20-F 1 trmd-20221231x20f.htm FORM 20-F
0001655891--12-312022FYfalseDK-29006000000400000019000006000000P25Y6000000.33P5D0.660001655891trmd:BunkerSwapContractsMemberifrs-full:NotLaterThanOneYearMemberifrs-full:CashFlowHedgesMember2021-12-310001655891trmd:BunkerSwapContractsMemberifrs-full:NotLaterThanOneYearMemberifrs-full:CashFlowHedgesMember2020-12-310001655891trmd:ChiefExecutiveOfficerCEOMembertrmd:LongTermIncentivePlanMember2017-01-012022-12-310001655891trmd:MainFleetMember2022-01-012022-12-310001655891ifrs-full:OtherPropertyPlantAndEquipmentMemberifrs-full:TopOfRangeMember2022-01-012022-12-310001655891ifrs-full:OtherPropertyPlantAndEquipmentMemberifrs-full:BottomOfRangeMember2022-01-012022-12-310001655891ifrs-full:LandAndBuildingsMemberifrs-full:TopOfRangeMember2022-01-012022-12-310001655891ifrs-full:LandAndBuildingsMemberifrs-full:BottomOfRangeMember2022-01-012022-12-310001655891trmd:ForwardFreightAgreementsMemberifrs-full:TopOfRangeMember2022-01-012022-12-310001655891trmd:ForwardFreightAgreementsMemberifrs-full:BottomOfRangeMember2022-01-012022-12-310001655891ifrs-full:InterestRateSwapContractMemberifrs-full:LaterThanSixMonthsMemberifrs-full:CashFlowHedgesMember2022-12-310001655891ifrs-full:CashFlowHedgesMember2022-01-012022-12-310001655891ifrs-full:CashFlowHedgesMember2021-01-012021-12-310001655891ifrs-full:CashFlowHedgesMember2020-01-012020-12-3100016558912019-01-012019-12-310001655891ifrs-full:NoncurrentAssetsHeldForSaleMember2021-12-310001655891ifrs-full:NoncurrentAssetsHeldForSaleMember2021-05-012021-05-310001655891ifrs-full:OperatingSegmentsMembertrmd:TankMember2022-09-012022-09-010001655891trmd:SeniorManagementTeamMember2022-12-310001655891trmd:SeniorManagementTeamMember2021-12-310001655891trmd:BocommFacilityMembertrmd:UnspecifiedMaturityMember2021-01-012022-12-310001655891trmd:BocommFacilityMembertrmd:UnspecifiedMaturityMember2022-01-012022-12-310001655891ifrs-full:TopOfRangeMember2022-01-012022-12-310001655891ifrs-full:BottomOfRangeMember2022-01-012022-12-310001655891trmd:TankMember2022-01-012022-12-310001655891trmd:CommonClassBSharesMember2022-01-012022-12-310001655891trmd:CommonClassBSharesMemberifrs-full:TopOfRangeMember2022-01-012022-12-310001655891ifrs-full:BottomOfRangeMember2022-12-310001655891trmd:MainFleetMemberifrs-full:TopOfRangeMember2022-01-012022-12-310001655891trmd:MainFleetMemberifrs-full:BottomOfRangeMember2022-01-012022-12-310001655891trmd:HandySizeMember2022-01-012022-12-310001655891trmd:VesselClassMrMember2022-12-310001655891trmd:VesselClassLrTwoMember2022-12-310001655891trmd:VesselClassLrOneMember2022-12-310001655891trmd:VesselClassHandysizeMember2022-12-310001655891trmd:VesselClassMrMember2021-12-310001655891trmd:VesselClassLrTwoMember2021-12-310001655891trmd:VesselClassLrOneMember2021-12-310001655891trmd:VesselClassHandysizeMember2021-12-310001655891trmd:VesselClassMrMember2020-12-310001655891trmd:VesselClassLrTwoMember2020-12-310001655891trmd:VesselClassLrOneMember2020-12-310001655891trmd:VesselClassHandysizeMember2020-12-310001655891trmd:ChiefExecutiveOfficerCEOMembertrmd:RsuGrantIn2016Member2016-01-012016-12-310001655891srt:ChiefExecutiveOfficerMember2020-01-012020-12-310001655891ifrs-full:GrossCarryingAmountMembertrmd:VesselsAndCapitalizedDryDockingMember2020-01-012020-12-310001655891trmd:ForwardFreightAgreementsMember2022-01-012022-12-310001655891trmd:ForwardFreightAgreementsMember2021-01-012021-12-310001655891trmd:ForwardFreightAgreementsMember2020-01-012020-12-310001655891ifrs-full:InterestRateSwapContractMembertrmd:HeldForHedgingMember2022-12-310001655891ifrs-full:ForwardContractMembertrmd:HeldForHedgingMember2022-12-310001655891trmd:ForwardFreightAgreementsMembertrmd:HeldAtFairValueThroughProfitOrLossMember2021-12-310001655891trmd:BunkerSwapContractsMembertrmd:HeldForHedgingMember2021-12-310001655891trmd:BunkerSwapContractsMembertrmd:HeldAtFairValueThroughProfitOrLossMember2021-12-310001655891ifrs-full:InterestRateSwapContractMembertrmd:HeldForHedgingMember2021-12-310001655891ifrs-full:ForwardContractMembertrmd:HeldForHedgingMember2021-12-310001655891trmd:ForwardFreightAgreementsMembertrmd:HeldAtFairValueThroughProfitOrLossMember2020-12-310001655891trmd:BunkerSwapContractsMembertrmd:HeldForHedgingMember2020-12-310001655891trmd:BunkerSwapContractsMembertrmd:HeldAtFairValueThroughProfitOrLossMember2020-12-310001655891ifrs-full:InterestRateSwapContractMembertrmd:HeldForHedgingMember2020-12-310001655891ifrs-full:ForwardContractMembertrmd:HeldForHedgingMember2020-12-310001655891ifrs-full:TopOfRangeMembertrmd:ForwardFreightAgreementsMember2022-01-012022-12-310001655891ifrs-full:TopOfRangeMembertrmd:CargoContractAndTimeCharterAgreementsMember2022-01-012022-12-310001655891ifrs-full:BottomOfRangeMembertrmd:ForwardFreightAgreementsMember2022-01-012022-12-310001655891ifrs-full:BottomOfRangeMembertrmd:CargoContractAndTimeCharterAgreementsMember2022-01-012022-12-310001655891ifrs-full:NotLaterThanOneYearMembertrmd:EstimatedVariableInterestPaymentsMember2022-12-310001655891ifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMembertrmd:EstimatedVariableInterestPaymentsMember2022-12-310001655891ifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMembertrmd:EstimatedVariableInterestPaymentsMember2022-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMembertrmd:EstimatedVariableInterestPaymentsMember2022-12-310001655891ifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMembertrmd:EstimatedVariableInterestPaymentsMember2022-12-310001655891ifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMembertrmd:EstimatedVariableInterestPaymentsMember2022-12-310001655891trmd:EstimatedVariableInterestPaymentsMember2022-12-310001655891ifrs-full:NotLaterThanOneYearMembertrmd:EstimatedVariableInterestPaymentsMember2021-12-310001655891ifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMembertrmd:EstimatedVariableInterestPaymentsMember2021-12-310001655891ifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMembertrmd:EstimatedVariableInterestPaymentsMember2021-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMembertrmd:EstimatedVariableInterestPaymentsMember2021-12-310001655891ifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMembertrmd:EstimatedVariableInterestPaymentsMember2021-12-310001655891ifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMembertrmd:EstimatedVariableInterestPaymentsMember2021-12-310001655891trmd:EstimatedVariableInterestPaymentsMember2021-12-310001655891ifrs-full:NotLaterThanOneYearMembertrmd:EstimatedVariableInterestPaymentsMember2020-12-310001655891ifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMembertrmd:EstimatedVariableInterestPaymentsMember2020-12-310001655891ifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMembertrmd:EstimatedVariableInterestPaymentsMember2020-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMembertrmd:EstimatedVariableInterestPaymentsMember2020-12-310001655891ifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMembertrmd:EstimatedVariableInterestPaymentsMember2020-12-310001655891ifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMembertrmd:EstimatedVariableInterestPaymentsMember2020-12-310001655891trmd:EstimatedVariableInterestPaymentsMember2020-12-310001655891trmd:Year2030Member2022-12-310001655891trmd:Year2025Member2022-12-3100016558912022-09-3000016558912022-06-300001655891trmd:HandySizeMemberifrs-full:TopOfRangeMember2022-12-310001655891trmd:HandySizeMemberifrs-full:BottomOfRangeMember2022-12-310001655891ifrs-full:OtherPropertyPlantAndEquipmentMember2022-01-012022-12-310001655891ifrs-full:LandAndBuildingsMember2022-01-012022-12-310001655891ifrs-full:ForwardContractMemberifrs-full:CashFlowHedgesMember2022-01-012022-12-310001655891ifrs-full:CashFlowHedgesMemberifrs-full:CurrencyRiskMember2022-01-012022-12-310001655891ifrs-full:ForwardContractMemberifrs-full:CashFlowHedgesMember2021-01-012021-12-310001655891ifrs-full:ForwardContractMemberifrs-full:CashFlowHedgesMember2020-01-012020-12-310001655891trmd:HandySizeMember2022-12-310001655891trmd:MrEcoProductTankerVesselsMemberifrs-full:MajorPurchasesOfAssetsMember2023-03-012023-03-160001655891trmd:Lr1VesselsMemberifrs-full:MajorPurchasesOfAssetsMember2023-01-252023-01-250001655891trmd:CommonClassCSharesMember2022-01-012022-12-310001655891ifrs-full:OtherPropertyPlantAndEquipmentMemberifrs-full:TopOfRangeMember2022-01-012022-12-310001655891ifrs-full:OtherPropertyPlantAndEquipmentMemberifrs-full:BottomOfRangeMember2022-01-012022-12-310001655891ifrs-full:ComputerSoftwareMemberifrs-full:TopOfRangeMember2022-01-012022-12-310001655891ifrs-full:ComputerSoftwareMemberifrs-full:BottomOfRangeMember2022-01-012022-12-310001655891ifrs-full:ComputerEquipmentMemberifrs-full:TopOfRangeMember2022-01-012022-12-310001655891ifrs-full:ComputerEquipmentMemberifrs-full:BottomOfRangeMember2022-01-012022-12-310001655891ifrs-full:MotorVehiclesMember2022-01-012022-12-310001655891trmd:ScrubberTestFacilityMember2022-01-012022-12-310001655891ifrs-full:CustomerrelatedIntangibleAssetsMember2022-01-012022-12-310001655891ifrs-full:ComputerSoftwareMember2022-01-012022-12-310001655891ifrs-full:LegalProceedingsProvisionMember2022-01-012022-12-310001655891trmd:CreditFacilityMember2022-12-310001655891trmd:CreditFacilityMember2021-12-310001655891trmd:CreditFacilityMember2020-12-310001655891trmd:VesselMemberifrs-full:NotLaterThanOneYearMember2022-12-310001655891trmd:VesselMemberifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMember2022-12-310001655891trmd:VesselMemberifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMember2022-12-310001655891trmd:VesselMemberifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMember2022-12-310001655891trmd:VesselMemberifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMember2022-12-310001655891trmd:VesselMemberifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMember2022-12-310001655891trmd:VesselMember2022-12-310001655891trmd:VesselMemberifrs-full:NotLaterThanOneYearMember2021-12-310001655891trmd:VesselMemberifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMember2021-12-310001655891trmd:VesselMemberifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMember2021-12-310001655891trmd:VesselMemberifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMember2021-12-310001655891trmd:VesselMemberifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMember2021-12-310001655891trmd:VesselMemberifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMember2021-12-310001655891trmd:VesselMember2021-12-310001655891trmd:VesselMember2020-12-310001655891trmd:TreasurySharesAtNominalValueMember2022-12-310001655891trmd:TreasurySharesAtNominalValueMember2021-12-310001655891trmd:TreasurySharesAtNominalValueMember2020-12-310001655891trmd:TreasurySharesAtNominalValueMember2019-12-310001655891ifrs-full:GrossCarryingAmountMembertrmd:LessThanOneMonthMember2022-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LaterThanSixMonthsMember2022-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LaterThanOneMonthAndNotLaterThanSixMonthsMember2022-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:CurrentMember2022-12-310001655891ifrs-full:GrossCarryingAmountMembertrmd:LessThanOneMonthMember2021-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LaterThanSixMonthsMember2021-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LaterThanOneMonthAndNotLaterThanSixMonthsMember2021-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:CurrentMember2021-12-310001655891ifrs-full:GrossCarryingAmountMembertrmd:LessThanOneMonthMember2020-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LaterThanSixMonthsMember2020-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LaterThanOneMonthAndNotLaterThanSixMonthsMember2020-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:CurrentMember2020-12-310001655891ifrs-full:JointVenturesMember2022-01-012022-08-310001655891ifrs-full:JointVenturesMember2021-01-012021-12-310001655891ifrs-full:JointVenturesMember2020-01-012020-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:OtherPropertyPlantAndEquipmentMember2022-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LandAndBuildingsMember2022-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:OtherPropertyPlantAndEquipmentMember2022-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:LandAndBuildingsMember2022-12-310001655891ifrs-full:OtherPropertyPlantAndEquipmentMember2022-12-310001655891ifrs-full:LandAndBuildingsMember2022-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:OtherPropertyPlantAndEquipmentMember2021-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LandAndBuildingsMember2021-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:OtherPropertyPlantAndEquipmentMember2021-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:LandAndBuildingsMember2021-12-310001655891ifrs-full:OtherPropertyPlantAndEquipmentMember2021-12-310001655891ifrs-full:LandAndBuildingsMember2021-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:OtherPropertyPlantAndEquipmentMember2020-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LandAndBuildingsMember2020-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:OtherPropertyPlantAndEquipmentMember2020-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:LandAndBuildingsMember2020-12-310001655891ifrs-full:OtherPropertyPlantAndEquipmentMember2020-12-310001655891ifrs-full:LandAndBuildingsMember2020-12-310001655891ifrs-full:GrossCarryingAmountMembertrmd:VesselsAndCapitalizedDryDockingMember2019-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:OtherPropertyPlantAndEquipmentMember2019-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LandAndBuildingsMember2019-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMembertrmd:VesselsAndCapitalizedDryDockingMember2019-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:OtherPropertyPlantAndEquipmentMember2019-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:LandAndBuildingsMember2019-12-310001655891trmd:WeldingAndMountingMember2022-01-012022-12-310001655891trmd:TransportationOfRefinedOilProductsMember2022-01-012022-12-310001655891trmd:ScrubbersAndRelatedServiceMember2022-01-012022-12-310001655891trmd:OthersMember2022-01-012022-12-310001655891ifrs-full:OperatingSegmentsMembertrmd:TankMember2021-01-012021-12-310001655891trmd:TransportationOfRefinedOilProductsMember2021-01-012021-12-310001655891ifrs-full:OperatingSegmentsMembertrmd:TankMember2020-01-012020-12-310001655891trmd:TransportationOfRefinedOilProductsMember2020-01-012020-12-310001655891trmd:ForwardFreightAgreementsMembertrmd:HedgingReserveMember2022-12-310001655891trmd:ForwardExchangeContractMembertrmd:HedgingReserveMember2022-12-310001655891trmd:BunkerSwapContractsMembertrmd:HedgingReserveMember2022-12-310001655891ifrs-full:InterestRateSwapContractMembertrmd:HedgingReserveMember2022-12-310001655891trmd:HedgingReserveMember2022-12-310001655891trmd:ForwardFreightAgreementsMembertrmd:HedgingReserveMember2021-12-310001655891trmd:ForwardExchangeContractMembertrmd:HedgingReserveMember2021-12-310001655891trmd:BunkerSwapContractsMembertrmd:HedgingReserveMember2021-12-310001655891ifrs-full:InterestRateSwapContractMembertrmd:HedgingReserveMember2021-12-310001655891trmd:HedgingReserveMember2021-12-310001655891trmd:ForwardFreightAgreementsMembertrmd:HedgingReserveMember2020-12-310001655891trmd:ForwardExchangeContractMembertrmd:HedgingReserveMember2020-12-310001655891trmd:BunkerSwapContractsMembertrmd:HedgingReserveMember2020-12-310001655891ifrs-full:InterestRateSwapContractMembertrmd:HedgingReserveMember2020-12-310001655891trmd:HedgingReserveMember2020-12-310001655891trmd:MainFleetMember2022-12-310001655891trmd:TreasurySharesAtNominalValueMember2022-01-012022-12-310001655891trmd:TreasurySharesAtNominalValueMember2021-01-012021-12-310001655891trmd:TreasurySharesAtNominalValueMember2020-01-012020-12-310001655891trmd:MarineExhaustTechnologyLtdMember2022-08-312022-08-310001655891ifrs-full:GrossCarryingAmountMembertrmd:VesselsAndCapitalizedDryDockingMember2022-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:OtherPropertyPlantAndEquipmentMember2022-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LandAndBuildingsMember2022-12-310001655891ifrs-full:AccumulatedImpairmentMembertrmd:VesselsAndCapitalizedDryDockingMember2022-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMembertrmd:VesselsAndCapitalizedDryDockingMember2022-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:OtherPropertyPlantAndEquipmentMember2022-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:LandAndBuildingsMember2022-12-310001655891trmd:VesselsMember2022-12-310001655891trmd:VesselsAndCapitalizedDryDockingMember2022-12-310001655891ifrs-full:OtherPropertyPlantAndEquipmentMember2022-12-310001655891ifrs-full:LandAndBuildingsMember2022-12-310001655891ifrs-full:GrossCarryingAmountMembertrmd:VesselsAndCapitalizedDryDockingMember2021-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:OtherPropertyPlantAndEquipmentMember2021-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LandAndBuildingsMember2021-12-310001655891ifrs-full:AccumulatedImpairmentMembertrmd:VesselsAndCapitalizedDryDockingMember2021-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMembertrmd:VesselsAndCapitalizedDryDockingMember2021-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:OtherPropertyPlantAndEquipmentMember2021-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:LandAndBuildingsMember2021-12-310001655891trmd:VesselsMember2021-12-310001655891trmd:VesselsAndCapitalizedDryDockingMember2021-12-310001655891ifrs-full:OtherPropertyPlantAndEquipmentMember2021-12-310001655891ifrs-full:LandAndBuildingsMember2021-12-310001655891ifrs-full:GrossCarryingAmountMembertrmd:VesselsAndCapitalizedDryDockingMember2020-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:OtherPropertyPlantAndEquipmentMember2020-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LandAndBuildingsMember2020-12-310001655891ifrs-full:AccumulatedImpairmentMembertrmd:VesselsAndCapitalizedDryDockingMember2020-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMembertrmd:VesselsAndCapitalizedDryDockingMember2020-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:OtherPropertyPlantAndEquipmentMember2020-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:LandAndBuildingsMember2020-12-310001655891trmd:VesselsMember2020-12-310001655891trmd:VesselsAndCapitalizedDryDockingMember2020-12-310001655891ifrs-full:OtherPropertyPlantAndEquipmentMember2020-12-310001655891ifrs-full:LandAndBuildingsMember2020-12-310001655891ifrs-full:GrossCarryingAmountMembertrmd:VesselsAndCapitalizedDryDockingMember2019-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:OtherPropertyPlantAndEquipmentMember2019-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LandAndBuildingsMember2019-12-310001655891ifrs-full:AccumulatedImpairmentMembertrmd:VesselsAndCapitalizedDryDockingMember2019-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMembertrmd:VesselsAndCapitalizedDryDockingMember2019-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:OtherPropertyPlantAndEquipmentMember2019-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:LandAndBuildingsMember2019-12-310001655891trmd:MarineExhaustTechnologyAsMember2022-01-012022-12-310001655891trmd:MarineExhaustTechnologyAsMember2022-09-012022-12-310001655891trmd:CustomerOneMemberifrs-full:OperatingSegmentsMembertrmd:TankMember2022-01-012022-12-310001655891country:MX2022-01-012022-12-310001655891country:CH2022-01-012022-12-310001655891trmd:CustomerOneMemberifrs-full:OperatingSegmentsMembertrmd:TankMember2021-01-012021-12-310001655891country:MX2021-01-012021-12-310001655891country:CH2021-01-012021-12-310001655891trmd:CustomerOneMemberifrs-full:BottomOfRangeMemberifrs-full:OperatingSegmentsMembertrmd:TankMember2020-01-012020-12-310001655891ifrs-full:BottomOfRangeMember2020-01-012020-12-310001655891country:US2020-01-012020-12-310001655891country:MX2020-01-012020-12-310001655891country:CH2020-01-012020-12-310001655891trmd:MrEcoProductTankerVesselsMemberifrs-full:MajorPurchasesOfAssetsMember2023-03-160001655891trmd:CommonClassCSharesMember2022-12-310001655891trmd:CommonClassBSharesMember2022-12-310001655891trmd:CommonClassASharesMember2022-12-310001655891trmd:CommonClassCSharesMember2021-12-310001655891trmd:CommonClassBSharesMember2021-12-310001655891trmd:CommonClassASharesMember2021-12-310001655891trmd:CommonClassCSharesMember2020-12-310001655891trmd:CommonClassBSharesMember2020-12-310001655891trmd:CommonClassASharesMember2020-12-310001655891trmd:LongTermIncentivePlanMember2022-12-310001655891trmd:LongTermIncentivePlanMember2021-12-310001655891trmd:LongTermIncentivePlanMember2020-12-310001655891trmd:LongTermIncentivePlanMember2019-12-310001655891trmd:LongTermIncentivePlanMembertrmd:JacobMeldgaardMember2022-03-232022-03-230001655891trmd:ChiefExecutiveOfficerCEOMembertrmd:RsuGrantIn2022Member2022-03-232022-03-230001655891trmd:OtherManagementMembertrmd:RsuGrantIn2022Member2022-01-012022-12-310001655891trmd:LongTermIncentivePlanMember2022-01-012022-12-310001655891trmd:LongTermIncentivePlanMembertrmd:JacobMeldgaardMember2021-03-182021-03-180001655891trmd:ChiefExecutiveOfficerCEOMembertrmd:RsuGrantIn2021Member2021-03-182021-03-180001655891trmd:OtherManagementMembertrmd:RsuGrantIn2021Member2021-01-012021-12-310001655891trmd:LongTermIncentivePlanMember2021-01-012021-12-310001655891trmd:OtherManagementMembertrmd:RsuGrantIn2020Member2020-01-012020-12-310001655891trmd:LongTermIncentivePlanMember2020-01-012020-12-310001655891trmd:LongTermIncentivePlanMembertrmd:JacobMeldgaardMember2018-04-252018-04-250001655891trmd:TwoNewBankFacilitiesMembertrmd:BankAndLeasingAgreementsMember2023-03-160001655891trmd:CreditToFinanceAdditionalSecondhandVesselsMembertrmd:BankAndLeasingAgreementsMember2023-03-160001655891trmd:WorkingCapitalFacilityMember2022-12-310001655891trmd:UnspecifiedTermFacilityAgreementIMember2022-12-310001655891trmd:UnspecifiedTermFacilityAgreementIiMember2022-12-310001655891trmd:TermFacilityAgreementWithKfwIpexBankMember2022-12-310001655891trmd:TermFacilityAgreementWithHamburgCommercialBankMember2022-12-310001655891trmd:TermFacilityAgreementWithDanishShipFinanceMember2022-12-310001655891trmd:TermFacilityAgreementWithChinaExportImportBankMember2022-12-310001655891trmd:SyndicatedFacilitiesAgreementMember2022-12-310001655891trmd:RevolvingCreditFacilityIMember2022-12-310001655891trmd:RevolvingCreditFacilitiesMember2022-12-310001655891trmd:OtherCountriesMember2022-12-310001655891country:SG2022-12-310001655891country:GB2022-12-310001655891country:DK2022-12-310001655891trmd:OtherCountriesMember2021-12-310001655891country:SG2021-12-310001655891country:DK2021-12-310001655891trmd:OtherCountriesMember2020-12-310001655891country:SG2020-12-310001655891country:GB2020-12-310001655891country:DK2020-12-310001655891ifrs-full:InterestRateSwapContractMembertrmd:LaterThanTwoYearsMemberifrs-full:CashFlowHedgesMember2022-12-310001655891ifrs-full:InterestRateSwapContractMemberifrs-full:NotLaterThanOneYearMemberifrs-full:CashFlowHedgesMember2022-12-310001655891ifrs-full:InterestRateSwapContractMemberifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMemberifrs-full:CashFlowHedgesMember2022-12-310001655891ifrs-full:InterestRateSwapContractMemberifrs-full:CashFlowHedgesMembertrmd:UsdLiborMember2022-12-310001655891ifrs-full:ForwardContractMemberifrs-full:NotLaterThanOneYearMemberifrs-full:CashFlowHedgesMember2022-12-310001655891ifrs-full:ForwardContractMemberifrs-full:CashFlowHedgesMember2022-12-310001655891ifrs-full:InterestRateSwapContractMembertrmd:LaterThanTwoYearsMemberifrs-full:CashFlowHedgesMember2021-12-310001655891ifrs-full:InterestRateSwapContractMemberifrs-full:NotLaterThanOneYearMemberifrs-full:CashFlowHedgesMember2021-12-310001655891ifrs-full:InterestRateSwapContractMemberifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMemberifrs-full:CashFlowHedgesMember2021-12-310001655891ifrs-full:InterestRateSwapContractMemberifrs-full:CashFlowHedgesMembertrmd:UsdLiborMember2021-12-310001655891ifrs-full:ForwardContractMemberifrs-full:NotLaterThanOneYearMemberifrs-full:CashFlowHedgesMember2021-12-310001655891ifrs-full:ForwardContractMemberifrs-full:CashFlowHedgesMember2021-12-310001655891ifrs-full:InterestRateSwapContractMembertrmd:LaterThanTwoYearsMemberifrs-full:CashFlowHedgesMember2020-12-310001655891ifrs-full:InterestRateSwapContractMemberifrs-full:NotLaterThanOneYearMemberifrs-full:CashFlowHedgesMember2020-12-310001655891ifrs-full:InterestRateSwapContractMemberifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMemberifrs-full:CashFlowHedgesMember2020-12-310001655891ifrs-full:InterestRateSwapContractMemberifrs-full:CashFlowHedgesMembertrmd:UsdLiborMember2020-12-310001655891ifrs-full:ForwardContractMemberifrs-full:NotLaterThanOneYearMemberifrs-full:CashFlowHedgesMember2020-12-310001655891ifrs-full:ForwardContractMemberifrs-full:CashFlowHedgesMember2020-12-310001655891ifrs-full:LongtermBorrowingsMember2022-12-310001655891ifrs-full:LongtermBorrowingsMember2021-12-310001655891ifrs-full:LongtermBorrowingsMember2020-12-310001655891ifrs-full:LongtermBorrowingsMember2019-12-310001655891ifrs-full:LegalProceedingsProvisionMember2022-12-310001655891trmd:ScrubberInstallationsMembertrmd:BocommFacilityMemberifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMember2022-12-310001655891trmd:NewbuildingLr2VesselMembertrmd:BocommFacilityMembertrmd:UnspecifiedMaturityMember2022-12-310001655891trmd:ThreeLrTwoVesselsMembertrmd:UnspecifiedMaturityMember2022-12-310001655891trmd:BocommFacilityMemberifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMember2022-12-310001655891ifrs-full:CashFlowHedgesMemberifrs-full:FixedInterestRateMember2022-12-310001655891trmd:JapaneseLeasingProvidersMember2022-12-310001655891trmd:ChinaMerchantBankFinancialLeasingMember2022-12-310001655891trmd:ChinaDevelopmentBankFinancialLeasingMember2022-12-310001655891trmd:BocommFacilityMember2022-12-310001655891ifrs-full:FixedInterestRateMember2022-12-310001655891trmd:GoranTrappMember2022-01-012022-12-310001655891trmd:DavidWeinsteinMember2022-01-012022-12-310001655891trmd:ChristopherHBoehringerMember2022-01-012022-12-310001655891trmd:AnnetteMalmJustadMember2022-01-012022-12-310001655891trmd:GoranTrappMember2021-01-012021-12-310001655891trmd:DavidWeinsteinMember2021-01-012021-12-310001655891trmd:ChristopherHBoehringerMember2021-01-012021-12-310001655891trmd:AnnetteMalmJustadMember2021-01-012021-12-310001655891trmd:TorbenJanholtMember2020-01-012020-12-310001655891trmd:GoranTrappMember2020-01-012020-12-310001655891trmd:DavidWeinsteinMember2020-01-012020-12-310001655891trmd:ChristopherHBoehringerMember2020-01-012020-12-310001655891trmd:AnnetteMalmJustadMember2020-01-012020-12-310001655891trmd:SeniorManagementTeamMember2022-01-012022-12-310001655891trmd:SeniorManagementTeamMember2021-01-012021-12-310001655891trmd:SeniorManagementTeamMember2020-01-012020-12-310001655891trmd:CommonClassASharesMemberifrs-full:IssuedCapitalMember2022-01-012022-12-310001655891trmd:CommonClassASharesMemberifrs-full:IssuedCapitalMember2021-01-012021-12-310001655891trmd:CommonClassASharesMemberifrs-full:IssuedCapitalMember2020-01-012020-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMember2022-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:PropertyPlantAndEquipmentSubjectToOperatingLeasesMember2022-01-012022-12-310001655891ifrs-full:LongtermBorrowingsMember2021-01-012021-12-310001655891ifrs-full:LongtermBorrowingsMember2020-01-012020-12-310001655891ifrs-full:LongtermBorrowingsMember2022-01-012022-12-310001655891trmd:CommonClassASharesMember2022-01-012022-12-310001655891trmd:CommonClassASharesMember2021-01-012021-12-310001655891trmd:CommonClassASharesMember2020-01-012020-12-310001655891trmd:HandySizeMember2020-01-012020-12-310001655891ifrs-full:NoncurrentAssetsHeldForSaleMember2021-01-012021-12-310001655891ifrs-full:AccumulatedImpairmentMember2022-01-012022-12-310001655891ifrs-full:AccumulatedImpairmentMember2021-01-012021-12-310001655891ifrs-full:AccumulatedImpairmentMember2020-01-012020-12-310001655891trmd:TotalTankerFleetMember2022-01-012022-12-310001655891trmd:TotalTankerFleetMember2021-01-012021-12-310001655891ifrs-full:InterestRateSwapContractMemberifrs-full:CashFlowHedgesMember2022-12-310001655891ifrs-full:NotLaterThanOneYearMemberifrs-full:BottomOfRangeMember2022-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanFiveYearsMember2022-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanFiveYearsMember2021-12-310001655891ifrs-full:LaterThanFiveYearsMember2021-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanFiveYearsMember2020-12-310001655891ifrs-full:LaterThanFiveYearsMember2020-12-310001655891ifrs-full:GrossCarryingAmountMember2022-12-310001655891ifrs-full:AccumulatedImpairmentMember2022-12-310001655891ifrs-full:GrossCarryingAmountMember2021-12-310001655891ifrs-full:AccumulatedImpairmentMember2021-12-310001655891ifrs-full:GrossCarryingAmountMember2020-12-310001655891ifrs-full:AccumulatedImpairmentMember2020-12-310001655891ifrs-full:GrossCarryingAmountMember2019-12-310001655891ifrs-full:AccumulatedImpairmentMember2019-12-310001655891ifrs-full:NoncurrentAssetsHeldForSaleMember2022-01-012022-12-310001655891ifrs-full:NoncurrentAssetsHeldForSaleMember2020-01-012020-12-310001655891trmd:RevenueMembertrmd:ForwardFreightAgreementsMember2022-01-012022-12-310001655891trmd:RevenueMembertrmd:ForwardExchangeContractMember2022-01-012022-12-310001655891trmd:RevenueMemberifrs-full:InterestRateSwapContractMember2022-01-012022-12-310001655891trmd:PortExpensesBunkersAndCommissionsMembertrmd:ForwardFreightAgreementsMember2022-01-012022-12-310001655891trmd:PortExpensesBunkersAndCommissionsMembertrmd:ForwardExchangeContractMember2022-01-012022-12-310001655891trmd:PortExpensesBunkersAndCommissionsMembertrmd:BunkerSwapContractsMember2022-01-012022-12-310001655891trmd:PortExpensesBunkersAndCommissionsMemberifrs-full:InterestRateSwapContractMember2022-01-012022-12-310001655891trmd:OperatingExpensesMembertrmd:ForwardFreightAgreementsMember2022-01-012022-12-310001655891trmd:OperatingExpensesMembertrmd:ForwardExchangeContractMember2022-01-012022-12-310001655891trmd:OperatingExpensesMembertrmd:BunkerSwapContractsMember2022-01-012022-12-310001655891trmd:OperatingExpensesMemberifrs-full:InterestRateSwapContractMember2022-01-012022-12-310001655891trmd:FinancialItemMembertrmd:ForwardFreightAgreementsMember2022-01-012022-12-310001655891trmd:FinancialItemMembertrmd:ForwardExchangeContractMember2022-01-012022-12-310001655891trmd:FinancialItemMembertrmd:BunkerSwapContractsMember2022-01-012022-12-310001655891trmd:FinancialItemMemberifrs-full:InterestRateSwapContractMember2022-01-012022-12-310001655891trmd:AdministrativeExpensesMembertrmd:ForwardFreightAgreementsMember2022-01-012022-12-310001655891trmd:AdministrativeExpensesMembertrmd:ForwardExchangeContractMember2022-01-012022-12-310001655891trmd:AdministrativeExpensesMembertrmd:BunkerSwapContractsMember2022-01-012022-12-310001655891trmd:RevenueMember2022-01-012022-12-310001655891trmd:PortExpensesBunkersAndCommissionsMember2022-01-012022-12-310001655891trmd:FinancialItemMember2022-01-012022-12-310001655891trmd:RevenueMembertrmd:ForwardFreightAgreementsMember2021-01-012021-12-310001655891trmd:RevenueMembertrmd:ForwardExchangeContractMember2021-01-012021-12-310001655891trmd:RevenueMembertrmd:BunkerSwapContractsMember2021-01-012021-12-310001655891trmd:RevenueMemberifrs-full:InterestRateSwapContractMember2021-01-012021-12-310001655891trmd:PortExpensesBunkersAndCommissionsMembertrmd:ForwardFreightAgreementsMember2021-01-012021-12-310001655891trmd:PortExpensesBunkersAndCommissionsMembertrmd:ForwardExchangeContractMember2021-01-012021-12-310001655891trmd:PortExpensesBunkersAndCommissionsMembertrmd:BunkerSwapContractsMember2021-01-012021-12-310001655891trmd:PortExpensesBunkersAndCommissionsMemberifrs-full:InterestRateSwapContractMember2021-01-012021-12-310001655891trmd:OperatingExpensesMembertrmd:ForwardFreightAgreementsMember2021-01-012021-12-310001655891trmd:OperatingExpensesMembertrmd:ForwardExchangeContractMember2021-01-012021-12-310001655891trmd:OperatingExpensesMembertrmd:BunkerSwapContractsMember2021-01-012021-12-310001655891trmd:OperatingExpensesMemberifrs-full:InterestRateSwapContractMember2021-01-012021-12-310001655891trmd:FinancialItemMembertrmd:ForwardFreightAgreementsMember2021-01-012021-12-310001655891trmd:FinancialItemMembertrmd:ForwardExchangeContractMember2021-01-012021-12-310001655891trmd:FinancialItemMembertrmd:BunkerSwapContractsMember2021-01-012021-12-310001655891trmd:FinancialItemMemberifrs-full:InterestRateSwapContractMember2021-01-012021-12-310001655891trmd:AdministrativeExpensesMembertrmd:ForwardFreightAgreementsMember2021-01-012021-12-310001655891trmd:AdministrativeExpensesMembertrmd:ForwardExchangeContractMember2021-01-012021-12-310001655891trmd:AdministrativeExpensesMemberifrs-full:InterestRateSwapContractMember2021-01-012021-12-310001655891trmd:RevenueMember2021-01-012021-12-310001655891trmd:PortExpensesBunkersAndCommissionsMember2021-01-012021-12-310001655891trmd:FinancialItemMember2021-01-012021-12-310001655891trmd:RevenueMembertrmd:ForwardFreightAgreementsMember2020-01-012020-12-310001655891trmd:RevenueMembertrmd:ForwardExchangeContractMember2020-01-012020-12-310001655891trmd:RevenueMembertrmd:BunkerSwapContractsMember2020-01-012020-12-310001655891trmd:RevenueMemberifrs-full:InterestRateSwapContractMember2020-01-012020-12-310001655891trmd:PortExpensesBunkersAndCommissionsMembertrmd:ForwardFreightAgreementsMember2020-01-012020-12-310001655891trmd:PortExpensesBunkersAndCommissionsMembertrmd:ForwardExchangeContractMember2020-01-012020-12-310001655891trmd:PortExpensesBunkersAndCommissionsMembertrmd:BunkerSwapContractsMember2020-01-012020-12-310001655891trmd:PortExpensesBunkersAndCommissionsMemberifrs-full:InterestRateSwapContractMember2020-01-012020-12-310001655891trmd:OperatingExpensesMembertrmd:ForwardFreightAgreementsMember2020-01-012020-12-310001655891trmd:OperatingExpensesMembertrmd:ForwardExchangeContractMember2020-01-012020-12-310001655891trmd:OperatingExpensesMembertrmd:BunkerSwapContractsMember2020-01-012020-12-310001655891trmd:OperatingExpensesMemberifrs-full:InterestRateSwapContractMember2020-01-012020-12-310001655891trmd:FinancialItemMembertrmd:ForwardFreightAgreementsMember2020-01-012020-12-310001655891trmd:FinancialItemMembertrmd:ForwardExchangeContractMember2020-01-012020-12-310001655891trmd:FinancialItemMembertrmd:BunkerSwapContractsMember2020-01-012020-12-310001655891trmd:FinancialItemMemberifrs-full:InterestRateSwapContractMember2020-01-012020-12-310001655891trmd:AdministrativeExpensesMembertrmd:ForwardFreightAgreementsMember2020-01-012020-12-310001655891trmd:AdministrativeExpensesMembertrmd:ForwardExchangeContractMember2020-01-012020-12-310001655891trmd:AdministrativeExpensesMemberifrs-full:InterestRateSwapContractMember2020-01-012020-12-310001655891trmd:RevenueMember2020-01-012020-12-310001655891trmd:PortExpensesBunkersAndCommissionsMember2020-01-012020-12-310001655891trmd:FinancialItemMember2020-01-012020-12-310001655891trmd:ForwardFreightAgreementsMember2022-01-012022-12-310001655891trmd:ForwardExchangeContractMember2022-01-012022-12-310001655891trmd:BunkerSwapContractsMember2022-01-012022-12-310001655891ifrs-full:InterestRateSwapContractMember2022-01-012022-12-310001655891trmd:ForwardFreightAgreementsMember2021-01-012021-12-310001655891trmd:ForwardExchangeContractMember2021-01-012021-12-310001655891trmd:BunkerSwapContractsMember2021-01-012021-12-310001655891ifrs-full:InterestRateSwapContractMember2021-01-012021-12-310001655891trmd:ForwardFreightAgreementsMember2020-01-012020-12-310001655891trmd:ForwardExchangeContractMember2020-01-012020-12-310001655891trmd:BunkerSwapContractsMember2020-01-012020-12-310001655891ifrs-full:InterestRateSwapContractMember2020-01-012020-12-310001655891trmd:FinancialLiabilitiesMeasuredAtFairValueMembertrmd:OtherLiabilityMemberifrs-full:Level2OfFairValueHierarchyMember2022-12-310001655891trmd:FinancialLiabilitiesMeasuredAtFairValueMembertrmd:OtherLiabilityMember2022-12-310001655891trmd:FinancialLiabilitiesMeasuredAtFairValueMemberifrs-full:Level2OfFairValueHierarchyMember2022-12-310001655891ifrs-full:FinancialLiabilitiesAtAmortisedCostCategoryMembertrmd:TradePayablesMember2022-12-310001655891ifrs-full:FinancialLiabilitiesAtAmortisedCostCategoryMembertrmd:OtherNonCurrentLiabilityMember2022-12-310001655891ifrs-full:FinancialLiabilitiesAtAmortisedCostCategoryMembertrmd:OtherLiabilityMember2022-12-310001655891ifrs-full:FinancialLiabilitiesAtAmortisedCostCategoryMembertrmd:BorrowingsMember2022-12-310001655891trmd:TradePayablesMember2022-12-310001655891trmd:OtherNonCurrentLiabilityMember2022-12-310001655891trmd:OtherLiabilityMember2022-12-310001655891trmd:FinancialLiabilitiesMeasuredAtFairValueMember2022-12-310001655891trmd:BorrowingsMember2022-12-310001655891ifrs-full:FinancialLiabilitiesAtAmortisedCostCategoryMember2022-12-310001655891trmd:FinancialLiabilitiesMeasuredAtFairValueMembertrmd:OtherLiabilityMemberifrs-full:Level2OfFairValueHierarchyMember2021-12-310001655891trmd:FinancialLiabilitiesMeasuredAtFairValueMembertrmd:OtherLiabilityMember2021-12-310001655891trmd:FinancialLiabilitiesMeasuredAtFairValueMemberifrs-full:Level2OfFairValueHierarchyMember2021-12-310001655891ifrs-full:FinancialLiabilitiesAtAmortisedCostCategoryMembertrmd:TradePayablesMember2021-12-310001655891ifrs-full:FinancialLiabilitiesAtAmortisedCostCategoryMembertrmd:OtherLiabilityMember2021-12-310001655891ifrs-full:FinancialLiabilitiesAtAmortisedCostCategoryMembertrmd:BorrowingsMember2021-12-310001655891trmd:TradePayablesMember2021-12-310001655891trmd:OtherLiabilityMember2021-12-310001655891trmd:FinancialLiabilitiesMeasuredAtFairValueMember2021-12-310001655891trmd:BorrowingsMember2021-12-310001655891ifrs-full:FinancialLiabilitiesAtAmortisedCostCategoryMember2021-12-310001655891trmd:FinancialLiabilitiesMeasuredAtFairValueMembertrmd:OtherLiabilityMemberifrs-full:Level2OfFairValueHierarchyMember2020-12-310001655891trmd:FinancialLiabilitiesMeasuredAtFairValueMembertrmd:OtherLiabilityMember2020-12-310001655891trmd:FinancialLiabilitiesMeasuredAtFairValueMemberifrs-full:Level2OfFairValueHierarchyMember2020-12-310001655891ifrs-full:FinancialLiabilitiesAtAmortisedCostCategoryMembertrmd:TradePayablesMember2020-12-310001655891ifrs-full:FinancialLiabilitiesAtAmortisedCostCategoryMembertrmd:OtherLiabilityMember2020-12-310001655891ifrs-full:FinancialLiabilitiesAtAmortisedCostCategoryMembertrmd:BorrowingsMember2020-12-310001655891trmd:TradePayablesMember2020-12-310001655891trmd:OtherLiabilityMember2020-12-310001655891trmd:FinancialLiabilitiesMeasuredAtFairValueMember2020-12-310001655891trmd:BorrowingsMember2020-12-310001655891ifrs-full:FinancialLiabilitiesAtAmortisedCostCategoryMember2020-12-310001655891trmd:FinancialAssetsMeasuredAtFairValueMembertrmd:OtherReceivablesMemberifrs-full:Level2OfFairValueHierarchyMember2022-12-310001655891trmd:FinancialAssetsMeasuredAtFairValueMembertrmd:OtherReceivablesMember2022-12-310001655891trmd:FinancialAssetsMeasuredAtFairValueMemberifrs-full:Level2OfFairValueHierarchyMember2022-12-310001655891ifrs-full:FinancialAssetsAtAmortisedCostCategoryMembertrmd:TradeReceivableMember2022-12-310001655891ifrs-full:FinancialAssetsAtAmortisedCostCategoryMembertrmd:OtherReceivablesMember2022-12-310001655891ifrs-full:FinancialAssetsAtAmortisedCostCategoryMembertrmd:CashAndCashEquivalentMember2022-12-310001655891ifrs-full:FinancialAssetsAtAmortisedCostCategoryMemberifrs-full:LoansAndReceivablesCategoryMember2022-12-310001655891trmd:TradeReceivableMember2022-12-310001655891trmd:OtherReceivablesMember2022-12-310001655891trmd:FinancialAssetsMeasuredAtFairValueMember2022-12-310001655891trmd:CashAndCashEquivalentMember2022-12-310001655891ifrs-full:LoansAndReceivablesCategoryMember2022-12-310001655891ifrs-full:FinancialAssetsAtAmortisedCostCategoryMember2022-12-310001655891trmd:FinancialAssetsMeasuredAtFairValueMembertrmd:OtherReceivablesMemberifrs-full:Level2OfFairValueHierarchyMember2021-12-310001655891trmd:FinancialAssetsMeasuredAtFairValueMembertrmd:OtherReceivablesMember2021-12-310001655891trmd:FinancialAssetsMeasuredAtFairValueMemberifrs-full:Level2OfFairValueHierarchyMember2021-12-310001655891ifrs-full:FinancialAssetsAtAmortisedCostCategoryMembertrmd:TradeReceivableMember2021-12-310001655891ifrs-full:FinancialAssetsAtAmortisedCostCategoryMembertrmd:OtherReceivablesMember2021-12-310001655891ifrs-full:FinancialAssetsAtAmortisedCostCategoryMembertrmd:CashAndCashEquivalentMember2021-12-310001655891ifrs-full:FinancialAssetsAtAmortisedCostCategoryMemberifrs-full:LoansAndReceivablesCategoryMember2021-12-310001655891trmd:TradeReceivableMember2021-12-310001655891trmd:OtherReceivablesMember2021-12-310001655891trmd:FinancialAssetsMeasuredAtFairValueMember2021-12-310001655891trmd:CashAndCashEquivalentMember2021-12-310001655891ifrs-full:LoansAndReceivablesCategoryMember2021-12-310001655891ifrs-full:FinancialAssetsAtAmortisedCostCategoryMember2021-12-310001655891trmd:FinancialAssetsMeasuredAtFairValueMembertrmd:OtherReceivablesMemberifrs-full:Level2OfFairValueHierarchyMember2020-12-310001655891trmd:FinancialAssetsMeasuredAtFairValueMembertrmd:OtherReceivablesMember2020-12-310001655891trmd:FinancialAssetsMeasuredAtFairValueMemberifrs-full:Level2OfFairValueHierarchyMember2020-12-310001655891ifrs-full:FinancialAssetsAtAmortisedCostCategoryMembertrmd:TradeReceivableMember2020-12-310001655891ifrs-full:FinancialAssetsAtAmortisedCostCategoryMembertrmd:OtherReceivablesMember2020-12-310001655891ifrs-full:FinancialAssetsAtAmortisedCostCategoryMembertrmd:CashAndCashEquivalentMember2020-12-310001655891ifrs-full:FinancialAssetsAtAmortisedCostCategoryMemberifrs-full:LoansAndReceivablesCategoryMember2020-12-310001655891trmd:TradeReceivableMember2020-12-310001655891trmd:OtherReceivablesMember2020-12-310001655891trmd:FinancialAssetsMeasuredAtFairValueMember2020-12-310001655891trmd:CashAndCashEquivalentMember2020-12-310001655891ifrs-full:LoansAndReceivablesCategoryMember2020-12-310001655891ifrs-full:FinancialAssetsAtAmortisedCostCategoryMember2020-12-310001655891ifrs-full:TopOfRangeMember2021-12-310001655891ifrs-full:TopOfRangeMember2020-12-310001655891ifrs-full:LaterThanSixMonthsAndNotLaterThanOneYearMemberifrs-full:TopOfRangeMember2022-12-310001655891ifrs-full:LaterThanSixMonthsAndNotLaterThanOneYearMemberifrs-full:BottomOfRangeMember2022-12-310001655891ifrs-full:LaterThanOneYearMember2022-12-310001655891ifrs-full:TreasurySharesMember2022-12-310001655891ifrs-full:SharePremiumMember2022-12-310001655891ifrs-full:RetainedEarningsMember2022-12-310001655891ifrs-full:ReserveOfExchangeDifferencesOnTranslationMember2022-12-310001655891ifrs-full:ReserveOfCashFlowHedgesMember2022-12-310001655891ifrs-full:NoncontrollingInterestsMember2022-12-310001655891ifrs-full:IssuedCapitalMember2022-12-310001655891ifrs-full:EquityAttributableToOwnersOfParentMember2022-12-310001655891ifrs-full:TreasurySharesMember2021-12-310001655891ifrs-full:SharePremiumMember2021-12-310001655891ifrs-full:RetainedEarningsMember2021-12-310001655891ifrs-full:ReserveOfExchangeDifferencesOnTranslationMember2021-12-310001655891ifrs-full:ReserveOfCashFlowHedgesMember2021-12-310001655891ifrs-full:IssuedCapitalMember2021-12-310001655891ifrs-full:EquityAttributableToOwnersOfParentMember2021-12-310001655891ifrs-full:TreasurySharesMember2020-12-310001655891ifrs-full:SharePremiumMember2020-12-310001655891ifrs-full:RetainedEarningsMember2020-12-310001655891ifrs-full:ReserveOfExchangeDifferencesOnTranslationMember2020-12-310001655891ifrs-full:ReserveOfCashFlowHedgesMember2020-12-310001655891ifrs-full:IssuedCapitalMember2020-12-310001655891ifrs-full:EquityAttributableToOwnersOfParentMember2020-12-310001655891ifrs-full:TreasurySharesMember2019-12-310001655891ifrs-full:SharePremiumMember2019-12-310001655891ifrs-full:RetainedEarningsMember2019-12-310001655891ifrs-full:ReserveOfExchangeDifferencesOnTranslationMember2019-12-310001655891ifrs-full:ReserveOfCashFlowHedgesMember2019-12-310001655891ifrs-full:IssuedCapitalMember2019-12-310001655891ifrs-full:EquityAttributableToOwnersOfParentMember2019-12-310001655891trmd:OperatingExpensesMember2022-01-012022-12-310001655891trmd:AdministrativeExpensesMember2022-01-012022-12-310001655891trmd:OperatingExpensesMember2021-01-012021-12-310001655891trmd:AdministrativeExpensesMember2021-01-012021-12-310001655891trmd:OperatingExpensesMember2020-01-012020-12-310001655891trmd:AdministrativeExpensesMember2020-01-012020-12-310001655891trmd:ChiefExecutiveOfficerCEOMember2022-01-012022-12-310001655891trmd:TormPlcMembertrmd:RsuGrantIn2022Membertrmd:JacobMeldgaardMember2022-01-012022-12-310001655891trmd:TormAsMembertrmd:RsuGrantIn2022Membertrmd:JacobMeldgaardMember2022-01-012022-12-310001655891trmd:TormPlcMembertrmd:JacobMeldgaardMember2021-01-012021-12-310001655891trmd:TormAsMembertrmd:JacobMeldgaardMember2021-01-012021-12-310001655891trmd:TormPlcMembertrmd:JacobMeldgaardMember2020-01-012020-12-310001655891trmd:TormAsMembertrmd:JacobMeldgaardMember2020-01-012020-12-310001655891trmd:TormasAdjustmentMembertrmd:JacobMeldgaardMember2020-01-012020-12-310001655891ifrs-full:TopOfRangeMember2022-12-310001655891trmd:HandySizeMember2021-12-310001655891trmd:HandySizeMember2020-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:OtherPropertyPlantAndEquipmentMember2022-01-012022-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:LandAndBuildingsMember2022-01-012022-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:OtherPropertyPlantAndEquipmentMember2021-01-012021-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:LandAndBuildingsMember2021-01-012021-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMembertrmd:VesselsAndCapitalizedDryDockingMember2020-01-012020-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:OtherPropertyPlantAndEquipmentMember2020-01-012020-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:LandAndBuildingsMember2020-01-012020-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:OtherPropertyPlantAndEquipmentMember2022-01-012022-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:LandAndBuildingsMember2022-01-012022-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:OtherPropertyPlantAndEquipmentMember2021-01-012021-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:LandAndBuildingsMember2021-01-012021-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:OtherPropertyPlantAndEquipmentMember2020-01-012020-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMemberifrs-full:LandAndBuildingsMember2020-01-012020-12-310001655891trmd:AdministrativeExpensesMemberifrs-full:OtherPropertyPlantAndEquipmentMember2022-01-012022-12-310001655891trmd:AdministrativeExpensesMemberifrs-full:OtherPropertyPlantAndEquipmentMember2021-01-012021-12-310001655891trmd:AdministrativeExpensesMemberifrs-full:OtherPropertyPlantAndEquipmentMember2020-01-012020-12-310001655891trmd:TemporaryDifferenceFromIntangibleAssetsMember2022-12-310001655891trmd:TemporaryDifferenceFromDerivativeFinancialInstrumentsMember2022-12-310001655891ifrs-full:AccumulatedImpairmentMembertrmd:VesselsAndCapitalizedDryDockingMember2022-01-012022-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMembertrmd:VesselsAndCapitalizedDryDockingMember2022-01-012022-12-310001655891ifrs-full:AccumulatedImpairmentMembertrmd:VesselsAndCapitalizedDryDockingMember2021-01-012021-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMembertrmd:VesselsAndCapitalizedDryDockingMember2021-01-012021-12-310001655891ifrs-full:AccumulatedImpairmentMembertrmd:VesselsAndCapitalizedDryDockingMember2020-01-012020-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMembertrmd:VesselsAndCapitalizedDryDockingMember2020-01-012020-12-310001655891ifrs-full:OperatingSegmentsMember2022-12-310001655891trmd:VesselcoFApsMember2022-01-012022-12-310001655891trmd:VesselcoEApsMember2022-01-012022-12-310001655891trmd:VesselcoCApsMember2022-01-012022-12-310001655891trmd:VesselcoAApsMember2022-01-012022-12-310001655891trmd:Vesselco9Pte.Ltd.Member2022-01-012022-12-310001655891trmd:Vesselco8Pte.Ltd.Member2022-01-012022-12-310001655891trmd:Vesselco7Pte.Ltd.Member2022-01-012022-12-310001655891trmd:Vesselco6Pte.Ltd.Member2022-01-012022-12-310001655891trmd:Vesselco6KSMember2022-01-012022-12-310001655891trmd:Vesselco5KSMember2022-01-012022-12-310001655891trmd:Vesselco3KSMember2022-01-012022-12-310001655891trmd:Vesselco1KSMember2022-01-012022-12-310001655891trmd:Vesselco12Pte.Ltd.Member2022-01-012022-12-310001655891trmd:Vesselco11Pte.Ltd.Member2022-01-012022-12-310001655891trmd:Vesselco10Pte.Ltd.Member2022-01-012022-12-310001655891trmd:TormUsaLlcMember2022-01-012022-12-310001655891trmd:TormSingaporePte.Ltd.Member2022-01-012022-12-310001655891trmd:TormShippingPhils.Inc.Member2022-01-012022-12-310001655891trmd:TormShippingIndiaPrivateLimitedMember2022-01-012022-12-310001655891trmd:TormCrewingServiceLtd.Member2022-01-012022-12-310001655891trmd:TormAsMember2022-01-012022-12-310001655891trmd:SuzhouMeProductionTechnologyCoLtdMember2022-01-012022-12-310001655891trmd:OmiHoldingLtd.Member2022-01-012022-12-310001655891trmd:OcmSingaporeNjordHoldingsSt.MichaelisPte.LtdMember2022-01-012022-12-310001655891trmd:OcmSingaporeNjordHoldingsSt.GabrielPte.LtdMember2022-01-012022-12-310001655891trmd:OcmSingaporeNjordHoldingsHardradaPte.LtdMember2022-01-012022-12-310001655891trmd:OcmSingaporeNjordHoldingsAlmenaPte.LtdMember2022-01-012022-12-310001655891trmd:OcmSingaporeNjordHoldingsAlicePte.LtdMember2022-01-012022-12-310001655891trmd:OcmSingaporeNjordHoldingsAlexandraPte.LtdMember2022-01-012022-12-310001655891trmd:OcmSingaporeNjordHoldingsAgnetePte.LtdMember2022-01-012022-12-310001655891trmd:MeProductionAsMember2022-01-012022-12-310001655891trmd:MarineExhaustTechnologyHongKongLtdMember2022-01-012022-12-310001655891trmd:MarineExhaustTechnologyAsMember2022-01-012022-12-310001655891trmd:DkVesselHoldcoKSMember2022-01-012022-12-310001655891trmd:DkVesselHoldcoGpApsMember2022-01-012022-12-310001655891trmd:MarineExhaustTechnologyLtd.Member2022-01-012022-12-310001655891trmd:Lr2ManagementKSMember2022-01-012022-12-310001655891trmd:LongRange2ASMember2022-01-012022-12-310001655891ifrs-full:NotLaterThanOneYearMembertrmd:TradePayablesAndOtherObligationsMember2022-12-310001655891ifrs-full:NotLaterThanOneYearMembertrmd:InterestPaymentsRelatedToScheduledInterestFixingMember2022-12-310001655891ifrs-full:NotLaterThanOneYearMembertrmd:CommittedScrubberInstallationsMember2022-12-310001655891ifrs-full:NotLaterThanOneYearMembertrmd:BorrowingsMember2022-12-310001655891ifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMembertrmd:InterestPaymentsRelatedToScheduledInterestFixingMember2022-12-310001655891ifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMembertrmd:BorrowingsMember2022-12-310001655891ifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMembertrmd:InterestPaymentsRelatedToScheduledInterestFixingMember2022-12-310001655891ifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMembertrmd:BorrowingsMember2022-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMembertrmd:InterestPaymentsRelatedToScheduledInterestFixingMember2022-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMembertrmd:CommittedScrubberInstallationsMember2022-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMembertrmd:BorrowingsMember2022-12-310001655891ifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMembertrmd:InterestPaymentsRelatedToScheduledInterestFixingMember2022-12-310001655891ifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMembertrmd:BorrowingsMember2022-12-310001655891ifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMembertrmd:TradePayablesAndOtherObligationsMember2022-12-310001655891ifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMembertrmd:InterestPaymentsRelatedToScheduledInterestFixingMember2022-12-310001655891ifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMembertrmd:BorrowingsMember2022-12-310001655891trmd:TradePayablesAndOtherObligationsMember2022-12-310001655891trmd:InterestPaymentsRelatedToScheduledInterestFixingMember2022-12-310001655891trmd:CommittedScrubberInstallationsMember2022-12-310001655891trmd:BorrowingsMember2022-12-310001655891ifrs-full:NotLaterThanOneYearMember2022-12-310001655891ifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMember2022-12-310001655891ifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMember2022-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMember2022-12-310001655891ifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMember2022-12-310001655891ifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMember2022-12-310001655891ifrs-full:NotLaterThanOneYearMembertrmd:TradePayablesAndOtherObligationsMember2021-12-310001655891ifrs-full:NotLaterThanOneYearMembertrmd:NewbuildingInstallmentsMember2021-12-310001655891ifrs-full:NotLaterThanOneYearMembertrmd:InterestPaymentsRelatedToScheduledInterestFixingMember2021-12-310001655891ifrs-full:NotLaterThanOneYearMembertrmd:CommittedScrubberInstallationsMember2021-12-310001655891ifrs-full:NotLaterThanOneYearMembertrmd:BorrowingsMember2021-12-310001655891ifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMembertrmd:TradePayablesAndOtherObligationsMember2021-12-310001655891ifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMembertrmd:NewbuildingInstallmentsMember2021-12-310001655891ifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMembertrmd:InterestPaymentsRelatedToScheduledInterestFixingMember2021-12-310001655891ifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMembertrmd:CommittedScrubberInstallationsMember2021-12-310001655891ifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMembertrmd:BorrowingsMember2021-12-310001655891ifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMembertrmd:TradePayablesAndOtherObligationsMember2021-12-310001655891ifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMembertrmd:NewbuildingInstallmentsMember2021-12-310001655891ifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMembertrmd:InterestPaymentsRelatedToScheduledInterestFixingMember2021-12-310001655891ifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMembertrmd:CommittedScrubberInstallationsMember2021-12-310001655891ifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMembertrmd:BorrowingsMember2021-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMembertrmd:TradePayablesAndOtherObligationsMember2021-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMembertrmd:NewbuildingInstallmentsMember2021-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMembertrmd:InterestPaymentsRelatedToScheduledInterestFixingMember2021-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMembertrmd:CommittedScrubberInstallationsMember2021-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMembertrmd:BorrowingsMember2021-12-310001655891ifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMembertrmd:TradePayablesAndOtherObligationsMember2021-12-310001655891ifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMembertrmd:NewbuildingInstallmentsMember2021-12-310001655891ifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMembertrmd:InterestPaymentsRelatedToScheduledInterestFixingMember2021-12-310001655891ifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMembertrmd:CommittedScrubberInstallationsMember2021-12-310001655891ifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMembertrmd:BorrowingsMember2021-12-310001655891ifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMembertrmd:TradePayablesAndOtherObligationsMember2021-12-310001655891ifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMembertrmd:NewbuildingInstallmentsMember2021-12-310001655891ifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMembertrmd:InterestPaymentsRelatedToScheduledInterestFixingMember2021-12-310001655891ifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMembertrmd:CommittedScrubberInstallationsMember2021-12-310001655891ifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMembertrmd:BorrowingsMember2021-12-310001655891trmd:TradePayablesAndOtherObligationsMember2021-12-310001655891trmd:NewbuildingInstallmentsMember2021-12-310001655891trmd:InterestPaymentsRelatedToScheduledInterestFixingMember2021-12-310001655891trmd:CommittedScrubberInstallationsMember2021-12-310001655891trmd:BorrowingsMember2021-12-310001655891ifrs-full:NotLaterThanOneYearMember2021-12-310001655891ifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMember2021-12-310001655891ifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMember2021-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMember2021-12-310001655891ifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMember2021-12-310001655891ifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMember2021-12-310001655891ifrs-full:NotLaterThanOneYearMembertrmd:TradePayablesAndOtherObligationsMember2020-12-310001655891ifrs-full:NotLaterThanOneYearMembertrmd:NewbuildingInstallmentsMember2020-12-310001655891ifrs-full:NotLaterThanOneYearMembertrmd:InterestPaymentsRelatedToScheduledInterestFixingMember2020-12-310001655891ifrs-full:NotLaterThanOneYearMembertrmd:CommittedScrubberInstallationsMember2020-12-310001655891ifrs-full:NotLaterThanOneYearMembertrmd:BorrowingsMember2020-12-310001655891ifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMembertrmd:TradePayablesAndOtherObligationsMember2020-12-310001655891ifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMembertrmd:NewbuildingInstallmentsMember2020-12-310001655891ifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMembertrmd:InterestPaymentsRelatedToScheduledInterestFixingMember2020-12-310001655891ifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMembertrmd:CommittedScrubberInstallationsMember2020-12-310001655891ifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMembertrmd:BorrowingsMember2020-12-310001655891ifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMembertrmd:TradePayablesAndOtherObligationsMember2020-12-310001655891ifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMembertrmd:NewbuildingInstallmentsMember2020-12-310001655891ifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMembertrmd:InterestPaymentsRelatedToScheduledInterestFixingMember2020-12-310001655891ifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMembertrmd:CommittedScrubberInstallationsMember2020-12-310001655891ifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMembertrmd:BorrowingsMember2020-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMembertrmd:TradePayablesAndOtherObligationsMember2020-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMembertrmd:NewbuildingInstallmentsMember2020-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMembertrmd:InterestPaymentsRelatedToScheduledInterestFixingMember2020-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMembertrmd:CommittedScrubberInstallationsMember2020-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMembertrmd:BorrowingsMember2020-12-310001655891ifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMembertrmd:TradePayablesAndOtherObligationsMember2020-12-310001655891ifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMembertrmd:NewbuildingInstallmentsMember2020-12-310001655891ifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMembertrmd:InterestPaymentsRelatedToScheduledInterestFixingMember2020-12-310001655891ifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMembertrmd:CommittedScrubberInstallationsMember2020-12-310001655891ifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMembertrmd:BorrowingsMember2020-12-310001655891ifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMembertrmd:TradePayablesAndOtherObligationsMember2020-12-310001655891ifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMembertrmd:NewbuildingInstallmentsMember2020-12-310001655891ifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMembertrmd:InterestPaymentsRelatedToScheduledInterestFixingMember2020-12-310001655891ifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMembertrmd:CommittedScrubberInstallationsMember2020-12-310001655891ifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMembertrmd:BorrowingsMember2020-12-310001655891trmd:TradePayablesAndOtherObligationsMember2020-12-310001655891trmd:NewbuildingInstallmentsMember2020-12-310001655891trmd:InterestPaymentsRelatedToScheduledInterestFixingMember2020-12-310001655891trmd:CommittedScrubberInstallationsMember2020-12-310001655891trmd:BorrowingsMember2020-12-310001655891ifrs-full:NotLaterThanOneYearMember2020-12-310001655891ifrs-full:LaterThanTwoYearsAndNotLaterThanThreeYearsMember2020-12-310001655891ifrs-full:LaterThanThreeYearsAndNotLaterThanFourYearsMember2020-12-310001655891ifrs-full:LaterThanOneYearAndNotLaterThanTwoYearsMember2020-12-310001655891ifrs-full:LaterThanFourYearsAndNotLaterThanFiveYearsMember2020-12-310001655891ifrs-full:LaterThanFiveYearsAndNotLaterThanTenYearsMember2020-12-310001655891trmd:MarineExhaustTechnologyLtd.Membertrmd:MarineExhaustTechnologyLtd.Member2022-01-012022-12-310001655891trmd:Lr2ManagementKSMembertrmd:Lr2ManagementKSMember2022-01-012022-12-310001655891trmd:LongRange2ASMembertrmd:LongRange2ASMember2022-01-012022-12-310001655891ifrs-full:SharePremiumMember2022-01-012022-12-310001655891ifrs-full:RetainedEarningsMember2022-01-012022-12-310001655891ifrs-full:ReserveOfExchangeDifferencesOnTranslationMember2022-01-012022-12-310001655891ifrs-full:ReserveOfCashFlowHedgesMember2022-01-012022-12-310001655891ifrs-full:NoncontrollingInterestsMember2022-01-012022-12-310001655891ifrs-full:IssuedCapitalMember2022-01-012022-12-310001655891ifrs-full:EquityAttributableToOwnersOfParentMember2022-01-012022-12-310001655891ifrs-full:SharePremiumMember2021-01-012021-12-310001655891ifrs-full:RetainedEarningsMember2021-01-012021-12-310001655891ifrs-full:ReserveOfExchangeDifferencesOnTranslationMember2021-01-012021-12-310001655891ifrs-full:ReserveOfCashFlowHedgesMember2021-01-012021-12-310001655891ifrs-full:IssuedCapitalMember2021-01-012021-12-310001655891ifrs-full:EquityAttributableToOwnersOfParentMember2021-01-012021-12-310001655891ifrs-full:TreasurySharesMember2020-01-012020-12-310001655891ifrs-full:SharePremiumMember2020-01-012020-12-310001655891ifrs-full:RetainedEarningsMember2020-01-012020-12-310001655891ifrs-full:ReserveOfExchangeDifferencesOnTranslationMember2020-01-012020-12-310001655891ifrs-full:ReserveOfCashFlowHedgesMember2020-01-012020-12-310001655891ifrs-full:IssuedCapitalMember2020-01-012020-12-310001655891ifrs-full:EquityAttributableToOwnersOfParentMember2020-01-012020-12-310001655891ifrs-full:CashFlowHedgesMember2022-12-310001655891ifrs-full:CashFlowHedgesMember2021-12-310001655891ifrs-full:CashFlowHedgesMember2020-12-3100016558912019-12-310001655891trmd:TermFacilityTwoThousandAndTwentySixMaturityMemberifrs-full:FloatingInterestRateMember2021-01-012021-12-310001655891trmd:SpringlinerFacilityMemberifrs-full:FixedInterestRateMember2021-01-012021-12-310001655891trmd:ShowaFacilityMemberifrs-full:FloatingInterestRateMember2021-01-012021-12-310001655891trmd:OtherCreditFacilitiesMemberifrs-full:FloatingInterestRateMember2021-01-012021-12-310001655891trmd:KfwFacilityMemberifrs-full:FloatingInterestRateMember2021-01-012021-12-310001655891trmd:HcobFacilityTwoMemberifrs-full:FloatingInterestRateMember2021-01-012021-12-310001655891trmd:HcobFacilityOneMemberifrs-full:FloatingInterestRateMember2021-01-012021-12-310001655891trmd:EifukuFacilityMemberifrs-full:FloatingInterestRateMember2021-01-012021-12-310001655891trmd:DsfFacilityFiveMemberifrs-full:FloatingInterestRateMember2021-01-012021-12-310001655891trmd:CeximFacilityMemberifrs-full:FloatingInterestRateMember2021-01-012021-12-310001655891trmd:CdblFacilityMemberifrs-full:FixedInterestRateMember2021-01-012021-12-310001655891trmd:BocommFacilityTwoMemberifrs-full:FloatingInterestRateMember2021-01-012021-12-310001655891trmd:BocommFacilityThreeMemberifrs-full:FloatingInterestRateMember2021-01-012021-12-310001655891trmd:BocommFacilityOneMemberifrs-full:FloatingInterestRateMember2021-01-012021-12-310001655891trmd:SaleAndLeaseBackTransactionPrepaymentMember2021-01-012021-12-310001655891trmd:CmbflMember2021-01-012021-12-310001655891trmd:TermFacilityTwoThousandAndTwentySixMaturityMemberifrs-full:FloatingInterestRateMember2020-01-012020-12-310001655891trmd:SpringlinerFacilityMemberifrs-full:FixedInterestRateMember2020-01-012020-12-310001655891trmd:ShowaFacilityMemberifrs-full:FloatingInterestRateMember2020-01-012020-12-310001655891trmd:OtherCreditFacilitiesMemberifrs-full:FloatingInterestRateMember2020-01-012020-12-310001655891trmd:KfwFacilityMemberifrs-full:FloatingInterestRateMember2020-01-012020-12-310001655891trmd:HcobFacilityTwoMemberifrs-full:FloatingInterestRateMember2020-01-012020-12-310001655891trmd:HcobFacilityOneMemberifrs-full:FloatingInterestRateMember2020-01-012020-12-310001655891trmd:EifukuFacilityMemberifrs-full:FloatingInterestRateMember2020-01-012020-12-310001655891trmd:DsfFacilityFiveMemberifrs-full:FloatingInterestRateMember2020-01-012020-12-310001655891trmd:CeximFacilityMemberifrs-full:FloatingInterestRateMember2020-01-012020-12-310001655891trmd:CdblFacilityMemberifrs-full:FixedInterestRateMember2020-01-012020-12-310001655891trmd:BocommFacilityTwoMemberifrs-full:FloatingInterestRateMember2020-01-012020-12-310001655891trmd:BocommFacilityThreeMemberifrs-full:FloatingInterestRateMember2020-01-012020-12-310001655891trmd:BocommFacilityOneMemberifrs-full:FloatingInterestRateMember2020-01-012020-12-310001655891trmd:SaleAndLeaseBackTransactionPrepaymentMember2020-01-012020-12-310001655891trmd:CmbflMember2020-01-012020-12-310001655891trmd:TermFacilityTwoThousandAndTwentySixMaturityMemberifrs-full:FloatingInterestRateMember2022-01-012022-12-310001655891trmd:SpringlinerFacilityMemberifrs-full:FixedInterestRateMember2022-01-012022-12-310001655891trmd:ShowaFacilityMemberifrs-full:FloatingInterestRateMember2022-01-012022-12-310001655891trmd:OtherCreditFacilitiesMemberifrs-full:FloatingInterestRateMember2022-01-012022-12-310001655891trmd:KfwFacilityMemberifrs-full:FloatingInterestRateMember2022-01-012022-12-310001655891trmd:HcobFacilityTwoMemberifrs-full:FloatingInterestRateMember2022-01-012022-12-310001655891trmd:HcobFacilityOneMemberifrs-full:FloatingInterestRateMember2022-01-012022-12-310001655891trmd:EifukuFacilityMemberifrs-full:FloatingInterestRateMember2022-01-012022-12-310001655891trmd:DsfFacilityFiveMemberifrs-full:FloatingInterestRateMember2022-01-012022-12-310001655891trmd:CeximFacilityMemberifrs-full:FloatingInterestRateMember2022-01-012022-12-310001655891trmd:CdblFacilityMemberifrs-full:FixedInterestRateMember2022-01-012022-12-310001655891trmd:BocommFacilityTwoMemberifrs-full:FloatingInterestRateMember2022-01-012022-12-310001655891trmd:BocommFacilityThreeMemberifrs-full:FloatingInterestRateMember2022-01-012022-12-310001655891trmd:BocommFacilityOneMemberifrs-full:FloatingInterestRateMember2022-01-012022-12-310001655891trmd:SaleAndLeaseBackTransactionPrepaymentMember2022-01-012022-12-310001655891trmd:CmbflMember2022-01-012022-12-310001655891ifrs-full:LeaseLiabilitiesMemberifrs-full:CashFlowHedgesMemberifrs-full:InterestRateRiskMember2022-12-310001655891trmd:TermFacilityTwoThousandAndTwentySixMaturityMemberifrs-full:FloatingInterestRateMember2022-12-310001655891trmd:SpringlinerFacilityMemberifrs-full:FixedInterestRateMember2022-12-310001655891trmd:ShowaFacilityMemberifrs-full:FloatingInterestRateMember2022-12-310001655891trmd:OtherCreditFacilitiesMemberifrs-full:FloatingInterestRateMember2022-12-310001655891trmd:KfwFacilityMemberifrs-full:FloatingInterestRateMember2022-12-310001655891trmd:HcobFacilityTwoMemberifrs-full:FloatingInterestRateMember2022-12-310001655891trmd:HcobFacilityOneMemberifrs-full:FloatingInterestRateMember2022-12-310001655891trmd:FixedRateBorrowingsMemberifrs-full:AtFairValueMember2022-12-310001655891trmd:EifukuFacilityMemberifrs-full:FloatingInterestRateMember2022-12-310001655891trmd:DsfFacilityFiveMemberifrs-full:FloatingInterestRateMember2022-12-310001655891trmd:CeximFacilityMemberifrs-full:FloatingInterestRateMember2022-12-310001655891trmd:CdblFacilityMemberifrs-full:FixedInterestRateMember2022-12-310001655891trmd:BocommFacilityTwoMemberifrs-full:FloatingInterestRateMember2022-12-310001655891trmd:BocommFacilityThreeMemberifrs-full:FloatingInterestRateMember2022-12-310001655891trmd:BocommFacilityOneMemberifrs-full:FloatingInterestRateMember2022-12-310001655891trmd:FixedRateBorrowingsMember2022-12-310001655891trmd:CmbflMember2022-12-310001655891ifrs-full:LeaseLiabilitiesMember2022-12-310001655891trmd:TermFacilityTwoThousandAndTwentySixMaturityMemberifrs-full:FloatingInterestRateMember2021-12-310001655891trmd:SpringlinerFacilityMemberifrs-full:FixedInterestRateMember2021-12-310001655891trmd:ShowaFacilityMemberifrs-full:FloatingInterestRateMember2021-12-310001655891trmd:KfwFacilityMemberifrs-full:FloatingInterestRateMember2021-12-310001655891trmd:HcobFacilityTwoMemberifrs-full:FloatingInterestRateMember2021-12-310001655891trmd:HcobFacilityOneMemberifrs-full:FloatingInterestRateMember2021-12-310001655891trmd:EifukuFacilityMemberifrs-full:FloatingInterestRateMember2021-12-310001655891trmd:DsfFacilityFiveMemberifrs-full:FloatingInterestRateMember2021-12-310001655891trmd:CeximFacilityMemberifrs-full:FloatingInterestRateMember2021-12-310001655891trmd:CdblFacilityMemberifrs-full:FixedInterestRateMember2021-12-310001655891trmd:BocommFacilityTwoMemberifrs-full:FloatingInterestRateMember2021-12-310001655891trmd:BocommFacilityThreeMemberifrs-full:FloatingInterestRateMember2021-12-310001655891trmd:BocommFacilityOneMemberifrs-full:FloatingInterestRateMember2021-12-310001655891trmd:SaleAndLeaseBackTransactionPrepaymentMember2021-12-310001655891ifrs-full:LeaseLiabilitiesMember2021-12-310001655891trmd:TermFacilityTwoThousandAndTwentySixMaturityMemberifrs-full:FloatingInterestRateMember2020-12-310001655891trmd:SpringlinerFacilityMemberifrs-full:FixedInterestRateMember2020-12-310001655891trmd:ShowaFacilityMemberifrs-full:FloatingInterestRateMember2020-12-310001655891trmd:KfwFacilityMemberifrs-full:FloatingInterestRateMember2020-12-310001655891trmd:HcobFacilityTwoMemberifrs-full:FloatingInterestRateMember2020-12-310001655891trmd:HcobFacilityOneMemberifrs-full:FloatingInterestRateMember2020-12-310001655891trmd:EifukuFacilityMemberifrs-full:FloatingInterestRateMember2020-12-310001655891trmd:DsfFacilityFiveMemberifrs-full:FloatingInterestRateMember2020-12-310001655891trmd:CeximFacilityMemberifrs-full:FloatingInterestRateMember2020-12-310001655891trmd:BocommFacilityOneMemberifrs-full:FloatingInterestRateMember2020-12-310001655891ifrs-full:LeaseLiabilitiesMember2020-12-310001655891trmd:VesselsMember2022-01-012022-12-310001655891trmd:VesselsMember2021-01-012021-12-310001655891trmd:VesselsMember2020-01-012020-12-310001655891ifrs-full:InterestRateSwapContractMemberifrs-full:CashFlowHedgesMember2022-12-310001655891ifrs-full:InterestRateSwapContractMemberifrs-full:CashFlowHedgesMember2021-12-310001655891ifrs-full:InterestRateSwapContractMemberifrs-full:CashFlowHedgesMember2020-12-310001655891trmd:BunkerSwapContractsMemberifrs-full:CashFlowHedgesMember2021-12-310001655891trmd:BunkerSwapContractsMemberifrs-full:CashFlowHedgesMember2020-12-310001655891ifrs-full:OperatingSegmentsMembertrmd:TankMember2022-12-310001655891ifrs-full:OperatingSegmentsMembertrmd:MarineExhaustMember2022-12-310001655891ifrs-full:EliminationOfIntersegmentAmountsMember2022-12-310001655891trmd:ImpairedVesselsMembertrmd:TotalTankerFleetMember2022-12-310001655891trmd:TotalTankerFleetMember2022-12-310001655891trmd:TotalTankerFleetMember2021-12-310001655891trmd:MainFleetMember2021-12-310001655891trmd:MainFleetMember2020-12-310001655891trmd:FreightReceivablesMember2022-12-310001655891trmd:FreightReceivablesMember2021-12-310001655891trmd:FreightReceivablesMember2020-12-310001655891trmd:FreightReceivablesMember2019-12-3100016558912021-01-012021-12-3100016558912020-01-012020-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:OtherPropertyPlantAndEquipmentMember2022-01-012022-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LandAndBuildingsMember2022-01-012022-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:OtherPropertyPlantAndEquipmentMember2021-01-012021-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LandAndBuildingsMember2021-01-012021-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LandAndBuildingsMember2020-01-012020-12-310001655891trmd:VesselsAndCapitalizedDryDockingMemberifrs-full:OperatingSegmentsMembertrmd:TankMember2022-01-012022-12-310001655891trmd:PrepaymentsOnVesselsMemberifrs-full:OperatingSegmentsMembertrmd:TankMember2022-01-012022-12-310001655891ifrs-full:OtherPropertyPlantAndEquipmentMemberifrs-full:OperatingSegmentsMembertrmd:TankMember2022-01-012022-12-310001655891ifrs-full:OtherPropertyPlantAndEquipmentMemberifrs-full:OperatingSegmentsMembertrmd:MarineExhaustMember2022-01-012022-12-310001655891ifrs-full:LandAndBuildingsMemberifrs-full:OperatingSegmentsMembertrmd:TankMember2022-01-012022-12-310001655891ifrs-full:LandAndBuildingsMemberifrs-full:OperatingSegmentsMembertrmd:MarineExhaustMember2022-01-012022-12-310001655891ifrs-full:IntangibleAssetsOtherThanGoodwillMemberifrs-full:OperatingSegmentsMembertrmd:TankMember2022-01-012022-12-310001655891ifrs-full:IntangibleAssetsOtherThanGoodwillMemberifrs-full:OperatingSegmentsMembertrmd:MarineExhaustMember2022-01-012022-12-310001655891ifrs-full:GoodwillMemberifrs-full:OperatingSegmentsMembertrmd:MarineExhaustMember2022-01-012022-12-310001655891trmd:VesselsAndCapitalizedDryDockingMemberifrs-full:OperatingSegmentsMember2022-01-012022-12-310001655891trmd:VesselsAndCapitalizedDryDockingMemberifrs-full:EliminationOfIntersegmentAmountsMember2022-01-012022-12-310001655891trmd:PrepaymentsOnVesselsMemberifrs-full:OperatingSegmentsMember2022-01-012022-12-310001655891ifrs-full:OtherPropertyPlantAndEquipmentMemberifrs-full:OperatingSegmentsMember2022-01-012022-12-310001655891ifrs-full:OperatingSegmentsMembertrmd:TankMember2022-01-012022-12-310001655891ifrs-full:OperatingSegmentsMembertrmd:MarineExhaustMember2022-01-012022-12-310001655891ifrs-full:LandAndBuildingsMemberifrs-full:OperatingSegmentsMember2022-01-012022-12-310001655891ifrs-full:IntangibleAssetsOtherThanGoodwillMemberifrs-full:OperatingSegmentsMember2022-01-012022-12-310001655891ifrs-full:GoodwillMemberifrs-full:OperatingSegmentsMember2022-01-012022-12-310001655891ifrs-full:OperatingSegmentsMember2022-01-012022-12-310001655891ifrs-full:EliminationOfIntersegmentAmountsMember2022-01-012022-12-310001655891ifrs-full:GrossCarryingAmountMembertrmd:VesselsAndCapitalizedDryDockingMember2022-01-012022-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:OtherPropertyPlantAndEquipmentMember2022-01-012022-12-310001655891ifrs-full:GrossCarryingAmountMembertrmd:VesselsAndCapitalizedDryDockingMember2021-01-012021-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:OtherPropertyPlantAndEquipmentMember2021-01-012021-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LandAndBuildingsMember2021-01-012021-12-310001655891ifrs-full:GrossCarryingAmountMembertrmd:VesselsAndCapitalizedDryDockingMember2020-01-012020-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:OtherPropertyPlantAndEquipmentMember2020-01-012020-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LandAndBuildingsMember2020-01-012020-12-310001655891trmd:MarineExhaustMember2022-01-012022-12-310001655891ifrs-full:GrossCarryingAmountMember2022-01-012022-12-310001655891ifrs-full:GrossCarryingAmountMember2021-01-012021-12-310001655891ifrs-full:GrossCarryingAmountMember2020-01-012020-12-310001655891trmd:FreightReceivablesMember2022-01-012022-12-310001655891trmd:FreightReceivablesMember2021-01-012021-12-310001655891trmd:FreightReceivablesMember2020-01-012020-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:PropertyPlantAndEquipmentSubjectToOperatingLeasesMember2022-01-012022-12-310001655891ifrs-full:GrossCarryingAmountMemberifrs-full:LandAndBuildingsMember2022-01-012022-12-310001655891ifrs-full:AccumulatedDepreciationAndAmortisationMember2022-01-012022-12-310001655891trmd:MarineExhaustTechnologyAsMember2022-09-012022-09-010001655891trmd:MarineExhaustTechnologyAsMember2022-09-0100016558912021-12-3100016558912020-12-3100016558912022-12-310001655891dei:BusinessContactMember2022-01-012022-12-3100016558912022-01-012022-12-31utr:oztiso4217:DKKxbrli:sharestrmd:itemutr:Ttrmd:persontrmd:companytrmd:segmenttrmd:leasetrmd:customertrmd:Assetxbrli:sharesutr:MTiso4217:USDxbrli:puretrmd:employeeiso4217:USDxbrli:sharesiso4217:DKKtrmd:EquityInstrumentstrmd:Voteiso4217:USDiso4217:DKK

