Consolidated Sustainability Statement HAL Trust

General information

The consolidated sustainability statement presented is that of HAL Trust (the ‘Trust’), a Bermuda trust, and its subsidiaries as well as the interests in associates and joint ventures to the extent relevant. For the year presented, the Trust’s only asset is all outstanding shares of HAL Holding N.V. (‘HAL’ or the ‘Company’), a Curaçao corporation based in Rotterdam. Accordingly, the consolidated sustainability statement of the Trust is identical to that of the Company. The consolidated sustainability statement forms an integral part of the Report of the Executive Board of the Company and has been presented in a separate section to enhance transparency and comprehensibility. In this consolidated sustainability statement, the term “Group” is solely used to indicate a reporting boundary of the sustainability statement that comprises the entities included in its financial consolidation.

Sustainability strategy and governance

HAL considers responsible behavior with respect to sustainability matters part of good business practice. HAL’s approach with respect to sustainability in its investment strategy can be summarized as follows:

As an active long-term shareholder, HAL expects its investee companies to structurally improve on all material aspects of sustainability, in order to create long-term value.

Sustainability strategy

In accordance with the decentralized management approach described in the section Administrative organization, risk management systems, sustainability and (non-) financial reporting on page , it is the management of each investee company who are responsible for their strategy and its execution. At the same time, the above statement addresses the fact that HAL considers sustainability an important element of long-term value creation and therefore expects investee companies to have a clear view on their material sustainability matters and to improve their performance on these matters.

Insight into the strategic sustainability framework of HAL as a standalone company is provided to enhance understanding of its focus areas regarding sustainability, including its approach toward investee companies throughout the investment life cycle. For HAL as a standalone company, the key impact of HAL on sustainability is through the allocation of its human and financial resources throughout the investment life cycle. Therefore, sustainability considerations are further embedded in the investment (management) process. For HAL as a standalone company the material sustainability matters are defined as follows:

• Sustainability in the investment life cycle (at due diligence and during ownership)
  HAL views sustainability holistically and therefore as an integral part of its operations and the (future) success thereof. HAL has the objective to structurally and explicitly take sustainability considerations into account when assessing, selecting and managing its investments;

• Employee engagement
  HAL strives to be an organization that offers equal opportunities to its employees whilst building engagement;

• Sustainability training
  HAL developed and maintains a sustainability training curriculum for its investment team members, enhancing their ability to effectively address sustainability matters in their daily responsibilities, including the assessment, selection and management of investments;

• Information security
  HAL expects and demands high standards of information security from its employees, suppliers and advisors. Additionally, HAL routinely engages external experts to conduct active security testing on its information technology environment;

• Greenhouse gas emissions
  HAL periodically reviews how to reduce its own emissions and compensate its remaining emissions; and

• Business ethics
  HAL expects and demands high standards of integrity and ethical behavior from all HAL employees. It is HAL’s policy to comply with all applicable laws, including but not limited to those with respect to employment, human rights, privacy, anti-discrimination, health, anti-trust, securities fraud, corruption and bribery.

These material sustainability matters are, together with the material sustainability matters from the consolidated investee companies, input to the Group double materiality assessment (refer to the section Group double materiality assessment on page ). This sustainability statement does not include standalone reporting on the material sustainability matters of HAL as a standalone company and provides insight in the material sustainability matters of the Group.

With respect to its investment portfolio, HAL continues to have a decentralized management approach. Therefore, it is the management of each investee company that addresses and manages their material sustainability matters, and it is their responsibility to include these in their business strategies, in order to allow integration of key sustainability value drivers into a sustainable business model and strategy. It is the responsibility of the supervisory boards of the investee companies to monitor this strategic process and its subsequent outcomes. Through its representation on the supervisory boards of the investee companies, HAL aims to support their sustainability ambitions and strategy and to monitor progress made. To safeguard a structural approach to sustainability, HAL expects investees to include the following focus areas in their approach to sustainability:

• Governance
  Investees should integrate sustainability in roles, responsibilities and performance evaluations;

• Materiality assessment
  Investees should be aware of the context they operate in and identify their material sustainability matters;

• Strategy and business model
  Investees should have a sustainability strategy aligned with, or integrated in, the corporate strategy in order to capitalize on sustainability opportunities and mitigate sustainability risks; and

• Performance and risk management
  Investees should have meaningful and ambitious targets for their material sustainability matters and corresponding policies, procedures and action plans. Investees should be aware of their sustainability-related risks and identify and capture those in their risk management framework and have mitigating controls in place.

When selecting investment candidates, the approach of a potential investee company to its material sustainability matters, which affects its long-term performance and valuation potential, is part of the due diligence process of HAL and is considered in the ultimate investment decision. New investee companies are expected to have a structural approach to sustainability in their strategy, by including the focus areas as mentioned above within three years after acquisition.

Sustainability governance

Reference is made to the section on Managing impacts, risks and opportunities on page for a description of the administrative procedures, risk management and internal control systems associated with the Company’s (sustainability) strategy and its implementation, and external reporting.

Group double materiality assessment

The Group double materiality assessment refers to the process whereby the Company establishes the sustainability matters where the Group has significant positive or negative (potential) impact on people or the environment (impact materiality perspective), and those matters that (potentially) pose significant risk or opportunity to the Group (financial materiality perspective).

Impact materiality
A sustainability matter is material to the Group from an impact perspective when it pertains to the Group’s material actual or potential, positive or negative impacts on people or the environment over the short, medium or long term. Impacts include those connected with the Group’s own operations and value chain, including through its products and services, as well as through its business relationships. Business relationships include those in the Group’s upstream and downstream value chain and are not limited to direct contractual relationships. They include indirect business relationships in the Group’s value chain beyond the first tier, and shareholding positions in joint ventures, associates and other investments.

For actual impacts, materiality is based on the scale, scope and (for negative impacts) the irremediability of the impact, whereas for potential impacts also likelihood is considered. In the case of a potential negative human rights impact, scope and scale take precedence over likelihood.

Financial materiality
A sustainability matter is material from a financial perspective if it triggers or could reasonably be expected to trigger material financial effects on the Group. This is the case when a sustainability matter generates risks or opportunities that (could reasonably) have a material influence on the Group’s financial position, performance, cash flows, or access to or cost of capital. The scope of financial materiality for sustainability reporting can be seen as an expansion of the scope of materiality used in the process of determining which information should be included in the Group’s consolidated financial statements.

In the context of the double materiality assessment, the term impact may relate to both positive and negative sustainability-related impacts and the term financial may relate to both sustainability-related financial risk and opportunities. A sustainability matter is material to the Group when it is material from an impact perspective, a financial perspective, or both.

Group approach to double materiality assessment
The Group material sustainability matters are the main driver for the required disclosures of sustainability information in the consolidated sustainability statement and HAL applied a stepped approach to determine these. In accordance with HAL’s decentralized management approach, HAL as a standalone company and each of its consolidated investee companies performed their own materiality assessment, applying the double materiality principle. HAL supported these local processes by providing targeted training, developing relevant guidance and templates, and sharing expertise directly with investee management and dedicated staff, complementing any external support already secured at the local level. These materiality assessments are based on stakeholder engagement, involving both affected stakeholders and anticipated users of sustainability information, including suppliers, customers, employees, authorities, non-governmental organizations and capital providers. From this granular process, a longlist of material sustainability matters, including associated impacts, risks and opportunities from consolidated investee companies was compiled to serve as input to the Group double materiality assessment. This list is a reflection of the local assessments of scale and scope, and where relevant likelihood and irremediability for impacts and a combination of magnitude and likelihood for risks and opportunities, considering the financial effects in the short- medium- and long-term.

Subsequently, HAL mapped the impacts, risks and opportunities reported by its consolidated investee companies to Group sustainability matters, in order to perform an assessment to determine the material sustainability matters for the Group reporting. This assessment was based on detailed definitions of the material sustainability matters and related impacts, risks and opportunities as reported by the consolidated investee companies. Where necessary, discussions were held with the management of consolidated investee companies to enhance the understanding of investees’ material sustainability matters, as well as their related impacts, risks, and opportunities. These discussions facilitated the appropriate clustering of individual material sustainability matters into group-level sustainability matters, ensuring the identification of those matters deemed material for the Group as a whole. With respect to weighting of material sustainability matters, both quantitative and qualitative considerations were applied. Reference is made to the section Assessment at Group level on page for more details on the Group assessment performed for this consolidated sustainability statement.

This stepped approach both respects the governance and management approach of HAL towards its consolidated investee companies and safeguards the involvement of stakeholders that are relevant to the diverse industries, business models and value chains of these companies. Reference is made to the section Group material sustainability matters (DMA results) on page for an overview and explanation of the material sustainability matters and related impacts, risks and opportunities for group reporting.

