I am pleased to confirm that Neptune Lines Shipping and Managing Enterprises S.A. reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labor, Environment and Anti-Corruption.
Through this Communication on Progress report, we demonstrate the ongoing commitment of our company to operate in a responsible and sustainable manner, sharing with our stakeholders our corporate policies, efforts and outcomes within those four pillars.
During this reporting period, we maintained our focus on the impact of our operations and the value that the company creates reflecting on society, the environment and the climate.
Towards that end, many corporate initiatives and actions took place (further analyzed in each section) - including engagement opportunities with our people, our business partners and important delegates of our industry.
We continued to invest heavily in business systems and latest technologies, on board and ashore, to better support our business functions, ensure safe and secure operations and seamless quality service with reduced environmental footprint.
Despite difficulties faced along the way, and thanks to the hard work and enduring team spirit of our ashore and seagoing personnel, the company managed to achieve important business milestones; Our services were further expanded, new business partners were added in our network and 2019 was marked a record year for our company in terms of units carried (i.e. 1,211,000 units).
On top of that, we were proud to receive the “GOLD” recognition, for the third consecutive year, from one of our major customers - following an in-depth assessment of our company’s sustainability performance.
As 2019 drew to an end, the worrying outbreak of Covid-19 in Wuhan, China and its further spreading at a rapid pace, caused growing concern worldwide. Within less than a year, turning into a pandemic, it caused major supply chain disruptions and changed the way we live and work.
To face this unprecedented health crisis, we concentrated our efforts on keeping well-informed, getting well prepared and staying protected; and though a difficult 2021 is foreshadowed, all of us at Neptune Lines are determined to face challenges together as a team and continue doing our best to safeguard human life and stay true to our broader commitments.

SUPORT STATEMENT
Neptune Lines respects the uniqueness of each and every individual and aims to treat everyone equally, with dignity and respect. Wishing to play an active role in protecting human rights in our sphere of influence, we are seeking ways to contribute not only to the elimination of their abuse, but also to their further advancement.
Being a signatory to the United Nations Global Compact (UNGC), our company has embraced its 10 Principles and is committed to demonstrating its efforts and progress with regard to the protection and further support of internationally proclaimed human rights (i.e. as these are expressed in the International Bill of Human Rights and the ILO Core Conventions on Labor Standards). Through our community investment programs and variety of actions we support fundamental rights, such as the right to an adequate standard of living and the right to education and self-development (see the Community Investment section). We also truly value and pursue diversity in our business relations; being a company that cherishes its long-term relationship with business partners from various places in the world and different cultures, Neptune Lines has gained a lot in terms of knowledge, experience and valuable insight thanks to its diversified network. In the same context, we seek to engage diverse employees that will bring a wealth of different thinking within the company. We believe that diverse personnel plays a critical role in company’s ability to adapt, grow and remain sustainable in the modern business landscape. We also believe in gender equality. Being a company that is chaired by a woman, Neptune Lines invests in the potential and skills of female employees, ashore and on board.
COMMITMENT TO HUMAN RIGHTS AND RELATED POLICIES
Our commitment to human rights and relative expectations from our employees, business partners and other parties directly linked to our operations and services, are reflected in our corporate Code of Conduct.
They are also enforced by related corporate policies in place:
• Non-Discrimination, Harassment and Bullying Policy: prohibiting discrimination of any kind and protecting the right to respectful treatment and free of hate activity.
• Health & Safety Policy: developed to protect the right to safe, healthy and decent working conditions on board and ashore. It is our goal to gain insight into relevant global guidelines from related institutions and organizations (such as, the 'Guiding Principles on Business and Human Rights' of the United Nations, respective guidelines from the ILO etc.) to further advance our existing policies.
DIVERSITY AND NON-DISCRIMINATION
Neptune Lines respects diversity and does not tolerate discrimination, or such behavior in the workplace, on any grounds (e.g. based on gender, race, color, age, origin, beliefs and opinions, preferences, individual disability, family status, or any other protected characteristic/status).
The company is committed to:
• Offer equal employment opportunities, in conformance with all applicable laws and regulations, to individuals who are qualified to perform job requirements.
• Ensure no unlawful discrimination is practiced in any aspect of the employment relationship (i.e. compensation/wages and benefits/remuneration, training and development opportunities, promotion, relocation, termination etc.).
• Provide an inclusive working environment, free from any form of disrespectful treatment and hate activity such as harassment and bullying.
• Encourage employees to report any concerns regarding discrimination in the workplace.
• Protect employees from retaliation for bringing about a complaint or for assisting in an investigation into discriminatory practices.
• Investigate any case reported and respond through appropriate and timely action.
• Ensure that no discrimination is practiced in the service provided to customers and in the business relationships with business partners

INTERNAL REPORTING
Neptune Lines encourages all employees to report any concerns they may have with regard to their own rights, as well as, possible incidents of discriminatory or other
disrespectful behavior such as bullying and harassment. Ownership of human and labor rights and issues of personnel conduct lies with the Human Resources department and in the case of seafarers, Crewing is primarily involved. These two departments make sure that employees feel comfortable to report any workplace issue they might be facing or any misconduct that comes to their attention - feeling certain that they will not be penalized or pinpointed for coming forward. Neptune Lines will protect an employee who reports any concern, from retaliation or reprisal (i.e. relative clause is included in the Code of Conduct and Company Policies
Acceptance form which is signed by employees) and will act with discretion and due diligence to resolve any issue. Following adequate investigation, if an actual breach of company's policies and Code of Conduct is identified, then the case will be brought to the attention of the Senior Management who shall decide on the course of action.
AVOIDING COMPLICITY IN HUMAN RIGHTS ABUSES
Assessing human rights impacts is a complex task for any company, especially those with global operations and business relationships, such as our own. Being part of a rather large supply chain, Neptune Lines faces this major challenge and the risks arising through its many business relationships - both direct (i.e. as in the case of our port agents who are our closest business cooperators) and indirect (i.e. entities where our company has no control over their business and activities, as in the
case of authorities).
Presently, the company manages this issue:
• Through explicit clauses in our Suppliers Code of Conduct referring to human rights protection and termination of the business relationship with our company in case of evidenced complicity in any such violation.
• By reminding company departments to be alerted during everyday practices and decision-making (e.g. in selecting providers) and reporting any related concerns.
• Through management meetings (i.e. with the participation of our Senior Management) enabling the identification of such risks and possible impacts arising from our operations or business network.
Despite these efforts, we acknowledge that human rights assessment of our supply chain has space for improvement in order to be more thorough and as comprehensive as possible; it is within our goals to upgrade our existing processes over the next years.

INTERNAL REPORTING
During the reporting period, there were no cases reported by employees regarding human rights issues or discrimination and other unaccepted conduct within the
company and on board fleet vessels.
INCIDENTS WITH REGARD TO HUMAN RIGHTS ABUSES OR COMPLICITY IN VIOLATION
During the reporting period, there were no external human-rights related incidents reported or identified in our network of business cooperators and suppliers. There were also zero legal offenses or accusations of human rights abuse (i.e. including offenses or accusations concerning forced or compulsory labor and/or child labor),
or complicity in such, against our company.

