2018 - Frontline Ltd. · TR-MT-110a.4 Number of travel days 768d TR-MT-160a.1 Number 54 TR-MT-510a.1 TR-MT-510a.2 Number ECOLOGICAL ... 6 • 2018 • Environmental Social Governance

environmental

social

governance

2018

THIS REPORT HAS BEEN PREPARED BASED ON

THE REQUIREMENTS OF THE SUSTAINABILITY

ACCOUNTING STANDARDS BOARD

1. INTRODUCTION

We believe that improving efficiency and reducing energy consumption will provide us with both environmental and economic advantages.

CO2 emissions are directly linked to marine fuel consumption. We therefore evaluate our CO2 emission controls by focusing on vessel fuel and voyage efficiency and optimisation. Frontline is currently taking proactive measures to ensure compliance with new 2020 Sulphur emission regulations. This includes investing in exhaust gas cleaning systems (scrubbers) and retrofitting them on our fleet.

Our report is based on SASB’s internationally recognized indicators and related definitions, scope and calculations. The report and data cover the period 1 January to 31 December 2018.

Robert Hvide Macleod,CEO, Frontline Management AS

Frontline Ltd. is a leading international shipping company operating seaborne transportation of crude oil and refined products. Frontline is listed on New York and Oslo Stock Exchanges. Today, we own and operate a large and modern fleet of 22 VLCCs, 28 Suezmax tankers and 20 Aframax/LR2 tankers.

Frontline has prepared this ESG report to accommodate investors and stakeholders by providing easy access to extra-financial information. Our report on Environmental, Social and Governance (ESG) factors has been prepared in accordance with the Marine Transportation framework established by the Sustainability Accounting Standards Board (SASB). The SASB standard allows us to identify, manage and report on material ESG topics with industry specific performance metrics. Additionally, we have incorporated the principles of the UN Global Compact.

Openness and availability of information are major factors in enhancing environmental, social and governance performance. Frontline’s emphasis on sustainability is reflected in our company’s agility in adapting to new regulations and demands from investors, partners and customers.

Some 90% of the volume of world trade requires seaborne logistics, and international shipping and ports provide crucial linkages in global supply-chains and are essential for the ability of all countries to access global markets. Although maritime transportation is crucial to global trade, meeting the challenges of reducing climate gas emissions will be imperative going forward.

The most recent IMO report on GHG emissions estimates that international marine transportation accounts for 2.81 per cent of annual global greenhouse gas emissions. Compared to other modes of transportation, shipping has relatively lower CO2 emissions - worldwide waterborne transport remains the most cost and energy efficient means of transporting large volumes of commodities and produced goods. Still, with increasing global trade, our industry will play an important role in lowering global CO2 emissions2. Frontline is committed to increase efficiency and reduce the greenhouse gases emitted from our vessels.

1 http://www.imo.org/en/OurWork/Environment/PollutionPrevention/AirPollution/Pages/Historic%20Background%20GHG.aspx 2 https://www.iea.org/newsroom/news/2019/june/demand-from-asia-is-set-to-power-the-growth-of-the-global-gas-industry-over-the-n.html

1 292NUMBER OF VESSEL

PORT CALLS

1 171NUMBER OF SHIPBOARD

EMPLOYEES

3 598 088TOTAL NAUTICAL MILES TRAVELLED BY VESSELS

19 009OPERATING

DAYS

9 954 085DEADWEIGHT

TONNAGE

52*NUMBER OF VESSELS IN TOTAL SHIPPING FLEET

“The SASB standard allows us to identify, manage and report on material ESG topics with industry specific performance metrics.”

Sour

ce: C

onve

rsio

n fa

ctor

s 20

19, D

EFR

ABULK CARRIER

CRUDE TANKER

LPG TANKER

LNG TANKER

L ARGE CONTAINER SHIP

SMALL CONTAINER SHIP

FREIGHT TR AIN

VECHICLE CARRIER

HE AV Y GOODS VEHICLE

AIR FREIGHT LONG HAUL

GLOBAL AVERAGE - CO2 PER TONNE KM

20 gr0 gr 40 gr 60 gr 80 gr 100 gr 120 gr 140 gr 160 gr 180 gr 200 gr 1132 gr

*Only owned and long term lease per Dec 31 2018

4 • 2018 • Environmental Social Governance 5 • SUSTAINABILITY ACCOUNTING STANDARDS DISCLOSURES

