2022 Communication on Progress

Navigator Holdings Ltd

Published date

June 16, 2022

No. of questions

65

Supplemental files

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

    1. Does the Board / highest governance body or most senior executive of the company:

    2. Does the company have a publicly stated commitment regarding the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    These are available on our website: www.navigatorgas.com

    3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

    No one is specifically responsible for this topic

    Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)

    Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)

    Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights

    Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

    No formal structure

    Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)

    Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)

    Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)

    Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Prevention

    6. Does the company have a process or processes to assess risk?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    6.1. During the assessment of risk, which business relationships are reviewed?

    A few suppliers or business relationships [approximately less than 25 %]

    Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]

    Most suppliers / relevant business relationships [approx. 51 - 99 %]

    All suppliers / relevant business relationships outside the supply chain

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Concerns and grievance mechanisms

    8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

    8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

    No

    Yes

    Is the process communicated to all employees/workers in local languages?

    Is the process available to non-employees (e.g., contractors, vendors, suppliers)?

    Is the process confidential (e.g., whistleblowing process)?

    Are there processes in place to avoid retaliation?

    Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)

    Other (Please provide additional information)

    9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

    No process to enable remedy to stakeholders

    Remedy available to some stakeholders (i.e., some geographies, employees only)

    Remedy is available to all affected stakeholders

    Remedy is available to all stakeholders, and suppliers are expected to have similar policies

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Lessons

    10. How does the company capture lessons regarding each of the following sustainability topics?

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

    Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly

    Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Executive Pay

    11. Is executive pay linked to performance on one or more of the following sustainability topics?

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Board Composition

    12. Percentage of individuals within the company’s Board / highest governance body by:

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    7

    Male (%)

    86

    Female (%)

    14

    Non-binary (%)

    0

    Under 30 years old (%)

    0

    30-50 years old (%)

    29

    Above 50 years old (%)

    71

    From minority or vulnerable groups (%)

    14

    Executive (%)

    0

    Independent (%)

    57

    13. Do you produce sustainability reporting according to:

    Data Assurance

    14. Is the information disclosed in this questionnaire assured by a third-party?

  • Human Rights

    Materiality / Saliency

    1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?

    Response

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    We have an extensive occupational health and safety management system covering the full scope of our operation. During the reporting period, we have successfully conducted internal and external audits to verify the integrity of our management systems and to determine areas for continuous improvement. We have implemented a Code of Conduct and Business Ethics which applies to everyone involved in our business and is applied to those we work with externally, including suppliers and contractors. During the pandemic, we carried out systematic risk assessments and implemented procedures to keep shore and sea staff safe. We responded to government advice and supported remote working to ensure the safety of our employees, customers, contractors and suppliers. The focus for the next reporting year will be to improve how we address human rights issues within the supply chain. This process has already started and we are currently completing a materiality assessment within the business to help us identify material sustainability issues. We have also drafted policy documentation addressing human rights, child labour, forced labour and other important issues within the supply chain. The next steps will include creating a mechanism to audit supplier performance.

  • Labour

    Commitment

    1. Does the company have a policy commitment in relation to the following labour rights principles?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    2021

    Child labour

    2021

    Non-discrimination in respect of employment and occupation

    2021

    Occupational safety and health

    2021

    Working conditions (wages, working hours)

    Various policies reviewed in 2020 and 2021

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving labour rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks /impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Created a Modern Slavery Statement and included this on our website.

    Child labour

    Created a Modern Slavery Statement and included this on our website.

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Made adjustments to the working environment in response to COVID.

    4. Who receives training for the following labour rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Performance

    6. What is the percentage of employees covered under collective bargaining agreements?

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    0
    Optional comment
    Our seafarers, though not direct employees, are covered through maritime-specific collective bargaining agreements and have company-paid membership of the International Transport Workers Federation (ITF).

    7. What is the percentage of employees in a trade union or other workers' organization?

    Percent of employees (%)

    Unknown

    Not applicable (Please provide additional information)

    Employees in a trade union or on a worker committee (%)

    0
    Optional comment
    Our seafarers, though not direct employees, are covered through maritime-specific collective bargaining agreements and have company-paid membership of the International Transport Workers Federation (ITF).

    8. In the course of the reporting period, what was the percentage of women in:

    Percent of women (%)

    Unknown

    Senior leadership level position

    29

    Non-executive board

    11
    Optional comment
    Our seafarers, though not direct employees, are covered through maritime-specific collective bargaining agreements and have company-paid membership of the International Transport Workers Federation (ITF).

    9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

    10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    2.97

    11. In the course of the reporting period, what was the company’s incident rate?

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    0

    Response and Reporting

    12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    During the reporting period, we applied salary benchmarking to shorebased employees.

  • Environment

    Commitment

    1. Does the company have a formal policy on the following environmental topics?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    2021

    Water

    2021

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    2021

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    2021

    Energy & Resource Use

    2021

    1.1. For each environmental policy, is it:

    Aligned with international environmental standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    Climate Action, Water and Air Pollution

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks/ impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    The company has conducted its first materiality assessment, including both internal and external stakeholders.

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

    Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)

    Climate Action

    Energy & Resource Use

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

    A reduction of 3% of air emissions by 2022.

