Accelerating ESG excellence

Anchored in our sustainability-driven strategy, we continue to invest in strengthening our Environmental, Social and Governance (ESG) framework, which we have prioritised as a key imperative of our business operations. Our efforts remain focussed on building a more resilient and future-ready ESG ecosystem — one that is equipped to address emerging sustainability challenges and support the nation’s broader development goals. Our holistic approach to sustainability is built around integration of our ESG objectives into our overall business strategy, ensuring alignment of our sustainability goals with our operational performance. We undertake targeted initiatives to promote ESG excellence across the entire value chain of our business.

Robust ESG Governance Structure

The governance structure at APSEZ is designed to maintain stringent oversight of our sustainability and ESG programmes. We have in place a well-defined and precise governance framework to guide our ESG policies and actions across the organisation – from the Board to our strategic business units (SBUs). The framework underscores the company’s overarching responsibility ethos, and enables us to keep our ESG and organisational goals completely synergised at all levels.

Various committees support the Board at APSEZ in executing its responsibilities:

Strategically Maintaining ESG Oversight

Our ESG approach encompasses a holistic process to maintain oversight on the relevant priorities, goals and targets. Each of these has been strategically embedded into the organisational fabric, ensuring consistent implementation at both the corporate and business unit levels.

The Management Approach

A comprehensive set of well-defined policies and guidelines is in place at APSEZ, underscoring our strong commitment to ESG and to the integration of sustainability into our business strategy. Aligned with global standards and approved by the Board, these policies provide a clear direction for identifying, managing and mitigating ESG-related risks and impacts across operations, logistics, procurement and stakeholder engagement.

Policies & Guidelines

Environmental Policy — Expansive Enterprise Coverage

Our Environmental Policy is a well formulated document providing clear guidance for driving environmental protection and nurturance across the organisation. The policy sets out our core environmental commitments, covering operations, logistics, and engagement with suppliers, customers, and joint venture partners. Aligned with the highest global benchmarks, the policy is applicable enterprise-wide, including for all service and maintenance sites, corporate functions, distribution and logistics activities, waste management facilities, suppliers, service providers, contractors, joint ventures, and due diligence for mergers and acquisitions.

Environment Action Plan

The APSEZ Environment Action Plan was launched in 2018 as an effective tool to guide the company’s efforts to systematically reduce its environmental footprint. The plan is focussed on enabling a positive sectoral change, through:

• Active advocacy
• Encouraging responsible practices across our value chain

Our commitment to reporting progress on the plan annually reinforces our focus on transparency and accountability. We are cognisant of the significant regulatory consequences that can result from non-compliance, and have accordingly prioritised early, proactive action for effective management of the impacts.

This forward-looking approach empowers us to foster a healthier, more competitive operating environment. At the same time, it enables us to:

• Continually boost operational efficiency
• Alleviate business and environmental risks
• Enhance community and stakeholder relationships

At APSEZ, we uphold the highest standards of corporate governance to ensure effective and responsible management of emissions, energy and water use, as well as biodiversity conservation.

Accountability for environmental policy implementation is clearly defined across the organisation, with oversight by the Board-level Corporate Responsibility Committee, execution by the Sustainability Leadership Committee, and monitoring at site level through designated ESG teams.

ESG Implementation Mechanism

An Integrated Management System is in place at APSEZ to steer consistent and effective implementation of our ESG policies across all units, including joint ventures, partners, customers, and suppliers. This system is:

• Fully aligned with applicable legal requirements
• Supported by standard operating procedures (SOPs)

This holistic approach helps us drive uniform compliance and performance across the organisation.

For ensuring compliance with our information security policy, we have strategically implemented ISO 27001:2013 across the company. The responsibility of enforcing compliance is entrusted to our business and department heads. As of March 31, 2026, 12 ports, 5 logistics and Ocean Sparkle Limited (OSL) are certified with ISO 27001:2013 (information security management).

Ensuring Effective ESG Implementation through Capacity Building

An organisation-wide training and capacity-building framework helps strengthen ESG implementation at APSEZ. The system is crafted to ensure that all employees and third-party stakeholders, including sub-contractors, consultants and vendors, are regularly trained on information security. This helps ensure strict adherence to audit, legal, statutory, regulatory, and contractual requirements across the company. We also invest actively in fostering a culture of continuous learning and improvement by promoting the exchange of knowledge and best practices. This is ensured through the conduct of comprehensive training programmes and deployment of cross-functional teams.