Gross global Scope 1 Financial control

Metric tonnes (t)CO₂-e

Discussion of long-term and short-term strategy or plan to manage Scope 1 emissions, emissions reduction targets, and an analysis of performance against those targets

Average Energy Efficiency Design Index (EEDI) for new ships

Grammes of CO₂ per ton-nautical mile

Shipping duration in marine protected areas or areas of protected conservation status

(1) Total energy consumed Gigajoules (GJ), Percentage (%) 24 280 844, 100 %

(2) percentage heavy fuel oil Gigajoules (GJ), Percentage (%) 22 960 702, 95 %

TOPIC ACCOUNTING METRIC UNIT OF MEASURE DATA CODE

E N E R G Y C O N S U M E D

E E D I

A I R E M I S S I O N S O F P O L L U TA N T S

M A R I N E P R O T E C T E D A R E A S

I M P L E M E N T E D B A L L A S T W AT E R

S P I L L S A N D R E L E A S E S T O T H E E N V I R O N M E N T

TR-MT-110a.3

(1) exchange Percentage (%) 79 %e

(2) treatment Percentage (%) 67 %eTR-MT-160a.2

(1) Number Number 0f

(2) aggregate volume Cubic meters (m³) 0TR-MT-160a.3

(1) NOx (excluding N2O) Metric tonnes (t) 49 443c

(2) Sox Metric tonnes (t) 29 205c

(3) particulate matter Metric tonnes (t) 3 671c

TR-MT-120a.1

Number of calls at ports in countries that have the 20 lowest rankings in Transpar-ency International’s Corrup-tion Perception Index

Total amount of monetary losses as a result of legal proceedings associated with bribery or corruption

Lost time incident rate (LTIR) Rate 0,45 TR-MT-320a.1

Number of Conditions of Class or Recommendations

TOPIC ACCOUNTING METRIC UNIT OF MEASURE DATA CODE

C O R R U P T I O N

L O S T T I M E I N C I D E N T R AT E

M A R I N E C A S U A LT I E S

C O N D I T I O N S O F C L A S S

P O R T S TAT E C O N T R O L i

Detentions Number 0 TR-MT-540a.3

Incidents Number 1g

Percentage classified as very serious

TR-MT-540a.1

BUSINESSETHICS

EMPLOYEEHEALTH &

SAFETY

ACCIDENT &SAFETY

MANAGEMENT

Reportingcurrency

0

Percentage (%) 0

TR-MT-320a.10

EEDI (3 gCO₂/t. nm)b

2. SUSTAINABILITY ACCOUNTING STANDARDS DISCLOSURES

C O R R U P T I O N I N D E XE M I S S I O N S

GREENHOUSEGAS

EMISSIONS

ACTIVITY METRIC UNIT OF MEASURE DATA CODE

Number of shipboard employees Number 1 171 TR-MT-000.A

Total distance travelled by vessels Nautical miles (nm) 3 598 088 TR-MT-000.B

Operating days Days 19 009 TR-MT-000.C

Deadweight tonnage Thousand deadweight tons 9 954 085 TR-MT-000.D

Number of vessels in total shipping fleet Number 52 TR-MT-000.E

Number of vessel port calls Number 1292 TR-MT-000.F

Twenty-foot equivalent unit (TEU) capacity TEU N/A TR-MT-000.G

Please see chapter 7 for assumptions regarding the SASB disclo-sures, and specific comments referred to above

1 330 023a TR-MT-110a.1

8 TR-MT-110a.2See page

TR-MT-110a.4

Number oftravel days

768d TR-MT-160a.1

Number 54 TR-MT-510a.1

TR-MT-510a.2

Number

ECOLOGICALIMPACTS

AIR QUALITY

6 • 2018 • Environmental Social Governance 7 • ESG GOVERNANCE

MATERIAL ISSUE INTERNAL GOVERNANCE DOCUMENTS INTERNATIONAL STANDARDS AND REFERENCES

Climate change Environmental Policy The Paris AgreementThe Intergovernmental Panel on Climate Change (IPCC)Initial IMO Strategy on Reduction of GHG Emissions from Ships

Air emissions Environmental Policy IMO MARPOL Convention Annex VIEU Sulphur Directive 2016/802UNCLOS