The Group double materiality assessment is subject to annual review, and updated as required, and a comprehensive assessment will be conducted every three years, or earlier if changes in the Group’s composition warrant this. This approach ensures that the material sustainability matters and the related impacts, risks and opportunities as well as the material information to be included in the sustainability statement are validated annually. In the absence of significant changes in organizational and operational structures or external factors, the outcome of the previous year’s double materiality assessment will remain applicable. However, the process remains adaptable to incorporate necessary adjustments should new developments materially influence the identified impacts, risks, opportunities, or the relevance of specific disclosures.

Based on the outcomes of the Group double materiality assessment described above, HAL has determined the topical European Sustainability Reporting Standards (ESRS) that are relevant to the Group’s material sustainability matters, the disclosure requirements and application requirements within those standards that apply and the datapoints that are significant to the plans and performance related to the Group’s material sustainability matters.

Material sustainability matters at investee level

Due to the diversity in industry, size, culture, geographical location and development stage of the companies in which HAL has interests, the material sustainability matters, including impacts, risks and opportunities, vary among the investee companies. Consequently, a sustainability matter that is considered material at Group level may not be relevant at investee level, and vice versa. To provide further insight into sustainability matters that were not significant at Group level, summarized information regarding the material sustainability matters of Boskalis and Vopak is included in Annex I on page . This additional disclosure on Boskalis and Vopak is based on their relative size within the Group. In the event of significant changes in the financial performance of these companies or in the composition of the Group, the weighting of these material sustainability matters may change, potentially impacting the outcome of the Group’s double materiality assessment, as described below.
Additionally, readers seeking more detailed (performance) information on material sustainability matters of individual investee companies are encouraged to refer to the sustainability reports issued by several of the investee companies themselves, including Boskalis, Vopak, Anthony Veder and Ahrend.

Impact of acquisitions and divestments

On October 21, 2024, Boskalis completed the acquisition of Smit Lamnalco. Boskalis has been 50% shareholder in Smit Lamnalco since 1963 and through this transaction acquired all remaining shares. Smit Lamnalco was considered in the review of the Boskalis double materiality assessment in 2024, which contributed to the Group double materiality assessment. The consolidation of Smit Lamnalco did not affect the outcome of the materiality assessment at the level of Boskalis.

On September 20, 2024, HAL transferred its entire shareholding in Pro Gamers Group to one of the existing lenders of this company as part of a financial restructuring. Pro Gamers Group was therefore excluded from the 2024 Group double materiality assessment. This did not affect the outcome of the double materiality assessment compared to previous year.

On February 29, 2024, Boskalis acquired a 100% interest in ALP Maritime Group B.V. (‘ALP’). The company is a specialist in marine services and operates a fleet of 8 powerful long-distance towing and anchor handling vessels. ALP was considered in the review of the Boskalis double materiality assessment in 2024, which contributed to the Group double materiality assessment. The consolidation of ALP did not affect the outcome of the materiality assessment at the level of Boskalis.

On March 14, 2023, HAL completed the acquisition of IQIP, a supplier of foundation and installation equipment to the offshore wind, coastal & civil and oil & gas markets. On August 11, 2023, HAL announced it had agreed to sell 40% of IQIP. Consequently, IQIP was classified as held for sale at the end of 2023. In 2024, the parties involved agreed to terminate the agreements (refer to note 3) and the classification of IQIP as held for sale was discontinued. As a result, IQIP was included in the Group double materiality assessment of 2024. This did not affect the outcome of the double materiality assessment compared to previous year.

Assessment at Group level

HAL performed a Group double materiality analysis in 2024. In defining the potential Group material sustainability matters, HAL clustered consolidated investees’ material sustainability impacts, risks and opportunities in overarching Group sustainability matters, ensuring the preservation of key aspects from investees’ materiality assessments. This approach ensures that the sustainability matters remain specific and concrete to maintain their relevance, while enabling the identification of common priorities across the Group.

Quantitative assessment
A quantitative assessment was performed on both impacts and risks and opportunities, reviewing the significance of a related potentially material sustainability matter in respect of the Group’s three-year (actuals of 2022 and 2023 and forecasted 2024) average revenues, year-end assets and full-time equivalents (FTE). A three-year average dataset is used as this more accurately reflects the group’s composition, reducing the impact of temporary fluctuations. This assessment considered the following factors:

• the aggregate three-year average revenues of the companies reporting the sustainability matter;

• the aggregate three-year average total assets at year-end of these companies; and

• the aggregate three-year average FTE at year-end of these companies.

These indicators are deemed appropriate as these are commonly applied in legislation and classification, including the determination of whether a company is in scope of the Corporate Sustainability Reporting Directive (CSRD). The three-year average figures have been adjusted for the impact from the acquisitions of Boskalis and IQIP, by adding the data for the full three years, as well as the impact from divestments, by excluding data of GrandVision, Floramedia, Livit, MYLAPS and Pro Gamers Group from these analyses.

A sustainability matter was deemed likely material if, in aggregate, it affected at least 60% of the Group’s average revenues, total assets or number of FTE over the three-year period. This threshold was determined by the Executive Board of HAL to capture the material sustainability matters and their related impacts, risks and opportunities that are relevant to the majority of the Group. A lower threshold would have led to the identification of more material sustainability matters, reference is made to the visual representation of the results of the quantitative assessment, below. As impacts, risks, or opportunities that occur less frequent or that are specific to smaller companies may be classified as non-material, the consolidated focus remains on sustainability matters that are broadly material across the Group. To ensure no individual impacts, risks or opportunities were overlooked that could potentially have a material impact on the environment or society (impact materiality perspective) or on the Group (financial materiality perspective), for example because they did not allow for proper aggregation, an additional qualitative assessment was performed at the impact, risk and opportunity level. Refer to the section Qualitative assessment below for more details.

The results of the quantitative assessment are as follows:

Qualitative assessment
A qualitative assessment was performed on the longlist of impacts, risks and opportunities identified as material at consolidated investee companies. This assessment aimed to evaluate (potential) impacts of materiality matters that are specific to an individual company or otherwise challenging to aggregate, to determine whether these might still be significant enough to meet the Group materiality threshold. Additionally, a reputational risks assessment was performed, to identify where structurally inadequate management of a sustainability matter by HAL or its consolidated investee companies could result in negative public perception and loss of trust and credibility, adversely affecting business opportunities, funding options and staff retention. Finally, an assessment was made whether there were any material (potential) financial effects that were not covered by the quantitative assessment.

Qualitative weightings applied were low, medium and high for:

• Impacts

  • individual impacts that cannot be aggregated; and if so

  • their materiality to the Group threshold

• Reputational risks:

  • scale: how grave the impact is on the reputation if the risk materializes;

  • scope: how widespread the impact of the risk is;

  • irremediability: whether and at which cost the reputational damage could be remediated; and

  • likelihood of occurrence: the probability that this reputational risk will materialize.

• Financial effects not covered in quantitative assessment

  • materiality of (expected) financial effects that are not covered in the quantitative assessment (e.g. future financial effects)

When assessing reputational risk, the key consideration is the impact of appropriately managing impacts, risks, and opportunities over the longer term, rather than the effect of individual events. In taking this approach, responsible behavior and good governance are regarded as fundamental business practices that foster long-term value creation. This approach is embedded in HAL’s governance and strategy and was reaffirmed through stakeholder engagement at the level of HAL as a standalone company. The identified key stakeholders for HAL as a standalone company, their relationship with HAL, and the strategy for stakeholder engagement can be defined as follows:

A sustainability matter is deemed material if the related impact, risk or opportunity is deemed high taking into account all of the considerations above.

From this qualitative assessment one sustainability matter, Occupational health and safety, was identified as material that was not yet identified as material in the quantitative analysis. This matter relates to the impact on health and well-being of employees and of non-employees working on-site and financially particularly in terms of operational efficiency, regulatory compliance and reputation. This decision is based on the higher reputational risk associated with industries in which the larger investee companies operate (construction, production, marine services, and fuel and chemical storage), the potential impact of insufficient health and safety management on individuals’ lives and the reputation of the individual company, and the significant measures investee companies have implemented to mitigate these risks.

Although already classified as material, based on the quantitative assessment, the qualitative assessment further confirmed the materiality of the sustainability matter Business ethics.

There were no other individual impacts, risks or opportunities defined as material for the Group.

Group material sustainability matters (DMA results)

Based on the quantitative and qualitative assessments, the following sustainability matters were considered material for the Group and form the basis for the 2024 sustainability statement.

The material impacts, risks and opportunities related to the Group material sustainability matters are as follows:

The stepped approach to double materiality both respects HAL’s governance and management approach towards its consolidated investee companies and safeguards the involvement of stakeholders relevant to the diverse industries, business models, and value chains of these companies. The number of Group material sustainability matters identified reflects the diversity of the consolidated investee companies and their business models, whilst capturing the impacts, risks, and opportunities relevant to the broad majority of the Group. In this context, the Executive Board considers these matters to provide an appropriate foundation for the consolidated sustainability statement.