SUPORT STATEMENT
Neptune Lines respects the uniqueness of each and every individual and aims to treat everyone equally, with dignity and respect. Wishing to play an active role in protecting human rights in our sphere of influence, we are seeking ways to contribute not only to the elimination of their abuse, but also to their further advancement.
Being a signatory to the United Nations Global Compact (UNGC), our company has embraced its 10 Principles and is committed to demonstrating its efforts and progress with regard to the protection and further support of internationally proclaimed human rights (i.e. as these are expressed in the International Bill of Human Rights and the ILO Core Conventions on Labor Standards). Through our community investment programs and variety of actions we support fundamental rights, such as the right to an adequate standard of living and the right to education and self-development (see the Community Investment section). We also truly value and pursue diversity in our business relations; being a company that cherishes its long-term relationship with business partners from various places in the world and different cultures, Neptune Lines has gained a lot in terms of knowledge, experience and valuable insight thanks to its diversified network. In the same context, we seek to engage diverse employees that will bring a wealth of different thinking within the company. We believe that diverse personnel plays a critical role in company’s ability to adapt, grow and remain sustainable in the modern business landscape. We also believe in gender equality. Being a company that is chaired by a woman, Neptune Lines invests in the potential and skills of female employees, ashore and on board.
FORCED OR COMPULSORY LABOR
"Forced or compulsory labor is any work or service that is extracted from any person under the menace of any penalty, and for which that person has not offered himself or herself voluntarily" (ILO Forced Labor Convention, 1930 -No. 29).
Neptune Lines does not tolerate any form of forced or compulsory labor and degraded treatment of workers. Work should only be performed as a result of free will,
under no threat or physical punishment and employees should be free to leave whenever they wish in accordance with established rules.
All of Neptune Lines' contractors, providers and business cooperators are required to uphold the same standards and give workers, whether local or migrant, the right and the ability to leave employment when they choose. Where adherence to forced or compulsory labor provisions of national laws and regulations is insufficient,
our company takes account of international standards.
CHILD LABOR
According to the ILO 'child labor' is defined as "work that deprives children (any person under 18 years old) of their childhood, their potential and their dignity, and that is harmful to their physical and/or mental development. It refers to work that:
• is physically, mentally, socially or morally dangerous and harmful to children; and/or
• interferes with their schooling by: depriving them of the opportunity to attend school; obliging them to leave school prematurely; or requiring them to attempt to combine school attendance with excessively long and heavy work."
Neptune Lines does not tolerate child labor in any of its forms and fully supports the fundamental ILO standards that constitute the two legal pillars for the global fight
against it (i.e. ILO Convention No.138 and 182). We are committed to make sure that our operations do not contribute in any way (whether directly or indirectly
through our business relationships) to violations of children's rights.
GENDER EQUALITY
Female employees are equally treated, remunerated and promoted within the company, as male employees. They are offered the same professional development
opportunities and have the same access in decision making processes and senior positions. On board fleet vessels we fully support the employment of female seafarers through our Cadet Program and strive to achieve a balanced overall ratio of men and women. It is Neptune Lines' goal to further enhance the representation of women throughout the company, as well as, their occupation in challenging assignments.

INTERNAL REPORTING
Neptune Lines encourages all employees to report any concerns they may have with regard to their own rights, as well as, possible incidents of discriminatory or other
disrespectful behavior such as bullying and harassment. Ownership of human and labor rights and issues of personnel conduct lies with the Human Resources department and in the case of seafarers, Crewing is primarily involved. These two departments make sure that employees feel comfortable to report any workplace issue they might be facing or any misconduct that comes to their attention - feeling certain that they will not be penalized or pinpointed for coming forward. Neptune Lines will protect an employee who reports any concern, from retaliation or reprisal (i.e. relative clause is included in the Code of Conduct and Company Policies
Acceptance form which is signed by employees) and will act with discretion and due diligence to resolve any issue. Following adequate investigation, if an actual breach of company's policies and Code of Conduct is identified, then the case will be brought to the attention of the Senior Management who shall decide on the course of action.
AVOIDING COMPLICITY IN HUMAN RIGHTS ABUSES
Assessing human rights impacts is a complex task for any company, especially those with global operations and business relationships, such as our own. Being part of a rather large supply chain, Neptune Lines faces this major challenge and the risks arising through its many business relationships - both direct (i.e. as in the case of our port agents who are our closest business cooperators) and indirect (i.e. entities where our company has no control over their business and activities, as in the
case of authorities).
Presently, the company manages this issue:
• Through explicit clauses in our Suppliers Code of Conduct referring to human rights protection and termination of the business relationship with our company in case of evidenced complicity in any such violation.
• By reminding company departments to be alerted during everyday practices and decision-making (e.g. in selecting providers) and reporting any related concerns.
• Through management meetings (i.e. with the participation of our Senior Management) enabling the identification of such risks and possible impacts arising from our operations or business network.
Despite these efforts, we acknowledge that human rights assessment of our supply chain has space for improvement in order to be more thorough and as comprehensive as possible; it is within our goals to upgrade our existing processes over the next years.

INTERNAL REPORTING
During the reporting period, there were no cases reported by employees regarding labor issues and other unaccepted conduct within the company and on board fleet vessels.
INCIDENTS WITH REGARD TO HUMAN RIGHTS ABUSES OR COMPLICITY IN VIOLATION
During the reporting period, there were no external labor rights related incidents reported or identified in our network of business cooperators and suppliers. There were also zero legal offenses or accusations of labor rights abuse (i.e. including offenses or accusations concerning forced or compulsory labor and/or child labor), or complicity in such, against our company.

The risks and impacts of shipping to the environment and human health are mainly associated with vessels’:
• accidental spills (i.e. oil spills, hazardous materials etc.)
• discharges (i.e. effluents, drains, waste etc.)
• hull fouling and ballasting/de-ballasting process (i.e. bringing invasive species to locations where there use to be none)
• emissions (i.e. CO2, SOx, NOx, Particulate Matter).
There are environmental impacts from shore-based facilities as well - however, not as significant. Mitigating these risks is critical in order to avoid further harm and preserve existing resources. Neptune Lines is committed to work continually to ensure environmental compliance and play its part in achieving both the Sustainable Development Goals relevant for environmental issues, as well as the sector specific environmental goals which are imposed in a regulatory way in the shipping industry. Neptune Lines’ commitment and environmental responsibility road map is set out in our Environmental Protection and Energy Efficiency policies and procedures. These policies and procedures are expressed through specific measures, processes and initiatives which are the driving forces for achieving the targets set. In general, our management approach to safeguarding the environment focuses on:
• Compliance with all applicable environmental rules and regulations and international or national legislation of countries in which the company operates.
• Compliance with all mandatory requirements related to ship energy management.
• Record-keeping, measuring (i.e. through established KPIs) and closely monitoring of our environmental impacts in order to mitigate them; monitoring data from vessels to ensure optimal performance and energy efficiency.
• Further reducing the environmental footprint deriving from our operations and business activities.
• Obtaining and maintaining all permits and approvals required for our business and the proper handling, storage and disposal of materials.
• Continual assessment of all identified environmental risks that emerge within Neptune Lines' sphere of influence or through its business activities.
• Preparedness for and on-time response to pollution incidents.
• Considering environmental parameters and criteria (e.g. CO2 emissions, CII, fuel efficiency) in chartering decisions.
• Investing in environmental technology (i.e. new buildings and retrofitting in existing vessel technology).
• Undertaking and promoting initiatives and programs within environmental focus areas
• Continually improving the environmental awareness and responsible conduct of onshore and seagoing personnel through training, familiarization and written instructions.
• Communication with stakeholders regarding the development and progress of environmental measures, initiatives and programs.
Neptune Lines requires from its providers, subcontractors and business cooperators to abide by all legislation and regulations related to the protection of the environment and the handling of dangerous and hazardous materials or substances.

IMPLEMENTING THE PRECAUTIONARY PRINCIPLE
Apart from the measures described previously to safeguard the environment, Neptune Lines implements the precautionary principle, as an integral part of its environmental safety culture and decision-making processes.
This principle states: "Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation." With regard to its implementation, Neptune Lines:
• Seeks to use the best available technology and environmental practices where technically and economically feasible (i.e. technology approved by legislators or regulators for meeting output standards).
• Seeks to obtain any additional information necessary for a more objective assessment of the risk to the environment.
• Performs post-decision monitoring.
• Tries to communicate effectively and cooperate with all involved parties to minimize any possible risk to the environment (i.e. providers, charterers, vessels, recognized organizations and regulatory bodies etc.).
Finally, our company is represented in various stakeholder working groups of the shipping sector that play an active role in shaping the regulatory scheme.
Through consultation, technical committee experts, shipping companies and other maritime stakeholders share their experience and knowledge and provide feedback to regulatory bodies that carve sectoral strategies and regulatory frameworks. This collective brainstorming and action, assists in overcoming environmental challenges in the most effective manner and casts light on the existing objective evidence, the gaps in knowledge and the scientific uncertainties.