Ecological impact Environmental Policy UN Global CompactIMO MARPOL Convention Annex VIIMO Ballast Water Management ConventionIMO MARPOL Convention Annex VIHong Kong Convention

Anti-Corruption Corporate Code of Business Ethics and ConductFinancial Crime Policy

UN Global CompactThe US Foreign Corrupt Practices Act and the UK Bribery Act

Employee Health & Saftey

Corporate Code of Business Ethics and Conduct

UN Global CompactILO ConventionsMaritime Labour Convention, 2006 (MLC, 2006)International Management Code for the Safe Operation of Ships and for Pollution Prevention (The ISM Code)Hong Kong ConventionMarine Crew Resource Management

Accident & SafetyManagement

Corporate Code of Business Ethics and Conduct

International Management Code for the Safe Operation of Ships and for Pollution Prevention (The ISM Code)Marine Crew Resource Management

3. ESG GOVERNANCE

Frontline aims to continuously have relevant procedures in place within the areas of environmental, social and governance issues. Developments in technical solutions influencing environmental performance or measures to tackle corruption, may not always be enough: Frontline recognises that some ESG related challenges can only be tackled when both industry members and regulatory authorities join forces. Frontline has decided to join the following important initiatives: Maritime Anti-Corruption Network (MACN), Clean Shipping Alliance, the International Association of Inde-pendent Tanker Owners (Intertanko) as well as complying with the requirements of Oil Companies International Marine Forum (OCIMF). We believe being part of these initiatives will keep us up to date on material risks and opportunities and thus it contributes positively to our risk management.

In order to ensure consistent management of ESG factors, we have established a set of policies and control processes which safeguards our employees’ diligent management of sustainability related factors. Our employees are to abide by the established policies to guide them in conducting their daily assignments for Frontline, and we have implemented a system of monitoring compliance. Frontline’s Board of Directors has established an Audit Committee which monitors reports and complaints received by the company relating to internal controls and compliance. Furthermore, the Board of Directors ensures that policies with respect to ethics, risk assessment and risk manage-ment are adequate at all times.

As part of our strategy to address sustainability in a broader perspective we have

identified two UN Sustainable Development Goals (SDGs) where we believe Frontline

can contribute: We have selected SDG 14 and SDG 16 since these goals are closely

tied to the industry we are a part of and they represent material topics for which we

monitor – please see chapters 4 and 6 for more information. Contributing to the

broader global agenda of achieving the SDGs is in our interest as they affect our

business, customers, suppliers, investors and regulators which we depend on.

8 • 2018 • Environmental Social Governance 9 • ENVIRONMENT

Gross global Scope 1 emissions , financial

Metric tonnes (t)CO₂-e

Average Energy Effi-ciency Design Index (EEDI) for new ships

Shipping duration in marine protected areas or areas of protected conserva-tion status

(1) Total energy consumed

Gigajoules (GJ), Percentage (%)

24 280 844, 100 %

(2) percentage heavy fuel oil

Gigajoules (GJ),Percentage (%)

22 960 702, 95 %

ACCOUNTING METRIC

UNIT OF MEASURE

DATA

E N E R G Y C O N S U M E D

E E D I

(1) Number Number 0

(2) Aggregate volume Cubic meters (m³) 0

A I R E M I S S I O N S O F P O L L U TA N T S

(1) exchange Percentage (%) 79 %

(2) treatment Percentage (%) 67 %

(1) NOx (excluding N2O) Metric tonnes (t) 49 443

(2) Sox Metric tonnes (t) 29 205

(3) particulate matter Metric tonnes (t) 3 671

M A R I N E P R O T E C T E D A R E A S

I M P L E M E N T E D B A L L A S T W AT E R

SPILLS AND RELE ASES TO THE ENVIRONMENT

A ship may represent potential hazardous waste which must be recycled under safe conditions with respect to human health, safety and environment. The Hong Kong Convention aims to ensure that ships, when recycled after reaching the end of their operational lives, do not pose a risk to safety of workers or to the environment. As mentioned above, Front-line has a young fleet. Recycling of vessels is therefore not currently relevant. However, Frontline is developing a Ship Recycling Policy to ensure that future recycling of Frontline’s ships may only take place at an approved yard compliant with the Hong Kong Convention and in alignment with the 10 UN Global Compact principles. The latter principles refer not only to environmental issues, but also social issues and anti-corruption.