Managing impacts, risks and opportunities

As a result of the decentralized management approach, there are no centralized Group policies, actions or targets defined for the Group material sustainability matters. It is the management of each consolidated investee company that addresses investees’ material sustainability matters and includes these material sustainability matters in their business strategies, in order to allow integration of key sustainability value drivers into a sustainable business model and strategy, including policies, actions, targets and metrics. It is the responsibility of the supervisory boards of the investee companies to monitor this strategic process and its subsequent outcomes. There is no system whereby the compensation of the Supervisory Board and the Executive Board of HAL is explicitly tied to the achievement of sustainability-related objectives. For further information on HAL’s decentralized management model, refer to the section Administrative organization, risk management systems, sustainability and (non-) financial reporting on page .

The Supervisory Board receives updates on sustainability strategy and performance of consolidated investee companies from the Executive Board. These updates are based on reports provided by the management of these investee companies to HAL, to the HAL representative on their supervisory board and/or on the sustainability reports published by several of the investee companies.

In this sustainability statement the metrics are disclosed at a consolidated level and any target data included also represents a straightforward consolidation of information provided by consolidated investee companies, and does not represent Group targets set by the Executive Board of HAL. Individually significant policies, actions and plans of individual operating companies are disclosed, where relevant.

Mapping Group material sustainability matters to ESRS

The Group material sustainability matters are mapped to topical standards and sub-topics within these standards as follows.

Although standard E1 comprises multiple sub-topics related to climate change, the Group’s double materiality assessment concluded that climate change adaptation, energy management, and energy transition were not material to the Group. Consequently, the disclosure on the material sustainability matter “reduction of GHG emissions” focuses on the required data points related to climate change mitigation. Similarly, the assessment determined that the sub-topic “health and safety” within standard S1 was material, along with three sub-topics within standard G1.

Refer to Annex II from page onwards for an overview of the disclosure requirements that have been complied with. This includes those derived from the outcomes of the double materiality assessment, along with references to the corresponding disclosed information.

Basis of preparation of the consolidated sustainability statement

The consolidated sustainability statement of the Company was authorized for issue by the Supervisory Board of HAL Holding N.V. on March 27, 2025, and has been prepared in accordance with the European Sustainability Reporting Standards (ESRS) as adopted by the European Commission and compliant with the reporting requirements provided for in Article 8 of Regulation (EU) 2020/852 (Taxonomy Regulation). In anticipation of the transposition of the Corporate Sustainability Reporting Directive (CSRD) into Dutch law, the Company decided to voluntarily report under ESRS and the Taxonomy Regulation.

The ESRS standards deal with a broad range of complex topics, and both the standards and their interpretative guidance are expected to continue to be developed and expanded in the coming years. In addition, increasing availability of (more refined) data, including quality and reliability of assumptions, is also expected to improve the maturity of sustainability reporting. As a result of the evolution of the understanding of the requirements in the ESRS and the improved availability of sustainability data, comparability of the current year consolidated sustainability statement with future consolidated sustainability statements may be affected.

Reporting period, base year and time horizons

This consolidated sustainability statement covers the period from January 1 through December 31, 2024. HAL has applied the transitional provision in ESRS that allows the omission of comparative information in its first-year consolidated sustainability statement.

HAL has adopted 2024 as its base year for performance measurement in consolidated reporting, as this is the first year of consolidated sustainability reporting. If an investee company has adopted a different base year for their target setting, this is either adjusted to reflect the target as compared to the 2024 base year, or additionally disclosed where relevant. The appropriateness of maintaining 2024 as the base year will be reviewed annually. Regarding future information, HAL defines the following time horizons as definition of short, medium, and long term:

• Short: up to one year

• Medium: one to five years

• Long: over five years

Consolidation and reporting boundaries

HAL applies the concept of financial control for the consolidated sustainability statement, aligning the consolidation scope with the consolidated financial statements. This includes Safilo, where the Company’s ownership interest does not exceed 50%, but the Company is deemed to have de facto control (reference is made to the Basis of preparation of the consolidated financial statements on page ). In addition, for the reporting on GHG emissions, any other entities, assets, or locations under operational control are disclosed separately.

Qualitative information is aggregated and disclosed separately if considered material information for the consolidated sustainability statement. This also applies for estimates, significant judgments and assumptions at consolidated investee company level that may be challenging to consolidate or aggregate. For further detail, reference is made to Use of estimates and judgments on page .

Acquisitions and divestments
Unless stated otherwise, acquisitions are included in, and divestments are excluded from, the consolidated sustainability reporting as from the date of the transaction. The timeline for full integration of the acquired company into the consolidated sustainability reporting may vary depending on the company’s maturity in sustainability reporting prior to acquisition. This is due to the time required for conducting a double materiality analysis, expanding reporting processes and training staff. In general, if actual data for acquired companies is not available, the information that is required to be reported is estimated.

Assets and liabilities held for sale are included up to the moment that control is relinquished.

On September 20, 2024, HAL transferred its entire shareholding in Pro Gamers Group to one of the existing lenders of this company as part of a financial restructuring. Since the actual data is only available until the end of April, 2024, estimated data is included for the remaining period.

Associates and joint arrangements
Associates and joint ventures of HAL and its consolidated investee companies are considered part of the value chain of the Group, unless stated otherwise. In line with financial consolidation principles, joint operations are proportionally consolidated based on the Group’s share in the joint operation.

Leased assets
Where the Group is lessee, leased assets that meet the definition of a lease under IFRS 16 (refer to Right-of-use assets and lease liabilities on page ) are considered part of own operations for the purpose of sustainability reporting. Where the Group is lessor, the assets remain within own operations unless they would be expected to meet the definition of a lease under IFRS 16 from the perspective of the lessee. Leased assets that are not considered part of own operations are considered part of the upstream or downstream value chain of the company.

Value chain scoping and information
The value chain comprises the relationships a company has with its business partners, entities in its value chain, and any other non-state or state entity directly linked to its business operations, products or services. Business relationships are not limited to direct contractual relationships. They may include indirect business relationships in the Group’s value chain beyond the first tier, and shareholding positions in joint ventures, associates or other investments.

For HAL as a standalone company, the upstream value chain primarily comprises shareholders, employees and service providers. Primary inputs obtained from the value chain are human and financial resources. The business model of HAL focuses on the optimal allocation of these human and financial resources throughout the investment life cycle. The downstream value chain mainly consists of the investee companies.

The value chain of the Group consists of the value chain of HAL as a standalone company and the value chains of the consolidated investee companies. The assessment of the material impacts, risks and opportunities in the Group’s value chain is embedded in the Group double materiality assessment. For the value-chain information on the Group material sustainability matters, a reference is made to the disclosures on these matters. Information with respect to the value chain is included in this consolidated sustainability statement when material to the Group.

Subsidiary exemption
In accordance with Articles 19a(9) or 29a(8) of the Accounting Directive 2013/34/EU, as amended by the Corporate Sustainability Reporting Directive (CSRD), all non-listed investee companies included in the consolidated sustainability statement of HAL have the possibility to use exemptions for individual sustainability reporting under CSRD, where applicable and allowed, if certain conditions are met. It is the responsibility of the management of each consolidated investee company to consider whether these exemptions are to be applied, taking into account its stakeholders and local legislation. The use of the exemption provides consolidated investee companies with the flexibility to publish sustainability information that does not need to adhere to ESRS, enabling tailored and relevant reporting aligned with their specific context.

Use of estimates and judgments

The preparation of the consolidated sustainability statement in conformity with ESRS requires management to make judgments, estimates and assumptions that affect the reported datapoints. Particularly value-chain information carries a higher inherent risk of uncertainty as it is obtained from indirect sources outside of the control of the Group and its availability may be limited, requiring the use of estimates. Information with respect to possible future events also carries a higher inherent outcome uncertainty as this relies on judgments, estimates and assumptions made by management. Estimates and judgments are periodically evaluated and are, where available, based on historical experience and other factors, including expectations of future events that are believed to be reasonable. Accordingly, it is reasonably possible that outcomes within the next year(s) that are different from the assumptions could have a significant impact on the affected datapoint and may require restatement. Estimates or significant judgment that are critical to the consolidated sustainability statement presentation are described in the following notes:

• Group double materiality assessment (page )

• GHG emissions calculations - Reduction of greenhouse gas emissions (page )

• Relevance of GHG scope 3 categories - Scope 3 - Gross value-chain GHG emissions (page )

• Capital goods in GHG scope 3 - Scope 3 - Gross value-chain GHG emissions (page )

Financial estimates
Where the consolidated sustainability statement includes or is related to financial data and estimates, these are consistent with the corresponding financial data and estimates used in the consolidated financial statements.

