-25 Clymene Shipping Limited Malta MR Pool Chios Star 2018 49,999 Mar-19 Lousios Shipping Corporation Marshall Islands MR Pool CMC Ancud 2014 49,990 Dec-24 MS CMC ANCUD GmbH & Co. KG Liberia MR Pool Flora Maris 2008 39,772 Nov-24 Flora Maris Shipping Inc Panama Panama MR Pool Grand Ace6 2007 46,192 Jun-25 Pos Maritime WD S.A. Panama MR Pool Ionian Star 2019 49,999 Mar-19 Yliki Shipping Corporation Marshall Islands MR Pool Jag Parth 2008 46,917 Nov-23 The Great Eastern Shipping Co. Ltd. India MR Pool Jag Prachi 2013 51,486 Aug-24 The Great Eastern Shipping Co. Ltd. India MR Pool Jag Priya 2010 49,999 Aug-24 The Great Eastern Shipping Co. Ltd. Marshall Islands MR Pool Jag Priyanka 2013 49,990 Sep-24 The Great Eastern Shipping Co. Ltd. India MR Pool Jag Punit 2016 49,717 Jun-22 The Great Eastern Shipping Co. Ltd. India MR Pool Lysias 2008 49,999 Jun-17 Lysias Maritime S.A. Malta MR Pool MP MR Tanker 1 2011 49,999 Apr-21 M Pallonji Shipping Singapore Pte. Ltd. Singapore MR Pool MP MR Tanker 2 2010 50,090 Nov-24 M Pallonji Shipping Singapore Pte. Ltd. Singapore MR Pool MP MR Tanker 3 2010 47,962 Sep-24 M Pallonji Shipping Pvt Ltd India MR Pool Oinoussian Star 2018 49,999 Feb-20 Louros Shipping Corporation Marshall Islands MR Pool OKEE Ulf(1) 2006 49,999 Nov-22 OKEE Ship Twelve GmbH & Co. KG Liberia MR Pool Philoxenia 2019 49,999 Sep-24 Formica Navigation Ltd. Marshall Islands MR Pool Rich Rainbow 2021 49,997 Nov-23 Rich Ocean Shipping Inc. Panama Handy Pool Bagheera(1) 2014 39,999 Oct-24 Vulcan Navigation Ltd Marshall Islands Handy Pool Prelude 2007 39,988 Sep-25 Verda Enterprises Company Liberia Handy Pool VS Leia 2006 38,461 Mar-19 Valloeby Leia Limited Isle of Man Handy Pool VS Lisbeth(1) 2006 38,492 Apr-18 Valloeby Lisbeth Limited Isle of Man Handy Pool VS Remlin 2003 34,530 Dec-21 Valloeby Remlin Limited Isle of Man Handy Pool VS Spirit 2007 34,671 Mar-20 Valloeby Spirit Limited Isle of Man Chemical-Handy Pool Chemtrans Mobile 2016 37,596 May-25 Chemtrans Mobile AS Marshall Islands Specialised Pool Amur Star 2010 13,019 Aug-20 Valloeby Amur Star Ltd. Malta Specialised Pool Colorado Star 2010 13,019 Aug-20 Valloeby Colorado Star Ltd. Malta Specialised Pool Ganges Star 2010 13,013 Aug-20 Valloeby Ganges Star Ltd. Malta Specialised Pool Kongo Star 2010 13,011 Aug-20 Valloeby Kongo Star Ltd. Malta Specialised Pool Lamentin 2007 11,320 Dec-20 Valloeby Lamentin Ltd. Malta Specialised Pool Lascaux 2007 11,674 Apr-22 Valloeby Lascaux Ltd. Malta Specialised Pool Mississippi Star 2010 13,054 Aug-20 Valloeby Mississippi Star Ltd. Malta Specialised Pool Murray Star 2011 13,006 Aug-20 Valloeby Murray Star Ltd. Malta Specialised Pool Pechora Star 2011 13,021 Aug-20 Valloeby Pechora Star Ltd. Malta Specialised Pool Shannon Star 2010 13,023 Aug-20 Valloeby Shannon Star Ltd. Malta Total 61 Pool Vessels 3,004,054 (1) This vessel has been redelivered from the Pools. Commercial Management From time to time we will, in addition to commercial management of third-party vessels through the Pools, perform commercial management of third-party vessels outside of the Pools. As at December 31, 2025, we commercially managed two third-party vessels in addition to the Pool Vessels. Commercial management of third-party vessels is typically only used when the vessels in question need employment for a limited period of time, for example, between other employment types or before being delivered to new owners. Because the period of commercial management is short, it is generally not practicable to place the vessel in a Pool as this involves a much more intensive and time consuming process, whereas it is much easier to establish a commercial management structure for a single vessel. On occasion, we may also use the commercial management structure to test-employ tonnage which may be a candidate for entering a Pool, but where we want to satisfy ourselves that the vessel in question is able to trade properly in the market before recommending it for pool entry. 57 Table of Contents When vessels are commercially managed by us, we act as agents to the vessel’s owner (registered owner or disponent owner, as the case may be), not as principals. Owners are responsible for providing the required working capital to us, so we have no outlays for vessel related expenses from our accounts. Commercial trading of the Combined Fleet Vessels are employed in the market through a number of different commercial arrangements. The general terms normally found in these types of contracts are described below. • Voyage charters in the spot market. The spot market generally refers to the segment of the market where vessels are employed for a single voyage. A vessel earns income from each individual voyage and the owner pays the voyage expenses, including bunker and port costs. Spot market pricing, which can be volatile, is influenced by a number of factors, including the number of competing vessels, the number of cargoes available, oil pricing and arbitrage, worldwide events, and weather. Idle time between voyages is possible depending on the availability of cargo and the positioning of the vessel. Under a spot market voyage charter, the vessel owner pays for both the voyage expenses (less specified amounts covered by the contract) and vessel operating costs. • Time charter. Under a time charter, a vessel is chartered to customers for a fixed period of time at rates that are generally fixed, but may contain a variable component based on inflation, interest rates or changes in current market rates. Under a time charter, the owner operates the vessel and is responsible for crewing and arranging for technical management for the vessel. The owner also bears other operating expenses, such as repairs and maintenance, insurance, stores, lube oil, communications expenses and technical management fees, whereas the charterer bears voyage expenses such as port costs and bunkers. • Contract of affreightment (“COA”). A COA is a contract for the carriage of a specific volume of cargo with multiple voyages over the same route and over a specified period of time which can span a number of years but in most cases runs for 12 months. A COA does not designate the specific vessel or voyage schedules that will transport the cargo, thereby providing both the charterer and the owner greater flexibility than a typical charter alone. The charterer has the flexibility to determine the individual voyage scheduling at a future date and the shipowner may use different vessels to perform the individual voyages. Under this contract arrangement, all of the vessels’ operating, voyage and capital costs are borne by the owner while the freight rate normally is a per-cargo-ton basis with a minimum cargo quantity for every lifting guaranteed by the charterer. • Consecutive voyage contract (“CVC”). Under a CVC, the shipowner provides one vessel for multiple voyages to transport a certain amount of cargo within a specified period covering a specified trade from a fixed place to fixed destinations designated by the customer. All of the vessel’s operating, voyage and capital costs are borne by the owner. The freight rate is normally agreed on a fixed rate basis but can also be floating according to a pre-agreed index. Our chartering department is responsible for the development, marketing and negotiation of the employment contracts for all of the vessels in our Combined Fleet. Contract negotiations are done directly with our clients as well as through shipbrokers, and in most cases a shipbroker will be nominated subsequently when negotiations are done directly with our clients. Our chartering department is also responsible for chartering-in tonnage on spot voyages to cover certain cargo commitments as well as time chartering-in vessels for arbitrage profits derived through offsetting time charter-out contracts on owned tonnage for longer periods. All contracts are negotiated and concluded by our chartering department on behalf of our Pools under instructions and authority from the Pool Board and our Chief Executive Officer in accordance with our internal approval procedures. Time charter-out portfolio As at December 31, 2025, we had 23 Hafnia Vessels and nine JV Vessels trading outside the Pools and entered into time charter contracts with customers for periods longer than six months. In addition, our Ecomar Joint Venture entered into long-term time charters for four newbuild JV Vessels which will commence upon delivery of the vessels. Three of these newbuilds have been delivered to the charterer, Total, on long-term charters and the final vessel, Ecomar Gironde, was delivered in January 2026. 58 Table of Contents The following table presents key information pertaining to the time charter contracts (including options) as at December 31, 2025: Vessel Name ​ Vessel type ​ Year built ​ Charterer ​ Expiry Date ​ Extension option period Hafnia Daisy ​ MR ​ 2016 ​ Valero ​ Nov-26 ​ — Hafnia Lise ​ MR ​ 2016 ​ Valero ​ Oct-26 ​ — Hafnia Myna ​ MR ​ 2015 ​ Petco Trading Labuan Company Ltd ​ Sep-26 ​ — Hafnia Bobcat(1) ​ MR ​ 2013 ​ Petco Trading Labuan Company Ltd ​ Nov-26 ​ — Hafnia Shinano ​ LR1 ​ 2008 ​ Mercuria Shipping Pte Ltd ​ Feb-26 ​ — Hafnia Soya ​ Handy ​ 2015 ​ ST Shipping and Transport Pte Ltd ​ Apr-27 ​ — Hafnia Alabaster Handy 2015 International Shipping and Transportation Company Limited Sep-27 — Hafnia Yangtze ​ LR1 ​ 2009 ​ Mercuria Shipping Pte Ltd ​ Apr-26 ​ — Hafnia Kestrel MR 2015 Orient Oil Express Pte Ltd Jan-26 — Hafnia Merlin MR 2015 Orient Oil Express Pte Ltd Jan-26 — Hafnia Cheetah ​ MR ​ 2014 ​ Orient Oil Express Pte Ltd ​ Feb-26 ​ — Hafnia Crux ​ MR ​ 2012 ​ PMI ​ Jan-26 ​ — Hafnia Falcon ​ MR ​ 2015 ​ BP Australia Pty Ltd ​ Nov-26 ​ — Hafnia Neso LR2 2019 Marathon Maritime Company May-27 — Hafnia Bering Handy 2015 ST Shipping and Transport Pte Ltd Jan-28 — Hafnia Lioness MR 2014 BP Singapore Pte Ltd Aug-26 — Hafnia Cougar MR 2014 Vitol International Shipping Pte. Ltd Aug-26 — Hafnia Tagus LR1 2017 Abu Dhabi Marine International Chartering Rsc Limited Sep-26 — Hafnia Triton LR2 2019 BP Singapore Pte Ltd Oct-28 — Hafnia Petrel MR 2016 BP SHIPPING LTD Oct-27 — Hafnia Thalassa LR2 2019 BP Singapore Pte Ltd Nov-28 — Hafnia Yarra LR1 2017 Abu Dhabi Marine International Chartering Rsc Limited Nov-26 — Hafnia Galatea LR2 2019 BP Singapore Pte Ltd Dec-28 — Hafnia Languedoc ​ LR2 ​ 2023 ​ CSSA ​ Mar-30 ​ 1+1+1 year Hafnia Larvik ​ LR2 ​ 2023 ​ Equinor ​ Oct-28 ​ — Hafnia Lillesand ​ LR2 ​ 2024 ​ Equinor ​ Mar-29 ​ — Hafnia Loire ​ LR2 ​ 2023 ​ CSSA ​ May-30 ​ 1+1+1 year PS Stars ​ MR ​ 2022 ​ Clearlake ​ Jan-27 ​ 1 year Yellow Stars ​ MR ​ 2021 ​ Clearlake ​ Jul-26 ​ 1 year Ecomar Gascogne ​ MR ​ 2025 ​ CSSA ​ Jan-32 ​ 1+1+1 year Ecomar Guyenne ​ MR ​ 2025 ​ CSSA ​ May-32 ​ 1+1+1 year Ecomar Garonne ​ MR ​ 2025 ​ CSSA ​ Jul-32 ​ 1+1+1 year Ecomar Gironde(2) ​ MR ​ 2026 ​ CSSA ​ Jan-33 ​ 1+1+1 year Total 32 vessels ​ ​ ​ ​ ​ (1) In January 2025, Hafnia Puma was replaced by Hafnia Bobcat as Hafnia Puma needed repairs. (2) Ecomar Gironde was delivered to the charterer after it was delivered from the shipyard in January 2026. As at December 31, 2025, we had no Hafnia Vessels or TC Vessels trading inside the Pools on time charter contracts with customers for periods longer than six months. Bareboat and time charter-in portfolio Bareboat charters As at December 31, 2025 we had three vessels bareboat chartered-in, all of which have been entered into in the course of the sale and lease-back financing of our Hafnia Vessels. See “Item 5. Operating and Financial Review and Prospects – B. Liquidity and Capital Resources” for additional information on our financing arrangements. All our sale and lease-back arrangements include annual or monthly purchase options and some also contain purchase obligations upon the expiration of the arrangement. The following table presents key information pertaining to these bareboat charter contracts as at December 31, 2025: Vessel Name ​ Vessel type ​ Year built ​ Owner ​ Expiry Date ​ Extension option period ​ Purchase Option(s) ​ Purchase Obligation Hafnia Africa ​ LR1 ​ 2010 ​ MI-DAS Line S.A. ​ Oct-29 ​ N/A ​ Yes ​ No Hafnia Australia ​ LR1 ​ 2010 ​ Yong Sheng Shipping Pte. Ltd. ​ Dec-29 ​ N/A ​ Yes ​ Yes Hafnia Ammolite ​ Handy ​ 2015 ​ Sea 15 Leasing Co. Ltd. ​ Mar-33 ​ N/A ​ Yes ​ Yes Total 3 Vessels ​ ​ ​ ​ ​ ​ ​ 59 Table of Contents Time charters As at December 31, 2025, we had nine vessels time chartered-in and nine have purchase options. The following table presents key information pertaining to these time charters: Vessel Name ​ Vessel type ​ Year built ​ Owner ​ Expiry Date ​ Extension option period Purchase option Basset ​ MR ​ 2019 ​ Grace Ocean Private Limited ​ Nov-26 ​ 1 year ​ Yes Beagle ​ MR ​ 2019 ​ Sun Lanes Shipping S.A. ​ Mar-27 ​ - ​ Yes Boxer ​ MR ​ 2019 ​ Grace Ocean Private Limited ​ Jun-26 ​ 1 year ​ Yes Bulldog ​ MR ​ 2020 ​ Grace Ocean Private Limited ​ Feb-27 ​ 1 year ​ Yes Sunda LR1 2019 Triton Navigation B.V. Jul-26 1 year Yes Karimata ​ LR1 ​ 2019 ​ Triton Navigation B.V. ​ Sep-26 ​ 1 year ​ Yes Orient Challenge ​ MR ​ 2017 ​ OMC Shipping Pte. Ltd. ​ Jul-26 ​ 1 year ​ Yes Orient Innovation ​ MR ​ 2017 ​ OMC Shipping Pte. Ltd. ​ Aug-26 ​ 1 year ​ Yes Hokkaido MR 2025 Sun Lanes Shipping S.A. Oct-30 1+1 years Yes Total 9 vessels Purchase options We have purchase options for a number of our chartered-in vessels. The following table presents an overview of our purchase options by year for our chartered-in vessels in millions of U.S. dollars (excluding purchase option premiums and fees and expenses associated with exercising purchase options). Vessel Name ​ 2026 ​ 2027 ​ 2028 ​ 2029 ​ 2030 ​ 2031 ​ 2032 ​ 2033 ​ 2034 2035 TC Vessels ​ ​ ​ ​ ​ ​ ​ ​ ​ Beagle(1) ​ 31.25 ​ 29.75 ​ — ​ — ​ — ​ — ​ — ​ — ​ — — Basset(1) ​ 31.25 ​ 29.75 ​ — ​ — ​ — ​ — ​ — ​ — ​ — — Boxer(1) ​ 31.25 ​ 29.75 ​ — ​ — ​ — ​ — ​ — ​ — ​ — — Bulldog(1) ​ 31.25 ​ 29.75 ​ — ​ — ​ — ​ — ​ — ​ — ​ — — Karimata(1) ​ 38.00 ​ 36.00 ​ — ​ — ​ — ​ — ​ — ​ — ​ — — Orient Challenge(1) ​ 23.90 ​ 22.30 ​ — ​ — ​ — ​ — ​ — ​ — ​ — — Orient Innovation(1) ​ 23.90 ​ 22.30 ​ — ​ — ​ — ​ — ​ — ​ — ​ — — Sunda(1) ​ 38.00 ​ 36.00 ​ — ​ — ​ — ​ — ​ — ​ — ​ — — Hokkaido(1) — — — 48.00 46.40 44.80 43.20 — ​ — — Sale and lease-back vessels(2) ​ ​ ​ ​ ​ ​ ​ ​ Hafnia Africa ​ 9.60 ​ 8.00 ​ 5.50 ​ 3.00 ​ — ​ — ​ — ​ — ​ — — Hafnia Ammolite(3) ​ 15.1-13.86 ​ 13.74-12.44 ​ 12.31-10.94 ​ 10.82-9.38 ​ 9.24-7.73 ​ 7.59-6.00 ​ 5.86-4.19 ​ 4.03-3.72 ​ — — Hafnia Australia ​ 10.90 ​ 8.90 ​ 6.35 ​ — ​ — ​ — ​ — ​ — ​ — — (1) The purchase option price set out in the table above for the respective vessel is based on the applicable price stipulated in the time charter on the applicable delivery anniversary date. If the vessel is repurchased in between delivery anniversary dates, the purchase option price will be reduced on a pro rata basis. (2) The table includes vessels chartered in as at December 31, 2025 (3) These vessels have purchase options based on the outstanding principal which reduces monthly. The above listed purchase option prices are the purchase options in January and December of the year. Purchase obligations A number of the charters under which we charter in our vessels contain purchase obligations according to which we are obligated to purchase the vessel upon the expiration of the charter (excluding fees and expenses associated with exercising purchase obligations). 60 Table of Contents Set out below is an overview of our purchase obligations for our chartered-in vessels as at December 31, 2025, in millions of U.S. dollars. Vessel Name(1) ​ 2026 ​ 2027 ​ 2028 ​ 2029 ​ 2030 ​ 2031 ​ 2032 ​ 2033 ​ 2034 2035 Hafnia Australia ​ — ​ — ​ — ​ 4.20 ​ — ​ — ​ — ​ — ​ — — Hafnia Ammolite ​ — ​ — ​ — ​ — ​ — ​ — ​ — ​ 3.72 ​ — — Environmental and Other Regulations in the Shipping Industry Our business and the operation of our Combined Fleet are subject to various international treaties and conventions and to the applicable local, national, and subnational laws and regulations of the countries in which the vessels operate or are registered. Such laws and regulations cover a variety of topics, including, but not limited, to air pollution, water pollution, waste management, protection of natural resources, safety and health and environmental protection including storage, handling, emission, transportation and discharge of hazardous and non-hazardous materials. Compliance with such laws, regulations and other requirements may entail significant expense, including vessel modifications and implementation of certain operating procedures. A variety of government and private entities subject the vessels in our Combined Fleet to both scheduled and unscheduled inspections of compliance with these laws and regulations. These entities include the local port authorities (applicable national authorities such as the U.S. Coast Guard (“USCG”), harbour master or equivalent), classification societies, flag state administrations (countries of registry), charterers, and terminal operators. Certain of these entities require us to obtain governmental or quasi-governmental permits, licenses, approvals, certificates, and other authorisations before our Hafnia Vessels and JV Vessels may operate or conduct certain activities. Failure to comply with these requirements or to obtain the necessary business and technical permits, licenses, approvals, and certificates could require us to incur substantial costs or result in sanctions including suspension and/or freezing of the operation of one or more of our Hafnia Vessels and JV Vessels, suspension and/or freezing of our business and responsibility for all damages arising from any violation. For the avoidance of doubt, all the vessels in our Combined Fleet are subject to the aforementioned requirements to obtain relevant permits, licenses, approvals, certifications and other authorisations, not only our Hafnia Vessels and JV Vessels; however, generally we will not be the entity required to obtain such permits, licenses, approvals, certifications and other authorisations for TC Vessels and/or Pool Vessels and/or other vessels where we are the commercial manager or time charterer. Governments and other regulators may periodically revise their environmental laws and regulations and other laws and regulations applicable to our industry and business or adopt new ones, and the effects of new or revised laws and regulations on our operations often cannot be predicted. In particular, as further discussed in this “—Environmental and Other Regulations in the Shipping Industry”, the Trump administration in the United States has moved toward rapid deregulation and withdrawal from numerous international organisations and treaties. Although we believe that the operation of our Hafnia Vessels and JV Vessels is substantially in compliance with applicable environmental laws and regulations and that we have all permits, licenses and certificates required for the operation of our Hafnia Vessels and JV Vessels, future noncompliance or failure to maintain necessary permits or approvals could require us to incur substantial costs or temporarily suspend the operation of one or more of our Hafnia Vessels and JV Vessels. There can be no assurance that additional significant costs and liabilities will not be required to 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 our operations, including, but not limited to, any new or inconsistent laws and regulations relating to climate change. In addition, even without such new or inconsistent regulations, our business may be indirectly affected to the extent that climate change results in sea level changes or more intense weather events. New laws and regulations may also apply to our customers, including oil and gas exploration and production companies, which may impact demand for our services. Compliance with environmental and other regulations applicable to vessels is generally the obligation of the “company” as this term is defined in the ISM Code (defined and described below). The “company” is a vessel’s registered owner unless the responsibility for operation of the vessel has been transferred to another party through a contractual arrangement such as a bareboat charter or a technical management agreement. For our Hafnia Vessels and JV Vessels, the “company” is either our internal technical management entity BW Fleet Management Pte. Ltd. or an external technical manager as described in “Item 4. Information on the Company – B. Business Overview – Technical Management” below. For the TC Vessels and the Pool Vessels, the “company” is either the vessels’ registered owners, a bareboat charterer of a vessel or a technical manager. We do not provide technical management services for vessels owned by third parties; however, we do perform technical management for some of the JV Vessels. Compliance with environmental and other regulations is in some circumstances not the obligation of the “company” and may continue to be the obligation of the registered owner regardless of whether a bareboat charter or technical management agreement has been entered into or be the obligation of the commercial manager or operator of the vessel. 