We have identified SDG 14 – Life below water – as relevant for our operations, and target 14.C is aimed at enhancing the conservation and sustainable use of oceans and their resources by implementing international law. At Frontline, we track and monitor our fleet continuously, and our HQ has full overview of when our ships are sailing in protected areas. Our crew members are trained in and must follow our stringent rules for avoiding spills at any time.

with condition-based cleaning. We also have periodic plans for propeller cleaning – this is conducted twice a year.

ECOLOGICAL IMPACTSMarine transportation represents environmental risks through discharges and emissions to air, land and water, as well as through potential spills. Frontline’s ability to manage its envi-ronmental risks are critical to our surroundings, including the sector, our customers and our own business. We have moni-toring and management tools in place to minimise the environ-mental impact of Frontline’s activities in this area and to ensure compliance with international and local regulations.

Frontline’s Environmental policy defines our commitment to environmental due diligence and how spills and operational emissions of sulphur oxides, nitrogen oxides, waste and other discharges are to be managed. We also work diligently with our Ship Energy Efficiency Management Plan and have established a thorough system for incident reporting.

Frontline recognises that larger volumes of oil spills have serious and long-lasting negative impacts on the ecosystem – which may cause severe injuries and fatalities. In addition, corporate consequences arising from spills concerns recovery efforts, reputational damage and fines. The highest likelihood of spills occurs in fuel transfer operations. However, spills in rela-tion to ship collisions carry the highest spill risk. No oil spills or other types of spills to the environment were reported in 2018.

Whilst ballast water is essential for safe and efficient modern shipping operations, it may also represent serious ecological, economic and health risks due to the multitude of marine species carried in the ships’ ballast water. The handling of ballast water is regulated by the International Convention for the Control and Management of Ships’ Ballast Water and Sedi-ments. We take ecological risks seriously and, of the vessels we owned at December 31 2018, 67 percent has installed ballast water treatment systems. Remaining installations are planned for, and will happen in line with each vessel’s triggering date of compliance. Along with the regulatory and approved ballast water management plan, the procedure of ballast water exchange is used as an alternative means of keeping the fleet compliant with the ballast water convention.

GREENHOUSE GAS EMISSIONS AND AIR QUALITYShipping is the mode of transportation with the least damaging environmental impact and is responsible for transportation of about 90% of global trade. The energy efficiency of shipping as a freight option is also evident from the graph on page two of this report. Even though shipping can be viewed as one of the preferred modes of transportation of goods today, pollu-tion derived from maritime shipping activities has significant implications for air and water quality. If precautionary actions are not taken, the industry may negatively impact marine and estuarine biodiversity. Identifying negative impacts and the associated risks has been the basis for our Environmental policy and procedures.

With increasing levels of international trade, air pollution from ships is on the rise and global emission standards are becoming more stringent. MARPOL Annex VI limits the main air pollutants originating from ships’ exhaust gas, including sulphur oxides (SOx) and nitrous oxides (NOx), and prohibits deliberate emissions of ozone-depleting substances. The NOx Emission Tier III standard in Emission Control Areas (ECA) from 2016 and the IMO 0.5% global cap on sulphur dioxide (SOx) content in fuels for shipping (will enter into force from 1 January 2020) mark a turning point for the global shipping industry.

Frontline emphasises the need to increase the efficiency of our ships, as well as to reduce the associated greenhouse gases emitted. We are convinced that improving energy effi-ciency and reducing consumption will provide the company with both environmental and economic advantages. Frontline controls one of the youngest fleets in the industry, an impor-tant element in ensuring that average emissions are kept low due to technical innovations. Our Chartering, Operations and Bunkering departments cooperates closely to optimise vessel routing and speed in order to increase voyage efficiency. These departments also closely interact with our Technical depart-ment, which actively tests state of the art ship energy manage-ment technologies with the purpose of further improving energy efficiency.