Classified and sensitive information in respect of intellectual property, know-how or results of innovation

The Company does not make use of the option to omit specific information in relation to intellectual property, know-how or the results of innovation.

Incorporation by reference

Some disclosures are incorporated by reference to other parts of this annual report, for example for Executive and Supervisory Board information, general information on governance and certain financial data. Wherever information was incorporated by reference to other parts of this annual report, this is clearly indicated. For an overview of references, refer to the Content Index on page .

Events after the reporting period

The events after the reporting period are disclosed in Note 45 of the consolidated financial statements on page . These events did not have significant effect on the sustainability statement.

Environmental information

Reduction of greenhouse gas emissions

Management approach for reduction of GHG emissions

There is no group-wide management approach for the reduction of GHG emissions. Consequently, no centralized Group policies, actions, plans or targets have been defined. This also means that the Group does not apply an internal carbon pricing scheme. For a description of the decentralized management model and its effect on the determination of the Group material topics, reference is made to the section Managing impacts, risks and opportunities on page .

The impact of GHG emissions from HAL as a standalone company on the total Group GHG emissions is negligible, apart from its investment (management) decisions. The impact of these decisions is reflected in the consolidated GHG reporting in scopes 1, 2 and 3 for consolidated investees, and in scope 3, category 15 Investments, for non-consolidated investments.

The consolidated gross emissions within scope 1 and 2 are almost entirely (98%) attributable to Anthony Veder, Boskalis, Broadview and Vopak. The consolidated gross scope 3 emissions are primarily (81%) associated with the value chains of Boskalis, Broadview, TABS, Van Wijnen and Vopak.

Policies, targets and decarbonization plans

The expected development of the Group’s emissions profile on scopes 1, 2 and 3, based on current investee-level targets, decarbonization plans and projected business growth, is presented in the table below and in the visualization on page .

1. Market-based
2. This represents a straightforward consolidation of information provided by consolidated investee companies, and does not represent a Group target set by the Executive Board of HAL

The difference between actual 2024 emissions and base year 2024 emissions in the table above is due to the divestment of Pro Gamers Group, which is included in the actual emissions but excluded from the base year and from further reporting on targets and plans. Additionally, the impact of acquisitions contributed to this difference, primarily through the acquisition of the remaining shares in Smit Lamnalco by Boskalis (refer to note Acquisition and divestment of subsidiaries on page onwards). While the company was consolidated for two months in 2024, the base year includes an adjustment for the full-year impact.

The above aggregated target level is based on targets and plans as adopted by the majority of the consolidated investee companies, supplemented with a high-level forecast of business development impact from the other investee companies that had not yet developed targets. All companies that make up the majority of the Group’s emissions have set target values on scope 1 and 2 emissions. However, Vopak applies an operational control approach and therefore does not have a target on financial control basis. For scope 3 emissions, targets are included from Broadview, Van Wijnen, Ahrend and Safilo. Certain consolidated investee companies have set a GHG-intensity reduction target, as this better reflects their performance and progress in relation to their business activities. For these companies, the absolute values for the target year, corresponding to the intended relative improvement in the intensity measure, were included.

The total aggregated decarbonization target level is not validated at Group level by the science-based targets initiative (SBTi) nor benchmarked in relation to a pathway to 1.5°C. Each investee company has considered its own unique set of circumstances to determine its targets, including the nature of its business, the availability of technical solutions and best practices applied in its industry. Consequently, the Company’s Executive Board and the Supervisory Board do not oversee the setting of targets related to material impacts, risks and opportunities at the level of the consolidated investee companies.

The following specific targets were set and policies implemented by the individual consolidated investee companies that together account for the majority of the Group’s consolidated total gross GHG emissions:

• Anthony Veder has set a net-zero target for 2035 on scope 1 and 2 emissions. For both existing vessels and newbuilds, the company focuses on energy efficiency and the capability to utilize synthetic gaseous fuels. Considering the current limited availability of low-carbon fuels, energy savings are the most effective method for reducing emissions in the short term. Over time, achieving the emission reduction ambitions of Anthony Veder will increasingly depend on its external stakeholders, including suppliers, customers, governments, and regulatory bodies. Progress is measured and monitored using a net-zero ratio relative to the base year 2022. An intermediate target for 2030 is set at 60% of the 2022 net-zero ratio. No target has currently been set for scope 3 emissions;

• Broadview aims to achieve a 29% reduction on scope 1, 2, and 3 emissions by 2026 compared to 2019 on a like-for-like basis. This is measured and monitored based on life-cycle-analysis calculations. The reduction of GHG emissions is included in Broadview’s strategic pillars and managed through the Broadview business cycle. Focus is on energy efficiency improvements, use of renewable energy, increased bio-based share in finished products and materials optimization. All these activities focus on the cradle-to-gate activities of the Broadview companies and targets are defined per company with focus on the operations;

• Boskalis has set a target to achieve net-zero scope 1 and 2 emissions across its own operations by 2050 and to become climate neutral for onshore projects in the Netherlands by 2030. Additionally, the company aims to reduce the carbon intensity of its fleet by 10% by 2030, relative to 2023 levels. This is measured and monitored using a carbon-intensity ratio developed in-house, which aligns with the pathway and intensity ratio established by the International Maritime Organization. This ratio expresses the emissions relative to the utilized installed power of a vessel and allows Boskalis to track the energy efficiency of its vessels, relative to their operations. Guided by their environmental and social policy, Boskalis expects to achieve its target through a combination of measures, including the adoption of energy efficiency measures and the use of renewable fuels.

  The decarbonization of the maritime industry presents specific challenges and depends on technologies and fuels that are either not yet developed or, where available, are not yet accessible at sufficient scale or across all geographies. The high energy density required by Boskalis’ work vessels precludes using electricity as a standalone alternative fuel. At the same time, the use of clean alternatives such as biofuels or potential fuels for the future, including methanol, are constrained by limited global supply and a lack of market readiness to absorb the additional costs compared to traditional fuels.
  Where Boskalis has direct control, it continues to explore measures to further reduce its carbon footprint, with a particular focus on improving energy efficiency within its fleet. Meanwhile, identifying and testing suitable alternative fuels and technologies is a responsibility shared by the industry as a whole. Boskalis actively contributes to this process through numerous partnerships and pilot programs. As the technologies and clean fuels required by the maritime sector continue to develop, Boskalis is leveraging its influence and resources to support the industry’s energy transition. No target has currently been set for scope 3 emissions;

• TABS aims to achieve a 45% reduction on scope 1 emissions in 2030, with 2023 as its base year. No target has currently been set for scope 2 emissions, and a target (with policies and decarbonization levers) for scope 3 emissions is under development;

• Van Wijnen has set a net-zero target for scope 1 and 2 emissions by 2030. For scope 3 emissions, net reduction targets are set relative to 2024 levels: 55% reduction by 2030, 90% by 2040, and net-zero by 2050. While policies are in place for the electrification of the vehicle fleet and the purchase of green energy, the company is actively working to further develop measures for the relevant scope 3 categories; and

• Vopak has communicated an ambition to achieve net-zero emissions by 2050, with an interim target of a 30% reduction in scope 1 and 2 emissions by 2030, compared to 2021 levels and including the anticipated growth of its business. To achieve its absolute reduction target while accommodating growth, Vopak required all business units to develop emissions reduction roadmaps. These outline potential reductions, cost and capital expenditure implications, and local emission targets. Execution is ensured through the 3-year maintenance program.

  Vopak maintains an internally developed carbon price for scope 1 and 2 GHG emissions when assessing capital investment proposals to ensure alignment with its climate objectives. On scope 3 emissions, there are currently no targets set. For setting and reporting sustainability targets, Vopak follows the operational control principle, including data from its headquarters, local offices, and all terminals under its operational control. This scope exceeds the financial control scope prescribed for this sustainability statement. Vopak applies this approach to ensure a comprehensive view of their sustainability performance and target-setting across its entire operational footprint.

The above-mentioned targets have not yet been externally assured or validated. Vopak has currently not set a scope 3 target, which is why its current GHG reduction goals do not fully align with the IPCC’s 1.5 °C warming scenario. As part of the development of its sustainability roadmap, Vopak will continue to assess how its targets should reflect the latest climate science, including the risks and opportunities associated with a 1.5 °C scenario.

With respect to emission-reduction targets at consolidated investee companies that have a significantly lower contribution to the Group’s emissions profile, Koninklijke Ahrend has committed to SBTi targets for scope 1, 2, and 3 emissions, FD Mediagroep has set a target for scope 1 and 2 emissions in line with SBTi, and Safilo has had its scope 1, 2 and 3 emissions targets validated by SBTi.

The most important levers for achieving the consolidated investee companies’ 2030 targets, relative to the base year 2024, can be outlined as follows. As indicated above, the 2030 target represents a straightforward consolidation of information provided by consolidated investee companies, and does not represent a Group target set by the Executive Board of HAL.

