
E2 Pollution
As part of our commitment to address these negative impacts, we have used our double materiality assessment (DMA) process to further enhance our understanding of potential pollution-related impacts, risks, and opportunities. Detailed information about the DMA process can be found in the ESRS 2 section.
Impact, risk and opportunity management
Material impacts, risks and opportunities and their interaction with strategy and business model
The following material pollution-related impacts and risks have been identified:
Material risks, impacts and opportunities | Location in the value chain | Time horizon | |||||
Upstream | Own operations | Downstream | Short-term | Medium-term | Long-term | ||
Pollution of air | Actual negative impact | ⚫ | ⚫ | ⚫ | ⚫ | ⚫ | ⚫ |
Risk | ⚫ | ⚫ | |||||
Pollution of water | Actual negative impact | ⚫ | ⚫ | ⚫ | ⚫ | ||
Underwater noise and vibration | Actual negative impact | ⚫ | ⚫ | ⚫ | ⚫ | ||
Risk | ⚫ | ⚫ |
Pollution of Air
Impacts from Höegh Autoliners own operations
Pollutants, such as nitrogen oxides (NOx), sulphur oxides (SOx), non-methane volatile organic compounds (NMVOCs), and particulate matter (PM) are released into the atmosphere from the combustion of fossil fuels as part of vessel operations. These pollutants can negatively impact both the environment and human health. The impact is systemic to the maritime sector, and it is relevant in the short, medium, and long term.
Impacts through Höegh Autoliners value chain activities
As part of both shipbuilding and ship recycling activities, the environment may be negatively impacted through pollution of air. Höegh Autoliners is currently carrying out a newbuilding project consisting of 12 vessels, expected to be completed by the end of first quarter of 2028. At the same time, it is likely that some of our existing vessels will be recycled over the coming years. The negative impacts are relevant in a short, medium and long term.
Potential risk for Höegh Autoliners
Pollution of air poses possible financial risks for Höegh Autoliners through potentially stricter pollution requirements and additional taxes in the longer term. These factors could lead to higher operational costs due to taxes, regulatory compliance, and capital expenditures for technical improvements of the existing fleet.
Pollution of water
Impacts from Höegh Autoliners own operations
Höegh Autoliners’ activities present potential risks of marine pollution from oil spills during bunkering operations, discharges of wastewater such as bilge and sludge water, and vessel cleaning activities. Bilge water, which contains a mixture of substances including water, oil, grease, sludge, and other chemicals, could potentially cause negative impacts if untreated water is released into the ocean. As these impacts are considered to be systemic matters in the maritime sector, it is relevant over both the short, medium, and long term.
Noise pollution
Impacts from Höegh Autoliners own operations
Sound is essential for marine animals and many species depend on it for locating food, navigating, and communicating. However, underwater noise and vibrations from shipping and other industries can disrupt these crucial activities. For Höegh Autoliners, this represents an actual negative impact of its vessels’ operations. Recognizing the significance of this issue, it is likely that future regulations will address pollution of underwater noise. Höegh Autoliners discloses noise pollution as an entity-specific disclosure, not covered by ESRS requirement.
Potential risk for Höegh Autoliners
Enhanced knowledge and awareness of the impact of underwater noise and vibration, along with potential future regulations, represent a financial risk for Höegh Autoliners. The risk relates to potentially increased operational costs due to further re-routing to avoid both existing and new marine protected areas. Additionally, the risk is also linked with potential technical upgrades to the existing fleet to comply with new regulations.

Policies related to pollution
Recognizing the severity of the mentioned impacts, the International Maritime Organization (IMO) has implemented strict regulations to limit the pollution within the sector through the IMO’s International Convention for the Prevention of Pollution from Ships (MARPOL). Höegh Autoliners has established policies and procedures that are aligned with applicable regulations for both own operations and, where relevant, across the value chain. Relevant policies are accessible to all employees via our internal platform.
Höegh Autoliners’ environmental actions, targets, and focus areas are outlined in its overarching Environmental Policy and Environmental Focus Plan, both detailed in disclosure requirement E1-2.
The policies Emission Control Areas (ECA) / Sulphur Emission Control Areas (SECA) Compliance, are describing the procedures in place to regulate emissions from our vessels to prevent, reduce, and control air pollution of NOx, SOx and particular matter (PM). This policy is applicable to Höegh Autoliners’ own shipping operations for certain areas.
The policy MARPOL Protected Areas provides operating guidelines to ensure all marine protected areas, special areas, emission control areas, and particularly sensitive areas are accurately identified and that all respective protective measures are strictly followed.
