Transition plan and consideration of biodiversity and ecosystems in strategy and business model
To prepare for upcoming CSRD requirements, Gunvor will incorporate biodiversity considerations into a comprehensive resilience analysis. The findings of this assessment will inform whether adjustments to the current strategy and business model are necessary and will guide the development of an appropriate transition plan where applicable with industry guidelines.
SBM3This is small tooltip textMaterial impacts, risks and opportunities and their interaction with strategy and business model
The following table provides a list of our operational sites, where Gunvor had operational control in 2024. The table includes information on local biodiversity sensitive areas and the potential impacts.
This is based on a preliminary assessment, as explained in the next section.

According to our preliminary assessment, the emissions from the production sites do not have a significant negative effect on the biodiversity and, to our knowledge do not affect threatened species.
See the illustration to get an impression of the distance between our newly acquired powerplant in Spain (BBE) relative to the nearest biodiversity preservation area (Natura 2000).

Policies related to biodiversity and ecosystems
Gunvor has documented its policies and expectations in relation to Health, Safety, Environment, Human Rights and Communities in a formal document called “Group HSEC Policy”. Biodiversity is covered in the environment section of the document. Please refer to the ESRS 2 MDR-P section of this report for further details (see p.30 in this report).
E4-3This is small tooltip textActions and resources related to biodiversity and
ecosystems
The Rotterdam and Ingolstadt sites cover large areas and serve as important habitats for a wide range of species, offering nesting and feeding place for local wildlife. We actively support biodiversity on these sites wherever it is practically feasible.
For example, at Gunvor Refinery Ingolstadt (GRI), efforts to reduceenvironmental impact are ongoing.
In this context, GRI has contributed to a biodiversity initiative aimed at enhancing local ecosystems. The refinery already hosts a variety of species, including birds such as nuthatches, redstarts, tits, and occasionally falcons that perch atop the chimneys. At night, bats are frequently observed, while ground-dwelling animals like hedgehogs, weasels, cats, and dormice inhabit the surrounding areas. To further promote biodiversity and provide safe nesting and resting areas, the refinery engaged external ecological experts to assess the site and recommend appropriate conservation measures.
On the shipping side, we implement sustainable technologies to minimize environmental impact. Our vessels are equipped with exhaust gas cleaning systems to reduce sulfur emissions and ballast water treatment systems to preserve marine biodiversity. Regular maintenance practices, such as scheduled hull cleanings and the use of eco-friendly antifouling paints, are carried out to improve operational efficiency and ensure environmental compliance.
E4-4This is small tooltip textTargets related to biodiversity and ecosystems
Gunvor has set targets in relation to environmental emissions and pollution (see the respective sections). These targets also serve the purpose of protection of biodiversity and ecosystems.
Currently there are no defined targets that address biodiversity and ecosystems specifically. As part of our preparations for the upcoming CSRD regulation, Gunvor is committed to developing and integrating such targets into our sustainability framework.
E4-5This is small tooltip textImpact metrics related to biodiversity and
ecosystems change
Gunvor reports metrics in relation to environmental emissions and pollution (see the respective sections). These metrics also serve the purpose of protection of biodiversity and ecosystems.
Currently Gunvor does not report metrics that are designed to address biodiversity and ecosystems specifically. As part of our preparations for the upcoming regulation, the Company is committed to developing and integrating such metrics into our sustainability framework.
E4-5This is small tooltip textAnticipated financial effects from material
biodiversity and ecosystem-related risks and
opportunities
At present, there is no quantified data on the financial impacts of biodiversity and ecosystem related risks and opportunities. As Gunvor prepares for compliance with the upcoming CSRD it is committed to identifying, assessing, and incorporating this information into our broader sustainability framework.