A significant part of gross scope 1 emission reductions until 2030 is primarily planned to arrive from energy efficiency and fuel switching for the vessels and floating equipment of Anthony Veder and Boskalis. For scope 3, key levers identified include material efficiency and optimalization of end-of-life processing at Van Wijnen, who also identifies net decarbonization levers for investments in carbon capture projects within its value chain. Significant effects from the use of low- and zero-carbon sustainable fuels are not expected before the 2030 target year, as their development is ongoing, commercial availability remains limited, and market readiness to absorb additional costs compared to traditional fuels is suboptimal.

In 2024, Heartwood, a 100% subsidiary of HAL, acquired land in Iceland with the aim of carbon sequestration through afforestation. These activities will require time to take effect, as seedlings must first be planted and nurtured. Heartwood is currently building the capacity to accelerate this process. These afforestation efforts are intended to offset own emissions that the Company is unable to reduce. Should the results of these activities exceed the Company’s residual emissions, certificates may be made available to other (Group) companies, at market rates.

‘Locked-in’ GHG emissions from key assets or products are those emissions that may pose a challenge to the decarbonization levers identified above due to long asset lifespans, high capital costs, or limited technological alternatives. At the individual consolidated investee companies that together account for the majority of the consolidated total gross emissions, the following key assets or products have been identified as contributing to this lock-in risk:

• Anthony Veder’s current generation of vessels relies on fossil fuels for propulsion, limiting immediate opportunities for emission reductions;

• Boskalis’ fleet includes many vessels with a long asset life, resulting in locked-in emissions and limiting the pace of decarbonization;

• Broadview’s products, including high-pressure laminates, worktops, and doors, contain locked-in carbon, posing a challenge to reducing embodied emissions; and

• Vopak’s boilers, vapor treatment units, and flares are integral to its core operations, resulting in locked-in GHG emissions that pose challenges to decarbonization.

No operational expenditures (‘Opex’) or capital expenditures (‘Capex’) have currently been allocated to align these plans with the EU Taxonomy Reporting. For the reporting on the Taxonomy Regulation, reference is made to EU Taxonomy on page .

Total GHG emissions performance

A breakdown of the total emissions from the consolidated investee companies is provided below. This is based on the consolidation scope for this sustainability statement, as included in Consolidation and reporting boundaries on page . The emissions from unconsolidated investee companies under operational control are excluded and disclosed separately under Additional disclosure on GHG emissions from unconsolidated companies under operational control on page .

1. The net revenue consisted of revenue as reported in the consolidated statement of income and rental and residential income as presented in note 27 income from real estate activities of the consolidated financial statements

Key actions
As 2024 serves as both the base year and the first year of reporting, progress compared to the base year or the previous year is not yet applicable. Key actions undertaken during the year to achieve (further) reduction of the gross GHG emissions included:

• Anthony Veder has ordered wind-assist propulsion systems for installation on two vessels and has equipped its newbuild vessels with a main engine that reduces methane slip;

• Boskalis has undertaken significant operational and technical efforts to reduce the carbon intensity of its fleet. In collaboration with clients and suppliers, the company has continued to explore and adopt cleaner fuels, including biofuels, to lower the carbon footprint of individual projects. As part of its energy efficiency measures, Boskalis has completed the retrofit of its first offshore vessels with energy storage systems, which can reduce carbon dioxide and nitrogen oxide emissions by an average of up to 20%;

• Broadview achieved a 10-20ktCO₂eq emissions reduction, mainly through the completion of energy-efficiency projects at its production locations;

• TABS defined its target and plans on scope 1 emission reduction, reference is made to Policies, targets and decarbonization plans, and started the development of its scope 3 reduction target and plans;

• Van Wijnen further optimized its designs, positively impacting both the sustainability of purchased materials and the energy efficiency of buildings during their use phase; and

• Vopak increased the share of renewable electricity to 73%, partly due to the use of renewable energy certificates. Additionally, the company has begun installing electric and renewable-powered assets for both new installations and replacements, rather than gas- or diesel-fired options. These efforts resulted in a 43% reduction in total absolute scope 1 and 2 emissions compared to Vopak’s restated 2021 base year, exceeding its initial 30% reduction target. The GHG reduction trajectory is, however, not linear, as planned growth projects may increase emissions. Vopak remains confident in maintaining its 30% reduction target and will actively evaluate the ambition of its current GHG reduction goal.

Scope 1 - Gross direct GHG emissions

From the total scope 1 emissions, 10% is related to activities at Anthony Veder, Boskalis and Vopak that were regulated under an emission trading scheme.

In addition to the scope 1 emissions as disclosed per above, the direct emissions from biogenic combustion were 82 ktCO₂eq for the year 2024, mainly at Broadview.

Scope 2 - Gross indirect GHG emissions

In addition to the Scope 2 emissions disclosed above, there were no indirect emissions from biogenic combustion in 2024.

Scope 3 - Gross value-chain GHG emissions

The “other categories” include only aggregated emissions data for categories deemed relevant by individual consolidated investee companies or for which data was readily available at consolidated investee companies regardless of relevance.

In addition to the scope 3 emissions as disclosed as per above, the value chain emissions from biogenic combustion were 320 ktCO₂eq for the year 2024, fully at Broadview. A carbon uptake of 324 ktCO₂eq for purchased goods and services at Broadview is not included in these emission numbers.

Category 1 - Purchased goods and services

The emissions in this category are mainly (83%) derived from Boskalis, Broadview, Safilo, TABS and Van Wijnen. These scope 3 emissions are calculated applying varying calculation methods, refer to the table below for the emissions per method applied.

Category 2 - Capital goods

The emissions in this category are mainly (86%) derived from Boskalis and Vopak. These emissions are calculated applying varying calculation methods, refer to the table below for the emissions per method applied.

Category 3 - Fuel and energy-related activities

In line with the scope 1 emissions, the emissions in this category are mainly (97%) derived from Anthony Veder, Boskalis, Broadview and Vopak. These emissions are calculated applying varying calculation methods, refer to the table below for the emissions per method applied.

Category 4 - Upstream transportation and distribution

The emissions in this category are mainly (97%) derived from Ahrend, Boskalis, Broadview, TABS and Safilo. These emissions are calculated applying varying calculation methods, refer to the table below for the emissions per method applied.

Category 15 - Financial investments

The reported emissions in this category primarily relate to the Company’s investments in real estate joint ventures, other joint ventures and associates, marketable securities and other financial assets. These emissions are estimated using publicly available 2023 emissions and financial data for the listed debt and equity investments and 2023 company information for the non-consolidated investee companies. An attribution factor is applied based on the outstanding amount relative to total equity and debt. This calculation resulted in an estimated 160 ktCO₂eq.

The remaining part relates to the emissions from Vopak’s equity investments. These are calculated based on a combination of the investment-specific method and the average-data method.

GHG removals and GHG mitigation projects financed through carbon credits

In 2024, there were no GHG removals and storage resulting from projects developed in own operations, or contributed to in the upstream and downstream value chain. On GHG emission reductions or removals from climate change mitigation projects outside the value chain, there was 19 ktCO₂eq financed through purchase of carbon credits. These cancelled carbon credits originated from a biogas project in Genova, Italy, which was not certified under a recognized quality standard.

Additional disclosure on GHG emissions from unconsolidated companies under operational control

This section includes additional disclosures as required by ESRS E1, that were not part of the plans and actual performance as disclosed in the previous sections.

The scope 1 and 2 emissions from unconsolidated investee companies under operational control are included in the table below. These emissions relate to terminals operated by Vopak, over which the company does not have financial control.

By adding these scope 1 and 2 emissions from unconsolidated investee companies under operational control to the consolidated gross scope 1, 2 and 3 emissions (based on financial control), the location-based emissions are 5,959 ktCO₂eq and market-based emissions are 5,769 ktCO₂eq.

EU Taxonomy

Eligibility and alignment per environmental objective

The EU Taxonomy eligibility and alignment is assessed at the level of the investee company, consistent with HAL’s decentralized management approach. These activities are then consolidated to reflect the overall eligibility and alignment. This can be summarized per environmental objective as follows:

1. Without adjusting for double counting by assigning activities that are eligible to multiple objectives to one objective, Taxonomy eligibility is 12% for revenue, 1% for capex and 3% for opex
2. Without adjusting for double counting by assigning activities that are eligible to multiple objectives to one objective, Taxonomy eligibility is 2% for revenue, 0% for capex and 1% for opex

For the detailed disclosures on the proportion of revenues, capital expenditure and operating expenses from products or services associated with Taxonomy-aligned economic activities reference is made to the tables on the next pages. It should be noted that for the disclosures a materiality threshold is applied. All taxonomy-eligible economic activities with consolidated revenue, capital expenditure or operating expenditure above € 0.5 million are reported separately, all others are reported within “other economic activities”.