61 Table of Contents International environmental treaties and conventions as well as U.S. environmental laws and regulations that apply to the operation of vessels are described below. Other countries, including member countries of the European Union, in which we operate or in which vessels in our Combined Fleet are registered, have or may in the future have laws and regulations that are similar, or more stringent, in nature to the U.S. laws referenced below. 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 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, e.g., oil leakage and oil spills, garbage management, sewage, air emissions, and handling and disposal of noxious liquids and harmful substances. MARPOL applies to tankers, among other vessels, and is broken into six Annexes, each of which regulates a different source of pollution. Additionally, IMO has adopted SOLAS, which is intended to specify minimum standards for the construction, equipment, and operations of ships, compatible with their safety. An important entity within IMO is the MEPC, which is the entity addressing environmental issues under IMO. MEPC holds two sessions a year and a reference to, for example, MEPC 83, is a reference to MEPC’s 83rd session. Water Pollution International The IMO and other international bodies have implemented various strategies, measures, codes, conventions, and other initiatives relating to water pollution which have an effect on our industry, including, but not limited to, the following: a. International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk Bulk carriage of chemicals is covered by regulations in Chapter VII of SOLAS (Carriage of Dangerous Goods) and Annex II of MARPOL (Regulations for the Control of Pollution by Noxious Liquid Substances in Bulk). Both SOLAS and MARPOL require chemical tankers constructed after July 1, 1986 to comply with the International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk (as amended, the “IBC Code”). The IBC Code provides international standards for the transportation in bulk by sea of dangerous chemicals and noxious liquid substances, including by prescribing design and construction standards of ships and their equipment, and also covers marine pollution aspects. Ships subject to the IBC Code are designed to one of three standards: type 1, type 2 or type 3, where type 1 prescribes the strictest requirements and type 2 and type 3 prescribe progressively less strict requirements. Additionally, under the IBC Code, those of our vessels carrying chemicals are required to obtain a certificate of fitness for the carriage of dangerous chemicals in bulk. All of our Hafnia Vessels and JV Vessels requiring a certificate under the IBC Code have obtained such a certificate. b. International Convention on Civil Liability for Oil Pollution Damage The IMO adopted the International Convention on Civil Liability for Oil Pollution Damage in 1969 (the “CLC”). The CLC was revised subsequently by the protocol of 1976, the protocol of 1984 and the protocol of 1992 (the “1992 Protocol”). The 1992 Protocol widened the scope of the CLC in certain areas. Parties to the 1992 Protocol are no longer parties to the CLC; however, there are a number of states which are party to the CLC, and which have not yet ratified the 1992 Protocol. The CLC governs pollution damage resulting from spills of persistent oils (i) caused by oil ships actually laden with oil or on first voyage after carriage of oil and have oil residues from a previous voyage and, if the 1992 Protocol applies, (ii) caused by ships constructed or adapted for the carriage of oil in bulk as cargo. Under the CLC, a vessel’s registered owner may be strictly liable for oil pollution damage caused in the territory of contracting states, including territorial waters, unless the owner can prove certain specific exceptions apply. The 1992 Protocol extends the applicability of the CLC to damage caused within 200 nautical miles from the coast of the contracting states. The CLC includes specific limitations of liability expressed in the International Monetary Fund currency unit, Special Drawing Rights. The specific limitations vary depending on whether the state where the damage occurred is party to the CLC or the 1992 Protocol. The right to limit liability is forfeited under the CLC where the oil pollution is caused by the owner’s actual fault and, under the 1992 Protocol, where the spill is caused by the owner’s intentional or reckless act or omission where the shipowner knew pollution damage would probably result. The CLC requires ships over 2,000 tons covered by it to maintain insurance or other financial security in sums equivalent to an owner’s total liability for a single incident. We have protection and indemnity insurance for environmental incidents. All of our Hafnia Vessels and JV Vessels are in possession of a state-issued certificate attesting that the required insurance coverage under the CLC and 1992 Protocol is in place. c. International Convention on Civil Liability for Bunker Oil Pollution The International Convention on Civil Liability for Bunker Oil Pollution (the “Bunker Convention”) entered into force on November 21, 2008. The Bunker Convention provides a liability, compensation, and compulsory insurance system for the victims of oil pollution damage caused by spills of bunker oil. The Bunker Convention imposes strict liability on shipowners (including the registered owner, bareboat charterer, manager, or operator) for pollution damage in the territorial waters, including the territorial sea and exclusive economic zones, of a state party caused by the escape or discharge of bunker fuel. 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, will be 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. All of our Hafnia Vessels and JV Vessels have received “Blue Cards” from their P&I Club and are in possession of a state-issued certificate attesting that the required insurance cover under the Bunker Convention is in place. 62 Table of Contents d. International Convention for the Control and Management of Ships’ Ballast Water and Sediments The International Convention for the Control and Management of Ships’ Ballast Water and Sediments (the “Ballast Water Management Convention”) aims to prevent the spread of harmful aquatic organisms from one region to another, by establishing standards and procedures for the management and control of ships’ ballast water and sediments. The Ballast Water Management Convention’s implementing regulations call for a phased introduction of mandatory ballast water exchange requirements, to be replaced in time with mandatory concentration limits, and require all ships to carry a ballast water record book and an international ballast water management certificate. The Ballast Water Management Convention was ratified in September 2016 and entered into force in September 2017. The IMO has imposed updated guidelines for ballast water management systems specifying the maximum amount of viable organisms allowed to be discharged from a vessel’s ballast water (the so-called D-2 standard) and required all vessels to meet D-2 standard no later than September 8, 2024. Amendments to the Ballast Water Management Convention came into force on June 1, 2022, which included changes to the form of the Ballast Water Management certificate and the rules requiring commissioning testing of ballast water management systems at the ship’s initial survey or during an additional survey for retrofits. This testing is required before the Ballast Water Management certificate for D-2 standard is issued but does not apply to ships that already have a certified ballast water management system installed. During 2025, two additional IMO resolutions came into force specifying a new format for the ballast water record book and mandating approval of electronic ballast water record books. All Hafnia Vessels and JV Vessels have ballast water treatment systems installed and have ballast water management certificates. e. International Convention on Liability and Compensation for Damage in Connection with the Carriage of Hazardous and Noxious Substances by Sea 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 (the “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 enters into force, we could be required to incur additional costs or capital expenses to be compliant. United States The United States has implemented various strategies, measures, laws, regulations, and other initiatives relating to water pollution which have an effect on our industry including, but not limited to, the following: a. Oil Pollution Act and the Comprehensive Environmental Response, Compensation, and Liability Act The U.S. Oil Pollution Act of 1990 (the “OPA”) established an extensive regulatory and liability regime for the protection and cleanup of the environment from oil spills. The 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 U.S. territorial seas and its 200-nautical-mile exclusive economic zone. The Comprehensive Environmental Response, Compensation, and Liability Act (the “CERCLA”) applies to the discharge of hazardous substances whether on land or at sea. These laws may affect us because we carry oil products, petroleum products, chemicals and other liquids, as wells as oil as fuel and lubricants for our engines, and the discharge of these substances could cause an environmental hazard. Under the 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. The OPA defines these damages broadly to include: • injury to, destruction or loss of, or loss of use of, natural resources and related assessment costs; • injury to, or economic losses resulting from, the destruction of real and personal property; • net loss of taxes, royalties, rents, fees, or net profit revenues resulting from injury, destruction, or loss of real or personal property, or natural resources; • loss of subsistence use of natural resources that are injured, destroyed, or lost; • lost profits or impairment of earning capacity due to injury, destruction, or loss of real or personal property or natural resources; and • net cost of increased or additional public services necessitated by removal activities following a discharge of oil, such as protection from fire, safety, or health hazards. 63 Table of Contents The limits of the OPA liability are the greater of $2,500 per gross ton or $21,521,000 for any tanker, other than single-hull tank vessels, over 3,000 gross tons (subject to adjustments for inflation). However, these limits of liability do not apply where the incident is caused by violation of applicable U.S. 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. The 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. In some cases, states, which have enacted their own legislation, have not yet issued implementing regulations defining shipowners’ responsibilities under these laws. The 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 the CERCLA does not include petroleum, crude oil, or any fraction thereof. Liability under the CERCLA is limited to the greater of $300 per gross ton or $0.5 million for each release from vessels not carrying hazardous substances as cargo or residue, and the greater of $300 per gross ton or $5 million for each release from vessels carrying hazardous substances as cargo or residue (subject to adjustments for inflation). As with the OPA, these limits of liability do not apply where the incident is caused by violation of applicable U.S. 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. The OPA and CERCLA each preserve the right to recover damages under existing law, including maritime tort law. We believe that we are in substantial compliance with the OPA, the CERCLA and all applicable state regulations in the ports where our Hafnia Vessels and JV Vessels call. The OPA and CERCLA both require owners and operators of vessels to establish and maintain with the USCG evidence of financial responsibility sufficient to meet the maximum amount of liability to which the particular responsible person may be subject. Vessel owners and operators may satisfy their financial responsibility obligations by providing a proof of insurance, a surety bond, qualification as a self-insurer or a guaranty. 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 the OPA/CERCLA. Each of our ship-owning subsidiaries that has vessels trading in U.S. waters has applied for and obtained from the U.S. Coast Guard National Pollution Funds Center three-year certificates of financial responsibility (“COFRs”), supported by guarantees purchased from an insurance-based provider. As at the date of this Annual Report, all Hafnia Vessels and JV Vessels have a COFR from the U.S. Coast Guard National Pollution Funds Center. b. Clean Water Act The U.S. Clean Water Act (the “CWA”) prohibits the discharge of oil, hazardous substances and ballast water in U.S. 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 the OPA and CERCLA. In addition, many U.S. 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 U.S. federal law. c. Vessel General Permit for Discharges Incidental to the Normal Operation of Vessels and Vessel Incidental Discharge Act The U.S. Environmental Protection Agency (the “EPA”) regulates the discharge of ballast and bilge water and other substances in U.S. 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 U.S. 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 authorising discharges incidental to operations of commercial vessels and contains ballast water discharge limits for most vessels to reduce the risk of invasive species in U.S. waters, more stringent requirements for exhaust gas scrubbers and the use of environmentally acceptable lubricants. In December 2018, the Vessel Incidental Discharge Act (“VIDA”) was signed into law and restructured the EPA and the USCG programs for regulating incidental discharges from vessels. Rather than requiring CWA permits, the discharges will be regulated under a new CWA Section 312(p) establishing Uniform National Standards for Discharges Incidental to Normal Operation of Vessels. 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. 64 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. The 2013 VGP was scheduled to expire in December 2018; however, under VIDA, the provisions of the 2013 VGP will remain in place until the new EPA and USCG regulations are in place, which remain outstanding. Pursuant to the requirements in the VGP, vessel owners and operators must meet twenty-five sets of state-specific requirements as the CWA’s 401 certification process allows tribes and states to impose their own requirements for vessels operating within their waters. 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. d. National Invasive Species Act The USCG regulations adopted under the U.S. 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 as-yet unapproved technology. In May 2016, the USCG published a review of the practicability of implementing a more stringent ballast water discharge standard. The results concluded that technology to achieve a significant improvement in ballast water treatment efficacy could not be practically implemented. In February 2016, the USCG issued a new rule amending the Coast Guard’s ballast water management record-keeping requirements. Effective February 22, 2016, vessels with ballast tanks operating exclusively on voyages between ports or places within a single Captain of the Port zone (an area under the command of an individual Coast Guard officer designated by the Coast Guard Commandant to enforce the relevant regulations and policies in such area), were required to submit an annual report of their ballast water management practices. Further, under the amended requirements, 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. European Union In October 2009, the European Union 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 increased civil liability claims. During 2024, the European Council adopted four directives relating to ‘maritime safety’ including directives on investigations of accidents, ship-source pollution, compliance with flag state requirements and port state control. These directives were aimed at aligning EU rules with international standards and enhancing cooperation between European and national authorities. These directives, as adopted by the EU member states, may have an effect on our business, for example if there is pollution from our Hafnia Vessels within the territory of an EU member state. Anti-Fouling AFS Convention 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. Our Hafnia Vessels and JV Vessels are subject to the IMO’s International Convention on the Control of Harmful Anti-fouling Systems on Ships (the “AFS Convention”) which prohibits the use of organotin compound coatings in anti-fouling systems. Vessels of over 400 gross tons engaged in international voyages must obtain an International Anti-fouling System Certificate (“IAFS Certificate”) and undergo an initial survey before the vessel is put into service or when the anti-fouling systems are altered or replaced. The AFS Convention was amended in June 2021 to prohibit anti-fouling systems containing cybutryne. Effective January 1, 2023, ships could not apply or re-apply anti-fouling systems containing cybutryne. For ships already bearing an anti-fouling system containing cybutryne, the amendments have effect from the next scheduled renewal of the anti-fouling system after January 1, 2023 but no later than 60 months following the last application to the ship of the anti-fouling system containing cybutryne. Ships bearing an anti-fouling system containing cybutryne shall within this timeframe either remove the anti-fouling system or apply a coating that forms a barrier to the cybutryne leaching from the underlying noncompliant anti-fouling systems. In addition, the IAFS Certificate has been updated to address compliance with the cybutryne restrictions. Ships in operation will need to comply within the first anti-fouling renewal survey and must receive an updated IAFS Certificate no later than January 1, 2025. Ships which are not affected (i.e., with anti-fouling systems which do not contain cybutryne) must receive an updated IAFS Certificate at the next anti-fouling application to the vessel. 