Hull cleaning will on average3 lead to a 9 percent increase in energy efficiency and thus lower fuel consumption and emis-sions. Frontline has in place a periodic plan for hull inspection

E M I S S I O N S

1 330 023

EEDI (3 gCO₂/t. nm)

Grammes of CO₂ per ton-nautical mile

Number oftravel days 768

4. ENVIRONMENT

3 https://safety4sea.com/wp-content/uploads/2018/03/Elsevier-The-energy-efficiency-effects-of-periodic-ship-hull-cleaning-2018_03.pdf

5. SAFETY, LABOUR CONDITIONS AND HUMAN RIGHTS

HUMAN RESOURCES AND DIVERSITYAt Frontline we believe that a strong health and safety focus, both onshore and offshore, will positively affect the long-term performance of our company. Ensuring safe working conditions is always our primary focus.

A detailed analysis of accidents and incidents for the entire fleet is prepared for Frontline by SeaTech Safety in accordance with the OCIMF guidelines on Lost Time Injuries (LTIs) and Total Recordable Cases and Frequency (TRC and TRCF). The reports allow us to identify the root causes of these reported incidents and functions as a tool for future improvement of our Corporate Code of Business Ethics and Conduct. All accidents, incidents and near misses shall be reported and proactive meas-ures are taken to ensure that we encourage our crew to report these with no hesitation and with support of their managers. Technical managers are regularly supervised and formally audited annually in order to ensure compli-ance.

In August 2018, our VLCC Front Hakata suffered a fire in the engine room while approaching Japan fully laden with crude oil. Due to the professionalism and quick action of both the crew and the Japanese coastguard, the vessel was safely towed to port and the oil was discharged. There was no loss of life, serious injuries or spills to the environ-ment as a result. We have investigated the root causes with our managers and then followed up with our insur-ance provider. We will continue to ensure that similar acci-dents are avoided in the future, and that all crew members abide by our safety procedures.

Even though the shipping industry remains a hazardous industry, where regrettable incidents do happen, progress has been made in terms of safety and Frontline is placing high priority on issues relating to safety. Frontline and its subcontractors adhere to industry best practice in rela-tion to the OCIMF TMSA framework when investigating incidents and takes appropriate actions to ensure lessons are positively learned so that similar incidents can be prevented in future.

Our employees are to abide by the values and guidelines set out in our Corporate Code of Business Ethics and Conduct. Suspected intentional deviation from external regulations such as Health & Safety or employment legis-lation or our guidelines for ethical behavior set out in our Code of Conduct are encouraged to notify the closest manager or make use of our telephone or web based compliance hotline

Through our Corporate Code of Business Ethics and Conduct, Frontline strives to ensure that the work envi-ronment on shore and on board always meet the highest standards complying with all safety regulations ensuring a safe and trusted workplace irrespective of nationality, race, ancestry or any other basis. Frontline is committed to respecting internationally recognised human rights as laid

out in the UN Guiding Principles on Business and Human Rights (UNGP). Respect for human rights is rooted in our values and key to our license to operate from employees, customers, investors, communities, governments and other stakeholders.

We are a company with global suppliers and aim to have the necessary policies, due diligence processes and access to remedy in line with the UNGPs. As an interna-tional company working with suppliers all over the world, we are planning to implement a Supplier Code of Conduct in 2019 to be able to work diligently with this issue in all our relations.

10 • 2018 • Environmental Social Governance 11 • SAFET Y, LABOUR CONDITIONS AND HUMAN RIGHTS

Number of Conditions of Class or Recommen-dations

M A R I N E C A S U A LT I E S

C O N D I T I O N S O F C L A S S

L O S T T I M E I N C I D E N T R AT E

P O R T S TAT E C O N T R O L

Detentions Number 0

Incidents Number 1

Percentage classified as very serious

EMPLOYEE HEALTH & SAFETY

UNIT OF MEASURE

DATA

Lost time incident rate (LTIR)

Rate 0,45

Percentage (%)

Number

0

0

12 • 2018 • Environmental Social Governance

Number of calls at ports in countries that have the 20 lowest rankings in Transpar-ency International’s Corrup-tion Perception Index

Total amount of monetary losses as a result of legal proceedings associated with bribery or corruption

BUSINESSETHICS

UNIT OF MEASURE

DATA

C O R R U P T I O N

C O R R U P T I O N I N D E X

Number

Reportingcurrency

54

0

Frontline emphasises that a commitment to honest and ethical conduct along with integrity are key values, and we have embedded this in our way of working with customers, suppliers, employees, shareholders and the communities in which we operate. Our commitment to transparent and honest business is outlined in our Financial Crime Policy which commits us to the most stringent rules and regula-tions which is in line with our NYSE listing commitment.