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

FORM 20-F

(Mark One)

REGISTRATION STATEMENT PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934

 

 

OR

 

 

ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

 

 

 

For the fiscal year ended December 31, 2022

 

 

OR

 

 

TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

 

 

 

For the transition period from _________________ to _________________

 

 

OR

 

 

SHELL COMPANY REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

 

 

 

Date of event requiring this shell company report:

Commission file number: 001-38294

TORM plc

(Exact name of Registrant as specified in its charter)

 

(Translation of Registrant’s name into English)

 

England and Wales

(Jurisdiction of incorporation or organization)

 

Office 105 | 20 St Dunstan’s Hill

London, EC3R 8HL, United Kingdom

(Address of principal executive offices)

 

Jacob Meldgaard, Executive Director and Principal Executive Officer, Tuborg Havnevej 18, DK-

2900 Hellerup, Denmark,

+45 39 17 92 00

 

(Name, Telephone, E-mail and/or Facsimile, and address of Company Contact Person)

Securities registered or to be registered pursuant to section 12(b) of the Act.

Title of each class

Trading Symbol(s)

Name of each exchange on which registered

Class A common shares, par value $0.01 per

share

TRMD

Nasdaq Stock Market LLC

Securities registered or to be registered pursuant to section 12(g) of the Act.

NONE

(Title of class) 

Securities for which there is a reporting obligation pursuant to Section 15(d) of the Act.

NONE

(Title of class)

Indicate the number of outstanding shares of each of the issuer’s classes of capital or common stock as of the close of the period covered by the annual report: As of December 31, 2022 there were 82,311,299 of the Registrant’s Class A common shares outstanding.

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.

Yes

 

No

If this report is an annual or transition report, indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934.

Yes

 

No

Note – Checking the box above will not relieve any registrant required to file reports pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934 from their obligations under those Sections.

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days.

Yes

 

No

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files).

Yes

 

No

Indicate by check mark whether the Registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer or an emerging growth Company. See the definitions of “large accelerated filer,” “accelerated filer” and “emerging growth company” in Rule 12b-2 of the Exchange Act.

 

Large accelerated filer  

 

Accelerated filer  

 

 

 

 

 

 

 

 

 

Non-accelerated filer  

 

Emerging growth company  

 

 

If an emerging growth company that prepares its financial statements in accordance with U.S. GAAP, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards† provided pursuant to Section 13(a) of the Exchange Act.   

† The term “new or revised financial accounting standard” refers to any update issued by the Financial Accounting Standards Board to its Accounting Standards Codification after April 5, 2012.

Indicate by check mark whether the registrant has filed a report on and attestation to its management’s assessment of effectiveness of its internal control over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.S 7262(b)) by the registered public accounting firm that prepared or issued its audit report.   

If securities are registered pursuant to Section 12(b) of the Act, indicate by check mark whether the financial statements of the registrant included in the filing reflect the correction of an error to previously issued financial statements.  

Indicate by check mark whether any of those error corrections are restatements that required a recovery analysis of incentive-based compensation received by any of the registrant's executive officers during the relevant recovery period pursuant to §240.10D-1(b).  

Indicate by check mark which basis of accounting the registrant has used to prepare the financial statements included in this filing:

 

 

U.S. GAAP 

 

 

International Financial Reporting Standards as issued by the international Accounting Standards Board

 

 

 

 

 

Other

If “Other” has been checked in response to the previous question, indicate by check mark which financial statement item the registrant has elected to follow:

Item 17

 

 Item 18

If this is an annual report, indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act).

Yes

 

No

TABLE OF CONTENTS

    

Page

PART I.

   

ITEM 1.

IDENTITY OF DIRECTORS, SENIOR MANAGEMENT AND ADVISERS

1

ITEM 2.

OFFER STATISTICS AND EXPECTED TIMETABLE

1

ITEM 3.

KEY INFORMATION

1

ITEM 4.

INFORMATION ON THE COMPANY

39

ITEM 4A.

UNRESOLVED STAFF COMMENTS

60

ITEM 5.

OPERATING AND FINANCIAL REVIEW AND PROSPECTS

60

ITEM 6.

DIRECTORS, SENIOR MANAGEMENT AND EMPLOYEES

74

ITEM 7.

MAJOR SHAREHOLDERS AND RELATED PARTY TRANSACTIONS

80

ITEM 8.

FINANCIAL INFORMATION

81

ITEM 9.

THE OFFER AND LISTING

82

ITEM 10.

ADDITIONAL INFORMATION

82

ITEM 11.

QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK

97

ITEM 12.

DESCRIPTION OF SECURITIES OTHER THAN EQUITY SECURITIES

97

PART II.

ITEM 13.

DEFAULTS, DIVIDEND ARREARAGES AND DELINQUENCIES

98

ITEM 14.

MATERIAL MODIFICATIONS TO THE RIGHTS OF SECURITY HOLDERS AND USE OF PROCEEDS

98

ITEM 15.

CONTROLS AND PROCEDURES

98

ITEM 16A.

AUDIT COMMITTEE FINANCIAL EXPERT

99

ITEM 16B.

CODE OF ETHICS

99

ITEM 16C.

PRINCIPAL ACCOUNTANT FEES AND SERVICES

99

ITEM 16D.

EXEMPTIONS FROM THE LISTING STANDARDS FOR AUDIT COMMITTEES

99

ITEM 16E.

PURCHASES OF EQUITY SECURITIES BY THE ISSUER AND AFFILIATED PURCHASERS

99

ITEM 16F.

CHANGE IN REGISTRANT’S CERTIFYING ACCOUNTANT

99

ITEM 16G.

CORPORATE GOVERNANCE

100

ITEM 16H.

MINE SAFETY DISCLOSURE

102

ITEM 16I.

DISCLOSURE REGARDING FOREIGN JUSISDICTIONS THAT PREVENT INSPECTION

102

PART III.

ITEM 17.

FINANCIAL STATEMENTS

103

ITEM 18.

FINANCIAL STATEMENTS

103

ITEM 19.

EXHIBITS

103

i

CAUTIONARY STATEMENT REGARDING FORWARD-LOOKING STATEMENTS

The Private Securities Litigation Reform Act of 1995 provides safe harbor protections for forward-looking statements in order to encourage companies to provide prospective information about their business. Forward-looking statements include statements concerning plans, objectives, goals, strategies, future events or performance, and underlying assumptions and other statements, which are statements other than statements of historical facts. We desire to take advantage of the safe harbor provisions of the Private Securities Litigation Reform Act of 1995 and are issuing this cautionary statement in connection therewith. Our disclosure and analysis in this annual report pertaining to our operations, cash flows and financial position, including, in particular, the likelihood of our success in developing and expanding our business, include forward-looking statements. Statements that are predictive in nature, that depend upon or refer to future events or conditions, or that include words such as, but are not limited to, “expects,” “anticipates,” “intends,” “plans,” “believes,” “estimates,” “targets,” “projects,” “forecasts,” “potential,” “continue,” “possible,” “likely,” “may,” “could,” “should” and similar expressions may identify forward-looking statements.

All statements in this annual report that are not statements of either historical or current facts are forward-looking statements. These forward-looking statements are based on current expectations, estimates, assumptions and projections about the business and our future financial results and readers should not place undue reliance on them. Forward-looking statements include, but are not limited to, such matters as:

our future operating or financial results;
global and regional economic and political conditions, including piracy;
our business strategy and expected capital spending or operating expenses, including dry-docking and insurance costs;
statements about shipping market trends, including charter rates and factors affecting supply and demand;
our financial condition and liquidity, including our ability to obtain financing in the future to fund capital expenditures, acquisitions and other general corporate activities;
our ability to enter into time charters after our current charters expire and our ability to earn income in the spot market;
the future price of our Class A common shares; and
our expectations of the availability of vessels to purchase, the time it may take to construct new vessels, and vessels’ useful lives.

Many of these statements are based on our assumptions about factors that are beyond our ability to control or predict and are subject to risks and uncertainties that are described more fully in “Item 3. Key Information—D. Risk Factors.” Any of these factors or a combination of these factors could materially affect our future results of operations and the ultimate accuracy of the forward-looking statements. These factors and the other risk factors described in this annual report are not necessarily all of the important factors that could cause actual results or developments to differ materially from those expressed in any of our forward-looking statements. Other unknown or unpredictable factors also could harm our results. Factors that might cause future results to differ include, but are not limited to, the following:

our future operating or financial results;
changes in governmental rules and regulations or actions taken by regulatory authorities;
the central bank policies intended to combat overall inflation and rising interest rates and foreign exchange rates;
inflationary pressure
increased cost of capital or limited access to funding due to EU Taxonomy or relevant territorial taxonomy regulations;

ii

the length and severity of epidemics and pandemics, including the ongoing global outbreak of the coronavirus (“COVID-19”), and its impact on the demand for seaborne transportation of petroleum products;
general domestic and international political conditions or events, including “trade wars” and the conflict between Russia and Ukraine, which remains ongoing as of this annual report;
changes in economic and competitive conditions affecting our business, including market fluctuations in charter rates and charterers’ abilities to perform under existing time charters;
changes in the supply and demand for vessels comparable to ours and the number of newbuildings under construction;
the highly cyclical nature of the industry that we operate in;
the loss of a large customer or significant business relationship;
changes in worldwide oil production and consumption and storage;
risks associated with any future vessel construction;
our expectations regarding the availability of vessel acquisitions and our ability to complete acquisition transactions planned;
availability of skilled crew members other employees and the related labor costs;
work stoppages or other labor disruptions by our employees or the employees of other companies in related industries;
the impact of increasing scrutiny and changing expectations from investors, lenders and other market participants with respect to our Environmental, Social and Governance, or ESG, policies;
Foreign Corrupt Practices Act of 1977, or FCPA, or other applicable regulations relating to bribery;
effects of new products and new technology in our industry, including the potential for technological innovation to reduce the value of our vessels and charter income derived therefrom;
new environmental regulations and restrictions, whether at a global level stipulated by the International Maritime Organization, and/or imposed by regional or national authorities such as the European Union or individual countries;
the impact of an interruption in or failure of our information technology and communications systems, including the impact of cyber-attacks, upon our ability to operate;
potential conflicts of interest involving members of our board of directors and senior management;
the failure of counterparties to fully perform their contracts with us;
changes in credit risk with respect to our counterparties on contracts;
our dependence on key personnel and our ability to attract, retain and motivate key employees;
adequacy of insurance coverage;
our ability to obtain indemnities from customers;
changes in laws, treaties or regulations;

iii

our incorporation under the laws of England and Wales and the different rights to relief that may be available compared to other countries, including the United States;
government requisition of our vessels during a period of war or emergency;
the arrest of our vessels by maritime claimants;
any further changes in U.S. trade policy that could trigger retaliatory actions by the affected countries;
potential disruption of shipping routes due to accidents, climate-related incidents, environmental factors, political events, public health threats, acts by terrorists or acts of piracy on ocean-going vessels;
the impact of adverse weather and natural disasters;
damage to storage and receiving facilities;
potential liability from future litigation and potential costs due to environmental damage and vessel collisions;
the length and number of off-hire periods and dependence on third-party managers; and
other factors discussed in “Item 3. Key Information - D. Risk Factors” in this annual report.

You should not place undue reliance on forward-looking statements contained in this annual report because they are statements about events that are not certain to occur as described or at all. All forward-looking statements in this annual report are qualified in their entirety by the cautionary statements contained in this annual report. These forward-looking statements are made only as of the date of this report. These forward-looking statements are not guarantees of our future performance, and actual results and future developments may vary materially from those projected in the forward-looking statements.

We have based these statements on assumptions and analyses formed by applying our experience and perception of historical trends, current conditions, expected future developments and other factors we believe are appropriate in the circumstances. All future written and verbal forward-looking statements attributable to us or any person acting on our behalf are expressly qualified in their entirety by the cautionary statements contained or referred to in this section. We undertake no obligation, and specifically decline any obligation, except as required by law, to publicly update or revise any forward-looking statements, whether as a result of new information, future events or otherwise. In light of these risks, uncertainties and assumptions, the forward-looking events discussed in this annual report might not occur.

iv

EXPLANATORY NOTE AND PRESENTATION OF OUR FINANCIAL AND OPERATING DATA

Throughout this annual report on Form 20-F, we incorporate information responsive to the items hereof by reference to our annual report for the year ended December 31, 2022, or the Annual Report 2022. Therefore, the information contained in this annual report should be read in conjunction with the Annual Report 2022, which was furnished to the U.S. Securities and Exchange Commission, or the SEC, on Form 6-K on March 16, 2023. The content of quotations, websites and other sources contained in the sections of the Annual Report 2022 referenced herein are not incorporated by reference into this Form 20-F.

Unless otherwise indicated, the terms “TORM plc,” “we,” “us,” “our,” the “Company” and the “Group” refer to TORM plc and its consolidated subsidiaries, which includes TORM A/S and its consolidated subsidiaries, following the closing of the Exchange Offer (defined below). When used in this annual report to describe events prior to the closing of the Exchange Offer, the terms “TORM A/S,” “we,” “us,” “our,” the “Company” and the “Group” refer to TORM A/S and its consolidated subsidiaries before such time. References to “Former TORM A/S” refer to TORM A/S and its consolidated subsidiaries prior to the Combination (defined below).

Unless otherwise indicated, all references to “U.S. dollars,” “USD,” “dollars,” “US$” and “$” in this annual report are to the lawful currency of the United States of America, references to “Sterling”, “£” and “GBP” are to the lawful currency of the United Kingdom, references to “Danish Kroner,” and “DKK” are to the lawful currency of Denmark. We use the term deadweight ton, or dwt, in describing the size of vessels. Dwt, expressed in metric tons, each of which is equivalent to 1,000 kilograms, refers to the maximum weight of cargo and supplies that a vessel can carry.

In 2016, a new corporate structure was established, whereby TORM plc effectively acquired all of the outstanding securities of TORM A/S in exchange for TORM plc’s securities. We refer to these transactions collectively as the “Exchange Offer.” On April 19, 2016, upon the closing of the Exchange Offer and the listing of TORM plc’s Class A common shares on Nasdaq Copenhagen A/S in Denmark, or Nasdaq Copenhagen, TORM plc became the Group’s publicly-held parent company incorporated under the laws of England and Wales. We refer to this as the “Redomiciliation.” The Redomiciliation was accounted for as an internal reorganization of entities under common control and, therefore, the assets and liabilities of TORM A/S were accounted for at their historical cost basis and not revalued in the transaction.

Our Class A common shares of TORM plc are issued and traded on Nasdaq Copenhagen under the symbol “TRMD A” and on the Nasdaq Stock Market LLC in New York, or Nasdaq New York, under the symbol “TRMD”. All commercial and technical management of our fleet of product tankers is led out of the Denmark office of TORM A/S and our subsidiaries in India, the Philippines, the United States and Singapore. See “Item 4. Information on the Company.”

We are therefore subject to the applicable corporate governance rules of Nasdaq New York, the UK Corporate Governance Code, the UKLA’s Disclosure and Transparency Rules and the applicable rules and regulations applicable to companies admitted to trading and official listing on Nasdaq Copenhagen.

We report our consolidated financial results in U.S. dollars and in accordance with International Financial Reporting Standards, or IFRS, as issued by the International Accounting Standards Board, or IASB, which also comply with reporting requirements under English law.

Accordingly, this document includes the audited consolidated financial statements of TORM plc as of December 31, 2022, 2021 and 2020 and for the years ended December 31, 2022, 2021 and 2020, which have been prepared in accordance with IFRS.

Enforcement of Civil Liabilities

We are a public limited company incorporated under the laws of England and Wales, and substantially all of our directors and officers are non-residents of the United States. A substantial portion of our assets, including the subsidiaries of TORM plc, and our directors and executive officers are located outside the United States. As a result, it may be difficult for shareholders of TORM plc to effect service within the United States upon directors, officers and experts who are not residents of the United States or to enforce judgments in the United States. In addition, there can be no assurance as to the enforceability in the United Kingdom against us or our respective directors, officers and experts who are not residents of the United States, or in actions for enforcement of judgments of United States courts, of liabilities predicated solely upon the federal securities laws of the United States.

v

PART I.

ITEM 1. IDENTITY OF DIRECTORS, SENIOR MANAGEMENT AND ADVISERS

Not applicable.

ITEM 2. OFFER STATISTICS AND EXPECTED TIMETABLE

Not applicable.

ITEM 3. KEY INFORMATION

A. Reserved

B. Capitalization and Indebtedness

Not applicable.

C. Reasons for the Offer and Use of Proceeds

Not applicable.

D. Risk Factors

Summary of Risk Factors

The below bullets summarize the principal risk factors related to an investment in the Company.

Substantially all of our revenues are generated from operating the product tanker fleet, and the demand for product tankers is affected by a number of external factors. The sector is cyclical and volatile, which may lead to reductions in our charter rates when we re-charter vessels.
Events such as piracy, immigrant salvage operations, government requisition during a period of war or emergency, marine disasters, bad weather and other acts of God could cause interruptions and adversely affect our business.
Our operations outside the United States expose us to global risks, such as political instability, terrorist or other attacks, war, international hostilities and global public health concerns, which may affect the seaborne transportation industry and could adversely affect our business.
The COVID-19 pandemic and the resulting disruptions to the international shipping industry may again adversely affect our business, financial performance and our results of operations, including the ability to obtain chartering and financing.
Since our vessels operate worldwide and are registered, flagged, and call-in ports in multiple countries where the applicable flag and/or port state rules, regulations and laws can differ, we are subject to complex laws and regulations, including environmental laws and regulations that can adversely affect our results of operations, cash flows and financial position. This complex web of rules, regulations, conventions, treaties and laws can be dynamic and influence the cost of owning and operating our vessels.
Environmental regulations such as ballast water regulations and the regulation related to low sulfur fuel requirements may require us to incur significant costs.
If labor interruptions are not resolved in a timely manner, they could have a material adverse effect on our business, results of operations, cash flows and financial position.

