1.	BACKGROUND AND PURPOSE	3
2.	APPLICABILITY, RESPONSIBILITY, ETC.	3
3.	DEFINITIONS	3
4.	EXPLANATION OF THE TERM "INSIDE INFORMATION"	4
4.1	General	4
4.2	Information of a "precise nature"	4
4.3	"Significant effect" on the price	4
4.4	Information that "has not been made public"	4
4.5	Events that may typically be considered Inside Information	5
5.	THE DUTIES AND OBLIGATIONS OF HAFNIA	5
5.1	Public disclosure of Inside Information	5
5.2	Delayed public disclosure of Inside Information	5
5.3	Insider lists	6
5.4	Project list	6
5.5	Disclosure of notifiable Transactions by Primary Insiders and Close Associates	7
5.6	Other disclosure obligations	7
5.7	Financial reporting	7
5.8	List of Primary Insiders and their Close Associates	7
5.9	Notification of obligations to Primary Insiders	7
6.	THE DUTIES AND RESPONSIBILITIES OF ALL INDIVIDUALS	7
6.1	Introduction	7
6.2	Prohibition of use of Inside Information	8
6.3	Duty of confidentiality	8
6.4	Liability, etc.	8
7.	ADDITIONAL OBLIGATIONS FOR PRIMARY INSIDERS AND THEIR CLOSE ASSOCIATES	9
7.1	Applicability	9
7.2	Obligation to clear Transactions	9
7.3	Duty of notification	9
7.4	Closed periods	10
7.5	Notification of obligations	10
7.6	General exercise of due care	10

Appendix 1 – Written record of delayed disclosure	11
Appendix 2 - Notification of transactions by Primary Insiders and Close Associates	12
Appendix 3 – Notification to Primary Insiders	13
Appendix 4 – Notification to Close Associates	16
Appendix 5 – Routines for secure handling of inside information	18
Appendix 6 – Criteria for trading in closed periods	19
Appendix 7 – Transactions to be notified by Primary Insiders and Close Associates	21

1.	BACKGROUND AND PURPOSE

2.	APPLICABILITY, RESPONSIBILITY, ETC.

3.	DEFINITIONS

a)

the Primary Insider's spouse or partner considered to be equivalent to a spouse in accordance with the law in the jurisdiction of the Primary Insider;

b)

the Primary insider's dependent children pursuant to the law in the jurisdiction of the Primary Insider;

c)

a relative who has shared the same household as the Primary Insider for at least one year on the date of the Transaction concerned; and

d)

a legal person, trust or partnership, the managerial responsibilities of which are discharged by a Primary Insider or by a person referred to in the points above, which is directly or indirectly controlled by such a person, which is set up for the benefit of such a person, or the economic interests of which are substantially equivalent to those of such a person. The reference to "the managerial responsibilities of which are discharged" should be read to cover those cases where a Primary Insider or a Close Associate takes part in or influences the decisions of another legal entity to carry out transactions in Financial Instruments issued by HAFNIA.

a)

a member of the administrative, management or supervisory body of HAFNIA; or

b)

a senior executive who is not a member of the bodies referred to above, who has (i) regular access to Inside Information relating directly or indirectly to HAFNIA and (ii) power to take managerial decisions affecting the future developments and business prospects of HAFNIA.

4.	EXPLANATION OF THE TERM "INSIDE INFORMATION"

4.1

General

4.2	Information of a "precise nature"

4.3	"Significant effect" on the price

4.4	Information that "has not been made public"

4.5	Events that may typically be considered Inside Information

•	financial results;

•	new equity or debt offerings;

•	entry into a material agreement or discussions regarding entry into a material agreement;

•	projections of future earnings or losses;

•	a proposed merger, amalgamation or acquisition;

•	sale or acquisition of material assets;

•	gain or loss of a substantial customer; and

•	project announcements of a significant nature.