65 Table of Contents We have obtained IAFS Certificates for all of our Hafnia Vessels and JV Vessels. Biofouling In 2023, the IMO’s Maritime Environmental Protection Committee adopted revised guidelines for the control and management of ships’ biofouling to minimise the transfer of invasive aquatic species to reduce the threat posed by invasive aquatic species through biofouling on vessels to the well-being of the sea and to improve the vessel’s hydrodynamic performance. Biofouling management practices enhance energy efficiency and reduce greenhouse gas emissions from vessels due to lower fuel demand in operation as a result of a clean hull. The 2023 guidelines focus 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”). Biofouling inspection frequency or inspection dates (or date ranges) for in-water inspections by competent organisations, crew or personnel should 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 update the BMFP and biofouling management record book. For vessels without performance monitoring, the first inspection date should be within 12 months of AFS application, reapplication, installation or renewal. Where monitoring indicates that the AFS is not performing effectively soon after application, reapplication, installation or renewal, an inspection should be conducted as soon as practical or possible, in line with the BFMP and contingency action plan. If adequate performance of the AFS is observed through monitoring, the inspection could be conducted up to 18 months after AFS application, reapplication, installation or renewal, noting that such monitoring may not reflect the level of biofouling in all niche areas. Subsequent inspections should occur at least every 12 to 18 months with increased frequency for ageing or damaged AFS. In-water inspections should seek to coincide with existing subsea operations where possible. If no AFS is installed in areas of a ship and no other measures are undertaken such as in-water cleaning or propeller polishing, then inspections should occur more frequently. A biofouling rating based on the type and extent of biofouling as well as the condition of the AFS and the functioning of any MGPS will be determined by each biofouling inspection. The determined rating scale provides a recommendation on the type of cleaning that should take place should biofouling of a certain rating be present. For example, a fouling rating of zero is given when there is no fouling. A fouling rating of one is given where submerged areas are partially or entirely covered in microfouling, where metal and painted surface may be visible beneath the fouling. A number of different fouling ratings are defined from light macrofouling (presence of microfouling and multiple macrofouling patches) all the way through to heavy macrofouling (large patches or submerged areas entirely covered in macrofouling). If the AFS is significantly deteriorated, drydocking with maintenance and reapplication of the AFS is recommended. We have developed a BFMP which is in place on board our Hafnia Vessels and JV Vessels. We measure hull performance daily and run full performance evaluations weekly. Based on the weekly analyses, we initiate inspections to verify the cause of AFS deterioration where such is observed and if the AFS is negatively affected, we effect the necessary rectifications. Air Pollution and Greenhouse Gasses International The IMO and other international bodies have implemented various strategies, measures, codes, conventions and other initiatives relating to air emissions and greenhouse gasses which have an effect on our industry including, but not limited to, the following: a. Air Pollution MARPOL 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, incineration of specific substances, and prohibits deliberate emissions of ozone depleting substances. 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. The certification requirements for Annex VI depend on size of the vessel and time of the periodic classification survey. Ships weighing more than 400 gross tons and engaged in international voyages involving countries that have ratified the conventions, or vessels flying the flag of those countries, are required to have an International Air Pollution Certificate (“IAPP Certificate”). Annex VI came into force in the United States on January 8, 2009. All our Hafnia Vessels and JV Vessels have been issued IAPP Certificates. From January 1, 2020, an upper limit of sulphur 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 low sulphur fuel oil (VLSFO) or marine gas oil (MGO), by installing exhaust gas cleaning systems (scrubbers), or by using alternative fuels with low or zero sulphur contents such as liquified natural gas or biofuels. In certain areas, so called emission control areas (“SOx ECAs”), the upper limit of sulphur content is reduced to 0.1%. SOx ECAs include certain coastal areas of North America, the U.S. Caribbean Sea, the Baltic Sea, the North Sea and the Mediterranean Sea and from March 1, 2027 the Canadian Arctic and Norwegian Sea will become SOx ECAs. It was expected that regulations designating areas in the North-East Atlantic as a SOx ECA would be adopted by MEPC in October 2025, but as MEPC ES.2 was postponed, there is currently no fixed timeline for the adoption of the North-East Atlantic SOx ECA to take effect. 66 Table of Contents In addition to requirements relating to the sulphur content of ship’s fuel oil, the IMO have adopted amendments to MARPOL Annex VI stipulating limits from the nitrogen oxide (NOx) emissions from ship’s engines. The NOx limits were split into different tiers, with tier III, the most restrictive tier, only applying in NOx emission control areas (“NOx ECAs”). Currently, areas in the North American and United States Caribbean, North Sea, Baltic Sea, Canadian Arctic and Norwegian Sea are NOx ECAs. It was expected that regulations designating areas in the North-East Atlantic as a NOx ECA would be adopted by MEPC in October 2025, but as MEPC ES.2 was postponed, there is currently no fixed timeline for the adoption of the North-East Atlantic NOx ECA to take effect. All our Hafnia Vessels and JV Vessels are in compliance with IMO NOx regulations. Additionally, MEPC 77 adopted a non-binding resolution which urges 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. With effect from July 1, 2024, the use or carrying for use of heavy fuel oil (HFO) in Arctic waters is with narrow exceptions prohibited under MARPOL Annex I. Some of our Hafnia Vessels have exhaust gas cleaning systems (scrubbers) installed. We comply with sulphur requirements by using compliant fuels for the vessels in our Hafnia Fleet. b. Greenhouse Gasses | EEDI, EEXI, SEEMP, CII IMO has introduced measures to reduce emissions of GHGs, including the so-called EEDI, EEXI, SEEMP & CII-frameworks which are described in further detail below. We may incur costs to comply with these standards. Existing rules and standards may be amended or additional or new conventions, laws and regulations may be adopted that could require the installation of expensive emission control systems and could adversely affect our business, results of operations, cash flows and financial condition. At the MEPC 83, the IMO has extended the CII measure to cover the years 2027-2030. The IMO is in the process of reviewing the EEDI/EEXI measures. The amended measures could be more burdensome on our business and operations than the current measures. i. EEDI & EEXI EEXI (Energy Efficiency eXisting ship Index) is a framework introduced by the IMO for determining energy efficiency and CO2 emissions from the vessel’s operations based on its design parameters. From January 1, 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 EEDI (Energy Efficiency Design Index) which has been in force since 2013. EEDI applies to newbuilds while EEXI applies to existing vessels. All of our Hafnia Vessels and JV Vessels are subject to the EEXI framework. Many of our Hafnia Vessels and JV Vessels were designed to fall below the minimum standard. For the remaining vessels, we have taken steps, including implementing engine and shaft power limitation devices, to ensure compliance with the EEXI regulation by each individual vessel’s compliance date. As at December 31, 2025, all Hafnia Vessels and JV Vessels are, as applicable, in compliance with EEDI or EEXI certification. ii. SEEMP As of January 1, 2013, certain measures relating to energy efficiency for ships were made mandatory under MARPOL. All ships above 400 gross tonnage became required to develop and implement a Ship Energy Efficiency Management Plan (“SEEMP”). A SEEMP is split into three different parts, each of which includes different requirements on vessel owners and vessel operators. • SEEMP Part I requires all ships of 400 gross tonnage and above to retain a ship-specific Ship Energy Efficiency Management Plan on board. The purpose of SEEMP Part I is to establish a mechanism for a company and/or a ship to improve energy efficiency and reduce carbon intensity. This plan is not subject to confirmation or verification. • SEEMP Part II requires ships of 5,000 gross tonnage and above engaging in international voyages to collect and report their fuel oil consumption data to their flag administration or an organisation authorised by the flag administration. The ships subject to this requirement must develop a ship fuel oil consumption data collection plan which should be confirmed by either their flag administration or an organisation authorised by the flag administration. 67 Table of Contents • SEEMP Part III applies to vessels subject to the below-described CII requirements. From January 1, 2023, all vessels subject to the CII ratings requirements are required to develop a Ship Operational Carbon Intensity Plan (known as “SEEMP Part III”) which must include certain information, including (i) the CII calculation methodology, (ii) required CII values for the next three years, (iii) an implementation plan to achieve the required CII value, and (iv) procedures for self-evaluation and improvement. Additionally, if a vessel has a CII ‘E’ rating for any year or a ‘D’ rating for three consecutive years, it must develop a corrective action plan in the SEEMP Part III. The SEEMP Part III must be verified by the flag administration or an organisation authorised by the flag administration. As at December 31, 2025, all Hafnia Vessels and JV Vessels were in compliance with the SEEMP Part I, Part II and Part III requirements. iii. CII Carbon Intensity Indicator (“CII”) is a rating scheme developed by the IMO. According to CII, vessels over 5,000 GT must quantify and report their carbon emissions from ongoing operations. CII determines the annual reduction factor needed to continuously 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. The rating indicates a performance level which is major superior, minor superior, moderate, minor inferior or inferior. The assessment of CII takes place annually. 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 at December 31, 2025, all Hafnia Vessels and JV Vessels were in compliance with the CII requirements. However, six vessels are rated D and one vessel is rated E. Where required, we have put in place corrective action plans. c. Greenhouse Gasses | Global Fuel Standard In April 2025, MEPC 83 approved amendments to MARPOL Annex VI (Chapter 5 “Regulations on the IMO net-zero framework”) containing mid-term measures to reduce GHG emissions of shipping. These amendments require formal adoption before coming into effect. The amendments were initially scheduled for adoption at MEPC ES.2 in October 2025. However, MEPC ES.2 was postponed by 12 months and it is currently uncertain whether these amendments will be adopted by MEPC and if adopted, when they will come into force. If adopted in the form approved by MEPC 83, the mid-term measures would introduce a global GHG fuel intensity (GFI) ‘standard’ (the “GFS”) that vessels must comply with. The GFS would decrease over time, thereby requiring gradual reduction of a vessel’s annual GFI and would apply to ships of 5,000 GT and above with certain vessels being excluded from the scope. The GFS would provide for a base tier GFI target (the “Base Target”) as well as a second tier GFI target (the “Direct Compliance Target”). The assessment of compliance would be undertaken by comparing the Direct Compliance Target with the vessel’s annual attained GFI. Where a vessel achieves a positive compliance balance (due to its attained annual GFI being less than the Direct Compliance Target), it would be considered compliant. Where a vessel achieved a negative compliance balance (due to the attained GFI being greater than the Direct Compliance Target), it would need to balance the negative compliance balance. A vessel which over-complies with the GFS would receive ‘surplus units’, which could be transferred to other vessels, banked for later use or cancelled. A vessel with an attained GFI between the Direct Compliance Target and the Base Target would need to balance a ‘tier 1’ deficit, while a vessel exceeding the Base Target would need to balance ‘tier 1’ and ‘tier 2’ deficits. ‘Tier 1’ deficits can only be balanced through the purchase of ‘tier 1’ remedial units whereas ‘tier 2’ deficits may be balanced by the use of banked surplus units, receipt of surplus units from other vessels and purchase of ‘tier 2’ remedial units. United States The United States has implemented various strategies, measures, laws, regulations and other initiatives relating to air emissions and greenhouse gasses which have an effect on our industry including, but not limited to, the following: a. Clean Air Act The U.S. Clean Air Act of 1970 (including its amendments of 1977 and 1990) (the “CAA”) requires the EPA to promulgate standards applicable to emissions of volatile organic compounds and other air contaminants. Our Hafnia Vessels and JV Vessels are 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 U.S. waters. The marine diesel engine emission standards are currently limited to new engines beginning with the 2004 model year. On April 30, 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. However, in October 2020, the EPA published a final rule to provide additional lead time for implementation for certain high-speed vessels. Pursuant to the final rule, the Tier 4 standards apply from model year 2022 for engines installed in a wide range of high-speed vessels, and from model year 2024 for engines installed in certain other such vessels, subject to certain limitations. Separately, in December 2019, the EPA published a final rule concerning national diesel fuel regulations that will 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. Compliance with these standards may cause us to incur costs to install control equipment on our Hafnia Vessels and JV Vessels in the future. 68 Table of Contents b. Greenhouse Gasses In 2009 the EPA issued a finding that GHGs endanger public health and safety (the “2009 EPA GHG Endangerment Finding”) and accordingly adopted regulations that regulate the emission of GHGs from certain sources. For example, fossil fuel companies to whom we provide services were subject to regulations by various government agencies, which may include the EPA and bodies within the Department of the Interior. These regulations may include restrictions on certain oil & gas production or stimulation techniques, requirements for the installation and use of certain emissions control technologies, and other regulations that may adversely impact the operations of our customers, which may ultimately reduce demand for our services. Regarding our own operations, the EPA has historically enforced both the CAA and 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 greenhouse gas emissions may follow, including climate change initiatives that have been considered in the U.S. Congress. By an executive order signed on January 20, 2025, the United States began the process of withdrawing from the Paris Agreement which finalised on January 27, 2026. The impact of such withdrawal is yet to be known. Further, in February 2026, the Trump administration revoked the 2009 EPA GHG 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 EPA GHG Endangerment Finding, arguing that the EPA is legally required to limit such emissions. The outcome of these legal challenges is uncertain. and the extent of the EPA’s enforcement of the CAA and the international standards found in Annex VI of MARPOL is unclear as of the date of this Annual Report. European Union The European Union has implemented various strategies, measures, directives, regulations and other initiatives relating to air emissions and greenhouse gasses which have an effect on our industry including, but not limited to, the following: a. EU Regulation on monitoring, reporting and verification of carbon dioxide (CO2) emissions On April 29, 2015, Regulation (EU) 2015/757 of the European Parliament and of the EU Council on the monitoring, reporting and verification of carbon dioxide emissions from maritime transport and amending Directive 2009/16/EC (“EU MRV”) 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 of vessels over 5,000 gross tons to monitor emissions for each ship on a per-voyage and annual basis from January 1, 2018. Further, from 2019, all ships above 5,000 gross tons, regardless of flag state, calling at EU ports must submit a verified emissions report to the European Commission and the vessel’s flag state by April 30 of each year, and by June 30 of each year vessels must carry a valid document of compliance confirming compliance with Regulation (EU) 2015/757 for the prior reporting period. b. EU Emissions Trading System From January 1, 2024, the EU Emissions Trading System (“EU ETS”) has been extended to cover emissions from ships of 5,000 gross tonnage and above entering EU ports, 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 will be required to submit 1 EU allowance (“EUA”) for each ton of CO2 (or CO2-equivalent) they emit. EUAs are financial instruments which can be purchased at auctions (primary market), OTC exchanges (secondary market) or on a direct, bilateral basis. The EU ETS covers 50% of emission from voyages starting or ending outside the European Union and 100% of emissions that occur between two EU ports and when ships are within EU ports. The EU ETS currently applies to CO2-emissions and will extend to methane (CH4) and nitrous oxide (N2O) from 2026. The EU ETS is gradually phased in and as such, shipping companies were obligated to surrender EUAs in 2025 for 40% of their emissions reported in 2024, and will in 2026 be required to surrender EUAs 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 from a vessel’s registered owner to a bareboat charterer or a technical manager. 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. Additionally, if a shipping company is noncompliant for at least two consecutive years, vessels with an EU flag state may be detained and vessels may be prohibited from entering EU member states other than their flag state (if the flag state is an EU member state). The sanctions are based on the shipping company and not the specific vessels. 