Assessment of alignment with EU Taxonomy regulation
To determine if an economic activity is Taxonomy-aligned, an assessment needs to be performed if the activity significantly contributes to one or more environmental objectives, does not cause significant harm to any of these objectives and if it adheres to the minimum safeguards. The Taxonomy-aligned activities for the Group are limited to Electricity generation using solar photovoltaic technology at TABS. Management of TABS conducted this assessment, including due diligence on responsible business conduct for the solar panel suppliers and concluded that this activity aligns with the climate change mitigation objective.

Revenue from taxonomy-eligible and taxonomy-aligned economic activities
Revenue pursuant to the EU Taxonomy Regulation consisted of revenue as reported in the Consolidated Statement of Income for the year 2024 on page of this annual report and rental and residential income as presented in the note Income from real estate activities on page .

The Taxonomy-aligned activities (€ 1 million) are limited to Electricity generation using solar photovoltaic technology at TABS. The majority of the Taxonomy-eligible (but not aligned) activities (€ 3,352 million) is related to:

• Construction of new buildings at GreenV and Van Wijnen

• Flood risk prevention and protection of infrastructure as well as electricity generation from wind power at Boskalis

• Installation, maintenance and repair of renewable energy technologies at Broadview, GreenV and IQIP

• Renovation of existing buildings by Van Wijnen and at Vopak

• Sea and coastal freight water transport, vessels for port operations and auxiliary activities at Anthony Veder

Capital expenditures (capex) on taxonomy-eligible and taxonomy-aligned economic activities|
Capital expenditures in accordance with the EU Taxonomy Regulation consisted of gross additions to property, plant and equipment, right-of-use assets, investment properties and intangible assets in the year 2024, including additions from business combinations. In this context, goodwill is excluded. Capital expenditures were measured on the same basis as in the consolidated financial statements. Capital expenditures correspond to the sum of the amounts recognized in the notes to the consolidated financial statements from investments (or new lease contracts) and consolidation (additions from acquisitions), which are presented in the notes Property, plant and equipment from page onwards, Investments properties from page onwards, Right-of-use assets and lease liabilities from page onwards, and Intangible assets from page onwards.

The Taxonomy-aligned activities (€ 1 million) are limited to Electricity generation using solar photovoltaic technology at TABS. The majority of the Taxonomy-eligible (but not aligned) activities (€ 251 million) is related to:

• Acquisition and ownership of buildings at Ahrend, Broadview, Pro Gamers Group and Van Wijnen

• Construction of new buildings at Auxilium, GreenV, TABS and Van Wijnen

• Electricity generation from wind power at Boskalis

• Installation, maintenance and repair of renewable energy technologies at Auxilium, Broadview, IQIP and Vopak

• Sea and coastal freight water transport, vessels for port operations and auxiliary activities at Anthony Veder

• Transport by motorbikes, passenger cars and light commercial vehicles at Ahrend, Van Wijnen and Vopak

Operating expenditures on taxonomy-eligible and taxonomy-aligned economic activities
Operating expenditures as defined in the EU Taxonomy Regulation include all direct, non-capitalized costs associated with research and development, renovation measures, short-term leases, and maintenance and repair. Operating expenditures were measured on the same basis as in the consolidated financial statements. However, a direct reconciliation with the consolidated financial statements is not possible, as not all expenses included in the financial statement amounts are included in the EU Taxonomy definition of operating expenditures.

The Taxonomy-aligned activities (€ 1 million) are limited to Electricity generation using solar photovoltaic technology at TABS. The majority of the Taxonomy-eligible (but not aligned) activities (€ 1,162 million) is related to:

• Construction of new buildings at GreenV, SB Real Estate and Van Wijnen

• Electricity generation from wind power at Boskalis

• Flood risk prevention and protection infrastructure at Boskalis and Vopak

• Installation, maintenance and repair of renewable energy technologies at Broadview and IQIP

• Sea and coastal freight water transport, vessels for port operations and auxiliary activities at Anthony Veder

For the allocation of operating expenditures to eligible activities at Boskalis, in the absence of specific data, an estimate was made based on the related project revenues. This estimate assumes no significant differences in margins between Taxonomy-eligible and non-eligible projects.

Nuclear and fossil gas related activities

EU Taxonomy tables on proportion of Taxonomy-aligned revenue, capex and opex

Proportion of revenues from products or services associated with Taxonomy-aligned economic activities

Proportion of capex from products or services associated with Taxonomy-aligned economic activities

Proportion of opex from products or services associated with Taxonomy-aligned economic activities

Social information

Occupational health and safety

Management approach for occupational health and safety

Occupational health and safety is defined as a material sustainability matter for the Group from a qualitative perspective. For more details, reference is made to the Qualitative assessment on page . In line with HAL’s decentralized management model, this matter is managed at the investee company level, with approaches varying based on company type, business, and other relevant factors. There is no group-wide management approach; consequently, no centralized Group policies, actions, or targets are defined. For a description of the decentralized management model and its effect on the determination of the Group’s material sustainability matters, reference is made to the section Managing impacts, risks and opportunities on page .

Work-related accidents, injuries, and illnesses can occur across the entire Group, with a higher risk at companies operating production and construction sites. Nearly half of the consolidated hours worked by employees and non-employees take place at Boskalis, followed by Broadview, Safilo and Vopak, together accounting for 70% of hours worked, where the inherent exposure to work-related accidents is relatively higher. Among the other investee companies, employees and non-employees of Anthony Veder, Atlas (for their non-employees), TABS, and Van Wijnen (together accounting for an additional 17% of hours worked) have an inherently heightened exposure to work-related accidents.

Health and safety management system

From the consolidated investee companies, all companies with a higher inherent exposure to work-related accidents have a formal health and safety management system in place, covering both employees and non-employees. At consolidated level, 94% of the Group’s 34,642 employees at year-end (based on headcount) are covered by local health and safety management systems.

Policies and targets for health and safety

The following specific targets have been set by individual consolidated investee companies that together account for the majority of the hours worked and have an inherent higher exposure to work-related accidents:

• For Boskalis, through their company-wide safety program “No Injuries, No Accidents”, maintains a strong focus on eliminating workplace incidents. Their ultimate goal is to reduce the number of workplace accidents resulting in absence from work, medical treatment cases and restricted work cases to zero;

• Within Broadview, each of its operating companies is required to set its own safety targets as part of its annual budget agreements. In 2024, key themes arising from these budget agreements included reduction of forklift use, enhancement of proactive risk identification, and stimulation of the reporting of unsafe situations. On a continuous basis, employees are encouraged to identify risks, which are then addressed by each operating company’s safety department. Operating companies submit monthly reports on work-related injuries, employee safety observations, improvement points, and corrective actions. On an annual basis, safety statistics, including accidents, incidents and near misses, are analyzed to track progress and challenges, and findings are shared across all companies for follow-up. In case of a lost-time accident or restricted work case, operating companies must submit a standardized investigation report to Broadview management, detailing the injury, its cause, and the corrective actions taken. Broadview conducts monthly “joint safety meetings” with its CEOs and safety managers, as well as quarterly meetings with each operating company. Safety objectives, linked to senior management compensation, are part of each operating company’s budget agreements, with fulfillment being their responsibility;

• At Safilo, no group safety performance targets were set, however, the topic is managed through the health and safety function. This function is dedicated to enhancing workplace safety, minimizing risks, and reducing costs associated with accidents and work-related illnesses. It ensures the implementation of employer directives by assessing risks, defining responsibilities, and organizing preventive measures. Internal committees oversee safety planning, the distribution of personal protective equipment, and emergency simulations, while structured reporting systems encourage hazard identification and corrective actions. Mandatory safety training is provided, requiring employees to pass tests and give feedback to support continuous improvement. Appointed managers oversee compliance and risk mitigation, particularly for factory workers, considering job type and location; and

• Vopak’s foremost priority is to have zero fatalities and life-changing injuries. In addition, targets are set on continuous improvement of their Total Injury Rate with increased attention on potential severity of events, in particular high-potential events. Vopak’s global Safety, Health and Environment policy commits to protecting the environment, adhering to local legislation, and systematically managing workplace hazards. In striving for continuous improvement, performance on the targets is continuously measured, assessed, and reported. A structured approach is applied to prevent, eliminate, and control risks in the workplace. Compliance is ensured through internal standards focused on occupational health, safety, and environmental protection. These standards guide terminals in maintaining safe operations. It should be noted that for setting and reporting sustainability targets, Vopak follows the operational control principle, including data from its headquarters, local offices, and all terminals under its operational control. This scope exceeds the financial control scope prescribed for this sustainability statement. Vopak applies this approach to ensure a comprehensive view of their sustainability performance and target-setting across its entire operational footprint.