COMPLIANCE WITH ENVIRONMENTAL LAWS AND REGULATIONS
One minor environmental incident took place within the reporting period and in particular within 2019, prior starting of cargo operations at port and while opening the stern ramp, a high-pressure pipe burst from starboard-side ramp hook, and about 3ltrs of hydraulic oil spilled from aft side to the sea. Oil leakage was immediately stopped and the burst high-pressure pipe was replaced. The small oil spill was cleaned by the port antipollution team, relevant environmental penalty was raised and settled prior vessel’s departure from the port.
Regarding the alleged environmental claim for the use of non-compliant fuel in that occurred during the previous reporting period (i.e. higher sulfur values were found during lab testing compared with the values described in BDN’s), the investigation is still ongoing in cooperation with the competent authorities.
No other environmental compliance issues occurred during the reporting period.

Its actual impacts can range from minor problems in operations and human health, to severe situations, major damages, losses and casualties. Sudden and extreme changes of weather, out-of-season storms, rise in temperature, as well as, increasingly high winds and abnormal sea-waves raising to unexpected heights, tend to be all the more frequent - rendering our crew's working and living conditions more difficult as the years go by.
During the reporting period, our seafarers have experienced difficult navigation situations quite a few times due to adverse weather conditions. And even though weather-forecast is provided on board through appropriate software, one cannot be completely prepared for sudden weather changes. Within 2020, during particularly adverse weather conditions, one of our vessels faced a difficult situation of heavily rolling and pitching, leading to cargo shifting and cargo damages.

Climate Change poses Risks and Opportunities to our company and stakeholders.
Climate Change related Risks are divided into two major categories as per TCFD . Risks related to the transition to a lower – carbon economy (Transition Risks) and risks related to the physical impacts of the climate change (Physical Risks).
Transition Risks refers to:
• Current and emerging regulations,
• Technological improvements or innovations,
• Legal implications through climate related litigation claims,
• Market changes due to shifts in supply and demand for certain services
• Reputation impacts related with shifts in consumer preferences, negative feedback or sector stigmatization
Physical Risks refers to
• Acute – risks that are event driven, including increased severity of extreme weather events, such as cyclones, hurricanes, or floods;
• Chronic – longer - term shifts in climate patterns such as sustained higher temperatures leading to rising sea levels or chronic heat waves.
On the other hand, Climate Change offers Opportunities which are related with:
• Resource efficiencies such as the use of more efficiency modes of transport, use of more efficient distribution processes, recycling processes, reduction of water usage
• Energy source through the use of lower emission sources of energy, use of new technologies as well participation in carbon markets
• Products and Services through the development and / or expansion of low emission goods and services as a result of R&D processes, reputational benefits resulting in increased demand for services and shifts to consumer preferences.
• Access to new markets
• Resilience through participation in renewable energy programs and adoption of energy – efficiency measures.
Neptune Lines identifies its Transition Risks in its direct operations through the current and emerging regulations related with the carbon pricing mechanisms and the enhanced emissions reductions and reporting obligations. Carbon pricing mechanisms may potentially increase the direct costs through the possible establishment of a carbon market while the even more demanding emissions reduction obligations may decrease the asset value or assets useful life leading to write offs, asset impairment or early retirement of existing assets.
Neptune Lines sets action plans to respond effectively in the above-mentioned Transition Risks by
- Setting up an internal carbon pricing policy
- Investing on low carbon technologies for our existing and newly designed vessels (biofuels, rotor sails etc.)
- Considering to upsize or replace tonnage
- Monitoring closely the performance of existing fleet and use AI-driven optimization tools
- Working with clients to optimize supply chain design from an emission-efficiency standpoint
- Investing in carbon capture and sequestration equipment
- Exploring other offsetting actions for the unavoidable emissions
- Optimizing vessels speed and on-time arrival using advanced applications and weather routing services
- Optimizing vessels rotation plans considering the cargo capacity utilization figures.

Acute Physical Risks are affecting significantly the normal execution of the routine operating tasks. Neptune Lines direct operations as well as its customers (downstream value chain) and service providers operations (upstream value chain) may severely been affected from the acute physical risks such as the severe and frequent extreme weather events i.e. cyclones, hurricanes, floods.
For direct vessel operations, the existence of such weather phenomena may lead to human injury or loss of life, property (vessel/cargo) damage or loss and marine pollution incidents.
Neptune Lines prepares itself to deal with such extreme phenomena by implementing proactive actions which include, advanced weather routing services able to monitor the future weather conditions for the intended voyage - enforcement of special cargo securing arrangements when heavy weather conditions are expected to minimize the possibility of cargo damages - implementation of onboard crew training programs to respond efficiently to critical situations identifying the corrective actions to be taken on each case (emergency response plans - step by step approach) as well as post incident investigation analysis allowing to identify possible areas of improvement.
Except from the impact on direct vessel operations, the acute physical risks may significantly affect Neptune Lines service providers (upstream value chain) such as the port operators which may face significant port infrastructure damages or even port closures due to extreme weather conditions. This will increase the operating costs due to prolonged stay of vessels at ports and subsequently distract vessel’s schedule. Neptune Lines regularly reviews vessels rotation schedules in order to adjust and minimize such impacts.
The acute physical risks may also affect its customers (downstream value chain) since factory production may eventually be reduced as a result of infrastructure damages or reduced sales.
On the other hand, Climate Change except from Risks, offers and Opportunities.
Climate change will shift consumer preferences and drive the demand for low or zero carbon vehicles and subsequently increase the sales on alternative fueled vehicles by speeding up the purchase of new low or zero carbon emitting vehicles from the consumers. The new environmental regulations coming in force will push the shipping industry to use new technologies in an effort to reduce the overall emission footprint.
Neptune Lines is implementing a more efficient transportation service with less energy demands satisfying at the same time its contractual obligations. Our new building projects incorporates the latest technologies in ship design with remote performance monitoring tools, expected to complete by Jan 2025.
Advanced ship designs include more efficient hydrodynamic hull forms, developed in consultation with specialized ship design houses, fitting of energy saving devices such as propeller-bulb rudder combination systems (PROMAS), shaft generators, variable frequency drives throughout the machinery room, battery installations, led lighting and advanced anti fouling coatings.
Neptune Lines focuses on new technologies by investing on fuels with a reduced GHG footprint such as LNG, representing at the moment a cost-effective alternative over the lifetime of the ship provided that methane slip is kept at the minimum.
At the same time Neptune Lines is looking ahead for the use of alterative zero emissions technologies like hydrogen, ammonia and synthetic fuels which are currently hampered by limited availability, infrastructure, low energy intensity, safety issues and most importantly by high capital and operational costs. Biofuels use are also considered as a solution for Neptune Lines strategy based on availability.

Monitor Financial Implications of Climate change

There are various costs and expenses rising from climate change risks and impacts. These range from smaller or medium-scale costs such as:
• investments in emergency response and weather routing training & systems for weather-forecasting
• costs from minor vessel damages or minor injuries
• costs of tug-boats assisting the vessels in heavy weather during port arrival and departure
• fuel consumption costs due to the fact vessels consume more fuel in bad weather
• costs created due to disruptions and delays (e.g. in vessel operations, flights of crew members or technicians joining the vessels, maintenance and dry dock works etc.) to greater-scale costs and implications such as:
• insurance costs
• claims from external parties due to major property and assets damages (e.g. cargo, port terminal),
• costs due to vessels’ structural damage
• costs deriving from a casualty.

Implementation and Evaluation
Environmental Management System
Neptune Lines’ Environmental Management System complies with all applicable regulations and conventions of our sector for the protection of the environment, with the major one being the International Convention for the Prevention of Pollution from Ships, also known as MARPOL.
Neptune Lines' Management System is certified under ISO 14001:2015 standard and is subject to periodic evaluation and verification by the appointed Recognized Organizations.