5.	THE DUTIES AND OBLIGATIONS OF HAFNIA

5.1	Public disclosure of Inside Information

5.2	Delayed public disclosure of Inside Information

a)	immediate disclosure is likely to prejudice the legitimate interests of HAFNIA;

b)	delay of disclosure is not likely to mislead the public;

c)	HAFNIA is able to ensure the confidentiality of that information.

a)	the Oslo Stock Exchange's market surveillance department shall immediately be informed on a confidential basis of the matter;

b)	HAFNIA shall keep a list of persons with access to the Inside Information in InsiderLog;

c)	the CFO shall make a written record of the delayed disclosure in the format attached hereto as Appendix 1 or by making a written record with the same information in InsiderLog when establishing an insider list as required by paragraph b) above; and

d)

where the confidentiality of the Inside Information is no longer ensured, HAFNIA shall disclose that Inside Information to the public as soon as possible, including situations where a rumour explicitly relates to Inside Information, where that rumour is sufficiently accurate to indicate that the confidentiality of that information is no longer ensured.

a)

inform the Oslo Stock Exchange that disclosure of the Inside Information was delayed through completing the applicable form available as a module in NewsPoint and thereby providing information to the Oslo Stock Exchange about (i) the full legal name of HAFNIA, (ii) the name, title, e-mail address and phone number of the person making the notification, (iii) identification of the publicly disclosed Inside Information that was subject to delayed disclosure, (iv) date and time of the decision to delay the disclosure of Inside Information and (v) the identity of all persons responsible for the decision to delay the public disclosure of Inside Information; and

b)	upon request by the Norwegian FSA and/or to the Oslo Stock Exchange, provide a written explanation of how the conditions for delayed disclosure were met.

5.3	Insider lists

5.4	Project list

5.5	Disclosure of notifiable Transactions by Primary Insiders and Close Associates

5.6	Other disclosure obligations

5.7	Financial reporting

5.8	List of Primary Insiders and their Close Associates

5.9	Notification of obligations to Primary Insiders

6.	THE DUTIES AND RESPONSIBILITIES OF ALL INDIVIDUALS

6.1	Introduction

6.2	Prohibition of use of Inside Information

6.3	Duty of confidentiality

6.4	Liability, etc.

7.	ADDITIONAL OBLIGATIONS FOR PRIMARY INSIDERS AND THEIR CLOSE ASSOCIATES

7.1	Applicability

7.2	Obligation to clear Transactions

7.3	Duty of notification

7.4	Closed periods

7.5	Notification of obligations

7.6	General exercise of due care

	The date and time when the inside information first existed within HAFNIA:
	The date and time when the decision to delay the disclosure was made:
	The date and time when HAFNIA is likely to disclose the Inside Information:
	The identity of the persons responsible for making the decision to delay disclosure and deciding on the start of the delay and its likely end, ensuring the ongoing monitoring of the conditions for the delay, making the decision to publicly disclose the inside information and providing the requested information about the delay and the written explanation to the Oslo Stock Exchange and/or the Norwegian FSA:
	Description of the evidence of the initial fulfilment of the conditions for delayed disclosure:
	Description of the information barriers which have been put in place internally and with regard to third parties to prevent access to inside information by persons other than those who require it for the normal exercise of their employment, profession or duties within HAFNIA:
	Description of the internal and external information barriers and the arrangements put in place to disclose the relevant inside information as soon as possible where the confidentiality is no longer ensured:

(i)

You must obtain clearance in writing from HAFNIA'S CFO as set out in HAFNIA'S internal Instructions for Handling of Inside Information prior to entering into any transactions on your own account or for the account of a third party, directly or indirectly, relating to the financial instruments issued by HAFNIA or to derivatives or other financial instruments linked to them.1

(ii)

You must not conduct any transactions on your own account or for the account of a third party, directly or indirectly, relating to the instruments issued by HAFNIA or to derivatives or other financial instruments linked to them during a closed period of 30 calendar days before the announcement of an interim financial report or a year-end report which HAFNIA makes public, unless explicitly permitted to do so by the CFO of HAFNIA.