1

If our vessels call at ports located in countries or territories that are subject to restrictions, sanctions or embargoes imposed by the U.S. government, the European Union, the United Nations or other governments, it could lead to monetary fines or penalties and adversely affect our reputation and the market for our Class A common shares.
We are dependent on spot charters and subject to certain risks with respect to entering into time charter-in contracts due to our dependence on spot charters, which could adversely affect our business.
We are subject to certain risks with respect to our counterparties on contracts, including dry-docking and newbuilding construction contracts, and failure of such counterparties to meet their obligations could cause us to suffer losses or negatively impact our results of operations and cash flows.
An inability to effectively time investments in and divestments of vessels could prevent the implementation of our business strategy and negatively impact our results of operations and financial condition.
A substantial portion of our revenues is derived from a limited number of customers, and the loss of any of these customers could result in a significant loss of revenues and cash flow.
We may not be able to meet our ongoing operations and working capital needs and may not be able to obtain additional financing in the future on acceptable terms or at all.
As our product tanker fleet ages, we are exposed to increased operating costs and decreased competitiveness, which could adversely affect our earnings, and the risks associated with older vessels could adversely affect our ability to obtain profitable charters.
A shift in consumer demand from oil and oil products towards other energy sources or changes to trade patterns for refined oil products may have a material adverse effect on our business.
Any failure to pass vessel inspections by classification societies and other private and governmental entities and operate our vessels may have a material adverse effect on our future performance, results of operations, cash flows and financial position. With the implementation of SIRE 2.0 that started in the fourth quarter of 2022 TORM may experience a decline in tradability and lead to additional vessel inspections.
Obligations associated with being a U.S.-listed public company require significant resources and management attention, and we incur increased costs as a result of being a U.S.-listed public company. Furthermore, if we fail to comply with rules of the U.S. Securities and Exchange Commission including those promulgated to the Sarbanes-Oxley Act of 2002, including as amended by the Holding Foreign Companies 3 Accountable Act, we may be subject to fines from the U.S. Securities and Exchange Commission or delisting from Nasdaq
U.S. tax authorities could treat us as a ‘‘passive foreign investment company’’, which could have adverse U.S. federal income tax consequences to U.S. shareholders.
Insurance may be difficult to obtain, or if obtained, may not be adequate to cover our losses that may result from our operations due to the inherent operational risks of the product tanker industry.
Breakdowns in our information technology, including as a result of cyberattacks, may negatively impact our business, including our ability to service customers, and may have a material adverse effect on our future performance, results of operations, cash flows and financial position.
We have a significant amount of financial debt, and servicing our current or future indebtedness may limit liquidity available for other purposes.
Our financial and operational flexibility is restricted by the covenants contained in our debt facilities, and we may be unable to comply with the restrictions and financial covenants imposed in such facilities.

2

Change of control and mandatory repayment provisions contained in certain of our debt facilities may lead to a foreclosure of our fleet.
We are exposed to volatility in the USD London Interbank Offered Rate, or LIBOR, and the potential discontinuance of LIBOR beyond 2023, which could, while limited, affect our profitability, earnings and cash flow.
The majority of our Class A shares are held by a limited number of shareholders, which may create conflicts of interest.
The United Kingdom has formally withdrawn from the European Union, and the implications for the laws and regulations in the United Kingdom are uncertain.
We are and will be subject to the United Kingdom Bribery Act, the U.S. Foreign Corrupt Practices Act and other anti-corruption laws as well as export control laws, customs laws, sanctions laws and other laws governing our operations. If we fail to comply with these laws, we could be subject to civil or criminal penalties, other remedial measures and legal expenses, which could adversely affect our business, results of operations and financial condition.
Increasing scrutiny and changing expectations from investors, lenders and other market participants with respect to our Environmental, Social and Governance (“ESG”) policies may impose additional costs on us or expose us to additional risks.

The following risks relate principally to the industry in which we operate and our business in general. The occurrence of any of the risk factors described herein could have a material adverse effect on our future performance, results of operations, cash flows and our financial position. We may also be subject to other material risks that as of the date of this annual report are not currently known to us or that we currently deem immaterial but which may significantly impair our business.

Risks Related to Our Business and Our Industry

The product tanker sector is cyclical and volatile, and this may lead to reductions and volatility in our charter rates when we re-charter our vessels, in vessel values and in our results of operations.

We are a pure-play product tanker company, meaning that most of our revenues are generated from operating our product tanker fleet. The product tanker market is cyclical in nature, which leads to volatility in freight rates, vessel values and industry profitability. The freight rates among different types of product tankers are highly volatile. For example, product tanker freight rates declined from the cyclical high levels reached in mid-2008 (TORM Medium Range (MR) Time Charter Equivalent, or TCE, rates up to $26,458/day) to a cyclical low period between 2009 and 2014 (TORM observed annual average MR TCE rates of approximately $14,200/day for the period). During 2021, we realized TCE rates of $13,703/day and this increased by 149% during 2022 to TCE rates of $34,154/day. A worsening of current global economic conditions may cause tanker charter rates to decline and thereby adversely affect our ability to charter or re-charter our vessels and any renewal or replacement charters that we enter into, may not be sufficient to allow us to operate our vessels profitably. In addition, the conflict in Ukraine is disrupting energy production and trade patterns, including shipping in the Black Sea and elsewhere, and its impact on energy prices and tanker rates, which initially have increased, is uncertain. The factors affecting the supply and demand for product tankers are beyond our control, and the nature, timing and degree of changes in industry conditions are unpredictable and we may not be able to correctly assess the nature, timing and degree of changes in industry conditions.

Factors affecting the supply and growth of product tanker capacity include:

supply and demand for energy resources and petroleum products;
the degree of scrapping or recycling of older vessels, depending, among other things, on scrapping or recycling rates and international scrapping or recycling regulations;
the number and size of newbuilding orders and deliveries, including slippage in deliveries, as may be impacted by the availability of financing for shipping activity;

3

the number of vessels used for floating storage;
the number of vessels in lay-up;
the number of vessels recycled for obsolescence or subject to casualties;
prevailing and expected future freight and charter hire rates;
the number of product tankers trading with crude or “dirty” oil products;
costs of bunkers and fuel oil and their impact on vessel speed;
the efficiency and age of the world product tanker fleet;
the number of shipyards and ability of shipyards to deliver vessels;
availability of financing including with respect to new vessels and shipping activity;
available interest rates on financing;
port and canal congestion;
technological developments, which affect the efficiency of vessels and time to vessel obsoletion;
government and industry regulation of maritime transportation practices, particularly environmental protection laws and regulations;
the number of vessel casualties;
the degree of scrapping or recycling rate of older vessels, depending, amongst other things, on scrapping or recycling rates and international scrapping or recycling regulations;
price of steel and vessel equipment;
the number of conversions of tankers to other uses or conversions of other vessels to tankers;
the number of vessels that are out of service, namely those that are laid up, drydocked, awaiting repairs or otherwise not available for hire;
product imbalances and hence lack of or surplus supply in certain regions (affecting the level of trading activity);
developments in international trade, including refinery additions and closures;
speed of vessel operation;
crew availability;

Demand for product tankers is primarily determined by the quantity of cargo to be transported and the distance from origin to destination. The demand is affected by a number of external factors including:

demand for alternative energy resources;
world and regional economic conditions;

4

increases in the production of oil in areas linked by pipelines to consuming areas, the extension of existing, or the development of new, pipeline systems in markets we may serve, or the conversion of existing non-oil pipelines to oil pipelines in those markets;
sanctions on harbors, transportation of oil products or parts of the world fleet;
demand for energy sources and oil and other petroleum products and changes in the consumption of oil and petroleum products due to availability of new, alternative energy sources or changes in the price of oil and petroleum products relative to other energy sources or other factors making consumption of oil and petroleum products less attractive;
the regulatory environment;
environmental issues and concerns;
developments in international trade including refinery additions and closures;
currency exchange rates;
the distance over which oil and oil products are to be moved by sea;
changes in seaborne and other transportation patterns;
climate, weather and natural disasters;
global and regional political developments, including “trade wars”, armed conflicts, including the ongoing conflict between Russia and Ukraine, and other international hostilities, terrorist activities and strikes;
international sanctions, embargoes, import and export restrictions, nationalizations and wars; and
availability of financing and changes in interest rates.

In addition to the prevailing and anticipated freight rates, factors that greatly affect our financial profitability will include newbuilding, recycling and laying-up prices, second-hand vessel values in relation to recycling prices, cost of bunkers, cost of crew, vessel availability, other operating costs, costs associated with classification society surveys, normal maintenance costs, insurance coverage costs and the efficiency and age profile of the existing product tanker fleet in the market and the economic lives of our vessels. We have adopted a new green recycling policy in 2021.

We anticipate that the future demand for our vessels will be dependent upon economic growth in the world’s economies, seasonal as well as regional changes in demand, changes in the capacity of the global product tanker fleet and the sources and supply of oil and petroleum products to be transported by sea. Adverse economic, political, social or other developments could have a material adverse effect on our business and operating results. The product tanker sector is cyclical and volatile, and this may lead to reductions and volatility in our charter rates when we employ our vessels, to volatility in vessel values and in our future performance, results of operations, cash flows and our financial position.

Our business is affected by macroeconomic conditions, including rising inflation, interest rates, market volatility, economic uncertainty, and supply chain constraints.

There has historically been a strong link between the development of the world economy and demand for energy, including oil and gas. An extended period of deterioration in the outlook for the world economy could reduce the overall demand for oil and gas and for our services. While product tanker market conditions have improved during the course of 2022, continued adverse and developing economic and governmental factors, together with the concurrent volatility in charter rates and vessel values, may have a material adverse effect on our results of operations, financial condition and cash flows, and could cause the price of our ordinary shares to decline.

5

Our ability to secure funding is dependent on well-functioning capital markets and on an appetite to provide funding to the shipping industry. At present, capital markets are well-functioning and funding is available for the shipping industry. However, if global economic conditions worsen or lenders for any reason decide not to provide debt financing to us, we may not be able to secure additional financing to the extent required, on acceptable terms or at all. If additional financing is not available when needed, or is available only on unfavorable terms, we may be unable to meet our obligations as they come due, or we may be unable to enhance our existing business, complete additional vessel acquisitions or otherwise take advantage of business opportunities as they arise. Relatedly, certain banks have reduced or ceased lending for oil cargoes, which could have an adverse economic impact on our customers.

Various macroeconomic factors could adversely affect our business and the results of our operations and financial condition, including changes in inflation, interest rates and overall economic conditions and uncertainties such as those resulting from the current and future conditions in the global financial markets. For instance, inflation has negatively impacted us by increasing our labor costs, through higher wages and further operating costs. Increasing inflation has subsequently led to increasing interest rates affecting our financial cost as well as our financial income. Supply chain constraints have led to higher inflation, which if sustained could have a negative impact on our product development and operations. If inflation or other factors were to significantly increase, our business operations may be negatively affected. Interest rates, the liquidity of the credit markets and the volatility of the capital markets could also affect the operation of our business and our ability to raise capital on favorable terms, or at all, in order to fund our operations.

Our revenues are derived substantially from a single segment, the product tanker segment, which exposes us to adverse developments in the product tanker market and which may adversely affect our future performance, results of operations, cash flows and financial position.

Substantially all of our revenues are derived from a single market, the product tanker segment, and therefore, our financial results depend on the development and growth in this segment. External factors that affect the product tanker market will have a significant impact on our business. Freight rates and asset prices have been volatile. Any adverse development in the product tanker segment would have a material adverse impact on our future performance, results of operations, cash flows and financial position. Further, our lack of diversification makes us increasingly vulnerable to adverse developments in the international product tanker market, and this could have a greater material adverse impact on our future performance, results of operations, cash flows and financial position than it would if we maintained more diverse lines of business.

An oversupply of product tanker capacity may lead to reductions in charter hire rates, vessel values and profitability.

The supply of product tankers is affected by a number of factors such as supply and demand for energy resources, including oil and petroleum products, supply and demand for seaborne transportation of such energy resources and the current and expected purchase orders for newbuildings. If the capacity of new product tankers delivered exceeds the capacity of product tankers being recycled and converted to non-trading tankers, overall industry capacity in the product tanker will increase. If the supply of product tanker capacity increases, and if the demand for product tanker capacity decreases or does not increase correspondingly, charter rates could materially decline, which may also negatively affect freight rates and the value of our vessels. During 2022, the value of our product tanker fleet, based on independent broker quotes, increased by approximately 41% (excluding vessels that we sold and/or acquired during 2022). A reduction in charter rates and the value of our vessels may have a material adverse effect on our future performance, results of operations, cash flows and financial position.

In addition, product tankers may be “cleaned up” from “dirty/crude” trades and swapped back into the product tanker market, which would increase the available tanker tonnage able to transport refined oil products and which may affect the supply and demand balance for product tankers. This could have a material adverse effect on our future performance, results of operations, cash flows and financial position.

Our results of operations are subject to seasonal fluctuations, which may adversely affect our results of operations, cash flows and financial position.

We operate our vessels in markets that have historically exhibited seasonal variations in demand and, as a result, freight rates. This seasonality may result in quarter-to-quarter volatility in operating results. The product tanker segment is typically stronger in the fall and winter months in anticipation of increased consumption of oil and petroleum products in the northern hemisphere. As a result, revenues from product tankers may be weaker during the fiscal quarters ending June 30 and September 30, and, conversely, revenues may be stronger in fiscal quarters ending December 31 and March 31. This seasonality could have a material adverse effect quarter to quarter on our future performance, results of operations, cash flows and financial position.

6

Variations in incoming cash flows due to the cyclical nature of the shipping industry may have a material adverse effect on our future performance, results of operations and financial position.

Due to the cyclical nature of the shipping industry and volatile freight rates, incoming cash flows may vary significantly from year to year, whereas outgoing operating and financing cash flows may not vary to the same extent and at the same time. Significant deviations between ingoing and outgoing cash flows can thus damage our financial position and could have a material adverse effect on our future performance, results of operations, cash flows and financial position.

A shift in consumer demand from oil and oil products towards other energy sources or changes to trade patterns for refined oil products may have a material adverse effect on our business.

A significant portion of our earnings are related to the oil industry. A shift in or disruption of the consumer demand from oil and oil products towards other energy resources such as electricity, LNG or hydrogen will potentially affect the demand for our product tankers. A shift from the use of internal combustion engine vehicles to electric vehicles may also reduce the demand for oil. These factors could have a material adverse effect on our future performance, results of operations, cash flows and financial position.

Seaborne trading and distribution patterns are primarily influenced by the relative advantage of the various sources of production, locations of consumption, pricing differentials and seasonality. Changes to the trade patterns of refined oil products may have a significant negative or positive impact on the ton-mile and therefore the demand for our product tankers. This could have a material adverse effect on our future performance, results of operations, cash flows and financial position.

“Peak oil” is the year when the maximum rate of extraction of oil is reached. Recent forecasts of “peak oil” range from 2022 to the 2040s, depending on economics and how governments respond to global warming. OPEC maintain that demand for oil will plateau around 2040, despite transition toward other energy sources. Irrespective of “peak oil”, the continuing shift in consumer demand from oil and oil products towards other energy resources such as wind energy, solar energy, hydrogen energy or nuclear energy, which shift appears to be accelerating as a result of the COVID-19 pandemic, as well shift in government commitments and support for energy transition programs, may have a material adverse effect on our future performance, results of operations, cash flows and financial position.

Acts of piracy on ocean-going vessels could adversely affect our business.

Acts of piracy have historically affected ocean-going vessels. At present, most piracy and armed robbery incidents are recurrent in the Gulf of Aden region off the coast of Somalia, South China Sea, Sulu Sea, Celebes Sea and in particular, the Gulf of Guinea region, which has experienced increased incidents of piracy in recent years. Sporadic incidents of robbery are also reported in many parts of Asia. The political turmoil in the Middle East region may also lead to collateral damages in waters off Yemen as well as in the Gulf of Oman or Arabian Gulf. The current diplomatic crisis between Gulf Co-operation Council (GCC) countries may lead to an uncertain security situation in the Middle East region.

The security arrangements made for ship staff and vessels to counteract the ever-evolving security threat and to comply with Best Management Practices to Deter Piracy and Enhance Maritime Security in the Red Sea, Gulf of Aden, the Gulf of Guinea region, Indian Ocean and Arabian Sea add to the cost of operations of our ships.

The “war risks” areas are established by the Joint War Risks Committee. Our vessels often trade in “war risk” areas due to the nature of our business. Due to the above issues when vessels trade in such areas, the insurance premiums are increased significantly to cover for the additional risks.

The above factors could have a material adverse effect on our future performance, results of operations, cash flows and financial position.

7

Increase in frequency of immigrant salvage operations in the Mediterranean could adversely affect our business.

In recent years, the number of immigrants attempting to cross the Mediterranean from North Africa to Europe in unseaworthy vessels has increased significantly. Many of the vessels are in such a poor condition that they capsize and sink, incur engine problems or are otherwise incapacitated en route to Europe. As a result, commercial ships may, if witnessing an immigrant vessel in distress, deviate from the task and course and conduct a salvage operation. Such salvage operation may prove costly in terms of time and resources spent and can thus prove a substantial cost for the commercial vessel and may pose risks to the safety of the crew, vessel and cargo. If we are not able to mitigate this potential exposure, and dependent on the number of such salvage operations which must be carried out in the future, this could have a material adverse effect on our future performance, results of operations, cash flows and financial position.

Rising fuel, or bunker, prices may adversely affect our profits.

Since we primarily employ our vessels in the spot market, we expect that fuel, or bunkers, will typically be the largest expense in our shipping operations for our vessels. The cost of fuel, including the fuel efficiency or capability to use lower priced fuel, can also be an important factor considered by charterers in negotiating charter rates. While we believe that we can transfer increased cost to the customer, and will experience a competitive advantage as a result of increased bunker prices due to the greater fuel efficiency of our vessels compared to the average global fleet, changes in the price of fuel may adversely affect our profitability. The price and supply of fuel is unpredictable and fluctuates based on events outside our control, including geopolitical developments, such as but not limited to the conflicts between Russia and Ukraine, supply and demand for oil and gas, actions by the Organization of the Petroleum Exporting Countries (the “OPEC”), and other oil and gas producers, war and unrest in oil producing countries and regions, regional production patterns and environmental concerns. Fuel may therefore become much more expensive in the future and we might not be able to fully recover this increased cost through our charter rates.

Furthermore, fuel may become significantly more expensive in the future, which may reduce our profitability. In addition, the entry into force, on January 1, 2020, of the 0.5% global sulfur cap in marine fuels used by vessels that are not equipped with sulfur oxide (“SOx”) exhaust gas cleaning systems (“scrubbers”) under the International Convention for Prevention of Pollution from Ships (“MARPOL”) Annex VI may lead to changes in the production quantities and prices of different grades of marine fuel by refineries and introduces an additional element of uncertainty in fuel markets, which could result in additional costs and adversely affect our cash flows, earnings and results from operations.

An economic slowdown or changes in the economic and political environment in the Asia Pacific region could have a material adverse effect on our business, financial condition, and results of operations.

We anticipate a significant number of port calls made by our vessels will continue to involve the loading or discharging of cargo in ports in the Asia Pacific region. As a result, any negative changes in economic conditions in any Asia Pacific country, particularly in China, may have a material adverse effect on our business, financial condition and results of operations, as well as our future prospects. Before the global economic financial crisis that began in 2008, China had one of the world’s fastest growing economies in terms of gross domestic product, or GDP, which had a significant impact on shipping demand. The annual year-over-year growth rate through the fourth quarter of 2022 was 4.0%, down from 8.1% for the year ended December 31, 2021. Although China’s GDP growth is expected to accelerate in 2023 as the global economy is set to recover from the heath crisis, there is a continuous threat of a Chinese financial crisis resulting from excessive personal and corporate indebtedness and “trade wars.” In recent years, China and the United States have implemented certain increasingly protective trade measures with continuing trade tensions, including significant tariff increases, between these countries. Although the United States and China successfully reached an interim trade deal in January 2020 that deescalated the trade tensions with both sides rolling back tariffs, the extent to which the trade deal will be successfully implemented is unpredictable. Notwithstanding the interim trade deal, the US policy on China may not change dramatically under President Joe Biden and there is no assurance that the Chinese economy will not experience a significant slowdown in the future. Further increased geopolitical tensions in 2022 and early 2023 may intensify and impact trade flows and product tanker flows in the future. A decrease in the level of imports to and exports from China could adversely affect our business, operating results and financial condition.

8

Although state-owned enterprises still account for a substantial portion of the Chinese industrial output, in general, the Chinese government is reducing the level of direct control that it exercises over the economy through state plans and other measures. There is an increasing level of freedom and autonomy in areas such as allocation of resources, production, pricing and management and a gradual shift in emphasis to a “market economy” and enterprise reform. Limited price reforms were undertaken with the result that prices for certain commodities are principally determined by market forces. Many of the reforms are unprecedented or experimental and may be subject to revision, change or abolition based upon the outcome of such experiments. If the Chinese government does not continue to pursue a policy of economic reform, the level of imports to and exports from China could be adversely affected by changes to these economic reforms by the Chinese government, as well as by changes in political, economic and social conditions or other relevant policies of the Chinese government, such as changes in laws, regulations or export and import restrictions. Notwithstanding economic reform, the Chinese government may adopt policies that favor domestic shipping companies and may hinder our ability to compete with them effectively. For example, China imposes a tax for non-resident international transportation enterprises engaged in the provision of services of passengers or cargo, among other items, in and out of China using their own, chartered or leased vessels. The regulation may subject international transportation companies to Chinese enterprise income tax on profits generated from international transportation services passing through Chinese ports. This tax or similar regulations, such as the recently promoted environmental taxes on coal, by China may result in an increase in the cost of raw materials imported to China and the risks associated with importing raw materials to China, as well as a decrease in any raw materials shipped from our charterers to China. This could have an adverse impact on our charterers’ business, operating results and financial condition and could thereby affect their ability to make timely charter hire payments to us and to renew and increase the number of their time charters with us. Moreover, an economic slowdown in the economies of the European Union and other Asian countries may further adversely affect economic growth in China and elsewhere.

Also, several initiatives are underway in China with a view to reduce their dependency on (foreign) oil, such as the Net Zero 2060 initiative and development of shale oil on their own territory, which could impact the need for oil transportation services. The method by which China attempts to achieve carbon neutrality by 2060, and any attendant reduction in the demand for oil, petroleum and related products, could have a material adverse effect on our business, cash flows and results of operations.

Outside of Asia, the product tanker industry may be negatively affected if a potential economic slowdown in Latin America or Africa were to cause a decrease in imports of refined products from the United States or Europe. This, in turn, could have a negative impact on our earnings, cash flows and financial position.

The COVID-19 pandemic and the resulting disruptions to the international shipping industry may again adversely affect our business, financial performance and our results of operations, including the ability to obtain charters and financing.

The COVID-19 pandemic has led a number of countries, ports and organizations to take measures against its spread, including travel bans, quarantines, and other emergency public health measures, including lockdowns, which resulted in a significant reduction in global economic activity and extreme volatility in the global financial and commodities markets (including oil). These measures have and will likely continue to cause severe trade disruptions due to, among other things, the unavailability of personnel, supply chain disruption, interruptions of production, delays in planned strategic projects and closure of businesses and facilities.

We expect that COVID-19 will continue to cause volatility in the commodities markets, however, due to progress with vaccines, the need for wide-scale mobility restrictions is less, implying less severe negative impact on oil demand in the future. Nevertheless, the scale and duration of these circumstances is unknowable but could have a material impact on our earnings, cash flow and financial condition for 2023 and beyond. The ultimate extent to which the COVID-19 outbreak impacts our business, financial condition, and results of operations will depend on future developments, which are highly uncertain, difficult to predict, and subject to change, including, but not limited to, the duration, scope, severity, proliferation of variants and increase in the transmissibility of the virus, its impact on the global economy, actions taken to contain or limit the impact of COVID-19, such as the availability of an effective vaccine or treatment, geographic variation in how countries and states are handling the pandemic, how long current restrictions over travel and economic activity in many countries across the globe remain in place over the course of the pandemic, and how quickly and to what extent normal economic and operating conditions may potentially resume.

Travel restrictions imposed on a global level also caused disruptions in scheduled crew changes on our vessels and delays in carrying out of certain hull repairs and maintenance during 2022, which disruptions could also continue to affect our operations. Our business and the shipping industry as a whole may continue to be impacted by a reduced workforce and delays of crew changes as a result of quarantines applicable in several countries and ports, as well as delays in the construction of newbuild vessels, scheduled drydockings, intermediate or special surveys of vessels and scheduled and unscheduled ship repairs and upgrades. In addition, any case of COVID-19 amongst crew, could result in a quarantine period for that vessel and, in turn, loss of charter hire and additional costs.

9

Over a longer time, increasing climate change related actions could have a negative impact on TORM earnings.

Over 2022, focus on climate change related issues increased not least in the framework of the COP26, with several countries including. the US, the United Kingdom and the European Union accelerating their climate targets. The Glasgow Climate Pact, an agreement reached at the COP26, calls for signatory states to voluntarily phase out unabated coal usage and fossil fuels subsidies. COP26 also produced the Clydebank Declaration, in which 22 signatory states (including the United States and the United Kingdom) announced their intention to voluntarily support the establishment of zero-emission shipping routes. Governmental and investor pressure to voluntarily participate in these green shipping routes could cause the Company to incur significant additional expenses to “green” our vessels. Even though many of these measures still need to be implemented and the real impact will impact us over longer time, accelerated take-up of electric vehicles during 2022 suggests that in the road transportation sector, demand for fossil fuels is on the steady path to decline.

Even though the demand for product tankers is more affected by regional imbalances between oil product demand and supply, rather than absolute level of oil demand, demand deterioration over longer term can have a negative impact for TORM earnings.

The Company may be impacted by transitional and other risks arising from climate change.