The Sludge and Bilge Water Operation and Maintenance policy outlines required procedures for proper sludge and bilge water handling during vessel operations in compliance with international and national regulations. Among other things, the policy includes guidelines for processing, record-keeping, potential leakages, and maintenance of processing equipment.
Wastewater generated during vessel operations, such as sewage, is managed under our Sewage Handling and Responsibility Policy, which complies with the requirements of MARPOL Annex IV. The policy addresses how to treat sewage, and how the responsibility is allocated among the crew members.
Höegh Autoliners ensures seafarers are well-prepared for marine casualties and emergencies through comprehensive training and upskilling. This enhances the implementation and security of our policy procedures.
Höegh Autoliners adheres to mandatory speed restrictions for vessels passing through the United States East Coast (USEC). The policy Speed Restrictions to Protect North Atlantic Right Whales describes guidelines on speed restrictions applicable to vessels passing USEC and Canada East Coast.
The Chief Operating Officer is responsible for implementing and monitoring the effectiveness of these policies.
Actions and resources related to pollution
Actions related to pollution closely interact with other environmental initiatives, particularly those addressing E1 Climate Change. Höegh Autoliners’ pollution-related efforts within own operations are detailed below, and additional measures targeting pollution in the upstream and downstream value chain are also discussed in sections E1-3 and E4-3.
Actions related to pollution of air
Executing fleet transition plan and energy efficiency measures
Pollution management is closely linked with energy efficiency, and Höegh Autoliners has systematically improved the fleet-wide energy efficiency through technical installations and operational measures. The planned fleet transition, and future adoption of alternative fuels, will help us move closer to our decarbonisation targets and corresponding reduction of non-GHG pollutants such as SOx and NOx.
Fuel consumption is the largest source of pollution in the shipping industry, and Höegh Autoliners is committed to using fuels compliant with the IMO Global Sulphur Cap 2020. To meet specific requirements of designated sea areas with stricter controls to minimize airborne emissions from ships (such as ECAs and SECAs), we have implemented strict fuel switching procedures to ensure compliance across all operational areas.
As pollution is a function of the fuel consumption, our decarbonization measures implemented as described in E1-4 will contribute to the reduction of non-GHG emissions. It is expected that reduced pollution of non-GHGs to air will follow the reduction in fuel consumption closely.
Actions related to pollution of water
Bilge water and oil spill management
The on-board Oily Water Systems (OWS) installed on all our vessels allow us to continuously monitor bilge water on board using an oil content meter. When bilge water cannot be processed through the OWS, it is collected and retained onboard until delivered to an approved shore reception facility. This ensures proper handling and disposal of all bilge and oily water and aims to prevent oil spills and release of untreated water to the sea. Operating the OWS in accordance with company policies mitigates the negative environmental impact of water pollution.
Further, we have comprehensive response plans and checklists in case of emergencies during bunkering operations. Our seafarers receive thorough training to prepare for potential oil spills. We promote crew awareness, conduct regular preventive maintenance (PMS) of vessels, and ensure equipment is well-maintained. This contributes to ensure we have the most prepared crew as possible and to enhance our emergency response capabilities.
Monitoring speed restriction
Höegh Autoliners complies to mandatory speed restrictions in specific marine areas and voluntarily adjusts sailing patterns to contribute to the protection of particularly sensitive marine areas. By having a continuous focus on controlling vessel speed and assessing alternative routes, we aim to reduce the negative impact of underwater noise and vibrations.


Metrics and targets
Targets related to pollution
Based on regulatory requirements and stakeholder expectations, Höegh Autoliners has set pollution-related targets to reduce its environmental footprint and enhance business resilience. These targets address impacts from our own operations. While not externally validated, they support our policies and procedures, and address pollution-related impacts and risks identified in the DMA.
This target aims to minimize operational oil spills from vessel operations. Achieving this target involves:
- Timely reporting of all types and quantities of accidental and operational oil spill into the water.
- Ensure crew awareness on company’s environmental policy.
- Strict monitoring of bunkering and bilge water operations.
Oil spills are reported based on their size: 700 tons categorized major oil spill.
In 2024 no major oil spills were recorded. We will continue to work on preventing the occurrence of oil spills, providing checklists on oil spill to use in case of emergency situations.
This target aims to avoid potential financial implications related to oil spills. By promptly reporting all types of potential oil spills and monitoring HIS reports, we aim to mitigate the risk of oil spill-related fines. The target covers the entire Höegh Autoliners’ fleet.
In 2024, we have not reported any major operational oil spill to the environment, and as such, no fines related to oil spill were received.