(iii)

You must notify your Close Associates (as defined in MAR article 3(26)) (the "Close Associates") of their obligations under MAR article 19 in writing and you must keep a copy of the said notification. Close Associates include (a) spouses or partners considered to be equivalent to a spouse according to your national law, (b) dependent children according to your national law, (c) relatives who have shared the same household with you for at least one year on the date of the transaction concerned and any legal persons, trusts or partnerships, the managerial responsibilities of which are either discharged by you or by a person referred to in point (a), (b) or (c), directly or indirectly controlled by such a person, set up for the benefit of such a person, or the economic interests of which are substantially equivalent to those of such a person. The reference to "the managerial responsibilities of which are discharged" should be read to cover those cases where you or a person referred to in point (a), (b) or (c) takes part in or influences the decisions of the legal entity to carry out transactions in financial instruments of HAFNIA. In the case of mere cross board membership, where you exercise executive or non-executive functions, without however taking part nor influencing the decisions of that legal entity to carry out transactions in financial instruments of HAFNIA, then you should not be considered discharging managerial responsibilities within that legal entity.

(iv)

You must notify HAFNIA and the Norwegian FSA of each transaction, including but not limited to, the transactions set out in Article 19 of MAR and Section 10 of regulation 2016/522 and as further described in Appendix 7 to HAFNIA'S internal Instructions for Handling of Inside Information and attached hereto for ease of reference2 (including, but not limited to, acquisition, disposal, short sale, subscription, exchange, acceptance or exercise of a stock option, subscription to a capital increase or debt instrument issuance, gifts and donations made or received, and inheritance received), conducted on your own account relating to the instruments issued by HAFNIA. The notification must be made promptly and no later than three business days after the date of the transaction. The obligation applies to any subsequent transaction once a total amount of EUR 5,000 has been reached within a calendar year. The notification to the Norwegian FSA must be provided through the link available through https://www.finanstilsynet.no/tema/markedsmisbruksforordningen-mar/ (Norwegian) https://www.finanstilsynet.no/en/topics/market-abuse-regulation-mar-in-norway/ (English) and the notification to HAFNIA must be provided by using the format attached as Appendix 2 to HAFNIA'S internal Instructions for Handling of Inside Information and attached hereto for ease of reference. When calculating whether the threshold has been reached, the transactions carried out by a primary insider and by Close Associates to that primary insider should not be aggregated. If transactions are carried out in a currency which is not EUR, the daily euro foreign exchange reference rate published by the European Central Bank on its website should be used. For the purpose of the price to consider for donations, gifts and inheritance, one should use the last published price for the financial instrument concerned on the date of acceptance of the donation, gift or inheritance (i.e. the date of the transaction), or where such price is not available that day, the last published price. As to the rules to calculate the price of options granted for free to managers or employees, the options should be based on the economic value assigned to the options by HAFNIA when granting them.

(v)

You must as soon as possible after receipt of this notification return the table below to HAFNIA, duly completed with a list of your Close Associates (as defined in item (ii) above) and inform HAFNIA immediately upon any subsequent change to your Close Associates. If you do not want to provide the details of your Close Associates per e-mail, please reach out to the CFO and provide the details by phone or in a secure manner.