Committed to the standard's principle of 'continual improvement', we constantly monitor and evaluate our system's effectiveness through internal processes (e.g. management review meetings) and when needed, take appropriate action to improve.
Any updates, amendments or revisions of the system, as well as, results from environmental audits, environmental objectives and targets are communicated throughout the company (including fleet vessels) through our annual Management System Review report or circular instructions and safety bulletins.
Evaluation of our performance within the reporting period will be demonstrated respectively in each one of the environmental sections that follow.
Environmental Compliance Onboard

Environmental compliance on board fleet vessels is ensured through:
• Established audited processes and plans (i.e. Ship Energy Efficiency Management Plan Part I and Part II, Ballast Water Management Plan, Garbage Management Plans etc.).
• Vessels’ reporting on environmental indicators (i.e. periodical reports on CO2 emissions and fuel consumption metrics, chemicals consumption, waste disposal, incineration process etc.) followed by performance monitoring from the office.
• Drills (e.g. oil-spill drills) and ship-to-shore simulation exercises with the participation of the Office Emergency Team and emergency response experts.
• Seafarers' familiarization with environmental measures and expected actions upon embarkation.
• Safety meetings - during which, relevant topics and instructions are discussed to enforce knowledge and understanding.
• Internal audits performed by shore auditing team to assess environmental awareness of crew and ensure compliance through existing procedures on board.
• On board Computer Based Training (CBT) modules.
• External auditing by Recognized Organizations (ROs).
• Ongoing programs and specific measures related with our Emissions Reduction and Energy Efficiency Program, effluents and waste measures and related procedures.
These will be presented in detail in the section of each environmental topic.

Monitor Financial Implications of Climate change
There are various costs and expenses rising from climate change risks and impacts. These range from smaller or medium-scale costs such as:
• investments in emergency response and weather routing training & systems for weather-forecasting
• costs from minor vessel damages or minor injuries
• costs of tug-boats assisting the vessels in heavy weather during port arrival and departure
• fuel consumption costs due to the fact vessels consume more fuel in bad weather
• costs created due to disruptions and delays (e.g. in vessel operations, flights of crew members or technicians joining the vessels, maintenance and dry dock works etc.) to greater-scale costs and implications such as:
• insurance costs
• claims from external parties due to major property and assets damages (e.g. cargo, port terminal),
• costs due to vessels’ structural damage
• costs deriving from a casualty.

Emissions
Why this topic is Material
Neptune Lines is committed to the sustainable development goal of ‘taking urgent action to combat climate change and its impacts' (SDG 13: Climate Action).
Being part of the transport sector supply chain, Neptune Lines inevitably contributes through the operation of its fleet vessels to the overall greenhouse gas emissions - which are the cause of global warming and climate change.
On the other hand, as a shipping company we are also directly and significantly affected by the impacts and potential threats of climate change due to vessels' complete exposure to weather conditions (see Climate Change section).
It is Neptune Lines' aim to continually work towards further reducing emissions from its operations and increasing energy efficiency, so as to contribute to the achievement of this critical global goal.

How we Manage this topic
Neptune Lines has invested in a young and modern fleet, equipped with the latest advances in technology. Its newer ships have been built in 2014, have been assigned with CLEAN notations from their classification societies meeting the set requirements for reducing the environmental impact from emissions to air, discharges to sea and deliveries to shore from vessels. The technologically advanced vessels result in a 20% improvement in fuel consumption and CO2 emissions, compared to the previous generation of vessels.
The types of energy used within our company (office premises and vessels) are related with electricity (purchased for shore premises and self-generated for vessels) and fuel oils (vessels).
While the environmental impacts from our shore-based facilities (mainly utilized for the technical management of the vessels as well as for the provision of our logistic services), are relatively small, the environmental impacts of shipping, arising from the operation of the vessels are more material and are mainly associated with emissions, accidental spills, discharges hull fouling and ballasting / de-ballasting processes.
As from Jan 01st, 2020, (IMO 2020), all ships are using fuel with a sulphur content of no more than 0.5% against the previous limit of 3.5% in an effort to reduce the amount of sulphur oxide. However, the use of high sulphur fuels is still allowed basis that exhaust gas cleaning technologies (scrubbers) are installed to the vessels.
Neptune Lines completed the installation of exhaust gas cleaning systems (scrubbers) in order to minimize the sulphur footprint produced from its vessels. Scrubbers have been installed on ten (10) vessels. The reduction achieved in SOx by using the scrubber technology is higher than the one mandated by the IMO 2020 sulphur regulation.
Neptune Lines monitors CO2 emissions in absolute and intensity numbers since 2010. Up to 2018, the emissions reporting was not regulated in the shipping sector.
As from 2020, Neptune Lines carbon intensity reduction target, is set to a total reduction of 11.0% till 2026, using 2019 as the base year. In absolute numbers (total Fleet CO2 emissions), the reduction target is set to a total of 21% reduction till 2026 having again 2019 as the base year.
Neptune Lines is currently designing its new generation of new building vessels, the construction of which is expected to start in 2023 and complete by the end of 2024. These new generation vessels aiming to achieve a 50% reduction on CO2 emissions per transported unit.

Progress and Performance

Progress made throughout the reporting period and performance on various measures, is presented hereinafter.

MEASURES FOR EMISSIONS REDUCTION AND ENERGY EFFICIENCY

Trim Optimization and Ballast Control

Lack of knowledge on optimum trim typically leads to unnecessary high fuel consumption. The trim and/or draft of the ship influences the hull resistance and therefore the fuel consumption.

Trim optimizer advises optimum trim and savings potential prior departing from the port:

Input : speed, draft, trim
Output : optimum trim, savings potential for fuel, power % and CO2

The trim of a ship describes its floating position in length direction, namely if the bow or the aft of the ship is deeper submerged into the water. The trim can have a significant impact on a vessel’s energy demand for propulsion during sailing. The most efficient trim for a particular ship depends on its design, operational draft and speed.
Trim optimization and ballast control is applied to 12 vessels in the fleet. Using the specific software, the ships are able to minimize the ballast and optimize the trim upon departure from a port. Optimizing the use of ballast (i.e. reducing its amount as much as possible without affecting vessel's safety) and properly adjusting vessel's trim, helps minimize hull resistance and fuel consumption resulting to emissions. These tools use 3D modelling software and computational fluid dynamics (CFD) for a variety of operating conditions; their results are based on high-end calculations for each vessel. Said software supports our crew in minimizing the ballast and optimizing the trim upon departure from a port.

Scrubbers

"Scrubber" is an exhaust gas treatment plant: i.e. a system that is designed to wash (by the use of water) the exhaust gases from main, auxiliary engines and boilers so as to remove SO2.

We continued the installation of scrubber systems within the reporting period (2019-2020) and completed the installations in the majority of our fleet to minimize the Sulphur footprint of our vessels. Ten (10) vessels were installed with scrubbers. All systems are approved and working successfully. Three (3) scrubbers were completed in 2020. The reduction in Sulphur is higher than mandated by the IMO 2020 Sulphur regulations as the ships operate the scrubbers with resulting Sulphur % less than mandated by the rules of 0.5% in non-ECA areas and 0.1% in ECA areas and EU ports.

Advanced Anti-Fouling (A/F) Coatings to Reduce Fuel Consumption

We continue to monitor the performance of fleet vessels coated with silicon and advanced efficiency anti-fouling - observing significant improvement in their fuel consumption. The performance of each vessel - based on the type of A/F applied - is recorded, monitored and benchmarked against that of other fleet vessels on an annual basis.

In 2019 and 2020 we drydocked in total eleven (11) fleet vessels all of which were re-coated with advanced antifouling.

Propeller Polishing

During the reporting period, eleven (11) fleet vessels had their propellers polished during drydock.

Speed optimization/Ship efficiency – Operational measures

In 2019 and 2020 we continued with the speed optimization for most of the fleet vessels. This is an operational measure and we have been monitoring the results in the fuel consumption. We continued in our policy of using the constant RPM mode. If the speed is above or equal to16 knots they continue to use the constant RPM mode and if the speed is less than 16 knots the combinator mode is used. The trade-off is between usage of the shaft generator and saving fuel in the propeller. The performance of the fleet in 2020 is improved compared to the performance in 2019 and 2018 due to the many dry dockings and hull coating improvements.