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Oceans

    4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

    Progress is reviewed against goals annually or more frequently

    Progress is reported internally to the most senior level

    Progress is reported externally

    Other (Please provide additional information)

    Climate Action

    Energy & Resource Use

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Oceans

    5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Climate Action

    6. What were the company’s gross global greenhouse gas emissions for the reporting period?

    Scope 1 Emissions

    Emissions (tCO2e)

    895349

    Scope 2 Emissions

    Our Scope 2 emissions equate to 52.57 metric tonnes CO2e, but this does not include our Joint Venture Ethlyene Terminal in Morgan's Point.

    Emissions (tCO2e)

    Scope 3 Emissions

    Currently, emissions are reported as absolute values (in metric tonnes). We are putting processes in place to report GHG Scope 1 and 2 emissions for reporting year 2022, from 2023 onwards. Some categories of Scope 3 emissions will be identified and reported from 2022 onwards.

    Emissions (tCO2e)

    7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

    Percent of revenue (%)

    8. Has the organization acted to support climate change adaptation and resilience?

    Energy / Resource Use

    9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

    % of total energy consumption

    Technology

    10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

    Percent of total revenue (%)

    Our company provides transportation and logistics services.

    Sector-specific Questions

    11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.

    Sector-specific: Water

    12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

    Water withdrawal (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    We provide transportation services only, and we do not refine or produce oil and gas products.

    Groundwater:

    We provide transportation services only, and we do not refine or produce oil and gas products.

    Surface water:

    We provide transportation services only, and we do not refine or produce oil and gas products.

    Rainwater:

    We provide transportation services only, and we do not refine or produce oil and gas products.

    Wastewater:

    We provide transportation services only, and we do not refine or produce oil and gas products.

    Percentage of water withdrawn in regions with high or extremely high water stress (%)

    We provide transportation services only, and we do not refine or produce oil and gas products.

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    We provide transportation services only, and we do not refine or produce oil and gas products.

    Groundwater:

    We provide transportation services only, and we do not refine or produce oil and gas products.

    Surface water:

    We provide transportation services only, and we do not refine or produce oil and gas products.

    Rainwater:

    We provide transportation services only, and we do not refine or produce oil and gas products.

    Wastewater:

    We provide transportation services only, and we do not refine or produce oil and gas products.

    Percentage of water consumed in regions with high or extremely high water stress (%)

    We provide transportation services only, and we do not refine or produce oil and gas products.

    13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

    Water intensity of products (cubic meter/$):

    Sector-specific: Forest, biodiversity, and land use

    14. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).

    Number

    Unknown

    Not applicable (Please provide additional information)

    Sites

    Our terminal is not adjacent to any protected areas or key biodiversity areas.

    Hectares

    Our terminal is not adjacent to any protected areas or key biodiversity areas.

    15. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?

    Conversion of natural resources (hectares)

    There were no natural ecosystems converted in areas specific to the ethylene terminal.

    16. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?

    No

    No, but we plan to in the next 2 years

    Yes

    Forest ecosystem restoration

    Other ecosystem restoration

    Reforestation

    Natural regeneration

    Agroforestry

    Set-aside land

    Biodiversity offsetting

    Other (please specify in text box)

    Sector-specific: Air pollution

    17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.

    Emissions (tCO2e)

    Unknown

    Not applicable (Please provide additional information)

    NOx

    SOx

    8938

    Volatile Organic Compounds (VOC)

    Hazardous air pollutants (HAP)

    Particulate matter (PM10)

    Persistent organic pollutants (POP)

    Other (please specify in text box)

    Sector-specific: Waste

    18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.

    Waste Generated (t)

    19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

    Hazardous Waste Ratio (%)

    20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

    Single-use plastics (tonnes)

    Overall Environment

    21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

    During the reporting period, we have continued our efforts to reduce Single Use Plastics, optimise supply chain movements and increase our level of cooperation and collaboration with supply chain partners. We have also implemented a series of technical optimisations which are helping to reduce emissions. The main actions planned for 2022/2023 include developing our decarbonisation strategy and implementing systems to facilitate reporting emissions in accordance with the GHG protocol.

  • Anti-corruption

    Commitment

    1. Does the company have an anti-corruption compliance programme?

    2022

    2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

    Prevention

    3. Who receives training on anti-corruption and integrity?

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

    4. Does the company monitor its anti-corruption compliance programme?

    Response and Reporting

    5. Please report the company's total number and nature of incidents of corruption during the reporting year.

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    0
    Not applicable

    Confirmed during the current year, and related to this year

    0
    Not applicable

    6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

    7. Does your company engage in Collective Action against corruption?

    Optional comment
    The company will join the Maritime Anti-corruption Network (MACN).

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

    During the report period, the company has: Reviewed and supplement the company anti-corruption policy. Creation of dedicated compliance team. Implementation of an externally-managed whistleblowing solution which facilitates anonymous reporting from both within the organisation and externally. Engaging with the Maritime Anti Corruption Network with a view to making an application to formally join the network. We plan to: Conduct more frequent training on antibribery and corruption throughout the organisation. Implement a new third party onboarding system, which includes sanctions compliance checks and adverse media attention, enhancing our Know Your Customer checks.