	Name and, if legal entity, type of entity		ID number/business reg. number		Address		E-mail		Relation to the Primary Insider

(i)

You must notify HAFNIA and the Norwegian FSA of each transaction, including but not limited to, the transactions set out in Article 19 of MAR and Section 10 of regulation 2016/522 and as further described in an Appendix hereto for ease of reference3 (including, but not limited to, acquisition, disposal, short sale, subscription, exchange, acceptance or exercise of a stock option, subscription to a capital increase or debt instrument issuance, gifts and donations made or received, and inheritance received), conducted on your own account relating to the instruments issued by HAFNIA. The notification must be made promptly and no later than three business days after the date of the transaction. The obligation applies to any subsequent transaction once a total amount of EUR 5,000 has been reached within a calendar year. The notification to the Norwegian FSA must be provided through the link available through https://www.finanstilsynet.no/tema/markedsmisbruksforordningen-mar/ (Norwegian) https://www.finanstilsynet.no/en/topics/market-abuse-regulation-mar-in-norway/ (English) and the notification to HAFNIA must be provided by using the format attached as an Appendix hereto.4 When calculating whether the threshold has been reached, the transactions carried out by a primary insider and by Close Associates to that primary insider should not be aggregated. If transactions are carried out in a currency which is not EUR, the daily euro foreign exchange reference rate published by the European Central Bank on its website should be used. For the purpose of the price to consider for donations, gifts and inheritance, one should use the last published price for the financial instrument concerned on the date of acceptance of the donation, gift or inheritance (i.e. the date of the transaction), or where such price is not available that day, the last published price. Further guidance on how to calculate the threshold may be found here: https://www.esma.europa.eu/document/qa-market-abuse-regulation.

(ii)

You should be cautious if you conduct any transactions on your own account or for the account of a third party, directly or indirectly, relating to the instruments issued by HAFNIA or to derivatives or other financial instruments linked to them during a closed period of 30 calendar days before the announcement of an interim financial report or a year-end report which HAFNIA makes public, noting that Primary Insiders are not permitted to conduct any transactions in such periods unless explicitly permitted to do so by HAFNIA.

•

Use password protection on PC, tablets, phones and other electronic devices that contain Inside Information. Change password on a routinely basis.

•

Do not store Inside Information locally in PC hard disks.

•

Make sure you have solutions in place for remote disabling of phones/tablets that are synced with your email, in case of loss/theft.

•

Always log off devices with access to Inside Information before leaving them.

•

Protect documents. All documents with Inside Information should be sent via secure channels or be secured with password protection.

•

Be careful when distributing Inside Information. Do not distribute Inside Information directly by email, but put the information in a password protected document (Word, PowerPoint, Excel, PDF, etc.)

•

Limited access to files and documents. In certain events as decided by the chief financial officer/investor relation officer, documents should be placed in restricted folders. In such cases, chief financial officer/investor relation officer is responsible ensuring that no unauthorized person has access to such restricted folders and documents. User access can only be given by requesting this by email to chief financial officer/investor relation officer.

•

Consider carefully whether you need to keep Inside Information as printed documents. Each individual is responsible for ensuring that confidential information kept as printed documents does not get in possession of unauthorized persons.

•

Be careful when printing. Do not print documents through printers in common areas without picking up the print immediately.

•

Do not use memory sticks unless they are password protected. They can easily be lost.

•

Secure physical documents: When leaving your work space: make sure to lock in documents. Documents should be shredded once there is no need to keep them. Documents that are put away to be destroyed or shredded must be put in a secure box, not through regular recycling.

•

Be careful when mentioning anything related to Inside Information. Do not discuss Inside Information in front of others, either by phone or through regular conversations.

•

Communication channels. Consider if communication through written channel is secured, or if it should be done through verbal channels.

•

Clean desk. Especially when handling Inside Information kept through physical documents.

•

"Clean room". Make sure to never leave documents with Inside Information at meeting rooms or common areas. Also, secure clean boards; remove flip-over-sheets and all other traces when leaving the room.

•

Misplaced Inside Information. If you get access to or find documents that might be Inside Information, for instance at a printer, in meeting rooms or other areas, make sure to inform the chief financial officer/investor relation officer and destroy the documents immediately.