Lean Marine System and FuelOpt – Speed Optimization

The Lean marine system is a unique system as it allows optimizing the fuel consumption in an automatic way when using the combinator mode and allows keeping a constant ship speed or constant ship consumption. The telemetry solutions generate a number of reports on a weekly basis to monitor the ship machinery condition and the fuel related consumptions and operational data.
Retrofitted in 2 vessels and are scheduled for 2 more in 2021. Improved efficiency of the main engine and the propeller in reduced vessel speed operation - Improved Speed Management with reduced overall propulsive power and consumption - Reduced fuel consumption up to 15% for CPP and up to 5% for FPP.

What is FueOpt:

With FuelOpt, the vessel is always run with optimized fuel economy. FuelOpt controls the main engine and propeller to the actual environment and loading conditions. It reduces fuel consumption by making sure the propulsive power is always optimized by automatically controlling the pitch and RPM based on the direct commands from the bridge.

Telemetry system

Presently we have installed Telemetry systems in 12 vessels of our fleet after a major investment in the METIS technology in 2020. All twelve vessels have a METIS telemetry installation of varying levels of sophistication and in addition we have two ships with MARORKA to monitor real time 24 parameters of the ship from ship performance to energy consumption.

METIS cyber technology is specializing in integrating IoT and NLP technologies with regards to vessel log and data collected from various vessel‘s systems; data collected is thereafter processed from METIS and forwarded to office . Data gathered and forwarded can be used to analyze voyage performance (e.g. against weather conditions, a previous voyage of the same service line etc.); data can also assist in predicting vessel‘s future behavior (voyage performance) by analyzing information available from past voyages.

Coriolis flowmeters
On 8 vessels in our fleet we have installed Coriolis flowmeters for accurate measurement of the fuel oil consumption for M/E and auxiliaries. On the two new vessels we have also installed Coriolis flowmeters for accurate measurements during bunkering.
Autotuning for M/E
During drydocking in February 2019, the autotuning system from MAN diesel was installed on one of our vessels. This allows operation of the M/E with balanced cylinders and improves fuel efficiency. In 2020 due to covid-19 the same system was not installed to more vessels as initially planned.

Projects Under Study

New building project – Dual Fuel PCTC (new high-efficiency vessels)
The uptake of LNG has been very strong in recent years, especially in new buildings. We are currently examining the construction of Dual Fuel PCTC’s over the next years taking into consideration the final formulation of the regulations.

Rotor Sails Retrofit Study
A study was conducted for retrofitting Rotor Sails on vessels trading on a specific trade lines. Rotor Sails harness power from the wind to propel ships. This results in improved vessel efficiency and reduces the fuel consumption and release of harmful emissions into the atmosphere. Project is under research and evaluation.

Use of Biofuels
Neptune lines investigates the viability of biofuels, considering availability and costs which are typically higher but results in significant reductions on CO2 emissions when compared with traditional fuels.

Emissions & Energy Efficiency Indicators

(Total Fleet Fuel Consumption (HFO, MGO & LFO) x Emission Factors) / Total Distance Traveled.

The indicator used since 2010 to monitor and report our direct (Scope 1) fleet emissions, is the intensity ratio of CO2 mass emitted (in metric tonnes) per nautical mile.

This calculation method is based on the IMO Resolution MEPC.1 / Circ.684 issued on August 17th 2009 without considering the transported work in the denominator.
The data for the distance traveled and fuel consumed were obtained from vessels’ monthly and daily position reports. Emissions calculations include only the fleet vessels managed from Neptune Lines. Chartered vessels are excluded. The distance traveled includes also all pilotage miles, deviations due to weather, vessels’ drifting etc.
Neptune Lines CO2 emissions as from 2010 till 2020, without taking into consideration the volume of the transported work and excluding chartered vessels. Both for 2019 and 2020 we achieved our target for 0.5% reduction on annual basis reducing our overall consumptions by 1.83% and 1.68% respectively.
Reviewing our reduction progress since 2010 we have managed to achieve an overall reduction of 11.35% using the specific calculation method.

As from 2019, Neptune Lines is calculating and reporting the direct (Scope 1) absolute and intensity fleet emissions in accordance with the IMO Data Collection System (DCS - AER - CII) and European Union (EU) Monitoring Reporting and Verification (MRV) regulatory regimes and IMO Resolution MEPC 281(70) as amended.
Indirect (Scope 2) emissions produced from purchased electricity, heat and cooling, are related only with our shore-based facilities since vessels are producing electricity from the onboard auxiliary engines powered by fuel.

At the end of each reporting cycle - defined as one calendar year - all voyage data are aggregated, quality-checked and submitted for verification to accredited bodies (DNV).
Using the IMO DCS voyage data, we are calculating our CO2 emissions in absolute and intensity metrics.
While absolute numbers are calculated and monitored on a total Fleet CO2 emissions number, the intensity metrics are calculated for each vessel type separately, using as a denominator the Gross Tonnage (GT) for our Ro Ro Vehicle Carriers and the Deadweight Tonnage (DWT) for our Ro Ro Cargo Ships, in order to calculate the transport work for each vessel type (GT or DWT X distance sailed-nautical miles), known also as Carbon Intensity Indicator (CII).
Intensity Metrics
EEOI CII (AER) CII (cgDIST)
(gr CO2 / t nm) (gr CO2 / dwt nm) (gr CO2 / gt nm)
2018 128.64 n/a n/a
2019 137.33 43.8 7.32
2020 128.48 45.07 7.09

Absolute CO2 mt

2019 345,894
2020 293,084

Energy Efficiency
Why this topic is Material
Using energy more efficiently is essential for lowering our company's overall environmental footprint and play our part in achieving the Sustainable Development Goal 7 (i.e. sustainable energy) and 13 (i.e. combating climate change).
The energy used for our shipboard and onshore operations comes exclusively from non-renewable sources.
Consuming non-renewable fuels is usually the main contributor to direct GHG emissions.
The types of energy used within our company (i.e. office premises and vessels) are:
• electricity (i.e. self-generated in the case of vessels and purchased for shore premises)
• fuel oil (vessels)
• natural gas (office premises).
Energy management and application of energy efficiency measures plays an important part in reducing fuel consumption and subsequently emissions - resulting, at the same time, in significant financial savings; And even though, the yield of each individual energy efficiency measure may be rather small, the collective effect can be significant.

How we Manage this topic

FLEET VESSELS
Energy efficiency in shipping can be addressed at many different levels.
The performance indicators in our sector refers to the CO2 emissions per transport work (intensity ratios) and in total metric tonnes of CO2 emitted by fleet vessels as defined in the applicable regulations. For this reason, when it comes to quantitative measurement, we monitor and evaluate the energy efficiency of our fleet vessels based on fuel consumption and CO2 emissions.
However, improvements on energy efficiency is often discussed in terms of technical and operational performance measures (e.g. related to operational speed and voyage planning, technologies applied on board, propulsion and hydrodynamic efficiency etc.) that result in energy savings.
Technical and operational measures applied by our company to improve the energy efficiency of fleet vessels were mentioned in the ‘Emissions’ section.
Monitoring and evaluating the performance of these measures is an ongoing task; each measure can be effective under certain circumstances and, most of the times, is affected by the rest of the measures applied. Hence, a technical solution optimized for a specific trade and operational pattern will most probably not be optimal if the trading pattern is changed - for instance by changing operational area, speed or cargoes.
Neptune Lines closely monitors and evaluates the performance of its energy efficiency measures through:
• the use of Performance Monitoring Systems (e.g. Telemetry System providing real time feedback from vessels), that serve as decision-support tools,
• the expertise of its onshore technical management,
• effective and transparent communication between the office, vessel, port and port agents - all of which play an important role in obtaining accurate and holistic reporting input.
Performance indicators are analyzed - taking into consideration the particulars and the different operation circumstances of each vessel - and compared for sister vessels to track any differences.
Performance results are then communicated within the company on a monthly basis and relevant circulars are sent to vessels, enclosing further guidance when needed.
Two other important aspects considered, when it comes to energy efficiency, are voyage planning and port efficiency so as to minimize the waste of energy due to unproductive time spent by the vessels while drifting at port waiting to operate (e.g. in cases of congestion).
Vessels' voyage planning and on-time arrival is closely monitored within Neptune Lines. However, it is not always possible to avoid waiting at port. Increasingly deteriorating weather conditions, reduced port productivity in terms of working hours and availability of gangs for loading/ unloading, as well as, the nature of car-carriers' trade (e.g. with last-minute changes in vessels' cargoes and schedule), make it difficult sometimes to ensure just-in-time arrival and operation.
For this reason, Neptune Lines invests in:
• New innovative technologies and newbuilding designs
• Shore personnel training, experience exchange and best practices sharing
• Increasing crew awareness, motivation and personal engagement during their contract on board fleet vessels
• Collective-action projects - through its participation at relevant European Union (EU) funded initiatives

OFFICE PREMISES
The energy consumed at office premises (i.e. electricity, heating and cooling) is purchased from external sources. For heating and cooling we use natural gas.
Energy-saving measures (ongoing) at the office include:
• Controlled printing and printer adjustments for more efficient printing.
• Optimization of energy settings on users' computers.
• Hibernation of computers, screens and printers when not used for a prolonged time.
• Temperature adjustment in the heating/cooling system to avoid misuse.
• Replacement of fluorescent tubes with LED.
• Adjustment of lighting self-closing time limits to minimize unnecessary use.