69 Table of Contents In 2025, all of our Hafnia Vessels surrendered EUAs for their emissions in 2024 in accordance with the EU ETS. c. FuelEU Maritime Regulation On January 1, 2025, Regulation (EU) 2023/1805 of the European Parliament and of the Council of September 13, 2023 on the use of renewable and low-carbon fuels in maritime transport, and amending Directive 2009/15/EC (“FuelEU”) came into effect. FuelEU sets out uniform rules (i) imposing a limit on the GHG intensity of energy used on board a ship arriving at, staying within, or departing from ports of an EU member state and (ii) an obligation for passenger ships and container ships to use on-shore power supply (OPS) or zero-emission technology in ports of an EU member state. FuelEU applies to ships of 5,000 gross tonnage and above, regardless of their flag state. FuelEU sets out a progressively decreasing maximum yearly average GHG intensity of the energy used on board a ship during the reporting period. The GHGs within the scope of FuelEU are carbon dioxide (CO2), methane (CH4) and nitrous oxide (N2O). The GHG energy intensity requirements in FuelEU will apply to 100% of energy used for voyages between two European Union ports of call and 100% of energy used while a vessel stays in a European Union port of call and to 50% of energy used for voyages between a European Union port of call and a destination outside the European Union and to 50% of the energy used for voyages to or from the outermost regions of the European Union. For container vessels, FuelEU will additionally apply to voyages to and from certain transshipment ports near the European Union. Shipping companies must submit a standardised emissions monitoring plan for each of their vessels and must collect information in accordance with this monitoring plan. Shipping companies must thereafter submit the relevant information to a verifier and a compliance database to be established by the European Union. Subject to certain restrictions, shipping companies can “bank” or borrow compliance surplus between reporting periods or pool compliance between multiple vessels, including pooling compliance with vessels controlled by another company. Alternatively, the shipping company must pay a FuelEU penalty in respect of the ship. Each year, following banking, borrowing and pooling of compliance and, as applicable, payment of FuelEU Penalty, 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. A ship that is noncompliant with FuelEU for two or more consecutive years may be issued an expulsion order. It is expected that FuelEU will be extended to apply to Norway and Iceland, but no specific date has been set for this extension. As at the date of this Annual Report, FuelEU documents of compliance for the 2025 calendar year have not yet been issued by the verifiers of our Hafnia Vessels, but we have made plans for complying with FuelEU for all Hafnia Vessels within the scope of FuelEU and expect to receive a FuelEU document of compliance for all these vessels. d. Directive (EU) 2016/802 of the European Parliament and of the Council of May 11, 2016 relating to a reduction in the sulphur content of certain liquid fuels (codification) The European Union has adopted regulations requiring vessels to use reduced sulphur content fuel for their main and auxiliary engines. The European Union has imposed a 0.1% maximum sulphur requirement for fuel used by ships at berth in the Baltic, the North Sea and the English Channel (the so called “SOx-Emission Control Area” under Annex VI to MARPOL). Additionally, as of January 2020, EU member states must ensure that ships in all EU waters, except the SOx-Emission Control Area, use fuels with a 0.5% maximum sulphur content. Other rules and regulations regarding air pollution and GHG The issue of climate change and the effect of GHG emissions, in particular emissions from fossil fuels, has attracted and continues to attract attention from a wide range of groups, including politicians, regulators, financial institutions, and the general public. 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. At the international level, at the 26th Conference to the Parties of the United Nations Framework Convention on Climate Change (“COP 26”), the United States and European Union 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. In 2025, Canada took over from the United States as co-convenor of the Global Methane Pledge. At COP 30, a global methane status report showed that more work is required by countries to align with the ambition of the global methane pledge. While at the 28th Conference to the Parties of the United Nations Framework Convention on Climate Change, the United States announced new regulations intended to cut methane pollution from the nation’s oil and gas industry by nearly 80% through 2038, the EPA has extended certain compliance deadlines and has indicated that it may reconsider substantive parts of these regulations. Additionally, on January 7, 2026, the Trump administration withdrew the United States from the United Nations Framework on Climate Change. 70 Table of Contents Wreck Removal The Nairobi Convention on the Removal of Wrecks (“Wreck Removal Convention”) entered into force on April 14, 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 tonnage and above. Member states may intervene in certain situations. They can remove, or have removed, wrecks that pose a danger or impediment to navigation or that may be expected to result in major harmful consequences to the marine environment, or damage to the coastline or related interests, of one or more member states. The same applies for a ship that is about, or may reasonably be expected, to sink or to strand as set forth in the Wreck Removal Convention. The cost of such removal and other measures falls on the vessel owner. Should one of our 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. 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 regulations might have on our operations. Waste Management and Ship Recycling International The IMO and other international bodies have implemented various strategies, measures, codes, conventions and other initiatives relating to waste management and ship recycling which have an effect on our industry including, but not limited to, the following: a. Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal (the “Basel Convention”) was adopted on March 22, 1989, entered into force on May 5, 1992, and has been amended a number of times after its adoption. The Basel Convention has 184 state parties, not including the United States. The aim of the Basel Convention is to protect human health and the environment against adverse effects of hazardous wastes. The Basel Convention, among other things, imposes restrictions and prohibitions on the transboundary movement of hazardous waste to or from non-parties to the convention and non-OECD states; imposes restrictions on the transboundary movement of waste to/from/through party states; and includes notification obligations applicable in the event of transboundary movement of wastes between parties to the convention. Ships are not categorised as special categories of waste and the general rules of the Basel Convention therefore apply to ships. The Basel Convention applies to waste generators, exporters, importers and disposers. There is a risk that a seller of a ship meant for recycling will be deemed a waste generator and become subject to the regulation, and compliance with the Basel Convention can be very costly and time consuming. While MEPC 82 approved guidance on the interplay between the Basel Convention and the Hong Kong Convention with respect of the transboundary movement of ships intended for recycling, there is not yet full legal clarity and certainty about the interplay between the Basel Convention and the Hong Kong Convention. b. The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships The 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 Hong Kong Convention entered into force on June 26, 2025. The Hong Kong Convention applies to vessels larger than 500 gross tonnage that fly the flag of a contracting state. Under the Hong Kong Convention, each vessel sent for recycling will have to carry an inventory of its hazardous materials, ship recycling facilities authorised 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 is 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. As noted above, there is uncertainty relating to the interplay between the Basel Convention and the Hong Kong Convention which has not yet been fully clarified. c. OECD Decision of the Council on the Control of Transboundary Movements of Wastes Destined for Recovery Operations On March 30, 1992, the OECD passed a decision relating to the transboundary movement of waste destined for recovery operations between OECD member countries. The decision has been amended subsequently, including to align with the requirements under the Basel Convention. The OECD decision provides a framework for OECD members to control transboundary movements of waste in an environmentally sound manner. European Union The European Union has implemented various strategies, measures, directives, regulations, and other initiatives relating to waste management and ship recycling which have an effect on our industry including, but not limited to, the following: 71 Table of Contents a. Regulation (EC) No 1013/2006 of the European Parliament and of the Council of June 14, 2006 on shipments of waste In 2006, the European Union adopted Regulation (EC) No 1013/2006 of the European Parliament and of the Council of June 14, 2006 on shipments of waste (the “EU Waste Regulation”) which entered into force in July 2007. The EU Waste Regulation implements the Basel Convention (as amended) at the level of the European Union. The EU Waste Regulation, among other things, prohibits the transboundary movement of hazardous waste from EU countries to non-OECD countries. Breaches of the EU Waste Regulation may lead to sanctions such as fines and involved management members may be criminally charged, including fines, jail, and prohibitions on working in certain industries, such as shipping, for a period of time. In 2024, the European Union adopted the Regulation (EU) 2024/1157 of the European Parliament and of the Council of April 11, 2024 on shipments of waste (“New EU Waste Regulation”). The New EU Waste Regulation entered into force on May 20, 2024; however, most provisions will apply from May 2026 and most export rules from May 2027. Until then, the EU Waste Regulation will continue to apply. b. Regulation (EU) No 1257/2013 of the European Parliament and of the Council of November 20, 2023 on ship recycling and amending Regulation (EC) No 1013/2006 and Directive 2009/16/EC In 2013, the European Parliament and the Council of the EU adopted the Regulation (EU) No 1257/2013 of the European Parliament and of the Council of November 20, 2023 on ship recycling and amending Regulation (EC) No 1013/2006 and Directive 2009/16/EC (the “EU Ship Recycling Regulation”). The EU Ship Recycling Regulation entered into force on December 31, 2018 and applies to vessels of no less than 500 gross tonnage operating between different states and flying the flag of an EU member state. The EU Ship Recycling Regulation prescribes that such vessels may be recycled only in facilities authorised by the European Commission. Additionally, any EU-flagged vessel and any non-EU flagged vessel calling at port or anchorage of an EU member state is required to set up and maintain an inventory of hazardous materials. Such a system includes information on the hazardous materials with a quantity above the threshold values specified in relevant EU regulations and that are identified in a ship’s structure and equipment. This inventory should be properly maintained and updated, especially after repairs, conversions, or unscheduled maintenance on board the ship and a statement of compliance must be issued by the ship’s flag state. Breach of or efforts to circumvent the EU Ship Recycling Regulation can lead to penalties and, in respect of breaches of the obligation to carry an inventory of hazardous materials and a statement of compliance, may lead to the ship being warned, detained, dismissed, or excluded from ports or offshore terminals in EU member states. Vessel Safety and Security Regulations Safe Management of Vessel and Cargo The IMO and other international bodies have implemented various strategies, measures, codes, conventions and other initiatives relating to the safe management of vessels and cargo which have an effect on our industry including, but not limited to, the following: a. International Safety Management Code for the Safe Operation of Ships and for Pollution Prevention The ISM Code, which is Chapter IX of SOLAS, imposes certain requirements on the “company”, as this term is defined in the ISM Code. The “company” is a vessel’s registered owner unless the responsibility for operation of the vessel has been transferred to another party through a contractual arrangement such as a bareboat charter or a technical management agreement. The ISM Code requires the “company” 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. For our vessels under internal technical management, we rely on the safety management system developed by our internal technical manager BW Fleet Management Pte. Ltd. for compliance with the ISM Code. For our vessels under external technical management, we rely on the safety management system developed by our external technical manager. If we are not in compliance with the ISM Code, we could be subject to increased liability, may not be able to obtain sufficient insurance coverage, may be in default under our financial arrangements and may be denied access to – or detained in – certain ports. The ISM Code requires that a safety management certificate be obtained for each vessel. The safety management certificate evidences the compliance with the ISM requirements for a safety management system. A prerequisite for obtaining a safety management certificate is that the relevant “company” holds a document of compliance issued by the flag state for the relevant vessel type. Our internal ship management entity, BW Fleet Management Pte. Ltd., holds documents of compliance under the ISM Code for operation of oil tankers issued by each relevant flag state and all of our Hafnia Vessels and JV Vessels have obtained a safety management certificate. 72 Table of Contents b. Goal-based ship construction standards for bulk carriers and oil tankers In 2010, the Maritime Safety Committee of the IMO adopted a SOLAS regulation on goal-based ship construction standards for bulk carriers and oil tankers. This regulation entered into force on January 1, 2012 with effect for new oil tankers and bulk carriers ordered on or after January 1, 2016, and requires that all oil tankers and bulk carriers over 150 meters in length must have adequate strength, integrity and stability to minimise risk of loss or pollution. c. International Convention on Standards of Training, Certification and Watchkeeping for Seafarers The IMO has adopted the International Convention on the Standards of Training and Certification of Watchkeeping Officers (“STCW”). The STCW establishes minimum training, certification, and watchkeeping standards for seafarers. As of February 2017, all seafarers must meet the STCW standards and be in possession of a valid STCW certificate. d. International Maritime Dangerous Goods Code Amendments to SOLAS Chapter VII apply to vessels transporting dangerous goods and require those vessels be in compliance with the International Maritime Dangerous Goods Code (“IMDG Code”). The IMDG Code was originally adopted in 1965 but has been changed several times since. The carriage of dangerous goods in packaged form shall comply with the IMDG Code. Additionally, the IMDG Code is considered an extension of SOLAS Chapter VII and MARPOL Annex III. e. Polar Code IMO’s International Code for Ships Operating in Polar Waters (the “Polar Code”) is mandatory under SOLAS and MARPOL. The Polar Code entered into force on January 1, 2017, and covers design, construction, equipment, operational, training, search and rescue as well as environmental protection matters relevant to ships operating in the waters surrounding the two poles. It also includes mandatory measures regarding safety and pollution prevention as well as recommendatory provisions. The Code requires ships intending to operate in defined waters of the Antarctic and Arctic to acquire a polar ship certificate. As at December 31, 2025, none of our Hafnia and JV Vessels operate in areas requiring them to acquire a polar ship certificate. f. Convention on Limitation of Liability for Maritime Claims In 1976, the IMO adopted the Convention on Limitation of Liability for Maritime Claims (“LLMC”). The LLMC entered into force in 1986 and has been amended by a protocol of 1996 (“1996 Protocol”) which entered into force in 2004. The 1996 Protocol has been amended subsequently. The LLMC provides a system of limitation of liability for shipowners with specific limits specified for two types of claims: claims for loss of life or personal injury, and property claims (includes damage to property, harbour works and damage to other ships). The limitations of the LLMC apply unless it can be proved that a loss resulted from the personal act or omission, committed with the intent to cause such loss, or recklessly and with knowledge that such loss would probably result. Under the 1996 Protocol, the limits for compensation were increased. g. Future regulations 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 our 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. Vessel Security Regulation In the wake of increased worldwide security concerns, particularly after the terrorist attacks of September 11, 2001 in the United States, there have been a variety of initiatives intended to enhance vessel security and to take preventative measures against security incidents affecting vessels or port facilities. 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 (the “ISPS Code”). The ISPS Code is designed to enhance the security of ports and ships against terrorism and is applicable to all vessels over 500 gross tonnage operating on international trades. To trade internationally, a vessel must attain an International Ship Security Certificate (“ISSC”) from a recognised security organisation approved by the vessel’s flag state. Vessels operating without a valid certificate may be detained, expelled from, or refused entry at port until they obtain an ISSC. The various requirements, some of which are found in SOLAS, include, for example, on-board installation of automatic identification systems to provide a means for the automatic transmission of safety-related information from among similarly equipped ships and shore stations, including information on a ship’s identity, position, course, speed and navigational status; on-board installation of ship security alert systems, which do not sound on the vessel but only alert the authorities on shore; the development of vessel security plans; ship identification number to be permanently marked on a vessel’s hull; a continuous synopsis record kept on board showing a vessel’s history including the name of the ship, the state whose flag the ship is entitled to fly, the date on which the ship was registered with that state, the ship’s identification number, the port at which the ship is registered and the name of the registered owner(s) and their registered address; and compliance with flag state security certification requirements. 73 Table of Contents In the United States, the U.S. 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-U.S. 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 our Hafnia Vessels and JV Vessels have a valid ISSC. Future security measures could have a significant financial impact on us. We intend to continue to comply with the various security measures addressed by MTSA, SOLAS and the ISPS Code. Vessel security costs are significantly affected by piracy, particularly off West Africa, Somalia, the Gulf of Aden, and the Arabian Sea. Detention, ransom. Implementation of industry-standard measures such as BMP Maritime Security is necessary to reduce the Risk As Low As Possible (ALAP). Beyond piracy, geopolitical tensions pose additional threats. Regional conflicts, state-sponsored hostilities, and the spread of missile and drone capabilities increase the risk of targeted attacks on commercial vessels, especially in strategic chokepoints like the Bab El-Mandeb and Strait of Hormuz and Black Sea. Escalating tensions may result in sanctions, port restrictions, or maritime interdictions, disrupting shipping routes and increasing operational and insurance risks. Ongoing monitoring of geopolitical developments, adherence to security advisories, and proactive mitigation measures are essential to safeguard our seafarers, vessels, and cargo to reduce the overall Risk ALAP. Cybersecurity Recent action by the IMO’s Maritime Safety Committee and U.S. agencies indicates 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 January 1, 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. Under this rule, U.S.