Corruption undermines economic and social develop-ment. For companies in the shipping industry, corruption is also associated with increased costs, and poses legal and reputational risks while also potentially threatening the safety of the crew. Frontline has a zero-tolerance policy towards bribery as stated in our Company Code of Conduct and Financial Crime Policy, which applies to all entities controlled by Frontline’s officers, directors, employees as well as workers and third party consultants, wherever they are located. Assessing and monitoring busi-ness processes, training and controls are fundamental tools in implementing our anti-corruption policy.

Our Code of Conduct illustrates the Company’s require-ments and expectations relating to: Compliance with Laws and Regulations, Honest and Fair Dealing, Conflict of Interest and Corporate Opportunity, Anticorruption, Confidentiality and Privacy, Proper use of Company assets, Antidiscrimination and Harassment and Integrity of corporate records. The Code of Conduct specifies how a violation of any of those standards is managed. The Code of Conduct obliges employees who observe or become aware of a situation they believe to be in violation of the Code of Conduct to promptly notify their manager.

As part of our Financial Crime Policy and associated compliance procedures, appropriate risk-based communi-cation and training is provided to employees as part of their on-boarding and ongoing development. Suspected devia-tions from our policy are to be reported to the line manager or by making use of our telephone or web-based compli-ance hotline as outlined in our Complaints Procedure.

Tackling systemic integrity challenges requires collec-tive action. Through the Marine Anti-Corruption Network

(MACN), Frontline has joined forces with other members of the shipping industry to share information and approaches, but also to engage with authorities and civil society. The core of the MACN collective action approach is that successful, lasting changes in the operating envi-ronment will take effect only if they are enabled and supported by, and beneficial to key stakeholders.

Through joint action, MACN members collaborate with local authorities to develop solutions that are beneficial to all parties and realistic to implement. In MACN collec-tive action projects, member companies unite with stake-holders including port and customs authorities, NGOs, and local governments to undertake root cause analyses and then implement a range of ‘recommended actions’ that tackle corruption in ports and across the maritime

13 • ANTI-CORRUPTION AND BUSINESS ETHICS

6. ANTI-CORRUPTION AND BUSINESS ETHICS

supply chain. MACN’s collective actions have generated major outcomes, including for example: reductions in demands for facilitation payments in the Suez Canal; new regulations in Argentina that make it more difficult for offi-cials to demand bribes; and improved ease of operations in Lagos, Nigeria, with the implementation of standardised operating procedures and grievance mechanisms.

SDG target 16.5 aims at substantially reducing corruption and bribery in all their forms. As a member of MACN, and through our own diligent anti-corruption procedures, we support collective action to reduce corruption and bribery in all their forms.

15 • INTRODUCTION15 • DISCLAIMER AND ASSUMPTIONS FOR SASB REPORTING

The information provided is based on the best data avail-able at the time of reporting. The ESG disclosures should be used to understand the overall risk management of sus-tainability related issues, however, in some areas data are based on estimates, please see comments below. aCO2 emissions (Metric tons (t) CO₂-e): Calculations are based on IMO emission factors and fuel consumption for the year. The financial control approach defined by the GHG Protocol has been applied (Scope 1). This includes company owned vessels only (note that this does not reflect the Total fleet count as that number includes vessels on leaseback agree-ments and long-term contracts).

Total energy consumption (TJ): Calculated based available data on fuel purchases by using the fuel properties defined by DEFRA, Conversion factors, 2019. Scope includes entire fleet, excluding Dewi Maswara.

bAverage Energy Efficiency Design Index (EEDI) for new ships: The EEDI provided represents Front Polaris and thus not necessarily reflect the average EEDI of the other three new ships entering the fleet in 2018.

cParticulate matter (PM), NOX, SOX emissions (Metric tonnes): NOX and SOX emissions from the combustion of fuels from owned vessels have been calculated based on the tool established by Danish Shipping. Scope includes entire fleet.