1.	HAFNIA may only allow a Primary Insider within it to trade on its own account or for the account of a third party during a closed period if permitted pursuant to MAR and Commission Delegated Regulation (EU) 2016/522 supplementing MAR, meaning, either:

(a)

on a case-by-case basis due to the existence of exceptional circumstances, such as severe financial difficulty, which require the immediate sale of shares; or

(b)

due to the characteristics of the trading involved for transactions made under, or related to, an employee share or saving scheme, qualification or entitlement of shares, or transactions where the beneficial interest in the relevant security does not change; and

2.

In the circumstances set out in 1(a) above, prior to any trading during the closed period, a Primary Insider shall provide a reasoned written request to HAFNIA for obtaining HAFNIA'S permission to proceed with immediate sale of shares of that issuer during a closed period. The written request shall describe the envisaged transaction and provide an explanation of why the sale of shares is the only reasonable alternative to obtain the necessary financing.

3.

When deciding whether to grant permission to proceed with immediate sale of its shares during a closed period, an issuer shall make a case-by-case assessment of a written request referred to above. HAFNIA shall have the right to permit the immediate sale of shares only when the circumstances for such transactions may be deemed exceptional. Such circumstances shall be considered to be exceptional when they are extremely urgent, unforeseen and compelling and where their cause is external to the Primary Insider and the Primary Insider has no control over them. When examining whether the circumstances described in the written request are exceptional, HAFNIA shall take into account, among other indicators, whether and to the extent to which the Primary Insider:

(a)

is at the moment of submitting its request facing a legally enforceable financial commitment or claim;

(b)

has to fulfil or is in a situation entered into before the beginning of the closed period and requiring the payment of sum to a third party, including tax liability, and cannot reasonably satisfy a financial commitment or claim by means other than immediate sale of shares.

4.	HAFNIA shall have the right to permit the Primary Insider within HAFNIA to trade on its own account or for the account of a third party during a closed period, including but not limited to circumstances where that Primary Insider:

(a)

had been awarded or granted financial instruments under an employee scheme, provided that the following conditions are met:

a.

the employee scheme and its terms have been previously approved by HAFNIA in accordance with national law and the terms of the employee scheme specify the timing of the award or the grant and the amount of financial instruments awarded or granted, or the basis on which such an amount is calculated and given that no discretion can be exercised;

b.

the Primary Insider does not have any discretion as to the acceptance of the financial instruments awarded or granted;

(b)

had been awarded or granted financial instruments under an employee scheme that takes place in the closed period provided that a pre-planned and organised approach is followed regarding the conditions, the periodicity, the time of the award, the group of entitled persons to whom the financial instruments are granted and the amount of financial instruments to be awarded, the award or grant of financial instruments takes place under a defined framework under which any inside information cannot influence the award or grant of financial instruments;

(c)

exercises options or warrants or conversion of convertible bonds assigned to him under an employee scheme when the expiration date of such options, warrants or convertible bonds falls within a closed period, as well as sales of the shares acquired pursuant to such exercise or conversion, provided that all of the following conditions are met:

a.

the Primary Insider notifies HAFNIA of its choice to exercise or convert at least four months before the expiration date;

b.

the decision of the Primary Insider is irrevocable;

c.

the Primary Insider has received the authorisation from HAFNIA prior to proceed;

(d)

acquires HAFNIA'S financial instruments under an employee saving scheme, provided that all of the following conditions are met:

a.

the Primary Insider has entered into the scheme before the closed period, except when it cannot enter into the scheme at another time due to the date of commencement of employment;

b.

the Primary Insider does not alter the conditions of his participation into the scheme or cancel his participation into the scheme during the closed period;

c.

the purchase operations are clearly organised under the scheme terms and that the Primary Insider has no right or legal possibility to alter them during the closed period, or are planned under the scheme to intervene at a fixed date which falls in the closed period;

(e)

transfers or receives, directly or indirectly, financial instruments, provided that the financial instruments are transferred between two accounts of the Primary Insider and that such a transfer does not result in a change in price of financial instruments;

(f)

acquires qualification or entitlement of shares of HAFNIA and the final date for such an acquisition, under HAFNIA'S statute, bye-law or such other constitutional documents falls during the closed period, provided that the Primary Insider submits evidence to HAFNIA of the reasons for the acquisition not taking place at another time, and HAFNIA is satisfied with the provided explanation.

