Management of impacts, risks and opportunities
Materiality assessment
The double materiality assessment forms the basis of the non-financial group statement and determines the topics that have to be reported on for the financial year concerned. The methodology and assessment criteria for the double materiality assessment for the 2025 financial year were conducted in accordance with the ESRS. This means that a topic is considered material, and therefore reportable, if it either has a material impact on the environment or society, or if external influences have a material financial effect (risk or opportunity) on the company (double materiality). This has to be identified and evaluated in the materiality assessment.
A distinction was made in the materiality assessment between the recording of impacts on the one hand, and opportunities and risks on the other.
Sustainability-related risks and opportunities
Sustainability-related risks and opportunities have been included in the HHLA ORMS on an equal footing with other risks and opportunities since 2024. In the first quarter of 2025, the materiality of sustainability-related risks and opportunities was fundamentally reviewed by the companies and departments directly in the HHLA ORMS. The companies and divisions conducted this process based on a bottom-up assessment of relevance and materiality based on the likelihood and the potential effect of ESG risks and opportunities, with the comprehensive longlist in accordance with ESRS 1 AR 16 serving as a starting point in this regard. The risks and opportunities were recorded in gross terms, i.e. before the effects of the actions, and classified according to their time horizon (short, medium, long term) and mapped within the value chain. The individual evaluations were consolidated at group level via the ORMS. The sustainability-related risks and opportunities were presented to, and validated by, stakeholders/relevant departments during the materiality assessment workshops. Engaging stakeholders / Risk and opportunity report
Sustainability-related risks and opportunities are assessed based on their effect and their likelihood. The materiality thresholds are set at a loss/opportunity amount of € 1 million or higher and a likelihood of 5 % or higher. Risk and opportunity report
Sustainability-related impacts
Impacts were recorded and assessed as part of a three-step process.
1. Identification of sustainability topics (longlist)
In order to identify relevant sustainability topics, the first step involved taking a detailed look at HHLA’s operations and their specific context (e.g. locations), stakeholders, business partners and the HHLA value chain. The collection of sustainability topics also included the results of the materiality assessment from previous years (based on CSR-RUG and the GRI), the analyses of the DNSH criteria and the climate risk assessment required under the EU Taxonomy, as well as the topics specified by the ESRS and the CDP and due diligence considerations. This enabled all topics relevant to HHLA to be identified and initially transferred to a longlist without any priorities being set. Corporate strategy in respect of sustainability issues
2. Identification of potential impacts
For each sustainability topic, internal experts developed a list of actual and potential positive and negative impacts, as well as short, medium and long-term impacts. Topics for which no impact could be identified were removed (shortlist). Affected communities were not consulted separately. Engaging stakeholders
The shortlist consisted of environmental topics and impacts relating to the climate, pollution, water and resource use, biodiversity and ecosystems, as well as social and governance topics and impacts.
Climate-related impacts, risks and opportunities
Climate-related risks were assessed for the first time in 2022 as part of the implementation of the EU Taxonomy, using a robust climate risk and vulnerability assessment. This assessment was updated in 2024 due to the adjustments to the underlying climate data to reflect the IPCC’s Sixth Assessment Report. The results, which remain valid, were incorporated into HHLA’s risk and opportunity management. The climate risk and vulnerability assessment was combined with HHLA’s internal opportunity and risk management system and incorporated into its reporting. The assessment is conducted with the involvement of the operating companies and experts, and includes consideration of the supply chain. The assessment looked at the chronic and acute climate-related hazards set out in Annex I, Appendix A of the EU Taxonomy. The climate data is evaluated on a location-specific basis using the coordinates for the individual locations. Depending on the potential climate hazard, this data includes the likelihood of occurrence, duration and extent, and is based on various emissions scenarios (SSP1-2.6 to SSP3-7.0 and SSP5-8.5). The climate scenarios were analysed over a short, medium and long-term period up to 2050. The definition of short, medium and long-term horizons corresponds to those used in the HHLA ORMS. This definition covers the expected service life of the assets as well as HHLA’s planning horizons (five years). Structure of the system / Climate risks
Climate-related opportunities and transition risks were recorded, assessed and evaluated on an ongoing basis as part of the operational risk and opportunity management process, and were put on an equal footing with other sustainability-related risks and opportunities. This assessment is not based on any climate scenarios.