The Company may be impacted by transitional and other risks arising from climate change and the global shift toward a low carbon future. Organizational, industrial and governmental shifts in operations as well as legal and regulatory requirements to reduce or eliminate emissions and/or increase efficiency may require the Company to increase expenditures, make changes to existing infrastructure, vessels and equipment and shift its business model. For example, the maritime industry is moving toward deployment of clean energy technologies and use of electricity powered by renewable energy sources to power terminal operations as a way to reduce shoreside greenhouse gas emissions. Compliance with new climate change requirements or regulations such as the International Maritime Organization’s (“IMO”) requirements related to Energy Efficiency Existing Ship Index (“EEXI”) and operational carbon intensity reduction requirements, based on a new operational Carbon Intensity Indicator (“CII”) could require the Company’s fleet to slow down if efficiency improvements or transitions to alternative fuels together are not enough to reduce greenhouse gas emissions sufficiently, thus impacting the Company’s expedited business model and competitive advantage. New environmental requirements for vessel performance and operation could also require the Company to accelerate the building of new vessels, increase the construction costs for new vessels and equipment to accommodate even newer technology as it emerges while today’s technology becomes obsolete, initiate unexpected retrofit projects for existing vessels or retire older vessels earlier than expected. If these outcomes were to occur, the Company’s business, results of operations, cash flows and financial condition could be adversely affected.

We are subject to complex laws and regulations, including environmental laws and regulations that can adversely affect our results of operations, cash flows and financial position.

We operate worldwide, where appropriate, through agents or other intermediaries. Compliance with complex local, foreign and U.S. laws and regulations that apply to our international operations increases our cost of doing business. These numerous and sometimes conflicting laws and regulations include, among others, data privacy requirements (in particular the European General Data Protection Regulation, enforceable as from May 25, 2018 and the EU-US Privacy Shield Framework, as adopted by the European Commission on July 12, 2016), labor relations laws, tax laws, anti-competition regulations, import and trade restrictions, export requirements, U.S. laws such as the FCPA and other U.S. federal laws and regulations established by the office of Foreign Asset Control, local laws such as the United Kingdom Bribery Act 2010 or other local laws which prohibit corrupt payments to governmental officials or certain payments or remunerations to customers.

Given the high level of complexity of these laws, there is a risk that we, our agent or other intermediaries may inadvertently breach certain provisions thereunder. Violations of these laws and regulations could result in fines, criminal sanctions against us, our officers or our employees, requirements to obtain export licenses, cessation of business activities in sanctioned countries, implementation of compliance programs, and prohibitions on the conduct of our business. Violations of laws and regulations also could result in prohibitions on our ability to operate in one or more countries and could materially damage our reputation, our ability to attract and retain employees, or our business, results of operations and financial condition. Furthermore, detecting, investigating and resolving actual or alleged violations is expensive and can consume significant time and attention of our senior management. Though we have implemented monitoring procedures and required policies, guidelines, contractual terms and audits, these measures may not prevent or detect failures by our agents or intermediaries regarding compliance.

10

Our vessels operate worldwide and are thus subject to numerous international laws, rules, regulations, conventions and treaties. Moreover, our vessels are registered, flagged, and call in ports in multiple countries where the applicable flag and/or port state rules, regulations and laws can differ. This complex web of rules, regulations, conventions, treaties and laws can be dynamic and influence the cost of owning and operating our vessels.

The various requirements we might have to comply with are discussed throughout and include, but are not limited to:

International requirements such as those from the International Maritime Organization, or IMO, like the International Convention for the Safety of Life at Sea of 1974, or SOLAS, the International Ship and Port Facility Security Code, or the ISPS Code, and the International Convention for the Prevention of Pollution from Ships of 1973, as from time to time amended, or MARPOL, as well as those from the Maritime Labor Convention 2006, or the MLC 2006, adopted by the International Labour Organization, or ILO;
United States, or U.S., requirements such as the U.S. Oil Pollution Act of 1990, or OPA, the Comprehensive Environmental Response, Compensation and Liability Act, or CERCLA, and those enforced by the U.S. Environmental Protection Agency, or the EPA, and the U.S. Coast Guard, or the USCG; and
European Union, or EU, regulations regarding greenhouse gas emissions.

Some laws also impose strict liability for pollution incidents. To avoid liability in those cases, parties may have to show they fall into an exception and took all reasonable precautionary steps to prevent a pollution incident. Thus, for remediation of environmental damage, the liability can include fines, penalties, criminal liability and costs for natural resource damages. In our case, these could harm our reputation with current or potential charterers of our product tankers. Compliance with environmental laws and regulations, where applicable, may require installation of costly equipment or operational changes and may affect the resale value or useful lives of our vessels. We may also incur additional costs in order to comply with other existing and future regulatory obligations, including, but not limited to, costs relating to air emissions including greenhouse gases, sulfur emissions, the management of ballast waters, maintenance and inspection, development and implementation of emergency procedures and insurance coverage or other financial assurance of our ability to address pollution incidents.

We are required to satisfy insurance and financial responsibility requirements for potential oil (including marine fuel) spills and other pollution incidents. Although we arrange insurance to cover environmental risks, there can be no assurance that such insurance will be sufficient to cover all the risks or that any claims will not have a material adverse effect on our future performance, results of operations, cash flows and financial position.

Developments in safety and environmental requirements relating to the recycling of vessels may result in escalated and unexpected costs.

The 2009 Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (the “Hong Kong Convention”), aims to ensure ships, being recycled once they reach the end of their operational lives, do not pose any unnecessary risks to the environment, human health and safety. The Hong Kong Convention has yet to be ratified by the required number of countries to enter into force. Upon the Hong Kong Convention’s entry into force, each ship sent for recycling will have to carry an inventory of its hazardous materials. The hazardous materials, whose use or installation are prohibited in certain circumstances, are listed in an appendix to the Hong Kong Convention. Ships will be required to have surveys to verify their inventory of hazardous materials initially, throughout their lives and prior to the ship being recycled. The Hong Kong Convention, which is currently open for accession by IMO member states, will enter into force 24 months after the date on which 15 IMO member states, representing at least 40% of world merchant shipping by gross tonnage, have ratified or approved accession. As of the date of this annual report, 20 countries have ratified or approved accession of the Hong Kong Convention, but the requirement of 40% of world merchant shipping by gross tonnage has not yet been satisfied.

On November 20, 2013, the European Parliament and the Council of the EU adopted the EU Ship Recycling Regulation, or ESSR, which retains the requirements of the Hong Kong Convention and requires that certain commercial seagoing vessels flying the flag of an EU member state may be recycled only in facilities included on the European list of permitted ship recycling facilities.

11

Apart from that, any vessel, including ours, is required to set up and maintain an Inventory of Hazardous Materials from December 31, 2018 for EU flagged new ships and from December 31, 2020 for EU flagged existing ships and Non-EU flagged ships calling at a port or anchorage of an EU member state. Such a system includes Information on the hazardous materials with a quantity above the threshold values specified in relevant EU Resolution and are identified in ship’s structure and equipment. This inventory should be properly maintained and updated, especially after repairs, conversions or unscheduled maintenance on board the ship.

Under the ESSR, commercial EU-flagged vessels of 500 gross tonnage and above may be recycled only at shipyards included on the European List of Authorised Ship Recycling Facilities (the “European List”). As of December 31, 2021, all our EU-flagged vessels met this weight specification. The European List presently includes eight facilities in Turkey but no facilities in the major ship recycling countries in Asia. The combined capacity of the European List facilities may prove insufficient to absorb the total recycling volume of EU-flagged vessels. This circumstance, taken in tandem with the possible decrease in cash sales, may result in longer wait times for divestment of recyclable vessels as well as downward pressure on the purchase prices offered by European List shipyards. Furthermore, facilities located in the major ship recycling countries generally offer significantly higher vessel purchase prices, and as such, the requirement that we utilize only European List shipyards may negatively impact revenue from the residual values of our vessels.

In addition, on December 31, 2018, the European Waste Shipment Regulation, or EWSR, requires that non-EU flagged ships departing from EU ports be recycled only in Organization for Economic Cooperation and Development (OECD) member countries. In March 2018, the Rotterdam District Court ruled that the sale of four recyclable vessels by third-party Dutch ship owner Seatrade to cash buyers, who then reflagged and resold the vessels to non-OECD country recycling yards, were effectively indirect sales to non-OECD country yards, in violation of the EWSR. If European Union Member State courts widely adopt this analysis, it may negatively impact revenue from the residual values of our vessels and we may be subject to a heightened risk of non-compliance, due diligence obligations and costs in instances where we sell older ships to cash buyers.

These regulatory requirements may lead to cost escalation by shipyards, repair yards and recycling yards. This may then result in a decrease in the residual recycling value of a vessel, which could potentially not cover the cost to comply with the latest requirements, which may have an adverse effect on our future performance, results of operations, cash flows and financial position. We have adopted a new green recycling policy in 2021.

We may incur additional costs to retrofit ballast water treatment systems in our vessels to comply with new regulations.

Vessels unload ballast water during passage by taking ballast water in one port and unloading it in another. This helps maintain safety and stability. However, the ballast water can contain local organisms and pathogens. When vessels unload ballast water, they can then release organisms and pathogens in new parts of the world, which can be invasive to that ecosystem. To avoid transfers of invasive species in ballast water, the IMO and the United States have regulations that require ballast water is treated prior to discharge.

In order to comply with IMO and U.S. ballast water regulations, we are required to install ballast water treatment plants on all vessels from December 2018 to September 2024. The cost of compliance per vessel for us is estimated to be between $1.0 and $1.3 million, depending on size of the vessel. There are uncertainties associated with installing the equipment both operationally and technically, which could have adverse effect on the cost. Significant investments in ballast water treatment systems may have a material adverse effect on our future performance, results of operations, cash flows and financial position. As of December 31, 2022, TORM has installed 69 ballast water treatment systems with another 16 scheduled to be completed by the end of the first quarter 2024.For more information on these regulations, see “Item 4. Information on the Company-B. Business Overview-Environmental and Other Regulations-The International Maritime Organization-Pollution Control and Liability Requirements.”

Regulations relating to ballast water discharge may adversely affect our revenues and profitability.

The IMO has imposed updated guidelines for ballast water management systems specifying the maximum amount of viable organisms allowed to be discharged from a vessel’s ballast water. Depending on the date of the International Oil Pollution Prevention (the “IOPP”) renewal survey, existing vessels constructed before September 8, 2017 must comply with the updated D-2 standard on or after September 8, 2019. For most vessels, compliance with the D-2 standard will involve installing on-board systems to treat ballast water and eliminate unwanted organisms. Ships constructed on or after September 8, 2017 are to comply with the D-2 standards upon delivery. All of our vessels comply with the updated guideline.

12

Furthermore, United States regulations are currently changing. Although the 2013 Vessel General Permit (“VGP”) program and U.S. National Invasive Species Act (“NISA”) are currently in effect to regulate ballast discharge, exchange and installation, the Vessel Incidental Discharge Act (“VIDA”), which was signed into law on December 4, 2018, requires that the U.S. Environmental Protection Agency (the “EPA”) develop national standards of performance for approximately 30 discharges, similar to those found in the VGP within two years. On October 26, 2020, the EPA published a Notice of Proposed Rulemaking for Vessel Incidental Discharge National Standards of Performance under VIDA. Within two years after the EPA publishes its final Vessel Incidental Discharge National Standards of Performance, the U.S. Coast Guard (“USGC”) must develop corresponding implementation, compliance, and enforcement regulations regarding ballast water. The new regulations could require the installation of new equipment, which may cause us to incur substantial costs.

Several countries have announced a ban on using open-loop scrubbers in their ports and inland waters

To comply with IMO 2020 0.5% global sulfur cap, shipowners have different options: switching to low-sulfur fuels, burning distillates, using LNG or installing an exhaust gas cleaning system, commonly known as a scrubber, on board their vessels. Scrubbers are currently an accepted measure in complying with IMO 2020. Scrubbers can be designed either as “closed-loop” or “open-loop”. Open-loop scrubbers discharge the “cleaned” washwater into the ocean. We have opted to install hybrid-prepared open-loop scrubbers on board our vessels, which in the future can be refitted at further costs into a hybrid scrubber that can operate in both open and closed loops. It has been widely discussed whether scrubbers in general, and in particular open-loop scrubbers, represent an environmentally sound option. A few ports and regions, including Singapore, China and certain states within the U.S., have already prohibited the discharge of washwater from scrubbers. Prior to investing in scrubbers, we evaluated scrubber economics, and the effects of local regulations have already been considered to only have a limited negative impact on the investment at this time. Further material restrictions on the use of open-loop scrubbers would likely result in vessels having to use low-sulfur fuel for longer periods, which in general comes at a higher cost compared to using scrubbers.

Climate change and greenhouse gas restrictions may adversely impact our operations and markets.

Due to concern over the risk of climate change, a number of countries and the IMO have adopted, or are considering the adoption of, regulatory frameworks to reduce greenhouse gas emissions. These regulatory measures may include, among others, adoption of cap and trade regimes, carbon taxes, increased efficiency standards and incentives or mandates for renewable energy. More specifically, on October 27, 2016, the IMO’s Marine Environment Protection Committee (the “MEPC”), announced its decision concerning the implementation of regulations mandating a reduction in sulfur emissions from 3.5% currently to 0.5% as of the beginning of January 1, 2020. Additionally, in April 2018, nations at the MEPC 72 adopted an initial strategy to reduce greenhouse gas emissions from ships. The initial strategy identifies levels of ambition to reducing greenhouse gas emissions, including (i) decreasing the carbon intensity from ships through implementation of further phases of the EEDI for new ships; (ii) reducing carbon dioxide emissions per transport work, as an average across international shipping, by at least 40% by 2030, pursuing efforts towards 70% by 2050, compared to 2008 emission levels; and (iii) reducing the total annual greenhouse emissions by at least 50% by 2050 compared to 2008 while pursuing efforts towards phasing them out entirely.

The European Commission has proposed adding shipping to the Emission Trading Scheme (ETS) as of 2023 with a phase-in period. It is expected that shipowners will need to purchase and surrender a number of emission allowances that represent their MRV-recorded carbon emission exposure for a specific reporting period. The person or organization responsible for the compliance with the EU ETS should be the shipping company, defined as the shipowner or any other organization or person, such as the manager or the bareboat charterer, that has assumed the responsibility for the operation of the ship from the shipowner. On December 18, 2022, the Environmental Council and European Parliament agreed to include maritime shipping emissions within the scope of the EU ETS on a gradual introduction of obligations for shipping companies to surrender allowances: 40% for verified emissions from 2024, 70% for 2025 and 100% for 2026. Most large vessels will be included in the scope of the EU ETS from the start. Big offshore vessels of 5,000 gross tonnage and above will be included in the ‘MRV’ on the monitoring, reporting and verification of CO2 emissions from maritime transport regulation from 2025 and in the EU ETS from 2027. General cargo vessels and off-shore vessels between 400-5,000 gross tonnage will be included in the MRV regulation from 2025 and their inclusion in EU ETS will be reviewed in 2026. Compliance with the Maritime EU ETS will result in additional compliance and administration costs to properly incorporate the provisions of the Directive into our business routines. Additional EU regulations which are part of the EU’s Fit-for-55, could also affect our financial position in terms of compliance and administration costs when they take effect.

13

Territorial taxonomy regulations in geographies where we are operating and are regulatorily liable, such as EU Taxonomy, might jeopardize the level of access to capital. For example, EU has already introduced a set of criteria for economic activities which should be framed as ‘green’, called EU Taxonomy. As long as we are an EU-based company meeting the NFRD prerequisites, we will be eligible for reporting our Taxonomy eligibility and alignment. Based on the current version of the Regulation, companies that own assets shipping fossil fuels are considered as not aligned with EU Taxonomy. The outcome of such provision might be either an increase in the cost of capital and/or gradually reduced access to financing as a result of financial institutions’ compliance with EU Taxonomy.

Since January 1, 2020, ships must either remove sulfur from emissions or buy fuel with low sulfur content, which may lead to increased costs and supplementary investments for ship owners. The interpretation of “fuel oil used on board” includes use in main engine, auxiliary engines and boilers. Shipowners may comply with this regulation by (i) using 0.5% sulfur fuels on board, which are available around the world but at a higher cost; (ii) installing scrubbers for cleaning of the exhaust gas; or (iii) by retrofitting vessels to be powered by liquefied natural gas, which may not be a viable option due to the lack of supply network and high costs involved in this process. Costs of compliance with these regulatory changes may be significant and may have a material adverse effect on our future performance, results of operations, cash flows and financial position. As of the date of this annual report, we have successfully installed scrubbers on 58 of our vessels, with another 11 installations scheduled to be completed by the end of 2023, to comply with the new regulations. In addition, one scrubber is scheduled to be installed in the first quarter of 2023 and we currently use, and intend to continue to use, compliant fuels with 0.5% sulfur content for vessels that have not been retrofitted with scrubbers, which account for approximately half of our fleet. The capital expenditure, or CAPEX, related to the confirmed scrubber orders is on average estimated below $2 million per scrubber including installation costs. The cost of compliance with these regulatory changes may be significant and may have a material adverse effect on our future performance, results of operations, cash flows and financial position. See “Item 4. Information on Company-B. Business Overview-Environmental and Other Regulations-The International Maritime Organization”.

MEPC 75 introduced draft amendments to Annex VI which impose new regulations to reduce greenhouse gas emissions from ships. These amendments introduce requirements to assess and measure the energy efficiency of all ships and set the required attainment values, with the goal of reducing the carbon intensity of international shipping. To achieve a 40% reduction in carbon emissions by 2023 compared to 2008, shipping companies are required to include: (i) a technical requirement to reduce carbon intensity based on a new Energy Efficiency Existing Ship Index (“EEXI”), and (ii) operational carbon intensity reduction requirements, based on a new operational carbon intensity indicator (“CII”). The EEXI is required to be calculated for ships of 400 gss tonnage and above. The IMO and MEPC will calculated “required” EEXI levels based on the vessel’s technical design, such as vessel type, date of creation, size and baseline. Additionally, an “attained” EEXI will be calculated to determine the actual energy efficiency of the vessel. A vessel’s attained EEXI must be less than the vessel’s required EEXI. Non-compliant vessels will have to upgrade their engine to continue to travel. With respect to the CII, the draft amendments would require ships of 5,000 gross tonnage to document and verify their actual annual operational CII achieved against a determined required annual operational CII. The vessel’s attained CII must be lower than its required CII. Vessels that continually receive subpar CII ratings will be required to submit corrective action plans to ensure compliance.

Additionally, MEPC 75 proposed draft amendments requiring that, on or before January 1, 2023, all ships above 400 gross tonnage must have an approved Ship Energy Efficiency Management Plan, or SEEMP, on board. For ships above 5,000 gross tonnage, the SEEMP would need to include certain mandatory content. MEPC 75 also approved draft amendments to MARPOL Annex I to prohibit the use and carriage for use as fuel of heavy fuel oil by ships in Arctic waters on and after July 1, 2024. The draft amendments introduced at MEPC 75 were adopted at the MEPC 76 session held on June 2021, entered into force on November 1, 2022 and became effective on January 1, 2023.

MEPC 76 adopted amendments to the International Convention on the Control of Harmful Anti-Fouling Systems on Ships, 2001, or the AFS Convention, which have been entered into force on January 1, 2023. From this date, all ships shall not apply or re-apply anti-fouling systems containing cybutryne on or after January 1, 2023; all ships bearing an anti-fouling system that contains cybutryne in the external coating layer of their hulls or external parts or surfaced on January 1, 2023 shall either: remove the anti-fouling system or apply a coating that forms a barrier to this substance leaching from the underlying non-compliance anti-fouling system.

14

In addition, although the emissions of greenhouse gases from international shipping currently are not subject to the Kyoto Protocol to the United Nations Framework Convention on Climate Change, which required adopting countries to implement national programs to reduce emissions of certain gases, or the Paris Agreement, a new treaty may be adopted in the future that includes restrictions on shipping emissions. Compliance with changes in laws, regulations and obligations relating to climate change affects the propulsion options in subsequent vessel designs and could increase our costs related to acquiring new vessels, operating and maintaining our existing vessels and require us to install new emission controls, acquire allowances or pay taxes related to our greenhouse gas emissions or administer and manage a greenhouse gas emissions program. Revenue generation and strategic growth opportunities may also be adversely affected.

Adverse effects upon the oil and gas industry relating to climate change, including growing public concern about the environmental impact of climate change, may also adversely affect demand for our services. For example, increased regulation of greenhouse gases or other concerns relating to climate change may reduce the demand for oil and gas in the future or create greater incentives for use of alternative energy sources. In addition, the physical effects of climate change, including changes in weather patterns, extreme weather events, rising sea levels, scarcity of water resources, may negatively impact our operations. Any long-term material adverse effect on the oil and gas industry could have a significant financial and operational adverse impact on our business that we cannot predict with certainty at this time.

If we fail to comply with international safety regulations, we may be subject to increased liability, which may adversely affect our insurance coverage and may result in a denial of access to, or detention in, certain ports.

The operation of our vessels is affected by governmental regulations in the form of international conventions, national, state and local laws and regulations in force in the jurisdictions in which the vessels operate, as well as in the country or countries of their registration. As such, we are subject to the requirements set forth in the IMO’s International Management Code for the Safe Operation of Ships and for Pollution Prevention, or the ISM Code. The ISM Code is promulgated by the IMO under SOLAS to provide an international standard for the safe management and operation of ships and for pollution prevention. The ISM Code requires the party with operational control of a vessel to develop and maintain an extensive safety management system that includes, among other things, the adoption of a safety and environmental protection policy setting forth instructions and procedures for the safe operation, and describing procedures for dealing with emergencies, when operating vessels. We rely on the safety management system that has been developed for our vessels for compliance with the ISM Code.

The ISM Code requires that vessel operators obtain a safety management certificate for each vessel they operate. This certificate evidences compliance by a vessel’s management with code requirements for a safety management system. No vessel can obtain a certificate unless its manager has been awarded a document of compliance, issued by each flag state, under the ISM Code. We have obtained documents of compliance for our offices and safety management certificates for all of our vessels for which the certificates are required by the ISM Code. These documents of compliance and safety management certificates are renewed as required.

Non-compliance with the ISM Code and other IMO regulations may subject the shipowner or bareboat charterer to increased liability, may lead to a reduction in, or invalidation of, available insurance coverage for affected vessels and may result in the denial of access to, or detention in, some ports. The USCG and EU authorities have indicated that vessels not in compliance with the ISM Code will be prohibited from trading in U.S. and EU ports. This could have a material adverse effect on our future performance, results of operations, cash flows and financial position. The IMO continues to review and introduce new regulations. It is impossible to predict what additional regulations, if any, may be passed by the IMO and what effect, if any, such regulations might have on our operations.

A major incident on one of our vessels affecting the safety and health of the crew could disrupt completely or delay operations thereby having a negative impact on customer confidence and on our future performance, results of operations, cash flows and financial position.

Recent action by the IMO’s Maritime Safety Committee and United States agencies indicate that cybersecurity regulations for the maritime industry are likely to be further developed in the near future in an attempt to combat cybersecurity threats. By IMO resolution, administrations are encouraged to ensure that cyber-risk management systems are incorporated by ship-owners and managers by their first annual Document of Compliance audit after January 1, 2021. In February 2021, the U.S. Coast Guard published guidance on addressing cyber risks in a vessel’s safety management system. This might cause companies to cultivate additional procedures for monitoring cybersecurity, which could require additional expenses and/or capital expenditures. The impact of future regulations is hard to predict at this time.

15

Increasing scrutiny and changing expectations from investors, lenders and other market participants with respect to our Environmental, Social and Governance (“ESG”) policies may impose additional costs on us or expose us to additional risks.

Companies across all industries are facing increasing scrutiny relating to their ESG policies. Investor advocacy groups, certain institutional investors, investment funds, lenders and other market participants are increasingly focused on ESG practices, especially as they relate to the environment health and safety, diversity, labor conditions and human rights in recent years, and have placed increasing importance on the implications and social cost of their investments. The increased focus and activism related to ESG and similar matters may hinder access to capital, as investors and lenders may decide to reallocate capital or to not commit capital as a result of their assessment of a company’s ESG practices. Failure to adapt to or comply with evolving investor, lender or other industry shareholder expectations and standards or the perception of not responding appropriately to the growing concern for ESG issues, regardless of whether there is a legal requirement to do so, may damage such a company’s reputation or stock price, resulting in direct or indirect material and adverse effects on the company’s business and financial condition.

In February 2021, the Acting Chair of the SEC issued a statement directing the Division of Corporation Finance to enhance its focus on climate-related disclosure in public company filings and in March 2021 the SEC announced the creation of a Climate and ESG Task Force in the Division of Enforcement (the “Task Force”). The Task Force’s goal is to develop initiatives to proactively identify ESG-related misconduct consistent with increased investor reliance on climate and ESG-related disclosure and investment. To implement the Task Force’s purpose, the SEC has taken several enforcement actions, with the first enforcement action taking place in May 2022, and promulgated new rules. On March 21, 2022, the SEC proposed that all public companies are to include extensive climate-related information in their SEC filings. On May 25, 2022, SEC proposed a second set of rules aiming to curb the practice of “greenwashing” (i.e., making unfounded claims about one’s ESG efforts) and would add proposed amendments to rules and reporting forms that apply to registered investment companies and advisers, advisers exempt from registration, and business development companies. These proposed sets of rules are not effective as of the date of this annual report.

The increase in shareholder proposals submitted on environmental matters and, in particular, climate-related proposals in recent years indicates that we may face increasing pressures from investors, lenders and other market participants, who are increasingly focused on climate change, to prioritize sustainable energy practices, reduce our carbon footprint and promote sustainability. As a result, we may be required to implement more stringent ESG procedures or standards so that our existing and future investors and lenders remain invested in us and make further investments in us. If we do not meet these standards, our business and/or our ability to access capital could be harmed.