The following specific targets have been set by other individual consolidated investee companies where the inherent exposure to work-related accidents is relatively higher:

• Anthony Veder has set safety targets for 2025, aiming to foster a safety culture with a rating above 4.3 on a 1-to-5 scale. To support this, senior management will conduct 42 ship visits per year. Additional targets include a near-miss frequency of 425 per million exposure hours, keep workplace injuries that lead to lost work time per million hours worked below 0.5, limit all recordable injuries to a rate of 2.25 per million hours worked, and a minimum Tanker Management Self-Assessment rating of 3 on a 1-to-4 scale. To reinforce its commitment to health and safety, the company has a policy booklet covering key areas such as lifesaving rules, health and welfare, workplace safety, harassment, drug and alcohol use, smoking, safe travel, diversity and inclusion, catering, and security;

• Atlas has set a target of zero for incidents where the injured party is unable to work for more than 24 hours, a target of fewer than one lost-time accidents per million hours worked and fewer than one recordable incident per 200,000 hours worked. A health and safety policy is in place, supported by procedures for accident and incident reporting, emergency response, and corrective and preventive actions, all aligned with a zero-harm policy;

• TABS has set 2030 targets to achieve Safety Culture Ladder level 3 of 5, along with a 50% reduction in Lost Time Injuries per million hours worked compared to 2024. A dedicated team manages health and safety impacts, risks, and opportunities. To support ongoing improvement, an internal online academy provides various health and safety courses, with confidants available for support. Additionally, a comprehensive health and safety plan, occupational safety protocols, and policies are in place. Regular training sessions, toolbox talks, and inspections are conducted throughout the year to reinforce workplace safety; and

• Van Wijnen has set a target for 2027 to reduce the number of lost time injuries to below 2.0 per million hours worked . Health and safety are integrated in the Van Wijnen human resource policy, which provides a framework for all HR activities aimed at ensuring employees’ continued participation in the workforce while minimizing absenteeism. The safety policy follows a system of written and unwritten rules in accordance with ISO 45001. Additionally, the safety enforcement policy outlines actions to be taken when sanctions are necessary for employees who fail to meet their responsibilities. A specific policy has also been developed to address the safety of young workers.

Performance on occupational health and safety

At the consolidated investee companies that together account for the majority of the hours worked and with inherent higher exposure to work-related accidents, the key actions were undertaken during the year on occupational health and safety included:

• Boskalis focused on improving practical safety knowledge and skills among their employees and subcontractors within the “No Injuries, No Accidents” program. Dedicated safety campaigns were launched under leadership of the board of management in each division. Multiple audits were conducted to assess safety risks and compliance on board vessels and at project sites. Tragically, during 2024, one fatality was recorded involving a non-employee.

  Over the year, Boskalis recorded a lost time injury frequency rate, including medical treatment cases and restricted work cases, of 0.25 per 200,000 hours worked. The number of workplace accidents resulting in absence from work per 200,000 hours worked was 0.01;

• Broadview operating companies focused on reducing the use of forklift trucks and eliminating open-blade knives across their factories. In addition, quarterly safety meetings with the operating companies were launched, which allowed for more specific follow-ups and collection of safety best practices. Sharing these safety best practices with all operating companies allows them learn from each other;

• Safilo conducted risk assessments, updated management models, and implemented preventive measures, including personal protective equipment distribution and emergency simulations. Employees received mandatory safety training and were encouraged to report hazards, with incidents carefully analyzed for corrective actions. Safilo maintained ISO 45001 certification in key locations, with plans for further expansion; and

• As part of Vopak’s broader sustainability management efforts, one life-altering incident occurred involving a value chain worker who sustained a severe head injury due to an impact and a subsequent fall from height, resulting in a coma for several months. Although now in recovery, the extent of recovery remains unclear. This incident was thoroughly investigated to determine the root causes and the lessons learned have been implemented across Vopak’s terminal network to help prevent similar occurrences in the future and mitigate the risk of this type of injury. While the target of zero life-changing injuries was not achieved, the target of maximum 0.22 injuries per 200,000 hours worked for the year was met, with a recorded rate of 0.21 for 2024. As part of the further key actions taken during the year, webinars were conducted on key safety topics to support onboarding and training. The incident learning process was further embedded to enhance lessons learned, communication sharing, and recognition of success in incident-free operations. Safety leadership remained a priority through a safety leadership campaign across business units and departments, culminating in a global safety, health and environment day and new training content. Shortened checklists for safety-critical processes were introduced as well as quarterly performance reviews between headquarters and the business units. The 2024 executive board leadership review round provided valuable engagement and learning opportunities.

Key actions by the other individual consolidated investee companies with higher inherent exposure to work-related accidents included:

• Anthony Veder enhanced reporting on near misses, input to root-cause investigations and implementation of preventive measures. Participation in a customers’ safety program supported ongoing safety enhancements. Psychological safety and misconduct were assessed through dedicated surveys, while office staff, including senior management, conducted ship visits. Safety leadership training, officer and rating conferences, and shipyard evaluations further strengthen the safety culture;

• Atlas recorded zero accidents and incidents at its offices during 2024. Accidents and incidents at client worksites were reported to senior management on a monthly basis, with lessons learned shared across the organization. Atlas has upheld their ISO 45001:2018 Safety Management System certification;

• TABS took actions in line with its policies, including training sessions, self-inspections, toolbox meetings, and safety inspections; and

• At Van Wijnen, the development towards a new absenteeism model was a key focus in 2024. This model aims to reduce the absenteeism rate by leveraging on internal specialists who support both prevention and recovery. In addition, training courses were introduced to enhance leadership skills, encourage discussions on well-being, and improve absenteeism prevention and guidance. Attention points were centered around 3 themes. First, creating a safe workplace by ensuring tidy conditions, using approved resources, and implementing proper protective equipment, with particular attention to reducing collision risks and improving scaffolding safety. Second, increasing preventive safety awareness by integrating safety considerations into project preparation and developing protocols for working with asbestos, Chrome-6, and diesel engine emissions. Third, ensuring safety through structured planning, including project-specific work plans, the development of a safety dashboard, and regular safety analyses and reports.

Work-related fatalities

Regrettably, a non-employee lost his life while working for Boskalis in 2024.

Recordable work-related injuries

The number and rate of recordable work-related injuries during the year were as follows.

1. As this is the Group’s first year of reporting in compliance with ESRS, a phase-in is applied to omit data points on non-employees. However, except for Safilo, all data available on non-employees is included voluntarily.
2. Including fatalities

The majority of the work-related injuries occurred at Auxilium, Boskalis, Broadview and Van Wijnen. It should be noted that a significant number of incidents at Auxilium are related to commuting. These incidents, due to legislation, fall under the company’s responsibility and are therefore included.

Recordable work-related ill health

In 2024, there were 1,121 cases of recordable work-related ill health of own employees. This number is impacted by challenges in classifying ill health as work-related, partly due to legal limitations on registration and the resulting absence of root-cause analysis of mental ill health.

Days lost to work-related fatalities, accidents and ill health

In 2024, the reported work-related fatalities, accidents and ill health of employees resulted in 37,322 days lost of own employees. Based on the 197 number of lost time injuries and 1,121 ill health cases, on average 28 days were lost per case. To provide some more context, the number of days worked in 2024 (based on a working day of 8 hours) throughout the Group exceeded 11 million.

Governance information

Business ethics

Management approach for business ethics

There are no centralized Group policies, actions or targets defined on business conduct as a result of the decentralized management model of HAL. The Company supports its consolidated unquoted investee companies through periodic legal and compliance reviews. These reviews aim to share best practices across investee companies, discuss the effectiveness of existing control frameworks based on the investee company’s own risk assessment, and identify areas for improvement. For a description of the decentralized management model and its effect on the determination of the Group material sustainability matters, reference is made to the section Managing impacts, risks and opportunities on page .

For more information on the approach to business ethics at HAL, reference is made to the business ethics paragraph in the Report of the Executive Board of HAL Holding N.V. on page .

Policies and targets on business ethics

All consolidated investee companies have integrity policies in place related to business ethics. At investee company level, targets primarily focus on compliance with its code of conduct with the goal to have no violations, breaches and fines. This includes objectives on preventing corruption and bribery, avoiding transactions with sanctioned parties, and ensuring accessibility and training on its code of conduct. To provide context on the policies to this material sustainability matter, detailed information on business ethics with respect to Boskalis and Vopak is included below, given their relative size within the Group.

At Boskalis, responsible business conduct means acting with integrity, honesty, and fairness while complying with international and national laws and the Boskalis code of conduct. This code of conduct outlines guiding principles based on core values and commitments to people, clients, investors, the environment and communities where Boskalis works. Supporting policies expand on key business principles, including anti-bribery and anti-corruption, environmental and social, human rights and labor, sanctions policies, tax, speak-up, and grievance policies. The code of conduct helps ensure responsible decision-making, strengthens stakeholder trust, and protects Boskalis’ reputation, applying to all its subsidiaries and employees globally. Regular reviews keep the code of conduct and its policies relevant and comprehensive. Boskalis also extends its environmental, social, and governance standards to suppliers, as detailed in the supplier code of conduct.