dShipping duration in marine protected areas or areas of protected con-servation status: A marine protected area as defined by the International Union for Conservation of Nature (IUCN): Any area of intertidal or sub-tidal terrain, together with its overlying water and associated flora, fauna, historical and cultural features, which has been reserved by law or other effective means to protect part or all of the enclosed environment, listed in the World Database of Protected Areas (WDPA) and mapped on Protected Planet. Protected Planet is the most up to date and complete source of information on protected areas, updated monthly with submis-sions from governments, non-governmental organizations, landowners and communities. It is managed by the United Nations Environment World Conservation Monitoring Centre. However, the reported number does not necessarily include all Marine protected areas internationally established and regulated in International the Marine Organization (IMO) Conventions and areas established nationally by member states. The data on shipping duration in Marine Protected Areas has been obtained through our tracking system (IHS).

ePercentage of fleet implementing ballast water exchange and treat-ment: Only ships performing ballast water exchange with an efficiency of at least 95 percent volumetric exchange of ballast water have been included. When it comes to treatment, approved systems must dis-charge (a) less than 10 viable organisms per cubic meter that are greater than or equal to 50 micrometers in minimum dimension and (b) less than 10 viable organisms per milliliter that are less than 50 micrometers in minimum dimension and greater than or equal to 10 micrometers in minimum dimension. Figures inlcude the total shipping fleet.

fSpills and releases to the environment (Number, Cubic meters (m³)): Any overboard spills and releases – intentional or accidental – shall be reported, even if the quantity is low and i.e. only causes a thin film or slight sheen upon or discoloration of the surface of the water.

Lost time incident rate (LTIR): A lost time incident is an incident that results in absence from work beyond the date or shift when it occurred. The rate is based on: (lost time incidents) / (1,000,000 hours worked).

gMarine Casualties: Regarding SASB TR-MT-540a.1 – we have defined the threshold for reporting on material damages as outlined in 1.1.4 and 1.1.6 as USD 1,000,000. The marine casualty reported relates to physical damages to Front Hakata, described on page 10 – note that the incident did not result in any loss of life or serious injuries to people. Injuries to personnel as described in point 1.1.1 are reported as part of Health & Safety statistics (LTIR).

hNumber of Conditions of Class or Recommendations: The practice of issuing conditions/recommendations of class does not follow an entire-ly harmonized reporting methodology making it less useful for reporting purposes without further explanations, hence we do not disclose these numbers. We may consider disclosing information on this in the future if the methodology becomes standardised. Currently our scope of dis-closure only includes Conditions of Class that resulted in withdrawal, suspension, or invalidation of a vessel’s Class certificate.

iPort State Control: Number of port state control (1) deficiencies and (2) detentions. Practices of port state controls reporting on deficiencies do not follow an entirely harmonised methodology making it less useful for reporting purposes without further explanations, hence we do not dis-close these numbers. We may consider disclosing information on this in the future. Currently our scope of disclosure only includes detentions. A detention is defined as an intervention action by the port state, taken when the condition of a ship or its crew does not correspond substan-tially with the applicable conventions and that a ship represen t an unreasonable threat of harm to the marine environment etc.

jTotal distance traveled by vessels: The distance (in nautical miles) trav-elled by all vessels during the calendar year.

Number of shipboard personnel: Only the number of personnel on board ships at any time are recorded, this does not reflect the aggregate number of shipboard personnel during the year.

Operating days: Operating days are calculated as the number of avail-able days in a reporting period minus the aggregate number of days that the vessels are off-hire due to unforeseen circumstances (i.e., a measure of days in a reporting period during which vessels actually generate revenue).

Number of vessels in total shipping fleet: This reflects the fleet at Dec 31 2018 and includes owned vessels (46), 4 vessels on long term contracts, year end 2018. Although GHG emissions Scope 1 only cover owned vessels, operational parameters throughout the report refer to activity over the entire year,including vessels in on long term contracts and vessels sold during the year.

7. DISCLAIMER AND ASSUMPTIONS FOR THE SASB REPORTING

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BERMUDA FRONTLINE LTD/FRONTLINE MANAGEMENT (BERMUDA) LTD.PO Box HM 1593,Par-la-Ville Place,14 Par-la-Ville Road,Hamilton HM 08

Phone.+ 1 441 295 69 35Fax.+ 1441 295 34 94

NORWAY FRONTLINE MANAGEMENT ASBryggegata 3P.O.Box 1327-VIKA0112 Oslo

Phone.+ 47 23 11 40 00 Fax. + 47 23 11 40 40