Rewards & Recognition

Our structured rewards and recognition framework is aimed at further promoting the adoption of ESG principles across the organisation. The framework comprises multiple incentives, including variable pay components linking employee performance with their contribution to ESG priorities. Integration of these elements into our performance management system helps to motivate our workforce to actively support ESG excellence, and to closely align their efforts with the organisation’s long-term sustainability goals.

Audits & Assurance Exercises

Through regular audit and assurance exercises, we ensure stringent compliance of our sustainable operations to the applicable laws and regulations. The exercises include:

• Annual environmental audits by IR Class
• Half-year sustainability assurance by TUV India Pvt. Ltd.
• Half-year internal audits by EY

We deploy the ISO 14001:2015 environmental management system standards and other management standards to assess the company’s performance on various ESG parametres.

Integrating ESG Standards with ESMS

The Environmental and Social Management System (ESMS) constitutes a key facet of APSEZ’s approach to responsible operations. Our environmental and social management frameworks and plans are aligned with the IFC Performance Standards, ensuring adherence to globally recognised benchmarks. The system helps in:

• Integrating environmental and social standards into the core of our business activities
• Supporting us in identifying and anticipating potential risks early
• Enabling timely responses to stakeholder concerns

Aligned with this approach, we conduct regular monitoring and evaluation of our suppliers and vendors. The exercise is aimed at evaluating their ESG performance, and encouraging continuous improvement across our value chain. All customers operating at our ports are also required to follow the established Berthing Guidelines, and comply stringently with environmental protection requirements as part of our commitment to safe and sustainable port operations.

Corrective & Preventive Actions

Our system of corrective and preventive actions provides a robust framework to support continuous improvement across our operations. This framework is embedded within our Integrated Management System (IMS), which is implemented across all facilities and complies with ISO 14001:2015, ISO 45001:2018, and ISO 9001:2015 standards.

Driven by our efforts to ensure accessible and transparent grievance redressal, we have established multiple channels through which concerns can be raised. These include a 24x7 reporting mechanism on our website, dedicated telephone numbers, and grievance drop boxes placed at prominent locations across our sites. Employees may also report issues directly to their supervisors, senior managers, or department heads.

A well-constructed process is also in place for community grievance reporting. All submissions are formally recorded, reviewed, and escalated as required, with resolutions provided within defined timelines. This approach reinforces our commitment to accountability, responsiveness, and trust building with our stakeholders.

We are further implementing an Integrated Grievance Management System, which will promote organisation-wide transparency by enabling aggrieved individuals to check the status of their grievances, track resolution, and share feedback.

Rigorous Compliance Management

Rigorous monitoring and adherence to all applicable legal and statutory requirements ensures strong compliance management at APSEZ. We have installed Legatrix – an IT-enabled compliance system, which provides a structured framework that functions as a central repository for all compliance-related obligations and guidance. The platform facilitates timely tracking, documentation, and verification of compliance across the organisation. In instances of non-compliance, Legatrix triggers regular reviews and corrective actions to address deviations promptly and reduce the likelihood of any potential risks.

Environmental Compliance

A series of measures helps in effective environmental compliance at APSEZ. These include regular submission of necessary reports and documents to the relevant regulatory authorities, such as the Ministry of Environment, Forest, and Climate Change (MoEF&CC), the Central Pollution Control Board (CPCB), the State Pollution Control Board (SPCB), and the State Coastal Zone Management Authority (SCZMA). The reports, accessible on the company’s website, include a half-yearly compliance report on Environment & Coastal Regulation Zone (CRZ) clearance and an Annual Environment Statement (Form V). We transparently share all environmental clearances received by the company on our website. Six-monthly environment compliance clearance reports are also posted on the website.

The company did not pay any environmental compensation during FY 2025-26.

2030 ESG Targets and Performance

We remain resolutely committed to progressing towards the ESG goals and targets we have set for 2030. Our reporting boundary encompasses our ports, logistics, dredging, and associated business operations. Enhancement of our ESG performance year after year is central to our progressive journey. To ensure our approach stays relevant and effective, we regularly review our strategies, targets, and initiatives, aligning them with the evolving expectations, emerging risks, and global best practices.

*Until previous year, FY 2015-16 was considered as base year. We have updated our base year to FY 2024-25 from this year.

^#From FY 2026 onwards, the targets are measured in numbers.