Additionally, certain investors and lenders may exclude oil transport companies, such as us, from their investing portfolios altogether due to environmental, social and governance factors. These limitations in both the debt and equity capital markets may affect our ability to grow as our plans for growth may include accessing the equity and debt capital markets. If those markets are unavailable, or if we are unable to access alternative means of financing on acceptable terms, or at all, we may be unable to implement our business strategy, which would have a material adverse effect on our financial condition and results of operations and impair our ability to service our indebtedness. Further, it is likely that we will incur additional costs and require additional resources to monitor, report and comply with wide ranging ESG requirements. Members of the investment community are also increasing their focus on ESG disclosures, including disclosures related to greenhouse gases and climate change in the energy industry in particular, and diversity and inclusion initiatives and governance standards among companies more generally. As a result, we may face increasing pressure regarding our ESG disclosures. The occurrence of any of the foregoing could have a material adverse effect on our business and financial condition.

Moreover, from time to time, in alignment with our sustainability priorities, we may establish and publicly announce goals and commitments in respect of certain ESG items. While we may create and publish voluntary disclosures regarding ESG matters from time to time, many of the statements in those voluntary disclosures are based on hypothetical expectations and assumptions that may or may not be representative of current or actual risks or events or forecasts of expected risks or events, including the costs associated therewith. Such expectations and assumptions are necessarily uncertain and may be prone to error or subject to misinterpretation given the long timelines involved and the lack of an established single approach to identifying, measuring and reporting on many ESG matters. If we fail to achieve or improperly report on our progress toward achieving our environmental goals and commitments, the resulting negative publicity could adversely affect our reputation and/or our access to capital.

16

Finally, organizations that provide information to investors on corporate governance and related matters have developed ratings processes for evaluating companies on their approach to ESG matters. Such ratings are used by some investors to inform their investment and voting decisions. Unfavorable ESG ratings and recent activism directed at shifting funding away from companies with fossil fuel-related assets could lead to increased negative investor sentiment toward us and our industry and to the diversion of investment to other, non-fossil fuel markets, which could have a negative impact on our access to and costs of capital.

Declines in charter rates and other market deterioration could cause us to incur impairment charges.

In accordance with IFRS, we review the carrying amounts of assets on a quarterly basis to determine any indication of impairment either due to a significant decline in market value or in the cash flows expected to be generated by the vessels. In case of such indication, the recoverable amounts of the assets are estimated as the higher of the net realizable value and the value in use in accordance with the requirements of applicable accounting standards. The value in use is the present value of the future cash flows expected to derive from an asset. For the purpose of assessing net realizable values, our management estimates the market values of the individual vessels, for which the most important parameters are the vessels’ tons deadweight, the shipyard they were built at and age. Management uses internal as well as external sources of information, including two internationally recognized shipbrokers’ valuations.

Accordingly, the carrying values of our vessels may not represent their fair market value at any point in time because the market prices of second-hand vessels tend to fluctuate with changes in charter rates and the cost of newbuildings. In 2022, the value of our product tanker fleet, based on independent broker values, increased by approximately 41% (when excluding vessels sold and/or acquired during 2022). As a result of further declines in charter rates or vessel values, we may in the future need to record impairment losses and loss from sale of vessels, which could have a material adverse effect on our future performance, results of operations, cash flows and financial position. Please see the consolidated financial statements as of and for the year ended December 31, 2022 and the accompanying notes included herewith for details on the impact of changes in charter rates and other key assumptions.

If our vessels suffer damage due to the inherent operational risks of the product tanker industry, we may experience unexpected dry-docking costs and delays or total loss of our vessels.

The operation of an ocean-going vessel carries inherent risks. Our vessels and their cargoes will be at risk of being damaged or lost because of events such as marine disasters, bad weather and other acts of God, business interruptions caused by mechanical failures, unexpected tank corrosion, grounding, fire, explosions and collisions, human error, war, terrorism, piracy and other circumstances or events. Changing economic, regulatory and political conditions in some countries, including political and military conflicts, have from time to time resulted in attacks on vessels, mining of waterways, piracy, terrorism, labor strikes and boycotts. Damage to the environment could also result from our operations, particularly through spillage of fuel, lubricants or other chemicals and substances used in operations, or extensive uncontrolled fires. These hazards may result in death or injury to persons, loss of revenue or property, environmental damage, higher insurance rates, damage to our customer relationships, delay or rerouting, any of which may subject us to litigation. As a result, we could be exposed to substantial liabilities not recoverable under our insurances. Further, the involvement of our vessels in a serious accident could harm our reputation as a safe and reliable vessel operator and lead to a loss of business.

In addition, international shipping is subject to various security and customs inspection and related procedures in countries of origin and destination and trans-shipment points. Inspection procedures can result in the seizure of the cargo and/or our vessels, delays in the loading, offloading or delivery and the levying of customs duties, fines or other penalties against us. It is possible that changes to inspection procedures could impose additional financial and legal obligations on us. Furthermore, changes to inspection procedures could also impose additional costs and obligations on our customers and may, in certain cases, render the shipment of certain types of cargo uneconomical or impractical. Any such changes or developments may have a material adverse effect on our future performance, results of operations, cash flows and financial position.

The protection & indemnity insurance coverage that we have arranged for our vessels covers the vessel owner’s liabilities towards the owner of any damaged cargo, subject to standard international conventions limiting such liability. If our vessels suffer damage, they may need to be repaired at a dry-docking facility. The costs of dry-dock repairs are unpredictable and may be substantial. We may have to pay dry-docking costs that our insurance does not cover in full. The loss of earnings while these vessels are being repaired and repositioned as well as the actual cost of these repairs would decrease the Company’s earnings. In addition, space at dry-docking facilities is sometimes limited and not all dry-docking facilities are conveniently located. We may be unable to find space at a suitable dry-docking facility or the vessels may be forced to travel to a dry-docking facility that is not conveniently located in relation to the vessels’ positions. The loss of earnings while these vessels are forced to wait for space or to sail to more distant dry-docking facilities could have a material adverse effect on our future performance, results of operations, cash flows and financial position.

17

If labor interruptions are not resolved in a timely manner, they could have a material adverse effect on our business, results of operations, cash flows and financial position.

We employ masters, officers and crews to man our vessels. We have in the past implemented and will potentially continue in the future to implement restructuring measures including divesting or closing down business activities, reducing our workforce and negotiating collective agreements with trade unions. Restructurings and other factors such as disagreements concerning ordinary or extraordinary collective bargaining may damage our reputation and the relationship with our employees and lead to labor disputes, including work stoppages, strikes and/or work disruptions. If not resolved in a timely and cost-effective manner, industrial action or other labor unrest could prevent or hinder our operations from being carried out as we expect and could have a material adverse effect on our future performance, results of operations, cash flows and financial position.

Our operations outside the United States expose us to global risks, such as political instability, terrorist or other attacks, war, international hostilities and global public health concerns, which may affect the seaborne transportation industry and could adversely affect our business.

We are an international company and primarily conduct our operations outside of the United States, and our business, results of operations, cash flows, financial condition and ability to pay dividends, if any, in the future may be adversely affected by changing economic, political and government conditions in the countries and regions where our vessels are employed or registered. Moreover, we operate in a sector of the economy that is likely to be adversely impacted by the effects of political conflicts, including the current political instability in the Middle East, as well as the South China Sea and Ukraine regions and other geographic countries and areas, geopolitical events, terrorist or other attacks, war (or threatened war) and international hostilities. The response of the United States and others to terrorist attacks, as well as the threat of future terrorist attacks around the world, continues to cause uncertainty in the world’s financial markets and may affect our business, operating results and financial condition. Continuing conflicts and recent developments in the Middle East, including increased tensions between the U.S. and Iran, as well as the presence of U.S. or other armed forces in Iraq, Syria, Afghanistan and various other regions, may lead to additional acts of terrorism and armed conflict around the world, which may contribute to further economic instability in the global financial markets. As a result of the above, insurers have increased premiums and reduced or restricted coverage for losses caused by terrorist acts generally. These uncertainties could also adversely affect our ability to obtain additional financing on terms acceptable to us or at all. Any of these occurrences could have a material adverse impact on our operating results, revenues and costs. Additionally, events in other jurisdictions, could impact global markets, including foreign exchange and securities markets; any resulting changes in currency exchange rates, tariffs, treaties and other regulatory matters could in turn adversely impact our business and operations.

Further, governments may turn and have turned to trade barriers to protect their domestic industries against foreign imports, thereby depressing shipping demand. In particular, leaders in the United States and China have implemented certain increasingly protectionist trade measures, which have been somewhat mitigated by the trade deal (first phase trade agreement) between the United States and China in early 2020, which, among other things, requires China to purchase over $50 billion of energy products including crude oil, and future phases may result in decreased tariffs.

In the past, political instability has also resulted in attacks on vessels, mining of waterways and other efforts to disrupt international shipping, particularly in the Arabian Gulf region and most recently in the Black Sea in connection with the conflicts between Russia and the Ukraine. Acts of terrorism and piracy have also affected vessels trading in regions such as the South China Sea and the Gulf of Aden off the coast of Somalia.

18

Beginning in February of 2022, President Biden and several European leaders also announced various economic sanctions against Russia in connection with the aforementioned conflicts in the Ukraine region, which have continued to expand over the past year and which may adversely impact our business. The Russian Foreign Harmful Activities Sanctions program includes prohibitions on the import of certain Russian energy products into the United States, including crude oil, petroleum, petroleum fuels, oils, liquefied natural gas and coal, as well as prohibitions on all new investments in Russia by U.S. persons, among other restrictions. Furthermore, the United States, the EU and other countries has also prohibited a variety of specified services related to the maritime transport of Russian Federation origin crude oil and petroleum products, including trading/commodities brokering, financing, shipping, insurance (including reinsurance and protection and indemnity), flagging, and customs brokering. These prohibitions took effect on December 5, 2022 with respect to the maritime transport of crude oil and took effect on February 5, 2023 with respect to the maritime transport of other petroleum products. An exception exists to permit such services when the price of the seaborne Russian oil into non-EU countries does not exceed the relevant price cap; but implementation of this price exception relies on a recordkeeping and attestation process that allows each party in the supply chain of seaborne Russian oil to demonstrate or confirm that oil has been purchased at or below the price cap. Violations of the price cap policy or the risk that information, documentation, or attestations provided by parties in the supply chain are later determined to be false may pose additional risks adversely affecting our business. Our business could also be adversely impacted by trade tariffs, trade embargoes or other economic sanctions that limit trading activities by the United States or other countries against countries in the Middle East, Asia or elsewhere as a result of terrorist attacks, hostilities or diplomatic or political pressures.

Finally, public health threats, such as COVID-19, influenza and other highly communicable diseases or viruses, outbreaks of which have from time to time occurred in various parts of the world in which we operate, including China, Japan and South Korea, which may even become pandemics, such as the COVID-19 virus, could lead to a significant decrease of demand for the transportation of energy and clean petroleum products. Such events may also adversely impact our operations, including timely rotation of our crews, the timing of completion of any outstanding or future newbuilding projects or repair works in drydock as well as the operations of our customers. Delayed rotation of crew may adversely affect the mental and physical health of our crew and the safe operation of our vessels as a consequence.

Any of these occurrences could have a material adverse impact on our future performance, results of operations, cash flows and financial position.

If our vessels call at ports located in countries or territories that are the subject of sanctions or embargoes imposed by the U.S. government, the European Union, the United Nations or other governmental authorities, it could lead to monetary fines or other penalties and adversely affect our reputation and the market for our Class A common shares and its trading price.

While none of our vessels called on ports located in countries or territories that are the subject of country-wide or territory-wide sanctions or embargoes imposed by the U.S. government or other applicable governmental authorities (“Sanctioned Jurisdictions”) in violation of sanctions and embargo laws during 2022, and we endeavor to take precautions reasonably designed to mitigate such risks, it is possible that, in the future, our vessels may call at ports located in Sanctioned Jurisdictions on charterers’ instructions and/or without our consent. If such activities result in a violation of sanctions or embargo laws, we could be subject to monetary fines, penalties, or other sanctions, and our reputation and the market for our ordinary shares could be adversely affected.

The applicable sanctions and embargo laws and regulations vary in their application, as they do not all apply to the same covered persons or proscribe the same activities, and such sanctions and embargo laws and regulations may be amended or expanded over time. The past few years have seen increased implementation of sanctions and embargoes imposed against trading with certain countries by in particular the United States, the European Union and the United Nations. Our operations are currently and may in the future become subject to various economic and trade sanctions

Further, our lenders may determine that any non-compliance with applicable sanctions and embargoes imposed by the United Kingdom, the European Union, the United Nations or the United States constitute an event of default under current or future debt facility agreements. An event of default may lead to an acceleration of the repayment of debt under the facility in question and, due to the cross-default provisions, under all other facilities as well, which could have a material adverse effect on our future performance, results of operations, cash flows and financial position, and could lead to bankruptcy or other insolvency proceedings.

19

Further, charterers and other parties that we have previously entered into contracts with regarding our vessels may be affiliated with persons or entities that are now or may soon be the subject of sanctions or embargoes imposed by the United States, EU, and/or other international bodies. If we determine that such sanctions require us to terminate existing or future contracts to which we, or our subsidiaries, are a party or if we are found to be in violation of such applicable sanctions, our results of operations may be adversely affected, or we may suffer reputational harm.

As a result of Russia’s actions in Ukraine, the U.S., EU and United Kingdom, together with numerous other countries, have imposed significant sanctions on persons and entities associated with Russia and Belarus, as well as comprehensive sanctions on certain areas within the Donbas region of Ukraine, and such sanctions apply to entities owned or controlled by such designated persons or entities. These sanctions adversely affect our ability to operate in the region and also restrict parties whose cargo we may carry. Sanctions against Russia have also placed significant prohibitions on the maritime transportation of seaborne Russian oil, the importation of certain Russian energy products and other goods, and new investments in the Russian Federation. These sanctions further limit the scope of permissible operations and cargo we may carry.

Although we believe that we have been in compliance with all applicable sanctions and embargo laws and regulations in 2022, and intend to maintain such compliance, there can be no assurance that we will be in compliance in the future. Any such violation could result in fines, penalties or other sanctions that could severely impact our ability to access U.S. capital markets and conduct our business and could result in our reputation and the market for our securities to be adversely affected and/or in some investors deciding, or being required, to divest their interest, or not to invest, in us. In addition, certain institutional investors may have investment policies or restrictions that prevent them from holding securities of companies that have contracts with countries identified by the U.S. government as state sponsors of terrorism. The determination by these investors not to invest in, or to divest from, our Class A common shares may adversely affect the price at which our Class A common shares trade. Additionally, some investors may decide to divest their interest, or not to invest, in our company simply because we do business with companies that do business in sanctioned countries. Moreover, our charterers may violate applicable sanctions and embargo laws and regulations as a result of actions that do not involve us or our vessels, and those violations could in turn negatively affect our reputation. In addition, our reputation and the market for our securities may be adversely affected if we engage in certain other activities, such as entering into charters with individuals or entities that are not controlled by the governments of countries or territories that are the subject of certain U.S. sanctions or embargo laws, or engaging in operations associated with those countries or territories pursuant to contracts with third parties that are unrelated to those countries or territories or entities controlled by their governments. Investor perception of the value of our Class A common shares may also be adversely affected by the consequences of war, the effects of terrorism, civil unrest and governmental actions in these and surrounding countries, which may have a material adverse effect on our future performance, results of operations, cash flows and financial position.

Maritime claimants could arrest or attach one or more of our vessels, which would have a negative effect on our cash flows.

Crew members, suppliers of goods and services to a vessel, shippers of cargo, secured lenders, time charter-in counterparties and other parties may be entitled to a maritime lien against the relevant vessel for unsatisfied debts, claims or damages.

In many jurisdictions, a maritime lien holder may enforce its lien by arresting a vessel and commencing foreclosure proceedings. In addition, in some jurisdictions a claimant may arrest both the vessel which is subject to the claimant’s maritime lien and any “associated” vessel owned or controlled by the same owner. Claimants could try to assert “sister ship” liability against one vessel in the fleet for claims relating to another of our vessels. Under some of our present charters, if the vessel is arrested or detained as a result of a claim against us, we may be in default of our charter and the charterer may terminate the charter, which will negatively impact our revenues and cash flows. The arrest or attachment of one or more of our vessels could under certain circumstances constitute an event of default under our financing agreements or interrupt operations and require us to pay a substantial sum of money to have the arrest lifted, which could result in a loss of earnings and have a material adverse effect on our future performance, results of operations, cash flows and financial position.

20

Governments could requisition our vessels during a period of war or emergency, which may have an adverse effect on our future performance, results of operations, cash flows and financial position.

A government of a vessel’s registry could requisition for title or seize one or more of our vessels. Requisition for title occurs when a government takes control of a vessel and becomes the owner. Such government could also requisition one or more of our vessels for hire. Requisition for hire occurs when a government takes control of a vessel and effectively becomes the charterer at dictated charter rates. Generally, requisitions occur during a period of war or emergency. Although none of our vessels have been requisitioned by a government for title or hire, a government requisition of one or more of our vessels in the future may adversely affect our future performance, results of operations, cash flows and financial position.

Technological innovation and quality and efficiency requirements from our customers could reduce our charter hire income and the value of our vessels.

Our customers, in particular those in the oil industry, have a high and increasing focus on quality and compliance standards with their suppliers across the entire supply chain, including the shipping and transportation segment. Our continued compliance with these standards and quality requirements is vital for our operations. Charter hire rates and the value and operational life of a vessel are determined by a number of factors including the vessel’s efficiency, operational flexibility and physical life. Efficiency includes speed, fuel economy and the ability to load and discharge cargo quickly. Flexibility includes the ability to enter harbors, utilize related docking facilities and pass through canals and straits. The length of a vessel’s physical life is related to its original design and construction, its maintenance and the impact of the stress of operations. More technologically advanced tankers have been built since our vessels, which have an average age of 11.1 years as of December 31, 2022, were constructed and tankers with further advancements may be built that are even more efficient or more flexible or have longer physical lives, including new vessels powered by alternative fuels or which are otherwise perceived as more environmentally friendly by charterers. We face competition from companies with more modern vessels with more fuel efficient designs than our vessels, and if new vessels are built that are more efficient or more flexible or have longer physical lives than the current eco vessels, competition from the current eco vessels and any more technologically advanced vessels could adversely affect the amount of charterhire payments we receive for our vessels and the resale value of our vessels could significantly decrease. In these circumstances, we may also be forced to charter our vessels to less creditworthy charterers, either because the oil majors and other top tier charters will not charter older and less technologically advanced vessels or will only charter such vessels at lower contracted charter rates than we are able to obtain from these less creditworthy, second tier charterers. Similarly, technologically advanced vessels are needed to comply with environmental laws the investment in which along with the foregoing could have a material adverse effect on our results of operations, charterhire payments, resale value of vessels, cash flows and financial condition.

The smuggling of drugs or other contraband onto our vessels may lead to governmental claims against us.

Our vessels may call in ports where smugglers attempt to hide drugs and other contraband on vessels, with or without the knowledge of crew members. To the extent our vessels are found with contraband, whether inside or attached to the hull of our vessel and whether with or without the knowledge of any of our crew, we may face governmental or other regulatory claims or restrictions which could have an adverse effect on our business, results of operations and financial condition.

Risks Related to Our Company

If we are unable to operate our vessels profitably, we may be unsuccessful in competing in the highly competitive international product tanker market, which would negatively affect our financial condition and our ability to expand our business.

Our ability to achieve positive cash flows is subject to freight rates, financial, regulatory, legal, technical and other factors, many of which are beyond our control. In addition, the operation of product tankers and transportation of petroleum products is extremely competitive, and reduced demand for transportation of oil and oil products could lead to increased competition. Competition arises primarily from other product tanker owners, including major oil companies as well as independent product tanker companies, some of whom have substantially greater resources than we do. Competition for the transportation of oil and oil products can be intense and depends on price, location, size, age, condition and the acceptability of the product tanker and its operators to the charterers. We will have to compete with other product tanker owners, including major oil companies as well as independent product tanker companies. Our ability to operate our vessels profitably depends on a variety of factors, including, but not limited to (i) loss or reduction in business from significant customers, (ii) unanticipated changes in demand for transportation of crude oil and petroleum products, (iii) changes in production of or demand for oil and petroleum products, generally or in particular regions, (iv) greater than anticipated levels of tanker newbuilding orders or lower than anticipated levels of tanker recycling, (v) increases in the cost of bunkers, and (vi) changes in rules and regulations applicable to the tanker industry, including legislation adopted by international organizations such as IMO and the EU or by individual countries. If we are unable to operate our vessels profitably, our financial condition and ability to expand our business would be negatively affected.

21

We are dependent on spot charters and any decrease in spot charter rates in the future may adversely affect our earnings.

We employ the majority of our vessels on spot voyage charters or short-term time charters and generate a significant portion of our revenue from the spot market. The spot charter market may fluctuate significantly based upon product tanker and oil supply and demand. The successful operation of our vessels in the competitive spot charter market depends on, among other things, obtaining profitable spot charters and minimizing, to the extent possible, time spent waiting for charters and time spent traveling ballast to pick up cargo. The spot market is very volatile, and, in the past, there have been periods when spot charter rates have declined below the operating cost of vessels. For example, over the past five years, MR rates expressed as an average time charter equivalent have ranged from a low of approximately $10,321/day to a high of approximately $53,558/day. During 2022, our product tanker fleet realized average spot TCE earnings of $34,154/day. If future spot charter rates decline, we may be unable to operate our vessels trading in the spot market profitably, meet our obligations, including payments on indebtedness, or pay dividends in the future. Furthermore, as charter rates for spot charters are fixed for a single voyage, which may last up to several weeks, during periods in which spot charter rates are rising, we will generally experience delays in realizing the benefits from such increases, which may have a material adverse effect on our future performance, results of operations, cash flows and financial position.

Our ability to renew the charters on our vessels on the expiration or termination of our current charters, or on vessels that we may acquire in the future, or the charter rates payable under any replacement charters and vessel values will depend upon, among other things, economic conditions in the sectors in which our vessels operate at that time, changes in the supply and demand for vessel capacity and changes in the supply and demand for the seaborne transportation of energy resources.

We are subject to certain risks with respect to entering into new time charter-in contracts due to our dependence on spot charters.

We have the opportunity to charter-in additional vessels for longer or shorter periods. Because we employ the majority of our vessels on spot voyage charters or short-term time charters, we may be exposed to changes in the freight rates that are significantly below the hire to be agreed in a time charter-in contract. This exposure could have a material adverse effect on our future performance, results of operations, cash flows and financial position.

We are subject to certain risks with respect to our counterparties on contracts, and failure of such counterparties to meet their obligations could cause us to suffer losses or negatively impact our results of operations and cash flows.

We have entered, and may enter in the future, into various contracts that are material to the operation of our business, including bunker, Interest rate and foreign exchange hedging contracts, employ vessels on Contracts of Affreightment, or COAs, time charters and voyage charters, and enter into newbuilding contracts with shipyards. Such agreements subject us to counterparty risks. The ability and willingness of each of our counterparties to perform its obligations under a contract with us will depend on a number of factors that are beyond our control and may include, among other things, general economic conditions, sensitivity to COVID-19, the condition of the maritime industry, the overall financial condition of the counterparty, charter rates received for specific types of vessels and various expenses. In addition, in depressed market conditions, our charterers and customers may no longer need a vessel that is currently under charter or contract or may be able to obtain a comparable vessel at lower rates. As a result, charterers and customers may seek to renegotiate the terms of their existing charter agreements or avoid their obligations under those contracts, and it may be difficult for us to secure substitute employment for such vessel. Furthermore, any new charter arrangements we secure in the spot market or on time charters may be at lower rates. Should a counterparty fail to honor its obligations under agreements with us or attempt to renegotiate our agreements, we could sustain significant losses, which could have a material adverse effect on our future performance, results of operations, cash flows, financial position and ability to pay dividends to holders of our common shares in the amounts anticipated or at all and compliance with covenants in our loan agreements. To reduce our counterparty risk, we perform a credit check on the prospective customers, however, we cannot guarantee that this process reveals the embedded default risk.

Charterers are sensitive to the commodity markets and may be impacted by market forces affecting commodities and/or uncertain industry conditions. In addition, in depressed market conditions, charterers may have incentive to renegotiate their charters or default on their obligations under charters. Should a charterer in the future fail to honor its obligations under agreements with us, it may be difficult to secure substitute employment for such vessel, and any new charter arrangements we secure on the spot market or on charters may be at lower rates, depending on the then existing charter rate levels, compared to the rates currently being charged for our vessels. In addition, if the charterer of a vessel in our fleet that is used as collateral under one or more of our loan agreements defaults on its charter obligations to us, such default may constitute an event of default under our loan agreements, which may allow the bank to exercise remedies under our loan agreements.

22

Although we assess the creditworthiness of our counterparties, a prolonged period of difficult industry conditions could lead to changes in a counterparty’s liquidity and increase our exposure to credit risk and bad debts. In addition, we may offer extended payment terms to our customers in order to secure contracts, which may lead to more frequent collection issues and adversely affect our financial results and liquidity.

We have received cargo claims as a result of a customer’s inability to honor its indemnification obligations, and failure to recover damages for these claims could adversely affect our business with an immaterial effect.

TORM has received two cargo claims, both relating to one of TORM’s customers having issued indemnities to allow TORM for discharge of cargoes, without the customer being able to honor those indemnity obligations. Both cases involved irregular activities by the customer in relation to the handling of bills of lading. Legal action has been initiated by the Group in the United Kingdom and in India against the customer and a number of individual owners and management representatives. During 2022, we settled one of the cargo claims and the proceedings are ongoing for the remaining cargo claim. Failure to recover damages for this claim could adversely affect our business although with an immaterial effect. TORM’s mitigation activities include, but are not limited to, credit assessment of all customers and contract clauses requiring documentation of the receiver stated in the bills of lading. TORM has adopted a policy that in some cases will require the customer to document that a discharge to a party - other than the receiver/consignee stated in the bill of lading - is in agreement with such receiver/consignee.