-flagged vessels, outer continental shelf facilities, and facilities subject to the MTSA are required to develop Cybersecurity and Cyber Incident Response Plans, designate a Cybersecurity Officer to implement plans, and to report certain cyber incidents to the National Response Center. In 2023, the European Union adopted its second Network and Information Security directive (“NIS2”). This directive has an impact on our business and may require us to incur additional expenses and take measures in order to monitor cybersecurity and if we are not in compliance with applicable rules, we may be subject to penalties for noncompliance. Maritime Labour Convention The International Labour Organization is a specialised agency of the UN that has adopted the Maritime Labour Convention, 2006 as amended (the “Maritime Labour Convention”). A Maritime Labour Certificate and a Declaration of Maritime Labour Compliance is required to ensure compliance with the Maritime Labour Convention for all ships that are 500 gross tonnage or above and are either engaged in international voyages or flying the flag of a member state of the International Labour Organization and operating from a port, or between ports, in another country. The Maritime Labour Certificate and Declaration of Maritime Labour Compliance are prima facie evidence of a vessel’s compliance with the requirements of the Maritime Labour Convention and are subject to port state control when vessels enter the ports of other countries which have ratified the Maritime Labour Convention. In addition, vessels flying the flag of countries that have not ratified the Maritime Labour Convention are also subject to inspection with respect to working and living conditions for the seafarers when those vessels enter in ports of countries where the Maritime Labour Convention is in force. Amendments to the Maritime Labour Convention were adopted in 2014, 2016, 2018, 2022 and 2025. We believe that all our Hafnia Vessels and JV Vessels are in compliance with and are certified to meet the Maritime Labour Convention; however, there are risks associated with ensuring proper compliance due to uncertainty relating to the interpretation of the Maritime Labour Convention and the local legislation enacting it in various countries as well as the methods to be used by port state control to check and ensure compliance. Technical Management Our technical department is responsible for the maintenance, marine, vetting, security, crew management and technical operations to ensure that the highest standards with regard to safety and environment are maintained on board our Hafnia Vessels and JV Vessels. As at December 31, 2025, 57 of our Hafnia Vessels and JV Vessels were externally managed on the basis of separate technical management agreements with the remaining Hafnia Vessels and JV Vessels being managed through our in-house technical department. 74 Table of Contents The following table provides an overview of these externally managed Hafnia Vessels and JV Vessels as at December 31, 2025. Technical Manager ​ Vessel Name(s) Donnelly Tanker Management Ltd ​ Hafnia Africa, Hafnia Asia, Hafnia Australia, Hafnia Beijing, Hafnia Guangzhou, Hafnia Leo International Andromeda ​ PS Stars, Yellow Stars MMS Co., Ltd. Singapore Branch ​ Hafnia Hong Kong, Hafnia Nanjing, Hafnia Shanghai, Hafnia Shenzhen Socatra Ecomar Garonne, Ecomar Gascogne, Ecomar Guyenne Suntech Ship Management Pte. Ltd. ​ Hafnia Amessi, Hafnia Amethyst, Hafnia Ammolite, Hafnia Andesine, Hafnia Aquamarine, Hafnia Aventurine, Hafnia Azotic, Hafnia Violette, Hafnia Viridian Synergy Marine Copenhagen A/S ​ Hafnia Crux, Hafnia Libra(1), Hafnia Phoenix Thome Croatia D.O.O ​ Hafnia Achroite, Hafnia Adamite, Hafnia Alabaster, Hafnia Almandine, Hafnia Amazonite, Hafnia Amber, Hafnia Ametrine, Hafnia Ane, Hafnia Aragonite, Hafnia Aronaldo, Hafnia Axinite, Hafnia Azurite, Hafnia Bering, Hafnia Daisy, Hafnia Henriette, Hafnia Kirsten, Hafnia Lene, Hafnia Lise, Hafnia Lotte, Hafnia Magellan, Hafnia Malacca, Hafnia Mikala, Hafnia Pioneer, Hafnia Soya, Hafnia Sunda, Hafnia Tanzanite, Hafnia Topaz, Hafnia Torres, Hafnia Tourmaline, Hafnia Turquoise ​ Total (57 Vessels) Further, our technical department is managing various technical projects and vessel modifications across our Hafnia Vessels and certain JV Vessels and is responsible for our programs for newbuilds, including site team, site control, construction, and delivery. As at December 31, 2025, our technical department had 73 employees, of which 53 are based in Singapore, 5 in Copenhagen, 2 in Houston, 11 in Mumbai, 1 in Monaco and 1 in Dubai. Classification Societies The hull, machinery, equipment and systems of every commercial vessel must be “classed” by a classification society authorised by the vessel’s country of registry. The classification society certifies that the vessel is “in-class”, signifying that the vessel has been built, certified and maintained in accordance with all national and international rules, regulations and applicable standards. Additionally, where surveys are required by international conventions, including SOLAS and MARPOL or by laws or other applicable regulations of the vessel’s flag state, the classification society may undertake such surveys acting on behalf of the relevant authority and will certify that the vessel complies with applicable rules and regulations of its flag state and applicable international conventions. Many insurance underwriters will require a vessel to be certified “in class” by a classification society which is a member of the International Association of Classification Societies (“IACS”). Our Hafnia Vessels and JV Vessels are currently classed with DNV (“DNV”), Nippon Kaiji Kyokai (“ClassNK”), American Bureau of Shipping (“ABS”), Lloyd’s Register of Shipping (“LR”) or Bureau Veritas (“BV”), all of which are members of IACS. At the date of this Annual Report, all Hafnia Vessels and JV Vessels are certified as being “in class” by their respective classification society. In order to maintain the class, regular and extraordinary surveys of a vessel’s hull and machinery, including electrical plant and any other equipment required to be classed are performed. These surveys can be divided into three categories: • Annual Survey: Annual surveys are conducted for the vessel’s hull and machinery, including the electrical plant and any special equipment classed. The annual survey must be conducted within three months before or after each anniversary of the date of commencement of the class period indicated in the certificate. • Intermediate survey: Extended annual surveys, referred to as intermediate surveys, have to be carried out either at or in between the second and third annual survey after each special survey. After the third special survey, each intermediate survey shall have the same scope as the previous special survey. • Special survey: Special surveys are conducted for the vessel’s hull, machinery, including the electrical plant, and for any special equipment classed. Special surveys may be referred to as class renewal surveys. Special surveys should be completed within five years after the completion of the construction of the vessel or within five years after the crediting date of the previous special survey. At the special survey, the vessel is thoroughly examined. In lieu of a special survey, at the owner’s request, the surveys relating to a vessel’s machinery may be split into a continuous survey cycle under which the machinery will be surveyed periodically over a five-year period. The period between two subsequent surveys of each area must not exceed five years. 75 Table of Contents Special surveys and intermediate surveys for vessels over the age of 15 may have a considerable financial impact. In addition to the abovementioned surveys, many vessels, including the Hafnia Vessels and JV Vessels, are subject to examinations of the outside of the vessel’s bottom and related items. During each five-year special survey period, a minimum of two examinations of the outside of the vessel’s bottom and related items must be conducted. One of these examinations must be conducted in conjunction with the special survey. The interval between two examinations of the vessel’s bottom and related items may not exceed 36 months. Normally, examinations of the vessel’s bottom and related items are conducted while the vessel is in drydock; however, in certain circumstances an alternate examination may be conducted while the vessel is afloat. For vessels over the age of 15, the bottom survey must be performed while the vessel is in drydock. Generally, if during any of the abovementioned surveys any defects are found, the classification surveyor will require immediate repairs or issue a “Condition of Class” which much be rectified within a prescribed time limit. If any vessel does not maintain its class and/or fails any annual survey, intermediate survey or special survey, the vessel cannot be traded. If a vessel has a Condition of Class or minor recommendations on its class record, dependent on the nature and severity of the noncompliance, the vessel may face restrictions in trading and could be required to be off-hire while the issues are remedied and additionally, any such failure may be a violation of conditions and covenants in, e.g., our financial contracts and insurance agreements. This could materially and adversely affect our business, financial condition, and results of operations. Risk of Loss and Liability Insurance General Inherent in operation of any ocean-going vessel is the potential risk of major losses and liabilities, death or injury of persons, property damage caused by adverse weather conditions, cargo loss or damage, mechanical failures, human error, collision, war, terrorism, piracy and other circumstances or events; pollution risk stemming from the transportation of oil cargo and chemical cargo by sea and use of hydrocarbon fuel to power vessels; and business interruption due to political unrest, hostilities, labour strikes and boycotts and activist disruption. The occurrence of any of these events may result in loss of revenues or increased costs and may have a material adverse impact on our financial condition and results of operation. OPA, which in certain circumstances imposes virtually unlimited liability on shipowners, operators, and bareboat charterers of any vessel trading in the U.S. exclusive economic zone for certain oil pollution accidents in the United States, has made liability insurance more expensive for shipowners and operators trading in the U.S. market. We carry insurance coverage as customary in the shipping industry and while we believe that our current insurance program, as described further below, is adequate to protect us against the majority of accident-related risks involved in the conduct of our business and that an appropriate level of protection and indemnity insurance against pollution liability and environmental damage is maintained, not all risks can be insured against. There can be no assurance that the range of risks we are exposed to are adequately insured against, that any particular claim will be paid, or that we in the future will be able to procure similar adequate insurance coverage on the terms and conditions equal to those we currently have. More international conventions governing shipping, including bunkers and wreck removal as well as increased limits of liability under existing conventions, have resulted in increased exposures and insurance costs. There may be circumstances where liabilities are difficult to insure or even become uninsurable. Our 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 us to revise our coverage. Marine and War Risks Insurance As an integral part of operating our Hafnia Vessels and JV Vessels, we maintain “hull and machinery”, “hull interest”, “war”, “protection and indemnity” insurances and other minor and locally required coverages such as cybersecurity, U.S. COFR, etc. Each insurance is placed with first class marine insurers and collectively affords protection against the majority of accident-related risks that may arise in connection with our marine operations, including damage to and loss of a vessel arising from marine perils such as collisions (including collision liability to third-party vessels where included under the hull policy), grounding, damage caused by crew negligence and adverse weather conditions as well as war perils, including political-type exposures. In the case of hull and war exposures, our Hafnia Vessels and JV Vessels are insured at no less than an average of 100% of the fair market value, with the product tanker hull deductible applicable to particular damage claims being $100,000 per vessel per casualty. Vessel values are currently reviewed twice a year. There is no deductible for a claim for total loss or for claims brought under the war cover. Within our war policy, we have war loss of hire insurance where a one-day deductible applies. However, not all war cyber exposure can be covered through market buy-backs that are currently available. 76 Table of Contents Protection and Indemnity Insurance Protection and indemnity (P&I) insurance is placed with P&I Clubs. We place P&I insurance with P&I Clubs who are members of the International Group of P&I Clubs. P&I insurance indemnifies us in respect of limited contractual exposures including under crew contracts and third-party liabilities arising out of a vessel’s operation in accordance with the rules of the P&I Club where such liabilities are not covered under the vessel’s hull and machinery insurance. P&I liabilities include injury or death of our crew or third parties, cargo loss or damage, claims arising from collisions, damage to third-party property, salvage, towing, wreck removal and pollution. The current insurance limit for pollution is $1 billion per vessel per incident except where pollution arises from a war peril in which case the limit may be lower. The 12 P&I Clubs that comprise the International Group insure approximately 90% of the world’s commercial blue water tonnage and have entered into a pooling agreement to reinsure each association’s liabilities. The pooling is regulated by a contractual agreement which defines the risks that can be pooled and how the risks are to be shared between the participating P&I Clubs. The International Group’s website states that the pool provides a mechanism for sharing all claims in excess of $10 million. The limit of cover provided by International Group Clubs is approximately $8.9 billion and is partly protected through a market reinsurance program from $100 million up to $3.1 billion. The reinsurance premium required by market underwriters is passed on by all P&I Clubs forming part of the mutual P&I rate. The reinsurance premium could materially affect the P&I premium paid by our vessels. Furthermore, if the International Group is unable to renew the reinsurance program, or should there be insufficient reinsurance capacity to maintain the current program, this may impact the limit International Group Clubs can offer. As a member of a P&I Clubs, which is a member of the International Group, we pay premium to the association based on our claim records as well as the claim record of all other members of the association and through contributions to other P&I Clubs claims via the International Group’s Pooling arrangements in excess of $10 million and any exposure placed with the International Group’s captive, Hydra. Permits and Authorisations We are required to obtain certain permits, licenses and certificates with respect to vessels in our Hafnia Fleet. The permits, licenses, and certificates we are required to obtain depend on several factors, including the cargo transported, the waters in which the vessel will operate, the nationality of the vessel’s crew and the age of the vessel. We believe we have obtained all permits, licenses and certificates currently required to permit our Hafnia Vessels and JV Vessels to operate. Additional laws and regulations may be adopted which could limit our ability to do business or increase the cost of us doing business. Legal Proceedings We have not been involved in any legal proceedings that we believe may have a significant effect on our business, financial position, results of operations or liquidity, and we are not aware of any proceedings that are pending or threatened that may have a material effect on our business, financial position, results of operations or liquidity. From time to time, we may be subject to legal proceedings and claims in the ordinary course of business, principally property damage and personal injury claims. We expect that these claims would be covered by insurance, subject to certain deductibles. However, those claims, even if lacking merit, could result in the expenditure of significant financial and managerial resources. Sustainability Reporting We measure our sustainability targets and goals under CSRD and the EU Taxonomy. Our CSRD Report 2025, furnished to the SEC on Form 6-K, dated April 17, 2026 details our progress meeting such sustainability targets and goals. The content of the CSRD Report 2025 is not incorporated by reference into this Form 20-F. Industry The information and data contained in this Annual Report relating to the international tanker industry has been provided by Clarksons Research and is taken from Clarksons Research’s database and other sources. Clarksons Research has advised that: (i) some information in Clarksons Research’s database is derived from estimates or subjective judgments; (ii) the information in the databases of other maritime data collection agencies may differ from the information in Clarksons Research’s database and (iii) while Clarksons Research has taken reasonable care in the compilation of the statistical and graphical information and believes it to be accurate and correct, data compilation is subject to limited audit and validation procedures. 