Progress and Performance
Energy consumption for shipboard operations is calculated separately from shore-based facilities.
Calculation of vessels' energy consumption is based on fuel oil consumption and the calorific value for each one of the fuels consumed.
Calculation of the shore-based energy consumption is based on the consumption of electricity and natural gas.

FLEET VESSELS
During the reporting period, we continued our lighting management policies.
Lighting Management Turning off the car deck lights during sailing and leaving on only vessel's emergency lights, is one of the energy saving measures initiated during the previous reporting period. Monitoring the results from its consistent implementation by some fleet vessels, we noticed significant savings on their auxiliary engine consumption.
LED Lights
Installation in 2019 and 2020. We continued with further replacements of vessels' fluorescent tubes with equivalent LED, after observing significant reductions in the energy consumption of existing installations. Fluorescent tubes in the Engine Room (E/R) and Accommodation were replaced, as well as, all lights in car decks. So far, 12 out of 13 vessels have completed the replacement with LED.

Energy Consumption
The energy consumption* shows a downstream trend over the last four years. The reduction on the fuel consumption following the implementation of energy efficiency measures as well as the use of fuels with higher calorific value (i.e. Light Fuel Oil with 41.2 contrary with HFO at 40.2) as a result of the new regulations implemented for the use of low sulphur fuels usage after Jan 01st, 2020, had a positive effect on the energy consumed achieving a 18 % reduction from 2018 to 2020. Chartered vessels are excluded from the calculation.

Effluents, Waste & Materials Used
Why this topic is Material
Oil and chemical spills, non-compliant discharges of ballast water, cargo residues, routine discharges of oily bilge and pollution from non-biodegradable solid waste (e.g. plastics), have severe negative impacts on the marine environment and, in many cases, the nearby communities.
Also, marine accidents involving ship grounding or sinking and ship breaking activities performed without due diligence, have cumulatively led to the contamination of the ocean's sediment.
Managing the risks and impacts of marine pollution effectively, is of critical importance for Neptune Lines due to the environmental orientation of our company and, above all, due to the profound and far-reaching implications associated with a possible miss in this area (i.e. environmental damage, legal implications, economic losses that tend to be enormous in such cases etc.).
Apart from our company, this topic is critical to our industry and to the rest of our stakeholders - since an environmental accident, more or less, impacts the wider shipping sector and ripples up to the broader society.
This is why we believe that compliance procedures to prevent environmental harm, as well as, carefully designed responsive measures to mitigate the impacts of a possible incident, need to be rigorously monitored and constantly assessed to ensure effectiveness at all times.
While working towards proper implementation of our sector's stringent requirements and safeguards, we also expect those who conduct business with us to follow the required procedures for using, storing, labeling, transporting and disposing of materials that are harmful to the environment.
This topic is closely linked to the Sustainable Development Goal 14 Life Below Water and its sub-target to "prevent and significantly reduce marine pollution of all kinds (…)”.
REGULATORY OVERVIEW
BWM Convention
Ballast Water Treatment Systems are now installed to all vessels of Neptune Lines in order to fulfill the D-2 standard ballast water discharge requirement after relevant treatment.
Relevant certificates are issued addressing the procedures for Ballast Water exchange and Ballast Water Treatment. Approved technical documentation for the Ballast Water Treatment system installation are available onboard vessels and relevant training performed to onboard personnel for the proper use of the system.
EU Ship Recycling Regulation and Inventory of Hazardous Materials (IHM)
The EU Ship Recycling Regulation came into force on 31 December 2020 and effects any in-service ship of 500 GT or over calling at any EU port or anchorage (regardless of flag). It requires that vessels hold a valid and certified Inventory of Hazardous Materials (IHM) on board which will be subject to Port State control inspections.
IHM is a structured system to control hazardous materials onboard ships and achieve compliance with both (EU SRR) and the Hong Kong Convention (HKC) for the Safe and Environmentally Sound Recycling of Ships.
Despite the restrictions imposed due to Covid-19 causing many difficulties in carrying out the IHM surveys/verification onboard by HazMat experts, the whole process was well-coordinated and completed successfully for all fleet vessels within the globally agreed deadlines.

How we Manage this topic
Waste Management Policies & Procedures
Our waste management policies and procedures focus on:
• the elimination of non-hazardous waste disposal at sea (e.g. comminuted food waste) - despite being allowed by regulations
• the environmentally friendly handling of waste disposal (i.e. proper segregation, reuse, recycling, onboard processing/treatment etc.),
• reduction at the source (i.e. minimization of generated waste and packaging materials, use of materials with increased service life),
Specific procedures for the monitoring and disposal of generated effluents and waste - including those followed in emergency cases (e.g. accidental marine pollution) are laid out in respective company manuals – approved according to established regulations (e.g. Shipboard Oil Pollution Emergency Plan, Garbage Management Plan, Sewage, Bilge Water & Refrigerant Systems Management Plan, Ballast Water Management Plan etc.).
Furthermore, the company is taking steps to minimize the taking aboard of potential garbage, in cooperation with its providers, encouraging them to consider their products in terms of the garbage they generate. Environmental Officers and staff being in direct contact with the local providers and having a clear picture of materials delivered to the vessel, ensure that unnecessary and/or undesired items/packages are not to be taken on board. (See also Environment: Our Management Approach section.)
Environmental Notation Vessels
Four of our fleet vessels have "CLEAN" notation, an environmental notation given by the Classification Society for voluntary compliance with additional pollution prevention measures.
Clean notation shows compliance with all mandatory MARPOL requirements, regardless of exemptions that may be granted by flag state administrations. It contains additional requirements to prevent oil pollution and requires a vessel to have improved technical and management procedures to reduce discharges to sea and emissions to air.
Moreover, all fleet vessels are fitted with a fuel oil overflow tank to minimize the risk of an overboard fuel oil spill.

Progress and Performance

Garbage (Solid Waste)

Zero waste disposal at sea

According to regulations in force, the only garbage type (see “types of garbage” as per MARPOL Annex V in pg.71) allowed to be disposed at sea – under certain conditions – is food waste (i.e the only solid waste that is not harmful to the marine environment). The rest are to be discharged ashore at appropriate reception facilities.
Despite the fact that disposal of food waste at sea is permitted by regulations, Neptune Lines implements a zero-disposal policy.
In 2019 the total amount of comminuted food waste discharged at sea was 0.006 m³/vessel/month, and in 2020 it reached the target of 0 m³/vessel/month.

Plastics

Neptune Lines aims to minimize the use of plastics on board and ashore.
In 2019, unfortunately, the volume of plastics used on board increased from 2.51 m³/vessel/month to 4.80 m³/vessel/month. However, in 2020, the volume of plastics used further decreased to levels similar to those prior 2018 (i.e 2.40 m³/vessel/month).
In an effort to further reduce plastics consumption at office premises, the company has provided all employees with stainless steel thermos coffee mugs that are used for their daily beverages, instead of the single-use coffee cups provided by the nearby coffee shops.