Vopak upholds business ethics and integrity through a structured framework, anchored in the code of conduct, which sets ethical expectations for employees, contractors, suppliers, customers, and joint venture partners. It defines principles on anti-bribery and corruption, conflicts of interest, health and safety, human rights, and responsible business conduct. This framework is reinforced by supporting policies, including the speak up policy, fraud risk management policy, integrity investigation protocol, and supplier code of conduct, extending ethical standards across the value chain. Biennial code of conduct training is mandatory for all employees, with targeted sessions for high-risk functions such as procurement and maintenance. The third-party speak up system provides a confidential platform for reporting concerns. Supplier relationships are managed transparently, ensuring compliance with ethical, environmental, and governance standards through structured monitoring and evaluations. Anti-corruption and anti-bribery measures are embedded in the anti-bribery and corruption policy, supported by mandatory employee training, fraud risk assessments, and regular fraud alerts. Business ethics and integrity is on the agenda for Vopak’s audit committee, quarterly. Separately, the audit committee of Vopak is kept up to date with business ethics and integrity developments as part of the quarterly reporting of speak up cases.

In addition, at HAL level, a code of conduct and whistle-blower rules, which include protective measures for whistle-blowers, are in place. For more information, reference is made to the business ethics paragraph in the Report of the Executive Board of HAL Holding N.V. on page .

Performance on business ethics

In 2024, various actions were undertaken across the Group to uphold ethical business practices and strengthen integrity. These locally driven initiatives can be summarized as follows: Several companies implemented measures to mitigate risks related to business ethics, with a strong emphasis on training, policy development, and governance enhancements. A number of companies have revised their codes of conduct and introduced regular training initiatives, including e-learning modules, to ensure employees are well-informed about expected behaviors and ethical standards. Others have reinforced their compliance frameworks by improving whistleblower policies, refining risk management governance, and strengthening regulatory adherence, including compliance with sanctions and fraud risk assessments. Participation in industry networks and collaborative initiatives further supports anti-corruption efforts. Additionally, some companies have incorporated business ethics considerations into broader operational and risk management strategies, such as business continuity planning, supplier engagement, and leadership accountability.

Whistleblower, fraud, corruption or bribery cases and confirmed incidents

In 2024, several fraud cases were reported through periodic fraud reporting. These cases were primarily related to inherent risks associated with the nature of the related companies’ businesses and were mostly identified through applicable internal controls. All reported cases were investigated and addressed, with mitigating controls implemented where necessary. There were no whistleblower cases reported and there were no convictions nor fines for violation of anti-corruption and anti-bribery laws reported.

Other information

General disclosures of metrics

This section includes certain headcount and revenue metrics as required by the ESRS general disclosure requirements, independent from the material sustainability matters identified for the Group.

Headcount of employees in own workforce by geographical areas

In line with the geographical segmentation in the consolidated financial statements (refer to Note 1 Segmentation on page ), the composition of headcount of employees in own workforce by geographical area is as follows.

Revenue from specified activities

The composition of revenue by the activities as specified in ESRS 2.40(d) is as follows:

1. Fully from non-EU Taxonomy-aligned economic activities related to fossil gas

The revenue from oil relates to storage of fossil fuels by Vopak and covers 46% of their total revenue.

The revenue from gas relates to transportation activities by Anthony Veder, distribution activities by Broadview and storage activities Vopak, and covers respectively 100%, 2% and 3% of their total revenue.

There are no activities related to coal, chemicals production, controversial weapons or cultivation and production of tobacco.

Capital expenditures related to coal, oil and gas-related economic activities

From the total capital expenditures of € 2,298 million as disclosed in the section EU Taxonomy on page onwards, during 2024, there were no capital expenditures to coal, oil and gas-related economic activities related to the NACE activities as included per above.

Annexes

Annex I - Material sustainability matters of Boskalis and Vopak

All sustainability matters related to Boskalis and Vopak were addressed within the Group DMA process, as outlined in the Group double materiality assessment section on page . This annex offers an overview of the sustainability matters specific to these two companies that were not deemed material at the Group level. Summarized information regarding these material sustainability matters is provided below.

Considering that these topics are not material to HAL group reporting, the information provided below does not intend to cover all ESRS requirements. Readers interested to obtain more detailed information on the material sustainability matters and performance of Boskalis and Vopak are encouraged to consult the sustainability reports published by these companies.

Boskalis identified the following material sustainability matters that are not included in a Group material sustainability matter.

Sustainable growth
Sustainable growth is a material sustainability matter for Boskalis, reflecting the balance between continued economic development through its activities and the integration of social and environmental considerations. In alignment with Boskalis’ business strategy and core values, sustainable growth is achieved through the creation of innovative infrastructure, including ports and transport links that foster economic development, renewable energy infrastructure that facilitates the energy transition, and climate adaptation projects that protect populations and natural environments from the effects of climate change.

Through Boskalis’ commitment to sustainable practices, it actively mitigates environmental impacts while striving to protect and enhance coastal ecosystems. Where possible, Boskalis’ activities generate positive social impacts, including local job creation, skills development, and opportunities for local trade and economic growth. However, infrastructure development and operational activities can also result in environmental impacts and social challenges, such as opposition to infrastructure projects. These negative effects are often temporary and primarily confined to the construction phase. Nonetheless, failure to effectively manage such impacts could lead to environmental degradation or disturbances to local communities, underscoring the importance of responsible and proactive stakeholder management.

Financially, integrating environmental, social, and governance principles strengthens Boskalis’ ability to capitalize on new market opportunities and innovative technologies. Such initiatives also foster greater trust and support among stakeholders, enhancing Boskalis’ competitive advantage, attracting responsible investment, and reinforcing long-term sustainability and economic resilience.

To achieve sustainable growth, Boskalis aims to advance the energy transition by creating infrastructure that delivers renewable, reliable, and affordable energy, protect through climate adaptation by safeguarding populations and the natural environment from climate change impacts such as rising sea levels and extreme weather through coastal defense and riverbank protection, and create innovative infrastructure that fosters socio-economic development. Boskalis tracks progress on each of these subjects specifically, refer to the below topics.

Energy transition
The energy transition is a material sustainability matter for Boskalis, both in terms of its environmental and financial impact. Boskalis actively supports the energy transition by creating infrastructure that enables renewable, reliable, and affordable energy, recognizing access to lower-carbon energy as essential for sustained socio-economic development. As part of its core business, Boskalis delivers a broad range of services that are crucial to developing renewable energy sources while maintaining sufficient energy supply. To expand its contribution, Boskalis continues to invest in adaptable assets and enhanced capabilities to support a growing client base across diverse geographies.

Boskalis has an important role to play in the energy transition, balancing the opportunities for growth in sustainable energy with the environmental challenges of offshore infrastructure development, such as greenhouse gas emissions and marine ecosystem impacts. The company is committed to mitigating these impacts.

From a financial perspective, the energy transition offers significant opportunities. By positioning itself in this growing market, Boskalis strengthens its competitive position and revenue streams tied to sustainable energy solutions. An accelerated transition is expected to drive further demand for its services.

Boskalis aims to expand and strengthen its capabilities and service offering to support renewable energy and serve a broader range of clients and regions. The company measures its performance by tracking its revenues, with offshore wind activities accounting for approximately 50% of its Offshore Energy division’s 2024 revenue. This revenue was generated across 31 different wind farms through a diverse range of services.

Climate adaptation
Climate adaptation is a material sustainability matter for Boskalis, both from an impact and financial perspective. The company defines climate adaptation as protecting populations and the environment from the consequences of climate change, such as rising sea levels and extreme weather events.

Boskalis focuses on developing innovative and adaptive solutions that meet the growing demand for climate resilience while simultaneously expanding its expertise and service offerings in climate adaptation, such as coastal defense and riverbank protection. While challenges persist, such as habitat disruption, resource consumption, and the impact on local communities, Boskalis engages with NGOs and other stakeholders to mitigate these concerns. The company’s projects deliver substantial benefits, including reducing the risk of flooding and erosion, safeguarding infrastructure and economic activities, and enhancing the resilience of ecosystems and communities, including reducing the costs associated with climate-related damages.

As global awareness of climate change continues to grow, the demand for climate resilience measures is also anticipated to increase, presenting significant opportunities for Boskalis. By delivering protective and adaptive solutions, the company is well-positioned to capitalize on the heightened attention for climate adaptation and resilience. This not only enables Boskalis to unlock new business opportunities but also attracts funding and partnerships for sustainability-focused projects, further reinforcing its reputation as a provider of climate-resilient solutions.