This target aims to avoid potential implications related to violation to speed restrictions. This includes continuous monitoring of vessel speed in restricted areas and evaluation of alternative sailing patterns, where applicable.
In 2024 we have reported zero violation of speed restrictions.
Accounting policies - Metrics and targets
Our pollution-related targets are absolute targets without a relative measurement towards a baseline. Metrics are not validated by an external body other than the assurance provider of the Sustainability Statements.
Air pollution is closely linked with Climate Change. Therefore, Höegh Autoliners has not set specific targets for air pollution, as these are implicitly included in the targets outlined in E1-4. Consequently, the effectiveness of policies and actions related to air pollution is tracked with the same level of ambition as established for climate change.
Pollution of air, water, and soil
Höegh Autoliners continues to report key metrics related to our environmental impacts, providing the reader with an understanding of the performance in relation to our climate and pollution-related targets and the methodologies and assumptions used to set them.
Air pollution reporting
Unit | 2024 | 2023 1 | |
Black Carbon (BC) | MT | 29 | 29 |
Carbon Monoxide (CO) | MT | 971 | 945 |
Nitrogen Oxides (NOx) | MT | 34 449 | 34 249 |
Particular Matter (PM) | MT | 1 594 | 1 595 |
Sulphur Oxides (SOx) | MT | 2 870 | 2 831 |
Volatile Organic Compouts (VOC) | MT | 1 277 | 1 273 |
1 2023 numbers restated due to improved reporting processes. |
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Accounting policies - Air pollution reporting
Air pollution:
Pollution of air consists in the amount of air pollutants emitted by Höegh Autoliners operations, not already included in GHG emissions already reported under Climate Change. The calculation and consolidation follows the same methodology as described for scope 1 emissions, considering the amount of fuel consumption and the application of a relevant emission factor.
Entity-specific metrics
Unit | 2024 | 2023 | |
Number of major oil spills | # | 0 | 0 |
Fines related to oil spills | $ | 0 | 0 |
Number of violations to speed restrictions | # | 0 | 2 |
Days in ECA/SECA (MARPOL) | # | 1 784 | 1 729 |
Non-compliance with environmental laws and regulations | # | 1 | 0 |
Generation of sludge water | m3 | 5 884 | 5 3111 |
Generation of bilge water | m3 | 5 892 | 4 8241 |
1 2023 numbers restated due to improved reporting processes. |
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In 2024, we recorded one instance of non-compliance with environmental laws and regulations, resulting in a minor fine due to the emission of black smoke from one of our vessel’s funnels while transiting the Yangtze River in China.
Generation of sludge and bilge water
Höegh Autoliners continuously monitors the generation of sludge and bilge water, in line with our policies. These entity-specific metrics support our goal of preventing oil spills.
During the year, about 96% of sludge generated was disposed of at designated shore facilities. In relation to bilge water, 83% was discharged to sea following proper processing through OWS, while 11% was disposed of at shore facilities.
Accounting policies - Entity-specific metrics
Oil spills:
Oil spills are reported based on their size: 700 tons categorized major oil spills. Vessels report all spills monthly.
Speed restrictions:
Höegh Autoliners is required to comply with speed restrictions in specified marine areas. Vessels document route and speed, translating to speed restriction violations.
Days in ECA/SECA (MARPOL):
Number of days vessels navigate through areas with stricter emission controls, as per IMO guidelines. The calculation is performed manually using the date and time of entry and exit. The results are aggregated monthly and then reported manually at the end of each month through the EFP survey form.
Water pollution:
Includes oil leakage, sludge, and untreated bilge water released into the ocean. These entity-specific metrics support our goal of preventing oil spills.
Total sludge generated:
Total sludge generated is the sum of all sludge generated during the year by vessels technically managed by the Höegh Autoliners Group. Total sludge generated is measured and reported through the Environmental Aspect Log.
Total bilge water generated:
Total bilge water generated is the sum of all bilge water generated during the year by vessels technically managed by the Höegh Autoliners Group. Data is measured and reported through the Environmental Aspect Log.
Environmental laws and regulations primarily refer to MARPOL 73/78 under the International Maritime Organization (IMO), as well as local regulations applicable to vessels calling at ports in different port states.
Technically managed vessels refer to the vessels for which the Höegh Autoliners Group holds responsibility under the IMO's International Safety Management (ISM) Code.
Anticipated financial effects from pollution-related risks and opportunities
Höegh Autoliners exercises its right, under the ESRS Phase-in allowances, to report on the anticipated financial effects from pollution-related impacts, risks and opportunities (E2-6), if any, from year 2.