In order to assess the climate-related impacts, HHLA’s climate targets were specifically included in the assessment, as were considerations related to the business model and financial planning data. See Structure of the system / Climate risks for the results from the climate risk assessment.
Ecosystem-related impacts, risks, dependencies and opportunities
The materiality assessment with regard to biodiversity was conducted by experts from the segments, departments and the management. In addition, the results of the EU Taxonomy assessment of the company’s own sites – whether they are located in or near biodiversity-sensitive areas – were taken into account. The value chain, including ecosystem services, was reviewed and assessed for environmental impacts, transition risks, and physical and systemic risks that may also arise from dependencies. Affected stakeholders were not consulted directly. EU Taxonomy
Across the Group, there are individual sites that are located near biodiversity-sensitive areas. Protective measures are taken to ensure that any negative impact on biodiversity or ecosystems is reduced to a regulatory minimum.
Impacts, risks, dependencies and opportunities in connection with resource use and the circular economy
The materiality assessment with regard to resource use and the circular economy was conducted by experts from the segments, departments and the management. No further assessments were performed. Affected stakeholders were not consulted directly.
Governance-related impacts, risks, dependencies and opportunities
The materiality assessment with regard to governance topics was conducted by the Compliance department, which assessed operations across the Group in all segments, particularly port-related services, the Intermodal segment and the Real Estate segment.
3. Identification of material impacts
The individual impact criteria were assessed together with the affected stakeholders and their representatives at a workshop, and a consensus was reached on the final assessment. Stakeholder representatives are internal specialists who have extensive knowledge of the relevant stakeholders and users of the non-financial group statement. No external experts were involved in the process. Engaging stakeholders
In line with the ESRS, the following distinction was made in terms of the assessment criteria for the various impacts:
Actual positive impacts: scale and scope
Potential positive impacts: scale, scope and likelihood
Actual negative impacts: scale, scope and irremediability
Potential negative impacts: scale, scope and likelihood
With the exception of likelihood, the criteria were each assessed on a five-point scale, with 1 representing the lowest score and 5 the highest. Likelihood, in accordance with the HHLA ORMS, was operationalised on a four-point scale.
The results scale was set at 0 to 10 and the materiality threshold was set at ≥ 5.
This assessment and the positioning on the scales determine the materiality of the impacts, risks and opportunities (IROs). In the event of potential negative human rights impacts, the severity of the impact takes precedence over its likelihood.
After the materiality workshop, the assessments of all IROs were critically reviewed as part of a quality assurance process in collaboration with the project lead and HHLA ORMS, taking into account the correlations between the IROs. This did not result in a change to the assessment or the list of the material IROs.
Results of the materiality assessment
The list and positioning in the value chain of the material IROs together with the corresponding material topics and sub-topics are listed in the section on the interaction between the IROs and the business strategy. Material impacts, risks and opportunities and their interaction with the company’s strategy and business model
The material IROs were assigned to the corresponding topics, sub-topics and sub-sub-topics in accordance with ESRS 1 AR 16. Once an IRO was identified as material, the corresponding sub-topic was identified as material, and therefore as reportable.
There are no material risks arising from our own business activities or from business relationships, products and services that are highly likely to have a serious negative impact on non-financial aspects in accordance with Section 289c of the German Commercial Code (HGB).
Monitoring and control
Throughout the process, internal controls were conducted to ensure that the data was accurate and complete, e.g. using the dual control principle or feedback loops. The results of the materiality assessment were confirmed by HHLA’s Executive Board and HHLA's Supervisory Board, and the HHLA Group Works Council was informed of the results.
The materiality assessment in accordance with the ESRS requirements will be reviewed annually and updated as necessary.