77 Table of Contents Summary • The product tanker market saw firm conditions in 2025, with vessel earnings remaining at high levels. • Into early 2026, conflict in the Middle East has caused significant disruption in the tanker shipping market, and increased uncertainty over the outlook, though initially product tanker vessel earnings have strengthened significantly. • Medium Range (MR) spot earnings averaged around $34,000 per day per day in the first quarter of 2026, up by 85% year-over-year (“y-o-y”), with earnings across March 2026 representing the strongest month on record, although regional variation is becoming marked. • In the short-term, despite the loss of cargo volumes (19% of seaborne products trade passed through the Strait in 2025, with transits 95% below normal levels in late March while some Asian exporters have also put in place oil product export restrictions), a range of mitigating factors are lending support (e.g., additional long-haul flows, supportive arbitrage dynamics, 4% of product tanker fleet capacity is ‘stuck’ in the Gulf, inefficiencies related to waiting time and re-positioning, stock draws to boost volumes on longer-distance trade routes). • A more prolonged period of disruption could cause greater challenges for markets, as negative impacts on oil supply, downstream activity and the global economy build. • Product tanker fleet growth has picked up after stronger newbuild ordering in 2023-24, with fleet capacity expanding by 5% in 2025 and projected to grow by 6% in 2026. Product Tanker Industry Overview The maritime shipping industry is fundamental to international trade as the only practicable and cost-effective means of transporting large volumes of many essential commodities and finished goods. The product tanker industry plays a vital link in the global energy supply chain. Tanker markets are highly competitive, with ship charter hire rates sensitive to changes in demand for and supply of tanker capacity, and are consequently cyclical and volatile. Tankers make up approximately one third of the world’s merchant fleet by tonnage, including product tankers, which generally carry refined petroleum products. In broad terms, tanker demand is a product of the amount of oil carried by tankers and the distance over which the cargo is transported. Seaborne oil trade volumes and patterns are principally affected by changes in underlying oil demand linked to world and regional economic conditions, developments in supply of crude oil and refined petroleum products, shifts in the regional prices of raw materials and products and changes in oil inventory levels. A total of 3.0 billion tonnes of crude oil and oil products were moved by sea in 2025, of which 1.0 billion tonnes was oil products. Over the past ten years, oil products trade has broadly held steady on a volume basis though tonne-mile demand has been stronger as geopolitical disruption has lent significant support to average haul trends in recent years. In particular, trade flow shifts related to the Russia-Ukraine conflict saw a significant surge in tonne-mile demand as Russian producers exported volumes outside of Europe while European importers stepped up purchases from the United States and the Middle East – this dynamic boosted tonne-mile demand by ~14% across 2022 and 2023. Attacks on vessels in the Red Sea, which commenced in late 2023, drove a further 4% uplift to products tonne-mile trade for a brief period during 2024 though this uplift faded over time as trade flows adjusted. In addition, the continued growth in long-haul Middle Eastern exports has been an underlying supportive driver of average haul trends in recent years. The product tanker demand outlook currently remains subject to significant levels of uncertainty, following the significant reduction in oil flows through the Strait of Hormuz (19% of global seaborne oil products passed through the Strait in 2025), with oil tanker transits >90% below normal levels in late March. More than 10m bpd of oil production is now offline in the Middle East (alongside 3% of oil refining capacity amid attacks on infrastructure), while a range of Asian refiners have cut runs with some Asian governments restricting oil product exports (~5% of seaborne oil products trade is currently under some form of export restriction). Clearly, a range of product tanker demand scenarios are possible and much depends on the duration of disruption and also the length of time for vessel traffic to return to ‘normal’. On the basis that significant disruption to vessel traffic lasts until the end of April (before a gradual recovery in volumes is then seen over the subsequent months), oil products trade could contract by 3-4% in 2026 on an annual basis, though significant variation is expected within the year with trade volumes likely to be weak through the second quarter (though tonne-mile demand may be less impacted) before firming during the second half of the year. Growth rates for 2027 are very sensitive to the situation in the Middle East, though some ‘bounce-back’ in volumes could be expected. Recent trends and short-term projections are illustrated in the table below – estimates remain highly subject to the situation in the Middle East. 78 Table of Contents World Seaborne Tanker Trade Year Crude Oil Oil Products Total million tonnes % y-o-y million tonnes % y-o-y million tonnes % y-o-y 2020 1,838 -7.7% 956 -11.7% 2,794 -9.1% 2021 1,807 -1.7% 998 4.4% 2,805 0.4% 2022 1,925 6.5% 1,049 5.1% 2,974 6.0% 2023 1,965 2.1% 1,075 2.5% 3,040 2.2% 2024 1,946 -1.0% 1,066 -0.8% 3,012 -0.9% 2025 (e) 1,987 2.1% 1,046 -1.9% 3,033 0.7% 2026 (f) 1,953 -1.7% 1,011 -3.4% 2,963 -2.3% 2027 (f) 2,015 3.2% 1,057 4.6% 3,073 3.7% CAGR* (2020-2025) 1.6% 1.8% 1.7% CAGR (2015-2025) 0.3% 0.0% 0.2% Source: Clarksons Research, March 2026 (f) forecasts, (e) estimates. * compounded annual growth rate The forecast for 2026 is for full year 2026 and is subject to change. There is only limited trade and economic data for 2026 and 2027, with these forecasts subject to significant levels of uncertainty given the current situation in the Middle East. There is no guarantee that trends are sustainable. World Seaborne Tanker Tonne-Mile Trade Year Crude Oil Oil Products Total billion tonne- miles % y-o-y billion tonne- miles % y-o-y billion tonne- miles % y-o-y 2019 10,479 -2.2% 3,118 1.6% 13,597 -1.3% 2020 9,766 -6.8% 2,790 -10.5% 12,556 -7.7% 2021 9,304 -4.7% 3,014 8.0% 12,319 -1.9% 2022 9,909 6.5% 3,216 6.7% 13,125 6.5% 2023 10,486 5.8% 3,434 6.8% 13,920 6.1% 2024 10,666 1.7% 3,666 6.8% 14,333 3.0% 2025 (e) 10,911 2.3% 3,600 -1.8% 14,511 1.2% 2026 (f) 10,864 -0.4% 3,567 -0.9% 14,431 -0.5% 2027 (f) 11,063 1.8% 3,734 4.7% 14,797 2.5% CAGR (2020-2025) 2.2% 5.2% 2.9% CAGR (2015-2025) 1.6% 1.9% 1.6% Source: Clarksons Research, Mar 2026 (f) forecasts, (e) estimates. The forecast for 2026 is for full year 2026 and is subject to change. There is only limited trade and economic data for 2026 and 2027, with these forecasts subject to significant levels of uncertainty given the current situation in the Middle East. There is no guarantee that trends are sustainable. Tanker supply is determined by the size of the existing fleet as measured by cargo carrying capacity. It is influenced by a variety of factors, primarily the size of the existing fleet, the rate of deliveries of newbuilds, scrapping (the terms “scrapping”, “demolition” and “recycling” are used interchangeably), and other operating efficiency factors (for example, storage, time in port or repair yards, congestion and vessel speed) which can influence the level of ‘active supply’ or ships available for charter. As of March 1, 2026, there are a total of 5,934 crude and product tankers sized above 10,000 dwt, with an aggregate capacity of 670.3 million dwt. Product tankers constitute 30% of this fleet in tonnage terms, but 60% of the combined crude and product tanker fleet in terms of vessel numbers. Product tanker fleet growth picked up somewhat in 2025, following several years of very limited expansion, though growth was driven by firm LR2 deliveries (LR2 fleet capacity grew by 11% last year), with many of these LR2s trading dirty for much of 2025, limiting the increase in ‘effective’ product tanker supply. MR/Handy fleet growth rose to 3.5% in 2025, up materially versus previous years but still ‘manageable’ given additional LR2 tonnage trading in the crude sector, while sanctions announcements have also limited ‘mainstream’ supply growth. Product tanker fleet growth is expected to rise to 6% in 2026, although this growth is again set to be driven by LR2 expansion (+10% y-o-y) with MR/Handy growth rising to 5% in 2026. While MR/Handy fleet growth is more moderate than the expansion seen in the LR2 sector and a range of factors may moderate the increase in ‘effective’ supply growth, multiple years of above-trend fleet growth may eventually exert some supply-side pressure on rates and earnings. 79 Table of Contents World Seaborne Tanker Fleet Development and Orderbook (million DWT) End Year Crude Tanker Product Tanker Total million DWT % y-o-y million DWT % y-o-y million DWT % y-o-y 2015 347.3 144.1 491.4 2016 367.6 5.8% 153.1 6.3% 520.7 6.0% 2017 386.0 5.0% 159.5 4.2% 545.4 4.7% 2018 388.3 0.6% 162.4 1.9% 550.7 1.0% 2019 413.5 6.5% 170.2 4.8% 583.7 6.0% 2020 427.4 3.4% 173.8 2.2% 601.2 3.0% 2021 434.9 1.8% 177.5 2.1% 612.4 1.9% 2022 453.1 4.2% 181.0 2.0% 634.1 3.5% 2023 461.4 1.8% 185.0 2.2% 646.3 1.9% 2024 462.9 0.3% 188.5 1.9% 651.4 0.8% 2025 (e) 466.2 0.7% 198.2 5.1% 664.4 2.0% 2026 (f) 483.8 3.8% 210.5 6.2% 694.3 4.5% 2027 (f) 510.1 5.4% 223.4 6.1% 733.5 5.6% CAGR (2020-2025) 1.8% 2.7% 2.0% CAGR (2015-2025) 3.0% 3.2% 3.1% Fleet (Mar-2026) 469.2 201.1 670.3 Orderbook (Mar-2026) 95.0 37.4 132.3 % Fleet 20.2% 18.6% 19.7% Source: Clarksons Research, March 2026. Note (1): (f) = forecast. Note (2): The product tanker fleet is classified as coated non-IMO graded tankers, IMO III graded tankers, IMO II graded tankers of 25,000 dwt and above which meet criteria: average tank size >3,000 cubic meters (“cbm”), or, where average tank size is unknown, number of tanks <16 (for vessels of 25,000 dwt – 39,999 dwt), <18 tankers (for vessels of 40,000 dwt – 54,999 dwt), < 30 tanks (for vessels of 55,000 dwt – 84,999 dwt), tankers of unknown IMO grade of 25,000 dwt and above, uncoated non-IMO graded tankers below 55,000 dwt. Tankers designated as specialised tankers and all tankers with stainless steel tanks are excluded. Note (3): The data relating to product tankers is for the fleet sized 10,000 dwt and above. Note (4): There is potential for the orderbook to be influenced by delays or cancellations. The charter market is highly competitive. Charter rates are determined by a range of factors, including the underlying supply and demand balance for sea transportation capacity, as well as specific vessel and voyage factors such as the individual route, location and specification of the vessel, and the reputation of the vessel and its manager. After a soft start to 2025, product tanker markets improved across last year with average clean MR earnings rising to $23,585 per day in fourth quarter of 2025 as firm earnings in the crude sector, disruption from sanctions, increased trade volumes (often on longer-haul flows) and seasonally stronger winter demand supported market conditions. Markets have improved further into early 2026, with earnings averaging $27,923 per day across the first couple of months of 2026, up 60% on the long-term trend. In March, earnings improved further, with the conflict in the Middle East causing significant disruption to oil and tanker markets, driving ‘scrambles’ for available tonnage (4% of product tanker fleet capacity is currently still in the Middle East Gulf), while elevated oil product prices have also boosted refining margins in the Atlantic and the temporary Jones Act waiver has provided opportunities for internationally trading vessels to lift domestic U.S. cargoes. Variation is also beginning to emerge regionally, with markets in the West (particularly in the U.S. Gulf) exceptionally strong while pressure has begun to emerge in the East. Overall, clean MR earnings have averaged $51,299 per day on a global basis in March 2026 so far, one of the strongest months on record. Looking ahead, disruption in the Middle East seems likely to be the key driver of product tanker markets in the short term. Despite the current loss of cargo demand out of the Middle East (and increasingly Asia), earnings generally remain very elevated for now, with a range of mitigating factors lending support though clearly, a prolonged period of disruption would cause greater challenges. The outlook remains very uncertain and much depends on the duration of the disruption to traffic through the Strait and also the length of time required to boost oil production and global refinery runs. On the basis that significant disruption to vessel traffic lasts until the end of April, before the situation then improves gradually over the coming months, initial forecasts suggest that oil products trade could now fall by 3-4% on an annual basis (though tonne-mile demand may be more resilient, potentially falling by 1%) though there is likely to be significant variation within the year. In combination with firmer fleet growth, it is likely that product tanker markets could eventually see softer earnings over the next 12-18 months though markets may remain relatively healthy overall with a range of scenarios possible. 80 Table of Contents Current Environmental and Regulatory Issues The global regulatory and policy consensus surrounding shipping emissions ‘stalled’ in 2025, with the IMO choosing at the Marine Environment Protection Committee’s (MEPC’s) 2nd Extraordinary Session in October to delay the vote on adoption of the Net-Zero Framework (‘Mid-Term’ Measures) for one year amid strong lobbying against the measures, particularly from the United States and Saudi Arabia. The next steps for shipping emissions regulations are now uncertain; the Net-Zero Framework, which includes a technical element limiting the greenhouse gas (GHG) emissions intensity of marine fuels and an economic element creating a maritime GHG emissions pricing measure, will now need to be renegotiated, and implementation timelines will need to be amended; it is unclear whether a year of further negotiations will bring about agreement. Additionally, the breakdown in global consensus has increased the potential for a ‘fragmenting’ of international shipping emissions regulations, with some national and regional governments continuing to develop their own regulations. Chiefly, the EU has continued to progress its shipping emissions regulations; in January 2026, the share of applicable emissions covered by the EU Emissions Trading System (ETS) for which companies will need to surrender allowances increased to 100% (up from 40% in 2024 and 70% in 2025) while the EU’s Carbon Border Adjustment Mechanism (CBAM), which aims to limit the movement of production for emissions-intensive goods to countries with less stringent emission regulations, also came into force at the start of the year. The decision to delay the vote on the Net-Zero Framework and the general breakdown in global consensus around the ‘green transition’ have extended uncertainty around the future regulatory framework and fuelling choices for shipping, and may result in greater regional fragmentation of emissions regulation. Uptake of alternative fuels on newbuild vessels continues in some segments (e.g., large containerships where ‘green’ fleet renewal remains a focus, gas carriers where the cargo can be used as fuel), but in the tanker segment few ships are now being ordered with alternative fuel capability. However, uptake of other ‘green’ technology has continued across the shipping industry, including ‘eco modern’ engines and Energy Saving Technologies. The Product Tanker Industry While crude tankers transport crude oil from points of production to oil refineries or storage locations, product tankers can carry both refined and unrefined petroleum products, including crude oil, “dirty products” (including fuel oil, vacuum gas oil and carbon black feedstock), and “clean products” (e.g., gas oil, gasoline, kerosene and naphtha). Transportation of clean products typically requires a vessel with coated tanks. Most product tankers have coated tanks, allowing vessels to transport various grades of refined petroleum products, vegetable oils and easy chemicals without degrading the vessel’s steel or contaminating the cargo. Dirty products, however, are transported by a mixture of coated and uncoated tankers, as trading patterns and market requirements dictate. “Dirty products” require heating to lower the viscosity of the cargo during transport, but require minimal tank or line preparation as contamination of the cargo is not a crucial consideration. Product tankers make up 60% of the combined crude and product tanker fleet (above 10,000 dwt) in terms of vessel numbers and 30% in terms of dwt, and are a key part of the global tanker trade. Although the product tanker market exhibits some independent behaviour from the crude tanker market, there is also correlation between the two sectors and changes in one market may influence the other. 81 Table of Contents Product Tanker Demand Introduction Demand for oil tankers is dictated by world oil demand and trade, and the location and accessibility of oil products supplies relative to the principal locations for discharging such cargoes. The metric of tonne-miles is often used as a proxy for oil tanker demand and is a product of (a) the amount of cargo transported in tankers, multiplied by (b) the distance over which cargo is transported. Macroeconomic forces, both globally and regionally, have a significant impact upon world oil products consumption and, consequently, upon the volume of oil products to be transported by sea. The average distance of sea transportation of oil products is affected by trading patterns, which are determined by a combination of economic and geographic factors, refinery developments, regional products imbalances, seasonal variations, oil price trends and differentials in oil products prices between regions, environmental influences, exceptional climatic conditions and geopolitical events. Oil demand cycles move broadly in line with developments in the global economy and are often a key factor influencing tanker demand. In 2025, oil accounted for around a third of world energy consumption. Oil demand has increased from 91.9 million barrels per day (“m bpd”) in 2013 to 103.5m bpd in 2025, driven by increasing world population, global economic expansion and rising oil consumption in the transportation industries in developing countries. The developing world has been the key driver of continued growth in global oil consumption, with oil demand in these nations growing by a CAGR of 1.4% per annum (“p.a.”) over 2015-2025, whilst oil demand in OECD countries has remained relatively steady across the period. In 2025, global oil consumption growth remained moderate, standing at +0.7% y-o-y, with U.S. trade policy volatility generating macro-economic pressures and constraining consumption gains. In particular, consumption of petrochemical feedstocks (e.g., LPG, ethane) was impacted by U.S.-Chinese tensions, though diesel and gasoline demand remained resilient. Projections for 2026 are uncertain, given the current conflict in the Middle East, with the current lack of oil supply (~10m bpd of production has been taken offline in March) and high oil prices (the price of Brent crude stands at around $110/bbl) likely to pressure oil demand significantly should the conflict in the Middle East last for a prolonged period. Key Oil Products Trade Trends Seaborne oil products trade volumes have held steady over the past 10 years overall, though trends have varied significantly during recent years. Oil products trade decreased significantly in 2020 (-11.7%) amidst the impact of COVID-19 on oil demand, before a strong ‘post-COVID’ recovery in trade volumes was seen across 2021-2023. In 2024, oil products trade eased by 0.8% on the back of Russian refinery outages and weaker refinery margins. Volumes then eased back by a further 1.9% in 2025 (standing at 22.6m bpd), as continued refinery outages limited Russian product exports, domestic refinery start-ups in Nigeria and Mexico pressured import demand while petrochemical plant closures in Asia also dragged on trade volumes. Volumes were particularly weak in the first half of 2025, though improvements were seen in the second half. 82 Table of Contents While oil products trade volume growth has been sluggish in recent years, tonne-mile trade growth has been stronger as a range of geo-political disruption factors have boosted the average haul of oil products trade. In particular, the re-distribution of Russian/European flows since the onset of the war between Russia and Ukraine towards longer-haul flows boosted products tonne-mile trade by ~14% across 2022-2023. The onset of re-routing away from the Red Sea in late 2023 also supported products trade average haul, though over time this ‘uplift’ faded as trade patterns adjusted. In 2025, the average haul of oil products trade held steady, as growth on some longer-haul flows (e.g., Middle East Gulf – East Asia, U.S. Gulf – Brazil) was counter-balanced by the decline in Russian longer-haul flows. Initial forecasts for 2026 were for a moderate rebound in oil products trade volumes, with volumes initially projected to increase by 1.3% led by firmer Middle Eastern exports, alongside growing import demand into Asia, driven by continued regional oil demand growth and United States / Europe, on the back of refinery closures in 2025. However, conflict in the Middle East has upended prior forecasts, with the closure of the Strait of Hormuz, attacks on refineries in the Middle East, refinery run cuts and export restrictions in Asia all expected to impact trade volumes. Clearly, a range of scenarios are possible and much depends on the duration of disruption and also the length of time that it takes for vessel traffic to return to ‘normal’. On the basis that significant disruption to vessel traffic lasts until the end of April (before a gradual recovery in volumes is then seen over the subsequent months), oil products trade could contract by 3-4% in 2026 on an annual basis, though significant variation is expected within the year with trade volumes likely to be under pressure through the second quarter before firming during the second half of the year. Growth rates for 2027 are very sensitive to the situation in the Middle East, though some ‘bounce-back’ in volumes could be expected. Key Import Trends In recent years, products imports into different regions have been shaped by a range of factors, including oil demand, refinery margins and trends in refinery capacity while geo-political factors continue to shape import trends, including the current conflict in the Middle East while changes in trade pattern related to the Russia-Ukraine conflict have also been impactful in recent years. 