Oily bilge water & Oil residues (Sludge)

Oily bilge water means water which may be contaminated by oil resulting from things such as leakage or maintenance work in machinery spaces.
Oil residue or ‘sludge’ means the residual waste oil products generated during the normal operation of a ship (i.e such as those resulting from the purification of fuel or lubricating oil, separated waste oil from oil filtering equipment, waste oil collected in drip trays etc.).
Oily bilge water cannot be discharged at sea. It has to be processed/filtered through the Oily Water Separator (OWS) – ensuring oil content of 15ppm (i.e parts of oil per million parts of water by volume) or less. The processed water of 15 ppm/less can be discharged at sea, as per regulation, while the remaining oil residue (sludge) is kept on board with the rest of sludges – for incineration or further discharging at shore facilities.
The chart “Oily Bilge Water Generated” includes both the processed/filtered water that is discharged at sea, and the remaining oil residue/sludge which is either incinerated or discharged at shore facilities.
In 2019, oily bilge water generation on board decreased (0.46 m³/vessel/day) in comparison with 2018 (0.49 m³/vessel/day). In 2020, it further decreased to 0.42 m³/vessel/day, achieving the target of less than 0.50 m3/day.
Sludge generated for 2020 (0.42 m3/vessel/day) decreased in comparison to 2019 (0.44 m3/day/vessel). The environmental character of our HMD vessels (8 Vessels) does not allow any drains (all engine room drains plus air condition condensed water, CO2 room drains etc.) to be directed overboard but on the contrary to be collected in oily water tank and further processed through 15 ppm or discharged at dedicated shore facilities.

Paints and Chemicals Consumption
Neptune Lines puts emphasis on the use of premium quality paints and chemicals for the maintenance and needs of its fleet vessels. Their use, however, is based on a ‘need to have’ basis aiming, through careful planning, in order to minimize their consumption.
Paints are supplied considering the stock available on board and each vessel’s actual maintenance and cosmetic needs, while chemicals also serve as fuel additives.
Monthly paints consumption per vessel increased in 2019, in comparison with 2018, from 135 liters/vessel/month to 140 liters/vessel/month. In 2020, monthly paints consumption remained at the same levels as in 2019 (i.e 140 liters/vessel/month). Dry dockings of fleet vessels within 2019, and some within 2020, were a contributory factor to this increasing trend.
Monthly chemicals consumption, on the other hand, decreased in 2019, in comparison with 2018, from 203 liters/vessel/month to 197 liters/vessel/month. In 2020, relevant figure further decreased to 175 liters/vessel/month.

Spills
Only one minor incident occurred during the reporting period and specifically in 2019. While opening the stern ramp on board one of our vessels, a high-pressure pipe burst from starboard side ramp hook, and about 3 ltrs of hydraulic oil spilled from aft side to the sea. Oil leakage was immediately stopped and the burst high- pressure pipe was replaced. The small oil spill was cleaned by the port antipollution team, relevant environmental penalty was raised and settled prior vessel’s departure from the port.

CODE OF CONDUCT & POLICIES
Neptune Lines is committed to conducting business with integrity and in compliance with all applicable legislation. Our company's history and reputation, as well as, its long lasting business relationships are based on these values and standards. Trust is hard to earn and easy to lose. Having gained the trust of our stakeholders - internal and external - throughout these years, our aim is to further secure it and work our best to continue inspiring it. Likewise, the trust that Neptune Lines has placed in its business relationships, must on no grounds be shattered. Business relationships can include relationships with business partners, entities in our value chain, and any other non-State or State entity directly linked to our business operations and services. We believe that corporate governance, compliance and business ethics are closely related with company's longevity and that "good business" is always rewarding for the company and those who are associated with it. In the opposite case, the consequences of an incident of such nature can be serious and far-reaching - ranging from endless legal proceedings to the damage of company's reputation, its relationships, its very own business continuity. Apart, though, from being material to our own company, this is a critical topic in itself - when it comes to the global agenda - as it can significantly affect the Sustainable Development Goals (SDGs). Business who operate ethically contribute to the goal of "Promoting, peace, justice and strong institutions" (SDGs Goal 16), including its sub-target "to substantially reduce corruption and bribery in all their forms" (Target 16.5). On the other hand, those who lack compliance and ethical boundaries pose a threat on all the SDGs, since all the goals can be undermined by corruption and ethical lapses.
In addition to the corporate Values, our commitment to ethical conduct is expressed and implemented through our governing Policies and Code of Conduct - applying to all hierarchy levels at Neptune Lines. These constitute our moral compass which requires all employees (shore-based and seagoing), leadership, as well as, parties that conduct business with or on behalf of Neptune Lines to act lawfully, with fairness and integrity, maintaining high standards of personal and business ethics.

COMMITMENT FROM LEADERSHIP AND SENIOR MANAGEMENT
Tone from the top is essential in developing and maintaining the ethical integrity of the business. Acknowledging this fundamental, our corporate leadership is committed to lead by example, prioritizing compliance and ethical conduct within the company. Apart from laying down the general structure of corporate governance, their role is to define and communicate consistently what the company is and what it stands for, setting a clear direction and course of action. Participating actively in internal consultation and meetings, our Board of Directors and company's CEO seek diversity of perspectives to better handle the complexity involved sometimes in making the right decision.
The tone from the top is conveyed and reinforced within the company through the active and definitive role of the senior management. Right after corporate leadership, the senior management oversees and monitors compliance, acting as a role model for employees and instilling among them and within all company levels a sense of shared accountability.
THE ROLE OF MIDDLE MANAGEMENT
During the selection of individuals to assume a managerial position, particular attention is given to their having the decision-making skills, knowledge, and competencies needed to make ethically sound decisions on a day-today basis. Regulatory awareness, ethical mindset and orientation must be part of every manager's profile. As department heads, they are responsible for:
• underlining the priority of compliance in all business aspects
• helping their teams understand how company's governing principles and Code of Conduct guide the way they work and interact with others
• coaching their subordinates in view of any related concern, addressing same as appropriate.
INTERNAL AWARENESS AND COMMUNICATION
Besides day-to-day coaching, Neptune Lines seeks to ensure that its ethical behavior requirements are embraced in all company levels through:
Induction and familiarization processes;
Every new hire (shore-based and seagoing) receives relevant familiarization regarding the established policies and signs the corporate Code of Conduct. This corporate material can be accessed at any time through the corporate intranet. In the case of seagoing employees who are on fixed-term contracts, prior their re-embarkation they receive familiarization at Neptune Lines' office premises or at the manning agent's office on any latest updates (e.g. regulations coming in
force), corporate guidelines and instructions.
Meetings; Concerns and issues linked to corporate governance, business ethics and compliance are thoroughly discussed during internal meetings, with the participation of the senior management and the Compliance Officer.
INTERNAL REPORTING (Whistleblowing)
All Neptune employees are encouraged to speak up and report any concerns or alleged incidents regarding compliance and business ethics. Office employees can address any concerns to their direct manager or Human Resources. Respectively, the seagoing personnel can contact Crewing - as the dedicated department for handling issues of conduct with regard to seafarers - or company's Designated Person Ashore (DPA). Any reported concern or issue is handled with strict confidentiality. When grounds for violation exist, the Compliance Officer is contacted who further investigates the reported case to define its nature.
The Compliance Officer (person with legal expertise) participates in the ESG Committee and reports to the Board of Directors. If a violation of ethical nature is identified, the case will be brought to the Executive Committee who further consults in order to decide on the course of actions to be taken - based on the nature and severity of the incident.