1.

the pledging or lending of financial instruments by or on behalf of a Primary Insider or a Close Associate (but not if the pledge, or a similar security interest, is done in connection with the depositing of the financial instruments in a custody account, unless and until such time that such pledge or other security interest is designated to secure a specific credit facility);

2.

transactions undertaken by persons professionally arranging or executing transactions or by another person on behalf of a Primary Insider or a Close Associate, including where discretion is exercised;

3.

transactions made under a life insurance policy, defined in accordance with Directive 2009/138/EC of the European Parliament and of the Council (26), where

(a)

the policyholder is a Primary Insider or a Close Associate,

(b)

the investment risk is borne by the policyholder, and

(c)

the policyholder has the power or discretion to make investment decisions regarding specific instruments in that life insurance policy or to execute transactions regarding specific instruments for that life insurance policy.

4.	acquisition, disposal, short sale, subscription or exchange;

5.	acceptance or exercise of a stock option, including of a stock option granted to managers or employees as part of their remuneration package, and the disposal of shares stemming from the exercise of a stock option;

6.	entering into or exercise of equity swaps;

7.	transactions in or related to derivatives, including cash-settled transaction;

8.	entering into a contract for difference on a financial instrument of the concerned issuer;

9.	acquisition, disposal or exercise of rights, including put and call options, and warrants;

10.	subscription to a capital increase or debt instrument issuance;

11.	transactions in derivatives and financial instruments linked to a debt instrument of the concerned issuer, including credit default swaps;

12.	conditional transactions upon the occurrence of the conditions and actual execution of the transactions;

13.	automatic or non-automatic conversion of a financial instrument into another financial instrument, including the exchange of convertible bonds to shares;

14.	gifts and donations made or received, and inheritance received;

15.	transactions executed in index-related products, baskets and derivatives;

16.	transactions executed in shares or units of investment funds, including alternative investment funds (AIFs);

17.	transactions executed by manager of an AIF in which a Primary Insider or a Close Associate has invested;

18.	transactions executed by a third party under an individual portfolio or asset management mandate on behalf or for the benefit of a Primary Insider or a Close Associate;

19.	borrowing or lending of shares or debt instruments of the issuer or derivatives or other financial instruments linked thereto.

20.	Transactions in financial instruments linked to shares or to debt instruments of the issuer referred to in that paragraph where at the time of the transaction any of the following conditions is met:

(a)

the financial instrument is a unit or share in a collective investment undertaking in which the exposure to the issuer's shares or debt instruments does not exceed 20 % of the assets held by the collective investment undertaking;

(b)

the financial instrument provides exposure to a portfolio of assets in which the exposure to the issuer's shares or debt instruments does not exceed 20 % of the portfolio's assets;

(c)

the financial instrument is a unit or share in a collective investment undertaking or provides exposure to a portfolio of assets and the person discharging managerial responsibilities or a Close Associate does not know, and could not know, the investment composition or exposure of such collective investment undertaking or portfolio of assets in relation to the issuer's shares or debt instruments, and furthermore there is no reason for that person to believe that the issuer's shares or debt instruments exceed the thresholds in point (a) or (b).

21.

Finally, transactions executed in shares or debt instruments of an issuer or derivatives or other financial instruments linked thereto by managers of a collective investment undertaking in which the Primary Insider or Close Associate has invested do not need to be notified where the manager of the collective investment undertaking operates with full discretion, which excludes the manager receiving any instructions or suggestions on portfolio composition directly or indirectly from investors in that collective investment undertaking.