83 Table of Contents Asia remains the largest oil product importer, with the region accounting for 7.2m bpd of import volumes in 2025, 33% of global volumes. Import growth into Asia has been relatively steady over the past few years, with varied trends across the region. In general, Chinese oil product imports have generally increased over recent years, with periods of tighter crude import quotas often driving fuel oil imports despite overall increases in Chinese refinery capacity though other Asian importers have seen softer trends amid increasing refining capacity. Overall, Asian imports fell by a CAGR of -0.3% across 2015-2025. Meanwhile, European product imports have largely held steady in recent years, with slowing oil demand growth being offset by refinery capacity closures – imports into the region fell by a CAGR of -0.6% across 2015-2025. Meanwhile, imports into Oceania have grown by a strong CAGR of 6.1% across the past decade, on the back of refinery closures stimulating increased shipments from East Asia (e.g., Korea). African product imports have grown by a steady CAGR of 1.2% across the past decade and saw modest growth in 2025 despite the gradual ramp-up of the Dangote refinery in Nigeria (though this refinery start-up may lessen import oil product requirement into Nigeria in the coming years). Meanwhile, oil product imports into North America have continued to fall in recent years and further declines were seen in U.S. product imports in 2025 (-6% y-o-y to 1.5m bpd) as increased crude was processed domestically in Gulf Coast refineries. In 2025, oil products imports eased back notably amid softer trends in Asia (as some weak petrochemical margins saw some producers shut-down capacity, lessening oil product import requirement), alongside lower imports in the United States while refinery start-ups in Mexico and Nigeria also dragged on volumes. Initial start-year forecasts for 2026 were for improved oil product import volumes, with refinery closures in Europe and the United States stimulating additional import demand (often on long-haul routes), while continued Asian oil demand growth was also expected to be supportive. However, the current conflict in the Middle East is now expected to be the key driver of oil product import trends in the short-term, with the reduction of crude and products flows through the Strait of Hormuz likely to exert clear pressure on volumes during the coming months. On an annual basis, oil products imports could fall by 3-4% though much depends on the duration of the conflict in the Middle East, while significant variation is expected through the year as well with volumes likely to be firmer in the second half of the year than the first (on the basis that significant disruption to vessel traffic lasts till the end of April, before the situation then improves gradually over the coming months). Key Export Trends The Middle East has been a key and growing products exporter in recent years. Shipments from the region grew by a CAGR of 3.4% across 2015-2025 to reach 4.5m bpd, supported largely by expansion in regional refinery capacity (notably in Saudi Arabia, the United Arab Emirates and Kuwait). Meanwhile, European exports have softened in recent years, with shipments falling by a CAGR of 2.1% on the back of refinery closures (exports fell 6% in 2025 to stand at 4.6m bpd). Exports from North America have been steadier, having grown in recent years (5-year CAGR: 3.2%) as trade flow shifts related to the Russia-Ukraine conflict boosted European demand for U.S. products. Elsewhere, Russian exports fell further in 2025, as Ukrainian drone attacks on Russian refineries led to outages and saw reduced shipments – over the past 10 years, Russian exports have fallen by a CAGR of 0.9%. Asian exports have also edged up in recent years, rising by a CAGR of 0.5% across 2015-2025 to stand at 6.3m bpd. In 2025, oil product exports fell by 1.6% on the back of outages in key exporter countries such as Russia and Kuwait as well as lower European exports due to refinery closures. Start-2026 forecasts were for a gradual recovery in exports led by refinery capacity expansion in the Middle East, alongside India – there was also some potential for some limited additional volumes from Nigeria following the ramp-up of Dangote. However, the reduction in oil flows through the Strait of Hormuz alongside attacks on refineries as well as export bans in Asia all seem set to pressure oil product trade volumes in the near-term. Oil products exports are provisionally projected to fall on an annual basis (by 3-4%) though significant variation across the year is likely. 84 Table of Contents Trading Patterns The average distance (or ‘haul’) of seaborne oil products trade has trended up significantly in recent years. Overall oil products average haul stood at 3,530 miles in 2025, up 21% since 2020, as the impact of Russia-related trade pattern shifts lent significant support (Russia-related trade flow shifts led to a ~14% uplift in oil products tonne-mile demand across 2022-23), while disruption related to Red Sea re-routing supported average haul trends after the onset of re-routing in late 2023 and into 2024, though this ‘uplift’ tapered over time on the back of increased levels of inter-regional trade. Refinery capacity changes have also seen increased trades on longer-haul routes, with increasing capacity in the Middle East a particularly supportive driver (the average haul of Middle Eastern exports stands close to 5,000 miles, well above global average haul). In 2025, products average haul held steady as strong growth in Middle East – East Asia trade was offset by lower Russian exports. Initial expectations for 2026 were for continued average haul growth, with refinery closures in the United States and Europe stimulating additional long-haul trades. However, given the current situation in the Middle East, oil products average haul trends are subject to significant uncertainty. Exports from the Middle East are typically long-haul and so the reduction in Middle Eastern flows would ordinarily pressure oil products trade average haul. However, it is likely that some long-haul replacement flows are also likely to emerge (e.g., USG-Asia / Europe - Asia) and this is likely to provide some support for tonne-mile demand. 85 Table of Contents Trends In Refining Capacity Trends in refinery capacity and throughput levels are a key driver of seaborne products trade patterns. At the start of March 2026, global refinery capacity totalled an estimated 101.8m bpd. Over a third of this capacity was located in Asia, with significant capacity also located in North America, Europe and the Middle East. Global refinery capacity has generally expanded steadily over time to meet underlying growth in consumption of oil products, and has grown by around 7m bpd since 2015, although capacity did contract in 2020 and 2021 amid impacts from the COVID-19 pandemic and also in 2025, following the impacts of closures in Europe and the US. In the past decade, the Middle East, Asia and Africa have driven most of the growth in refining capacity. Chinese refining capacity (17m bpd currently) surged during the 2010s, though growth has been slower in the 2020s amid maturing oil demand with a couple of refineries closing in 2024. In the Middle East, refinery capacity has grown by ~3m bpd over the past decade, following the start-ups of the Al Zour refinery in Kuwait and Duqm in Oman in recent years. Other recent refinery start-ups include Dangote refinery in Nigeria (0.65m bpd currently, with further phases proposed) and the Dos Bocas development in Mexico (0.35m bpd capacity, which started up in 2023 but took time to ramp-up). Refinery capacity in the United States and Europe both fell back last year, following closures at LyondellBasell’s 264,000 bpd Houston facility and Phillips 66’s Los Angeles 139,000 bpd plant while the 150,000 bpd Grangemouth site in the UK shut down in 2025. Global refining margins improved marginally in 2025 amid the impacts of refining closures while increased crude oil production also supported, following pressured margins during 2024 when OPEC+ cuts, slowing oil demand growth and refinery capacity growth impacted margins. Steady expansion in global refinery capacity is expected in coming years, driven largely by refinery expansion/development projects in India, China and Africa. Global capacity was provisionally projected to expand by ~1.5% across 2026, with expected start-ups scheduled to come online later in 2026 including projects in India, including Panipat (0.3m bpd capacity currently, rising to 0.5m bpd) and Gujarat (0.28m bpd, increasing to 0.36m bpd) as well as Panjin (0.3m bpd) in China. However, conflict in the Middle East could impact projections, with 3% of global refinery capacity currently offline due to attacks in March and depending on how long this capacity is off-line. Oil Price Trends Developments in the oil price environment can also impact seaborne oil products trade. Oil prices softened further during 2025, on the back of increased oil production (amid the unwinding of OPEC+ curbs, alongside continued growth in Atlantic supply) while demand growth was relatively moderate. Overall, oil supply grew by 2.3% last year, versus a 0.7% gain in demand, with the price of Brent crude softening to $68/bbl across last year, the lowest level in 5 years. However, in early 2026, the conflict in the Middle East and disruption to oil flows through the Strait of Hormuz has led to significant oil price gains – by late March, prices were standing at ~$110/bbl, up from around $60/bbl at the start of 2026. 86 Table of Contents Trends in inventory levels also shape products trade trends. After products inventory levels built significantly during the first half of 2020 due to impacts from the COVID-19 pandemic on oil demand, inventories then eased back over the next couple of years. In the US, inventories have increased in recent years whereas inventories have remained low in Europe. In 2026, IEA member countries agreed to release 400m bbl of oil stocks to combat shortages related to the Middle East conflict (~100m bbl of which was oil products) – while some of these stocks are likely to be used domestically, the drawdown could create tanker demand requirement when volumes are traded internationally. Further stock releases are possible if oil flows through the Strait of Hormuz remain low for a prolonged period. Note (1): March 2026 Brent price as of 27th March 2026 Product Tanker Supply Tanker supply is determined by the size of the existing fleet as measured by cargo carrying capacity. It is influenced by a variety of factors, primarily the size of the existing fleet, the rate of deliveries of newbuilds, scrapping, and other operating efficiency factors (for example, storage, time in port or repair yards, congestion and vessel speed) which can influence the level of ‘active supply’ or ships available for charter. The global oil tanker fleet is generally divided into several key vessel types, distinguished principally by carrying capacity. The major types of crude and product tankers are shown in the following table. Crude and Product Tanker Vessel Types Class of Tanker Cargo Capacity (DWT) Typical Use Ultra Large Crude Carriers (“ULCCs”) > 320,000 Long-haul crude oil transportations from the Middle East Gulf, West Africa and the Americas, with main destination being the Far East and Northern Europe. Very Large Crude Carriers (“VLCCs”) 200,000 - 319,999 Suezmax 125,000 - 199,999 Medium-haul crude oil transportations from the Middle East Gulf, West Africa, Black Sea, Mediterranean and the United States. Longer-haul shipments from Russia to Asia have increased since the onset of the war between Russia and Ukraine. Aframax/LR2 85,000 - 124,999 Short-to-medium haul crude oil trades, with major trade routes including intra-regional routes in Europe, the United States/Caribbean, and Asia and growing volumes from the US to Europe and elsewhere. Long-haul shipments from Russia to Asia are also often carried on Aframaxes. LR2 tankers typically trade clean products on medium-to-long haul routes, e.g., from the Middle East Gulf to the Far East or Europe. Panamax/LR1 55,000 - 84,999 Carriage of crude oil and clean and dirty petroleum products cargoes. Transportations often carried out on the Caribbean to U.S. trade lane, along with North Sea, Far East and Mediterranean routes. Large volumes of clean products also carried from the Middle East to Asia or Europe. MR 40,000-54,999 Flexible vessels involved in medium-haul petroleum products trades both in the Atlantic Basin and intra-Asian/Middle East/Indian Sub-Continent trades. Short Range (SR)/Handy 25,000 - 39,999 Short-haul of mostly refined petroleum products worldwide, usually on local or regional trade routes (notably intra-Europe). Source: Clarksons Research, March 2026 87 Table of Contents The world fleet of crude and product tankers (of 10,000 dwt and above) totaled 5,934 ships of 670.3m dwt at the start of March 2026, including 2,359 crude oil tankers of 469.2m dwt, and 3,575 products tankers of 201.1m dwt. The breakdown of the crude and products components of the fleet is illustrated in the table below. The footnotes to this table detail the assumptions used. World Crude Oil and Product Tanker Fleet Class of Tanker Size (DWT) Fleet % Share of DWT Average Age (Years) % Fleet Over 15 Years Number million DWT Crude Tankers UL/VLCC (Uncoated) 200,000 + 912 280.9 41.9 % 13.5 42.6 % Suezmax (Uncoated) 125,000 - 199,999 678 106.4 15.9 % 12.8 40.0 % Aframax (Uncoated) 85,000 - 124,999 695 76.7 11.4 % 15.3 58.1 % Panamax (Uncoated) 55,000 - 84,999 74 5.2 0.8 % 17.8 76.9 % Crude Tanker Total 2,359 469.2 70.0 % 14.0 45.0 % Product Tankers UL/VLCC (Coated) 200,000 + 2 0.6 0.1 % 12.1 0.0 % Suezmax (Coated) 125,000 - 199,999 20 3.2 0.5 % 16.3 59.4 % LR2 (Coated Aframax) 85,000 - 124,999 521 57.8 8.6 % 10.6 33.2 % LR1 (Coated Panamax) 55,000 - 84,999 383 28.2 4.2 % 15.8 66.7 % Medium Range (MR) 40,000 - 54,999 1,864 90.4 13.5 % 13.4 46.6 % SR/Handy 25,000 - 39,999 435 15.9 2.4 % 18.2 73.0 % SR 10,000 - 24,999 350 5.1 0.8 % 16.0 45.1 % Product Tanker Total 3,575 201.1 30.0 % 14.1 47.6 % Total Oil Tanker 10,000 + 5,934 670.3 100.0 % 13.9 46 % Source: Clarksons Research, March 2026. Product Tanker Total refers to all vessels of 10,000+ dwt. Note (1): The product tanker fleet is classified as coated non-IMO graded tankers, IMO III graded tankers, IMO II graded tankers of 25,000 dwt and above which meet criteria: average tank size >3,000cbm, or, where average tank size is unknown, number of tanks <16 (for vessels of 25,000 dwt – 39,999 dwt), <18 tankers (for vessels of 40,000 dwt – 54,999 dwt), < 30 tanks (for vessels of 55,000 dwt – 84,999 dwt), tankers of unknown IMO grade of 25,000 dwt and above, uncoated non-IMO graded tankers below 55,000 dwt. Tankers designated as specialised tankers and all tankers with stainless steel tanks are excluded. Note (2): The data relating to product tankers is for the fleet sized 10,000 dwt and above. 88 Table of Contents The fleet of product tankers increases as a result of the construction and delivery of newbuilds to the fleet and decreases as a result of the removal of older vessels by demolition or otherwise, or through vessel loss. Over a short-term period, ‘active’ vessel supply is also affected by other factors, such as lay-up, use of vessels for oil storage, or if vessels are awaiting repairs or dry docked. Trends in vessel productivity can also influence effective supply. Although oil product tankers are capable of transporting crude oil, dirty oil products and clean oil products, the transportation of dirty products or crude oil requires significant cleaning operations, which can affect the number of ships immediately available to carry clean refined products. Crude oil tankers can also carry refined oil products once having been cleaned in accordance with applicable law. Permanent removal of a vessel can take place within a relatively short time frame, typically within three months. The construction of a newbuild products tanker, however, typically requires between 18 months and three years from contract signing to delivery of the vessel by the shipyard, depending on the schedule of the relevant shipyard’s orderbook. Product tanker fleet capacity (vessels 10,000+ dwt) grew by a CAGR of 3.2% between the start of 2016 and the start of 2026, a more moderate rate of increase than the 2000-2010 CAGR of 8.4%, when fleet growth was boosted by strong newbuild investment amid robust product tanker market conditions during 2004-2008. In recent years, product tanker fleet growth has been more moderate, averaging 2.7% p.a. across 2021-2025, largely reflecting the more limited contracting appetite in this period, though expansion picked up in 2025, with fleet capacity growth at 5.1%, as deliveries reached a 15-year high in dwt terms. This pickup in projected fleet expansion is forecast to continue in the short-term, after a notable uptick in contracting activity across 2023-2024. Considering potential trends in deliveries and scrapping, growth of 6.2% is projected in 2026, followed by another robust 6.1% in 2027. Fleet growth across 2026 is likely to be strongest in the LR2 sector (10.2% fleet capacity expansion expected in 2026), while fleet growth in the MR/Handy sector may be slightly more moderate (picking up to an expected 3.5% in 2026). However, it is anticipated that fleet growth is likely to be lower in reality, as a number of larger product tankers may trade dirty given the very firm market conditions in 2026 so far, thus limiting available tonnage to transport clean cargoes. Product tanker deliveries (vessels 10,000+ dwt) totalled 162 units of 11.3m dwt in 2025, the highest number of ships delivered since 2010 and ~71% above the ten year average of 110 units of 6.6m dwt. With 50 ships of 3.1m dwt already delivered in the first two months of 2026, the pace of deliveries is expected to increase further across 2026 (13.7m dwt currently scheduled to deliver in 2026) and 2027 (14.8m dwt, set to break 2009’s record of 14.7m dwt), supporting anticipated fleet growth. Fleet growth has also been supported by limited demolition levels in recent years. The level of ship recycling is generally impacted by current and prospective charter market conditions in relation to scrapping prices, while other factors also impact, including operating, repair and survey costs. Product tanker demolition (vessels 10,000+ dwt) has averaged 47 vessels of 2.0m dwt p.a. over the 2010s, with a recent peak of 81 units of 3.5m dwt seen in 2021 during a period of weak earnings. After a period of record low recycling volumes in 2023-2024 (averaging 6 ships of c.0.2m dwt p.a.), scrapping in 2025 reached 33 vessels of 1.7m dwt, which came as markets softened back from their very firm levels over 2022-2024 – which had played a role in holding back tonnage from scrap markets during this period. Demolition activity is expected to remain moderate across 2026-2027. Going forward, in addition to market developments, environmental regulations are eventually expected to become an increasingly important factor in ship recycling decision making, with potential for owners of older units to increasingly scrap ships as environmental and emissions regulations tighten further. Significant ‘fleet renewal’ is expected amidst an ageing product tanker fleet; at the start of March 2026 the fleet had an average age of 14.1 years (up from 9.8 years at the start of 2016), whilst 17% of product tanker fleet capacity was aged 20+ years and 48% was aged 15+ years. 