RAISING EXTERNAL AWARENESS AND COMMITMENT
External Communication
We expect and encourage our external stakeholders to act in a way that is consistent with our policies and Code of Conduct and we take appropriate actions where
we believe they have not met our expectations or their contractual obligations. External communication refers to communication channels with Neptune Lines’ associated parties, as well as, outside their scope i.e. reaching out to the general public. The main external channels to communicate our policies, and respective measures and updates are:
• our ESG report (uploaded to our website and shared with stakeholders)
• our Communication on Progress (COP) uploaded annually to the UN Global Compact website
External Reporting
Neptune Lines encourages its business cooperators or any other external party associated with the company, to report any concerns or alleged incidents putting at stake company's integrity through our dedicated, confidential communication channel (compliance@neptunelines.com).
FAIR BUSINESS & ANTI-COMPETITIVE BEHAVIOR
Neptune Lines has in place a Fair Business Practices Policy, expressing our bond to always engage in transparent business transactions and fair trading (i.e. anti-competitive behavior, fair business practices etc.) Fair-competition law may on no account be violated. Any such violation may result in substantial fines for our
company as well as its employees. In particular, price-fixing among competitors (verbal, written or in any other form), market allocation and any other practices which may inhibit free competition, are strictly prohibited.
CONFLICTS OF INTEREST
Neptune Lines is committed to preventing situations of conflict of interest from materializing (i.e. meaning an employee being able to choose a course of action that benefits them to the detriment of the company). The company encourages employees to report any situation coming to their notice that could influence, or be
perceived to influence, their or their colleagues’ decisions or actions on behalf of the company. Despite efforts, if such incidents do occur, the company will seek to take appropriate countermeasures.
ANTI-CORRUPTION
Neptune Lines has in place an Anti-Corruption and AntiBribery Policy explicitly stating company’s zero tolerance towards corruption in all its forms - including bribery and extortion.
We are committed to conducting business in compliance with all applicable anti-corruption legislation - including the UK Bribery Act1 Anti-Corruption Rule and to take action against any unlawful act - no matter how small in degree or scale (i.e. from the minor use of influence - as in the case of facilitation payments - to institutionalized bribery, fraud, money laundering or abuse etc.).
In the Code of Conduct, it is clearly stated that employees, as well as, representatives and business cooperators of Neptune Lines must not offer, provide, accept, or
promise (directly or indirectly) any undue financial or other advantage to a public and/or private official, person or entity for the purpose of obtaining any favorable
treatment, business advantage, or for personal gain

MONITORING CONTROLS
Monitoring of Requisitions, Invoices & Corporate Expenses
All requisitions and incoming invoices are subject to electronic approval work flows, passing through various levels of verification for better control. Moreover, all corporate expenses are closely monitored (extraordinary expenses are reviewed and agreed prior to taking place).
Tender Processing
Tender processing is also implemented for selected categories of materials or service providers.
Screening Tools
We have developed a system of internal controls to address money laundering concerns. The main points of such controls are the following:
collect KYC information for each new customer/ provider
update such information regularly and carry out screening tests in periodical intervals for existing customers/providers
maintain documentary evidence of each due diligence action taken
understand and be able to identify “red flags” and report same as per set procedure
make and receive payments only from designated banks accounts in the name of contracted vendor and/ or purchaser and
comply with applicable data privacy laws.
Charitable Donations
Our charitable donations and sponsorships are not related to the company's main business operations and are never provided in a cash deposit form, so as to ensure that they are not considered or used as a disguised form of bribery.
Anti-Corruption Training
Compliance and business ethics training is provided, so far, on an ad-hoc basis and mainly to the staff whose business role is most relevant (i.e. the Compliance Officer, the DPA, the Human Resources department etc.). However, as our company progressively grows bigger in size and expands its business network (i.e. hence its risk exposure) the need to further focus on such training is increasingly essential. We are currently planning relevant training for governance body members (decision-makers) and employees.

COLLECTIVE ACTION - The MACN
Companies are all the more expected to work collectively and join forces to combat corruption in all its aspects. Neptune Lines is an active member of the Maritime AntiCorruption Network (MACN) since 2015. The MACN was established in 2011 as an industry-led collective action initiative, to stamp out corruption in the maritime industry and to promote inclusive trade. Its members (i.e. over 90 members globally) represent a significant percentage of the total global tonnage and play a key role in ocean transport. In MACN collective action projects, member companies work in partnership with stakeholders including port and customs authorities, NGOs, and local governments, to undertake root cause analyses and then implement a range of realistic "recommended actions" to tackle corruption in ports and across the maritime supply chain. Through our MACN membership, we gain knowledge from other companies' experience and best practices. We have, also, access to a wide range of useful material (e.g. toolkits, risk assessment tools, methodologies etc.) which we use to support our onboard anti-corruption measures.
MACN's Incident Reporting System
Neptune Lines participates in the MACN’s anonymous incident reporting system - developed to collect data of corruption practices. This system enables maritime
companies to submit reports on corrupt demands they have faced during port operation. The accumulated data are analyzed by the MACN in an effort to scope the problem and develop further action plans to eliminate its extent and frequency.
Neptune Lines has provided specific instructions to fleet vessels regarding the reporting of such incidents to the office. Once reported to the office, company's DPA is
responsible to submit them to the MACN's database. Due to legal issues and constraints, we do not report in detail the corrective actions taken in response to these
external incidents presented so far.
SAY-NO Campaign
Since 2017, we are enforcing on board a “SAY NO” campaign, to publicly state our company’s clear stance towards bribery and our zero tolerance to such practices.
The aim of this campaign is to provide guidance to our Masters and crew on how to handle cases of demands of bribery or facilitation payments at calling ports, based on company's anti-corruption and anti-bribery policy. At a first stage, and in order to ensure a smoother implementation, we launched the campaign at ports belonging to countries with stricter and more structured regulatory controls (i.e. hence, with not so frequent bribery demands) to check its applicability. Under current scope of implementation remain all EU and Turkish ports - with the prospect of expanding it to the ports with loose regulatory control and a more intense presence of corruption incidents. The outcome, so far, has turned out to be very positive. Moreover, the COVID-19 restrictions imposed seem to have contributed to the reduction of such occurrences.

Additional Membership Requirements
Fulfilling our duties as an active member of the MACN, we participate in its biannual members' meetings. We also complete and submit an annual self–assessment
to its Secretariat, namely "Business for Social Responsibility (BSR)". Results of the assessment are shared at the established members meetings and used as a tool to
identify topics on which we could work further (with the guidance from MACN) in order to further support our onboard compliance.

COMPLIANCE PROGRAM
During the previous reporting period, in an effort to upgrade our existing compliance program and further elaborate on our corporate risk exposure, we decided to
externally assess our system. For this purpose, we contracted a well-established law firm to review our existing policies and processes and perform a thorough gap-analysis. Throughout the project, which is currently ongoing, we expect to identify possible blind spots with regard to compliance and business ethics, as well as weaknesses of our program, in order to take appropriate action.
The workshops held, so far, were conducted with the full involvement of our leadership and will continue over the following year along with implementation of next steps.
Progress and Performance
An overview of our progress and performance during the reporting period in terms of ethical business and compliance, is presented here below.
COMPLIANCE/ANTI-CORRUPTION TRAINING
Training Highlights
During the reporting period, the below compliance-related trainings took place:
• Participation of our legal department in the 'World Shipping Law Forum' held in January 2019.
• Participation of our HSQE Manager/DPA in the two day seminar and workshops of the Maritime Anticorruption Network (MACN) in the context of their Members' Fall Meeting in October 2019.
• In-house live training on the handling and protection of Confidential Information and the establishment of the requirement of Non-Disclosure Agreements (led by our legal advisor and Compliance Officer in November 2020; performed via Video Conferencing due to COVID-19)
COMPLIANCE RECORD
Corruption Incidents
There were no corruption incidents during the reporting period, nor any legal actions, sanctions or fines posed against Neptune Lines for corruption or any other form of
unethical conduct.
legal Actions for Anti-Competitive Behavior, Anti-Trust and Monopoly Practices
There are no legal actions pending or completed during the reporting period regarding anti-competitive behavior and violations of anti-trust and monopoly legislation in
which Neptune Lines has been identified as a participant. Socioeconomic Compliance (e.g. accounting fraud, corruption, provision of service and labor-related laws
and regulations)
Socioeconomic compliance includes our company's overall compliance record, as well as compliance with specific laws or regulations in the social and economic area. Compliance can relate to accounting and tax fraud, corruption, bribery, competition, the provision of products and services, or labor issues, such as workplace discrimination, among others. This includes compliance with international declarations, conventions, and treaties, as well as national, sub-national, regional, and local regulations.