89 Table of Contents Average product tanker vessel speeds have generally trended downwards over the last c.15 years, against a backdrop of periods of market pressure and an increasing focus on reducing vessel emissions. Product tanker speeds are down by ~19% since 2008, with speeds edging down in 2025. Eventual pressure from environmental regulations could lead to further downwards movement in vessel speeds going forwards, particularly for older ships. The orderbook indicates the number of vessels which have been contracted at shipyards but are yet to be delivered to owners and is indicative of how vessel supply may develop in the coming years. The product tanker orderbook (vessels 10,000+ dwt) stood at 528 vessels of 37.4m dwt at the start of March 2026, equivalent to 19% of existing fleet capacity in dwt terms. Following stronger contracting volumes across 2023-2024, the orderbook rose to 41.6m dwt at the start of 2025 (equivalent to 22% of fleet capacity) – up from a low of 9.5m dwt (5% of fleet capacity) in May 2022. The orderbook has since decreased amid firmer deliveries. World Crude Oil and Product Tanker Orderbook Class of Tanker Size (DWT) Orderbook Orderbook Delivery Schedule (million DWT) No. million DWT % of fleet 2026 2027 2028+ Crude Tankers UL/VLCC 200,000 + 199 61.3 21.8 % 9.2 19.1 32.9 Suezmax (Uncoated) 125,000 - 199,999 177 27.8 26.1 % 27.8 5.9 8.6 Aframax (Uncoated) 85,000 - 124,999 51 5.8 7.6 % 5.8 1.5 2.5 Panamax (Uncoated) 55,000 - 84,999 1 0.1 1.3 % 0.1 0.1 0.0 Crude Tanker Total 428 95.0 20.2 % 42.9 26.6 44.1 Product Tankers UL/VLCC (Coated) 200,000 + 0 0.0 0.0 % 0.0 0.0 0.0 Suezmax (Coated) 125,000 - 199,999 0 0.0 0.0 % 0.0 0.0 0.0 LR2 (Coated Aframax) 85,000 - 124,999 166 19.0 32.8 % 5.6 7.4 5.9 LR1 (Coated Panamax) 55,000 - 84,999 64 4.7 16.7 % 1.5 2.2 1.1 Medium Range (MR) 40,000 - 54,999 260 12.7 14.1 % 4.4 4.7 3.6 SR/Handy 25,000 - 39,999 21 0.7 4.4 % 0.5 0.2 0.0 SR 10,000 - 24,999 17 0.3 4.9 % 0.2 0.1 0.0 Product Tanker Total 528 37.4 18.6 % 12.2 14.6 10.6 Total Oil Tanker 10,000 + 956 132.3 19.7 % 55.1 41.2 54.7 Source: Clarksons Research, March 2026. Product Tanker Total refers to all vessels of 10,000+ dwt. 90 Table of Contents Note (1): The product tanker fleet is classified as coated non-IMO graded tankers, IMO III graded tankers, IMO II graded tankers of 25,000 dwt and above which meet criteria: average tank size >3,000cbm, or, where average tank size is unknown, number of tanks <16 (for vessels of 25,000 dwt – 39,999 dwt), <18 tankers (for vessels of 40,000 dwt – 54,999 dwt), < 30 tanks (for vessels of 55,000 dwt – 84,999 dwt), tankers of unknown IMO grade of 25,000 dwt and above, uncoated non-IMO graded tankers below 55,000 dwt. Tankers designated as specialised tankers and all tankers with stainless steel tanks are excluded. Note (2): Going forward, the orderbook may be influenced by delays, cancellations and the re-negotiation of contracts. Due to these technical and contractual issues, there is currently some uncertainty surrounding the orderbook. The figures quoted above relate to the orderbook as at March 1, 2026 and take no account for these potential delivery problems. In addition further newbuild orders will be placed going forward. Note (3): The data relating to product tankers is for the fleet sized 10,000 dwt and above. 2025 saw 121 product tankers (vessels 10,000+ dwt) of 8.6m dwt contracted, in line with the ten-year average despite easing back from 2024’s recent high of 21.4m dwt, where very firm ordering was supported by the extended period of strong vessel earnings across 2022-2024. Orders in 2025 and 2026 were placed with delivery scheduled in 2026-2031, with total product tanker deliveries in 2026-2027 projected to tick up notably, mainly in the LR2 sector. Newbuild demand is affected by newbuilding prices in relation to current and anticipated charter market conditions. Newbuild prices remain elevated, with the guideline price for an LR1 20% above the ten year average, despite having eased back 4% from 2024’s high. The table below outlines the major builders of MR tankers, ranked by orderbook: MR Tankers - Top Builders Builder Builder Country Delivered 2025 Orderbook Orderbook Delivery Schedule (million DWT) million DWT No. million DWT 2026 2027 2028+ GSI Nansha China 0.2 38 1.8 0.1 0.4 1.4 HD Hyundai Vietnam Vietnam 0.5 26 1.3 0.4 0.6 0.3 HD Hyundai (Medium) South Korea 0.1 19 1.0 0.7 0.2 0.1 K SB (Jinhae) South Korea 0.4 17 0.8 0.1 0.6 0.1 Chengxi Shipyard China 0.2 13 0.6 0.5 0.1 Jingjiang Nanyang China 12 0.6 0.1 0.3 0.2 Jiangsu New YZJ China 0.4 12 0.6 0.3 0.1 0.1 Hanwha Philly SY United States 10 0.5 0.5 COSCO HI (Dalian) China 10 0.5 0.0 0.2 0.2 Penglai Jinglu SY China 10 0.5 0.1 0.4 Top 10 % Share 42% 64% 64% 54% 63% 80% Total 4.3 260 12.7 4.4 4.7 3.6 Source: Clarksons Research, March 2026 91 Table of Contents Recent developments in the fleet and orderbook are shown below: 92 Table of Contents The overall comparison between supply growth and demand growth can be seen in the graph below: The Product Tanker Market The charter market is highly competitive and based primarily on the offered charter rate, the location and technical specification of the vessel and the reputation of the vessel and its manager. Typically, the agreed terms are based on standard industry charter parties prepared to streamline the negotiation and documentation processes. The most common types of employment structures for a tanker are spot market, COA, time charter, bareboat charter and pool employment. When employed in a pool, the vessel is part of a fleet of similar vessels, brought together by their owners in order to exploit efficiencies and benefit from a revenue sharing mechanism. The pool operator sources different cargo shipment contracts and directs the vessels in an efficient way to service these obligations. Pools can benefit from profit and loss sharing effects, sharing geographical market exposure and potentially less idle time through coordination of vessel movements, but vessels sailing in a pool remain vulnerable to adverse market conditions. Freight and hire rates for product tankers trading under spot charters are very sensitive to fluctuating demand for and supply of vessels, and rates are consequently volatile. Rates are also strongly affected by seasonal fluctuations in demand from end consumers. While trends in the product tanker market are heavily impacted by product tanker supply and demand trends, typically market conditions have also been well correlated with crude oil tanker market developments, partly reflecting the fact that some crude and products tankers have the potential to act as ‘swing tonnage’ between the crude, dirty and clean product markets. Rates and earnings in the product tanker market eased back across 2025 overall, though generally remained healthy. Average clean MR spot earnings averaged $20,907 per day, down 24% y-o-y though still 18% above the 10-year average. Markets started the year on a soft note as weak trade volumes during the first half of the year impacted market conditions. However, as the year progressed, some improvement in trade volumes (often on longer-haul trade routes, e.g., East Asia – USWC) and stronger crude tanker earnings helped to support stronger conditions in the product tanker segment - clean MR earnings averaged $23,585 per day in the fourth quarter of 2025, up 30% y-o-y. Markets have enjoyed a very strong start to 2026 as well, as very firm crude tanker earnings have incentivised an increased number of LR2s to trade dirty, while increased trade volumes (amid increased oil production and demand) have also been supportive. Average clean MR spot earnings have averaged $33,557 per day in 2026 so far, close to some of the strongest quarters on record. In particular, Atlantic markets have been very strong in recent weeks, with strong U.S. product exports, high refinery margins and the recent relaxation of Jones Act restrictions supporting demand. LR markets have generally seen similar trends, with earnings generally softer across the first half of 2025 before strengthening in the second half of last year, with further improvement seen during early 2026. Since the start of the Middle East conflict, LR2 liftings have fallen significantly, with a significant share of LR2 demand originating from the Middle East and rates on some ex-Asia routes had begun to ease by late March. 93 Table of Contents Premiums for scrubbers and ‘eco’ engines also remain. Vessels fitted with scrubbers and those built with ‘eco’ specifications are generally able to achieve premiums on these levels. For example, clean earnings for a c.2015-built ‘eco’ scrubber-fitted MR averaged $23,856 per day in 2025, compared with $19,363 per day for a c.2010-built unit (non-‘eco’, non-scrubber fitted). The vessels used in the time charter estimates are standard modern vessels in this market sector. Clarksons Brokers estimate time charter rates each week for these standard vessels, which is informed by transactions and ongoing negotiations associated with vessels of similar size. There is no guarantee that current rates are sustainable and rates may increase and decrease significantly over short periods of time. Product tanker asset values have also fluctuated over time and there is a relationship between changes in asset values and the charter market. Newbuilding prices remain at elevated levels, with price assessments edging up through late 2025 and into early 2026 after softening during early 2025. In March 2026, the guideline newbuilding price for an MR stood at $50m, up 47% since the start of 2020, with a prolonged period of elevated newbuild appetite across various shipping segments, long orderbooks at yards and increases in the cost base at yards providing support. Meanwhile, secondhand product tanker prices picked up materially over the past six months. The guideline price for a 5-year old secondhand MR tanker stood at $47m in March 2026, up 15% versus levels seen a year ago and 45% above the 10-year trend. Asset values for LR and Handy tankers have followed similar trends to MR tankers. 94 Table of Contents The following tables summarise recent market developments relating to Handy, MR and LR1 product tankers for both charter rates and asset values. Handy Product Tankers: Timecharter and Asset Value Summary Table Spot Timecharter (US$/day) Asset Prices (US$ million) Earnings 1 Year 3 Year 5 Year Old 10 Year Old 2015 22,094 15,880 15,250 25.0 17.0 2016 8,962 13,998 14,264 19.0 14.0 2017 7,380 11,430 12,841 22.0 13.0 2018 6,734 11,572 12,750 24.0 14.0 2019 14,560 13,425 12,938 25.0 15.0 2020 13,881 12,995 13,399 23.0 14.0 2021 7,930 10,797 12,854 25.0 14.5 2022 45,087 17,774 14,346 34.0 23.0 2023 40,512 24,947 17,760 38.0 29.0 2024 25,215 26,192 19,563 37.0 27.0 2025 20,925 18,120 16,567 39.0 29.0 2026 YTD* 36,956 20,542 16,188 45.0 35.0 March-2026 60,132 22,000 16,750 45.0 35.0 5 Year Avg 28,859 19,883 16,313 34.2 24.8 5 Year Peak 96,711 28,000 23,250 45.5 36.0 5 Year Trough 2,525 10,250 12,250 23.0 13.5 10 Year Avg 19,443 16,181 14,730 28.6 19.6 10 Year Peak 96,711 28,000 23,250 45.5 36.0 10 Year Trough 333 10,250 12,250 19.0 13.0 20 Year Avg 18,360 16,115 15,213 29.0 20.0 20 Year Peak 96,711 28,000 23,250 47.0 37.0 20 Year Trough 333 10,000 10,500 19.0 12.0 *YTD January - March 2026 Source: Clarksons Research, March 2026. Note (1): All earnings are basis annual or monthly averages, with values basis end period. MR Product Tankers: Timecharter and Asset Value Summary Table Spot Timecharter (US$/day) Asset Prices (US$ million) Earnings 1 Year 3 Year Newbuild 5 Year Old 2015 21,405 17,769 16,409 35.5 29.0 2016 12,124 15,092 15,212 32.5 22.0 2017 10,220 13,219 14,000 33.8 25.0 2018 8,750 13,120 14,154 36.5 27.5 2019 13,740 14,683 14,714 35.8 30.0 2020 15,251 14,440 14,930 34.0 26.0 2021 6,740 12,429 13,545 41.0 29.0 2022 31,775 20,570 16,123 43.5 40.0 2023 28,933 26,832 22,034 47.5 43.5 2024 27,484 27,589 23,880 52.0 42.0 2025 20,907 19,654 17,481 49.0 43.0 2026 YTD* 33,557 24,417 18,833 50.0 47.0 March-2026 51,299 31,583 21,750 50.0 47.0 5 Year Avg 24,067 21,776 18,774 45.8 39.1 5 Year Peak 59,518 31,250 26,250 52.0 50.5 5 Year Trough 3,185 11,750 13,500 34.3 27.5 10 Year Avg 17,827 17,842 16,634 40.2 32.8 10 Year Peak 74,081 31,250 26,250 52.0 50.5 10 Year Trough 3,185 11,625 13,500 32.5 22.0 20 Year Avg 16,681 17,751 16,936 40.0 33.0 20 Year Peak 74,081 31,250 26,250 53.5 54.0 20 Year Trough 3,185 11,500 12,500 32.5 22.0 *YTD January - March 2026 95 Table of Contents Source: Clarksons Research, March 2026. Note (1): All earnings are basis annual or monthly averages, with values basis end period. LR1 Product Tankers: Timecharter and Asset Value Summary Table Spot Timecharter (US$/day) Asset Prices (US$ million) Earnings* 1 Year 3 Year Newbuild 5 Year Old 2015 24,847 23,567 20,510 45.0 35.0 2016 12,903 18,116 17,715 41.0 28.0 2017 8,247 13,077 14,875 41.5 28.0 2018 8,397 12,962 14,500 44.0 30.0 2019 15,147 16,635 15,233 44.5 32.5 2020 19,858 16,918 16,288 42.5 29.0 2021 7,052 13,583 15,625 51.0 31.0 2022 33,338 25,236 20,423 54.0 45.0 2023 28,155 32,707 26,188 57.5 51.0 2024 30,121 34,077 28,606 62.0 53.0 2025 22,078 21,534 18,743 59.0 48.0 2026 YTD* 44,398 28,688 21,708 60.0 55.0 March-2026 78,733 38,250 23,917 60.0 55.0 5 Year Avg 25,484 25,906 22,107 55.8 45.2 5 Year Peak 110,914 42,500 32,000 62.0 58.0 5 Year Trough 566 12,750 15,625 43.0 30.0 10 Year Avg 18,904 20,547 18,822 49.4 37.6 10 Year Peak 114,370 42,500 32,000 62.0 58.0 10 Year Trough 566 12,500 14,375 41.0 26.5 20 Year Avg 18,755 20,568 19,373 49.5 38.8 20 Year Peak 114,370 42,500 32,000 68.0 62.0 20 Year Trough 566 12,500 14,000 40.5 24.0 *Basis LR1 Ras Tanura-Chiba Route, **YTD January -March 2026 Source: Clarksons Research, March 2026. Note (1): All earnings are basis annual or monthly averages, with values basis end period. Competitive Landscape The product tanker market is comprised of a variety of ship owners and operators of varying sizes. A vessel is either operated directly by the owner, or by a third party. This includes the use of commercial pool management. Pools are an important feature of the product tanker market, and have been relatively successful compared to other sectors. Pools are arrangements in which owners work together to organise the commercial management of a group of vessels, allowing them to share revenues, while potentially minimising idle time. Conversely, the decision not to compete can mean that pooled vessels are prone to sharing the effects of any adverse market conditions. The leading owners within the product tanker market are detailed below. Ownership of product tankers is more consolidated than in the bulk carrier sector. The below table reflects the ownership of vessels and therefore, vessel operators who have financed one or more vessels through sale and lease-back arrangements may operate a higher number of vessels than the number of vessels listed in the respective segments below. Additionally, some of the owners listed in the below tables are not operators of vessels and therefore not competitors in the market for the operation of product tankers. Certain tankers capable of carrying chemicals are not included in the below tables. 96 Table of Contents Top Handy Product Tanker Top MR Product Tanker (25,000-39,999 dwt) Owners (40,000-54,999 dwt) Owners Name Fleet & Orderbook Name Fleet & Orderbook Number m DWT Number m DWT Waruna Nusa Sentana 27 0.96 TORM A/S 58 2.89 Scorpio Tankers 14 0.54 Scorpio Tankers 46 2.27 Maersk Tankers 10 0.39 COSCO Shpg Energy 48 2.27 Evalend Shipping 8 0.30 Sinokor Merchant 45 2.24 Navi Montanari 7 0.27 Nissen Kaiun 40 2.00 IMS SA 7 0.27 Hafnia Limited 38 1.90 Hafnia Limited 6 0.23 CMG Nanjing Tanker 39 1.88 Spring Marine Mgmt 6 0.23 Intl Seaways 31 1.55 Iver Ships BV 6 0.22 Pertamina Intl Shpg 23 1.11 Transka Tankers 6 0.22 Eastern Pacific Shpg 21 1.05 Top 10 % Share 21.3% 22.0% Top 10 % Share 18.3% 18.6% Total 456 16.58 Fleet Total 2,124 103.09 Source: Clarksons Research, March 2026 Top LR1 Product Tanker Top LR2 Product Tanker (55,000-84,999 dwt) Owners (85,000-124,999 dwt) Owners Name Fleet & Orderbook Name Fleet & Orderbook Number m DWT Number m DWT Hafnia Limited 24 1.80 Scorpio Tankers 38 4.20 Dynacom Tankers Mgmt 22 1.63 TORM A/S 21 2.45 COSCO Shpg Energy 17 1.26 Eastern Pacific Shpg 20 2.24 Tsakos Energy Nav 14 1.03 Navios MLP 18 2.07 d’Amico Intl Shpg 10 0.75 Minerva Marine 18 2.03 Evalend Shipping 10 0.75 Frontline 18 1.98 Intl Seaways 10 0.75 Cido Shipping 16 1.84 TORM A/S 10 0.74 Dynacom Tankers Mgmt 16 1.84 Navios MLP 8 0.60 Union Maritime 16 1.81 CMG Nanjing Tanker 8 0.54 COSCO Shpg Energy 16 1.75 Top 10 % Share 29.8% 29.9% Top 10 % Share 28.7% 28.9% Fleet Total 447 32.94 Fleet Total 687 76.77 Source: Clarksons Research, March 2026 97 Table of Contents C. Organizational Structure Hafnia is the parent company of our subsidiaries. See Exhibit 8.1 for a list of our material subsidiaries and material companies in which we have a 50% (direct or indirect) ownership interest or voting rights interest as at December 31, 2025 and their respective jurisdictions of formation. We note that in addition to the subsidiaries listed in Exhibit 8.1, we have made investments in a number of companies where our ownership and voting interest is below 50%. In the past, we have for example invested in projects relating to the production of green energy and projects regarding the development of technologies that can possibly be used in our business in a short, medium, or long-term perspective. We do not consider these investments a material part of our business. D. Property, Plant and Equipment We own no material property other than our Hafnia Vessels, shares in our joint ventures and shares in other companies. We lease office space in various jurisdictions and had the following material leases in place as at December 31, 2025: • Singapore: 10 Pasir Panjang Road, #18-01 Mapletree Business City, Singapore 117438 • Copenhagen: Hans Bekkevolds Alle 7, 2900 Hellerup, Denmark • Houston: 1800 West Loop South, Suite 1925, Houston, Texas 77027, United States of America • Dubai: Tamweel Tower, #304, Cluster U, Jumeirah Lake Towers, Dubai, United Arab Emirates. Patents, Licenses and Trademarks We have no material patents and do not use any licenses other than ordinary information technology licenses. We do not have a trademark registration of our name (Hafnia) or logo. We have usage rights to our logo. We have registered our primary domains: hafnia.com, hafniatankers.com and hafniabw.com. None of the information contained on our website is incorporated into or forms a part of this Annual Report. Facilities We are not aware of any environmental issues or other constraints that would materially impact the intended use of our facilities.