We are subject to certain risks with respect to our counterparties on our newbuilding construction contracts, and the failure of our counterparties to meet their obligations under our newbuilding contracts could cause us to suffer losses or otherwise adversely affect our business.

Timely delivery of the any newbuildings we may acquire in the future, are subject to our counterparties meeting their obligations. We are therefore exposed to the risk of failure, cost overruns, delayed delivery, technical problems, quality or engineering problems and other counterparty risks. A number of shipping construction companies have reportedly been experiencing financial challenges. Any such financial challenges may affect operations and the timely delivery of newbuildings. Furthermore, a cancellation due to financial difficulties or bankruptcy of the yard could imply that pre-delivery installments are not recovered or are recovered only after long arbitrations that can last occasionally several years.

Measures have been taken to supervise the quality of the work completed at the yard where our newbuildings are being constructed. In the past we have obtained refund guarantees for the pre-delivery installments as security for pre-delivery installment payments paid.

We can provide no assurance that these, or any other measures we may take, will fully mitigate these risks, and any failure by a counterparty to meet its obligations in relation to the newbuildings may result in delays or cancellations of the delivery of the newbuildings, renegotiation of terms, delayed renewal of our product tanker fleet and consequent deterioration of our competitive position, any of which may result in significant losses for us which could have a material adverse effect on our future performance, results of operations, cash flows and financial position.

An inability to effectively time investments in and divestments of vessels could prevent the implementation of our business strategy and negatively impact our results of operations and financial condition.

Our strategy is to own and operate a fleet large enough to provide global coverage, but no larger than what the demand for our services can support over a longer period by both contracting newbuildings and through acquisitions and disposals in the second-hand market. Our business is greatly influenced by the timing of investments and/or divestments and contracting of newbuildings. If we are unable to identify the optimal timing of such investments, divestments or contracting of newbuildings in relation to the shipping value cycle due to capital restraints, this could have a material adverse effect on our competitive position, future performance, results of operations, cash flows and financial position.

23

An increase in operating costs would decrease our earnings and have a material adverse effect on our future performance, results of operations, cash flows and financial position.

Our vessel operating expenses include the costs of crew, provisions, deck and engine stores, insurance, security measures and maintenance and repairs. Those expenses depend on a variety of factors, many of which are beyond our control and subject to development in the market of the respective input. Voyage expenses include bunkers (fuel), port and canal charges. If our vessels suffer damage, they may need to be repaired at a dry-docking facility. The costs of dry-dock repairs are unpredictable and can be substantial. Some of these costs, primarily relating to insurance, crewing and enhanced security measures, have been increasing on a relative basis and may increase further in the future. During the COVID-19 outbreak crew change has been difficult, which has led to an increase in crew cost. An increasing cost base may have a material adverse effect on our future performance, results of operations, cash flows and financial position.

When purchasing and managing previously second-hand vessels, we are exposed to unforeseen operating costs and vessels off-hire. Second-hand vessels are typically acquired without a warranty period, and inspections prior to purchase may not fully reveal the condition of the vessel. We may therefore be required to perform repair and maintenance resulting in additional operating costs.

A substantial portion of our revenues is derived from a limited number of customers, and the loss of any of these customers could result in a significant loss of revenues and cash flow.

We currently derive substantially all of our revenues from a limited number of customers. In 2022, 20 customers accounted for approximately 74% of our revenue. If these customers cease doing business or do not fulfill their obligations under the charters of our vessels, due to the increasing financial pressure on these customers or otherwise, our results of operations and cash flows could be adversely affected. Further, if we encounter any difficulties in our relationships with these charterers, our results of operations, cash flows and financial condition could be adversely affected.

We may not be able to meet our ongoing operations and working capital needs and may not be able to obtain additional financing in the future on acceptable terms or at all.

As of December 31, 2022, the Group had available liquidity including undrawn committed facilities of $416 million, comprising of cash and cash equivalents, including restricted cash ($3 million) of $324 million and undrawn committed credit facilities amounting to $93 million. The undrawn committed credit facilities consist of two revolving credit facilities of $93 million as part of the Syndicated Facilities Agreement.

If we do not generate sufficient cash flows from our operations to finance our ongoing operations and working capital needs, including funding for, among other things, our newbuilding commitments, we may need to procure additional funding in the future in the public or private equity or debt capital markets. Adequate sources of funding may not be available when needed or may not be available on terms acceptable to us. Our ability to obtain such additional capital or financing will in part depend on prevailing market conditions as well as the financial position of our business and our operating results, which may affect our efforts to arrange additional financing on satisfactory terms. If new shares are issued, it may result in a dilution of the existing shareholders. There can be no assurance that we will be able to maintain or obtain required loan or equity financing to meet any additional working capital or capital investment needs.

In line with industry practice, our suppliers provide us with short-term credit, or short-term supply credits, to purchase, among other things, bunkers and other petroleum products. If our short-term supply credits are reduced or withdrawn, this could have a material adverse effect on our business, results of operations, cash flows and financial position.

In addition, if available and satisfactory funding is insufficient at any time in the future, we may be unable to respond to competitive pressures or customers’ requirements regarding vessel maintenance and fleet age or take advantage of business opportunities. Failure to obtain additional financing could have a material adverse effect on our business, results of operations, cash flows and financial position and could lead to bankruptcy or other insolvency proceedings.

24

As our product tanker fleet ages, we are exposed to increased operating costs and decreased competitiveness, which could adversely affect our earnings, and the risks associated with older vessels could adversely affect our ability to obtain profitable charters.

Our owned vessels had an average age of 11.1 years as of December 31, 2022. The recent introduction of eco-designs for vessels emphasizes that there is a continuous need for us to focus on cost optimizing measures to remain competitive, which may require us to more rapidly upgrade our product tanker fleet in the future. We may not be able to fund or secure additional financing to complete the acquisition of new or second-hand vessels required to renew and upgrade our product tanker fleet, which may lead to deterioration of our product tanker fleet’s performance.

In general, the cost of maintaining a vessel in good operating condition increases with the age of the vessel, and the current age of our fleet means that we must spend substantial resources on maintenance. It is also difficult to estimate with certainty the maintenance and operating costs that will be incurred for an older vessel and there is a risk that these costs will exceed expectations. Further, older vessels are typically less fuel-efficient than more recently constructed vessels due to improvements in engine technology. This difference in fuel-efficiency is likely to be compounded going forward as a result of the IMO’s lower sulfur fuel requirements currently in effect. Cargo insurance rates increase with the age of a vessel, as older vessels may be less desirable to charterers and may be restricted in the type of activities in which the vessels can engage. Some oil companies chartering our vessels have stricter compliance and maintenance requirements on vessels of 15 years of age or older and therefore such vessels’ tradability may decrease. Governmental regulations, including environmental regulations, safety or other equipment standards related to the age of vessels may require expenditures for alterations, or the addition of new equipment, to our vessels and may restrict the type of activities in which our vessels may engage. As our vessels age, market conditions might not justify those expenditures or enable us to operate our vessels profitably during the remainder of their useful lives.

Our strategy has been to create a balanced portfolio based on return on invested capital of vessel types and age, the increasing average age of our product tanker fleet, the potential for more fuel-efficient vessels to enter the market, uncertainties regarding our maintenance costs going forward and our willingness or ability to renew our product tanker fleet could have a material adverse effect on our competitive position, future performance, results of operations, cash flows and financial position. We have several mitigating activities in place such as early maintenance schedules, Condition Assessment Program (CAP1) etc.

Any failure to pass vessel inspections by classification societies and other private and governmental entities and operate our vessels may have a material adverse effect on our future performance, results of operations, cash flows and financial position. With the implementation of SIRE 2.0 that started in the fourth quarter of 2022, TORM may experience a decline in tradability and lead to additional vessel inspections.

Our vessels are subject to inspections from government and private entities, and we are required to obtain permits, licenses and certificates for the operation of our vessels as well as vetting or other types of commercial and operational approvals. In addition, the hull and machinery of every commercial vessel must be classed by a classification society authorized by the vessel’s country of registry. Classification societies are non-governmental, self-regulating organizations and certify that a vessel is safe and seaworthy in accordance with the applicable rules and regulations of the country of registry of the vessel. A vessel must undergo various mandatory surveys. A vessel’s machinery may be on a continuous survey cycle, under which the machinery would be surveyed periodically over a five-year period. The Company’s vessels are on survey cycles for hull inspection and continuous survey cycles for machinery inspection. Every vessel is subject to statutory annual, intermediate and special surveys in a five-year cycle, this will include two surveys of the vessel’s underwater areas. During the COVID-19 outbreak, our vessels have continued audits and has not utilized possible dispensations. If any vessel fails any survey, the vessel may be unable to trade between ports and therefore be unemployable, which may have a material adverse effect on our future performance, results of operations, cash flows and financial position.

During 2022, the Oil Companies International Marine Forum implemented a more comprehensive inspection process by introducing its Ship Inspection Report Program 2.0 (SIRE 2.0). This new program facilitates a risk-based approach assessing the safety and quality of a vessel and its crew on an ongoing basis. TORM allocates resources to implement the new standards and is well prepared for the more comprehensive requirements. However, this may cause TORM to experience a decline in tradability and lead to additional vessel inspections.

25

If we cannot meet our customers’ quality and compliance requirements, we may not be able to operate our vessels profitably.

Customers, and in particular those in the oil industry, have a high and increasing focus on quality and compliance standards with their suppliers across the entire value chain, including the shipping and transportation segment. Our continuous compliance with these standards and quality requirements is vital for the Company’s operations. Related risks could materialize in multiple ways, including a sudden and unexpected breach in quality and/or compliance concerning one or more vessels, a continuous decrease in the quality concerning one or more vessels occurring over time. Moreover, continuously increasing requirements from oil industry constituents can further complicate our ability to meet the standards. Any non-compliance by the Company, either suddenly or over a period of time, on one or more vessels, or an increase in requirements by oil operators above and beyond what we deliver, may have a material adverse effect on our future performance, results of operations, cash flows and financial position.

Obligations associated with being a U.S.-listed public company require significant resources and management attention, and we incur increased costs as a result of being a U.S.-listed public company.

We are subject to the reporting requirements of the Securities Exchange Act of 1934, as amended, or the Exchange Act, and the other rules and regulations of the SEC, including Sarbanes-Oxley, and the listing and other requirements of Nasdaq New York. The various financial and other reporting obligations place significant demands on our management, administrative, operational and accounting resources and cause us to incur significant legal, accounting and other expenses that we would not otherwise incur. These rules and regulations increase our legal and financial compliance costs and may divert management’s attention to ensure compliance and make some activities more time-consuming and costly. We may need to upgrade our systems or create new systems, implement additional financial and management controls, reporting systems and procedures, create or outsource an internal audit function and hire additional accounting and finance staff. If we are unable to accomplish these objectives in a timely and effective fashion, our ability to comply with the financial reporting requirements and other rules that apply to reporting companies could be impaired. We cannot accurately predict the amount of the additional costs we may incur in the future, the timing of such costs or the degree of impact that our management’s attention to these matters will have on our business.

Any failure to maintain effective internal control over financial reporting could have a material adverse effect on our business, prospects, liquidity, results of operations and financial condition. Furthermore, if we are unable to satisfy our obligations as a public company, we could be subject to delisting of our Class A common shares from Nasdaq New York and/or Nasdaq Copenhagen, fines, sanctions and other regulatory action.

Sarbanes-Oxley requires, among other things, that we maintain and periodically evaluate our internal control over financial reporting as well as disclosure controls and procedures. Section 404(a) of the Sarbanes-Oxley Act requires that our management assess and report annually on the effectiveness of our internal controls over financial reporting and identify any material weaknesses in our internal controls over financial reporting. Compliance with Section 404(a) requires substantial accounting expenses and significant management efforts. The costs of compliance with the foregoing requirement may have a material adverse effect on our future performance, results of operations, cash flows and financial condition. Additionally, as we are no longer an “emerging growth company”, Section 404(b) of the Sarbanes-Oxley Act requires the external auditor to attest to, and report on, our management’s assessment of our internal controls over financial reporting, which will increase the overall cost of compliance.

The possibility that we may in the future be unable to retain and recruit qualified key executives, key employees or key consultants, may delay our development efforts or otherwise harm our business.

Our future development and prospects depend to a large degree on the experience, performance and continued service of our senior management team. Retention of these services or the identification of suitable replacements in case of future vacancies cannot be guaranteed. There can be no guarantee that the services of the current Directors and senior management team will be retained, or that suitably skilled and qualified individuals can be identified and employed, which may adversely impact our ability to commercial and financial performance. The loss of the services of any of the Directors or other members of the senior management team may have a material adverse effect on our commercial and financial performance as well. If we are unable to hire, train and retain such personnel in a timely manner, our operations could be delayed and our ability to grow our business will be impaired and the delay and inability may have a detrimental effect upon our performance

26

Failure to obtain or retain highly skilled personnel could adversely affect our operations.

We require highly skilled personnel to operate our business. There can be no assurance that we will be able to attract and retain such employees on reasonable terms in the future. Our ability to attract and retain employees and management in the future may be affected by circumstances beyond our control. Competition for skilled and other labor required for our operations has increased in recent years as the number of ocean-going vessels in the worldwide fleet has increased. If this expansion continues and is coupled with improved demand for seaborne shipping services in general, shortages of qualified personnel could further create and intensify upward pressure on wages and make it more difficult for us to staff and service vessels. In addition, we employ staff and vessel crews in a number of countries, all of which are covered by international rules of employment. Changes are made on an ongoing basis to international rules of employment and this may have a material influence on our flexibility in manning our vessels.

Such developments could adversely affect our ability to attract and retain qualified employees and management on reasonable terms in the future and, in turn, could adversely affect our future performance, results of operations, cash flows and financial position.

U.S. tax authorities could treat us as a ‘‘passive foreign investment company’’, which could have adverse U.S. federal income tax consequences to U.S. shareholders.

A foreign corporation will be treated as a ‘‘passive foreign investment company,’’ or PFIC, for U.S. federal income tax purposes if either (1) at least 75% of its gross income for any taxable year consists of certain types of ‘‘passive income’’ or (2) at least 50% of the average value of the corporation’s assets produce or are held for the production of those types of ‘‘passive income’’. For purposes of these tests, ‘‘passive income’’ includes dividends, interest and gains from the sale or exchange of investment property and rents and royalties other than rents and royalties which are received from unrelated parties in connection with the active conduct of a trade or business. For the purposes of these tests, income derived from the performance of services does not constitute ‘‘passive income’’. U.S. shareholders of a PFIC are subject to certain reporting obligations and a disadvantageous U.S. federal income tax regime with respect to the income derived by the PFIC, the distributions they receive from the PFIC and the gain, if any, they derive from the sale or other disposition of their shares in the PFIC.

Based on our current and proposed method of operation, we do not believe that we are or that we expect to become, a PFIC with respect to any taxable year. In this regard, we intend to treat the gross income we derive or are deemed to derive from our time chartering and voyage chartering activities as services income rather than rental income. Accordingly, we believe that our income from these activities does not constitute ‘‘passive income’’, and the assets that we own and operate in connection with the production of that income do not constitute assets that produce or are held for the production of “passive income”.

Although there is no direct legal authority under the PFIC rules addressing our method of operation, there is substantial legal authority supporting our position, consisting of the Code, legislative history, case law and United States Internal Revenue Service, or IRS, pronouncements concerning the characterization of income derived from time charters and voyage charters as services income for other tax purposes. However, it should be noted that there is also authority that characterizes time charter income as rental income rather than services income for other tax purposes. Accordingly, no assurance can be given that the IRS or a court of law will accept our position, and there is a risk that the IRS or a court of law could determine that we are a PFIC. Moreover, no assurance can be given that we would not constitute a PFIC for any future taxable year if there were to be changes in the nature and extent of our operations or the composition of our income or assets change. If the IRS were to find that we are or have been a PFIC for any taxable year, our U.S. shareholders will face adverse U.S. federal income tax consequences and will incur certain information reporting obligations that may be onerous. Under the PFIC rules, unless those shareholders make an election available under the Code (which election could itself have adverse tax consequences for such shareholders), such shareholders would be liable to pay U.S. federal income tax at the then prevailing income tax rates on ordinary income plus interest upon excess distributions and upon any gain from the disposition of our common shares, as if the excess distribution or gain had been recognized ratably over the shareholder’s holding period of the common shares. Please see “Item 10. Additional Information—E. Taxation –U.S. Federal Income Taxation of U.S. Holders—Passive Foreign Investment Company Status and Significant U.S. Federal Income Tax Consequences” for a more comprehensive discussion.

We may have to pay tax on U.S. source income, which would reduce our earnings.

Under the U.S. Internal Revenue Code of 1986, or the Code, 50% of the gross shipping income of a vessel owning or chartering corporation, such as ourselves and our subsidiaries, that is attributable to transportation that begins or ends, but that does not both begin and end, in the United States may be subject to a 4% U.S. federal income tax without allowance for deduction, unless that corporation qualifies for exemption from tax under Section 883 of the Code or under the terms of a U.S. income tax treaty.

27

We and/or one or more of our subsidiaries (collectively referred to as “we” for purposes of this paragraph) may qualify for exemption from tax under the terms of the U.S.-U.K. Income Tax Treaty or the U.S.-Denmark Income Tax Treaty. Whether we so qualify depends, among other things, on whether we satisfy the Limitation on Benefits article of the applicable U.S. income tax treaty. In particular, we would generally satisfy the Limitation on Benefits article if we can establish that we are engaged in the active conduct of a trade or business in the U.K. or Denmark, whichever is applicable, our U.S. source shipping income is derived in connection with, or is incidental to, such trade or business, and such trade or business activity in the applicable treaty jurisdiction is substantial in relation to our trade or business activity in the United States. Given the legal and factual uncertainties in making the foregoing determination, there can be no assurance that we will be able to qualify for exemption from tax under a U.S. income tax treaty, or that the IRS or a court of law will agree with our determination in this regard.

If we or our subsidiaries are not entitled to the exemption under Section 883 of the Code or under the terms of a U.S. income tax treaty for any taxable year, we and our subsidiaries would be subject to a 4% U.S. federal income tax on gross U.S. source shipping income for such taxable year. The imposition of this taxation could have a negative effect on our business and result in decreased earnings available for distribution to our shareholders. For example, if the benefits of Section 883 and the applicable U.S. income tax treaties were unavailable for our taxable year ended December 31, 2022, we estimate that our U.S. federal income tax liability for such taxable year would have increased by approximately $7.4 million, although our U.S. federal income tax liability for future taxable years would vary depending upon the amount of U.S. source shipping income that we earn in each such year. See “Item 10. Additional Information—E. Taxation—United States Federal Income Taxation of the Company” for a more comprehensive discussion.

Changes to the tonnage tax or the corporate tax regimes applicable to us, or to the interpretation thereof, may impact our future operating results.

TORM is currently subject to a tonnage tax scheme in Denmark. If our participation in the tonnage tax scheme is abandoned, or if our level of investments and activities is significantly reduced (e.g. from significant or fully disposal of the Danish owned fleet), we may have to pay, in part or in full, a non-current tax liability related to held over gains, which as of December 31, 2022 is $45.2 million.

Additional taxes may be payable as a result of a change in other tax laws of any country in which we operate or a change in complex tax laws that affect our international operations.

In the event that tonnage tax schemes or other tax laws are changed in the future, our overall tax burden could increase, which could have a material adverse effect on our future performance, results of operations, cash flows and financial position.

Moreover through our acquisition of Marine Exhaust Technology A/S we are exposed to changes to Danish corporate tax regime.

Insurance may be difficult to obtain, or if obtained, may not be adequate to cover our losses that may result from our operations due to the inherent operational risks of the product tanker industry.

The operation of ocean-going vessels represents a potential risk of significant losses and liabilities caused by adverse weather conditions, mechanical failures, human error, war, terrorism, piracy and other circumstances or events. In the course of the fleet’s operation, various casualties, accidents and other incidents, including an oil spill or emission of other environmentally hazardous agents from a vessel, may occur that may result in significant financial losses and liabilities for us. An accident involving any of the fleet’s vessels could result in death or injury to persons, loss of property, environmental damage, delays in delivery of cargo, loss of revenue from termination of contracts or unavailability of vessels, fines or penalties, higher insurance rates, litigation and damage to our reputation and customer relationships.

In order to reduce the exposure to these risks, we carry insurance to protect us against most of the accident-related risks involved in the conduct of our business, including marine hull and machinery insurance, cyber and crime insurance, protection and indemnity insurance, including pollution risks, crew insurance and war risk insurance. Incidents may occur where we may not have sufficient insurance coverage, and some claims may not be covered. Furthermore, insurance costs may increase as a consequence of unforeseen incidents or other events beyond our control. In addition, in the future particularly in adverse market conditions it may not be possible to procure adequate insurance coverage or only on commercially unacceptable terms.

28

Any significant loss or liability for which we have not or have not been able to take out adequate insurance, or events causing an increase of insurance costs could have a material adverse effect on our future performance, results of operations, cash flows and financial position.

We may be subject to litigation that, if not resolved in our favor and not sufficiently insured against, could have a material adverse effect on us.

We and our activities are subject to both U.K. and foreign laws and regulations many of which include legal standards, which are subject to interpretation, and we are party to agreements and transactions, involving matters of assessment of interests of various stakeholders and valuation of assets, liabilities and contractual rights and obligations. Furthermore, we may be subject to the jurisdiction of courts or arbitration tribunals in many different jurisdictions.

Our counterparties and other stakeholders or authorities may dispute our compliance with laws and regulations or contractual undertakings or the assessments made by us in connection with our business and the entry into agreements or transactions. The outcome of any such dispute or legal proceedings is inherently uncertain and may include payment of substantial amounts in legal fees and damages or that a transaction or agreement is deemed invalid or voidable. Such proceedings or decisions could have a material adverse effect on our future performance, results of operations, cash flows and financial position. If cases or proceedings in which we may be involved are determined to our disadvantage, it may result in fines, default under our debt facilities, damages or reputational damage and could have a material adverse effect on our future performance, results of operations, cash flows and financial position.

Fluctuations in exchange rates and non-convertibility of currencies could result in losses to us.

As a result of our international operations, we are exposed to fluctuations in foreign exchange rates due to parts of our revenues being received and operating expenses paid in currencies other than United States dollars. We use United States dollars as the functional currency because the majority of the Company’s transactions are denominated in United States dollars. Thus, the Company’s exchange rate risk is related to cash flows not denominated in United States dollars. The primary risk relates to transactions denominated in Danish Krone or DKK, Euro or EUR, Indian Rupee or INR, Singapore Dollar or SGD, or other major currencies, which relate to administrative and operating expenses.

We have historically generated almost all revenues and incurred the majority part of our expenses in United States dollars. The remaining balances were in DKK, EUR, INR, SGD and other major currencies. Accordingly, we may experience currency exchange losses if we have not fully hedged our exposure to a foreign currency. A change in exchange rates could have a material adverse impact on our future performance, results of operations, cash flows and financial position.

Investment in derivative instruments such as freight forward agreements could result in losses to us.

We use the derivative markets and take positions in derivative instruments, such as forward freight agreements (“FFAs”), for the purposes of hedging our exposure to fluctuations in the charter market, interest rates, foreign exchange rates and bunker prices. Our financing agreements set forth limitations on our level of forward freight agreements exposure and prohibit speculation on interest rates, foreign exchange and bunker swaps. From time to time, we may take positions in such derivative instruments, and as a result we may incur derivative exposure that could have a material adverse effect on our future performance, results of operations, cash flows and financial position. If liquidity in these derivative markets decreases or disappears, it could make it difficult or more expensive for us to perform such hedging, which could have a material adverse effect on our future performance, results of operations, cash flows and financial position.

U.S. and other non-U.K. holders of our Class A common shares may not be able to exercise pre-emptive subscription rights or participate in future offerings.

Holders of our Class A common shares have certain pre-emption rights with respect to certain of our issuances unless those rights are disapplied by virtue of a resolution of the shareholders at a general meeting. Securities laws of certain jurisdictions may restrict the ability for shareholders in such jurisdictions to participate in any future issuances of shares carried out on a pre-emptive basis. Shareholders residing or domiciled in the United States, as well as certain other countries, may not be able to exercise their pre-emption rights or participate in future capital increases or securities issuances, including in connection with an offering below market value, unless we decide to comply with local requirements and, in the case of the United States, unless a registration statement is effective, or

29

an exemption from the registration requirements of the Securities Act of 1933, as amended, or the Securities Act, is available with respect to such rights.

In such cases, shareholders resident in such non-U.K. jurisdictions may experience a dilution of their shareholding, possibly without such dilution being offset by any compensation received in exchange for subscription rights. No assurance can be given that local requirements will be complied with or that any registration statement would be filed in the United States or other relevant jurisdictions, or that another exemption from the registration requirements of the Securities Act or laws of other relevant jurisdictions would apply, so as to enable the exercise of such holders’ pre-emption rights or participation in any future securities issuances.

Because we are a non-U.S. corporation, you may not have the same rights that a creditor of a U.S. corporation may have, and it may be difficult to serve process on or enforce a U.S. judgment against us and our officers and directors.

We are an English company, and our executive offices are located outside of the United States. Our officers and the majority of our directors reside outside of the United States. In addition, substantially all of our assets and the assets of our officers and directors are located outside of the United States. As a result, you may have difficulty serving legal process within the United States upon us or any of these persons or enforcing any judgments obtained in U.S. courts to the extent assets located in the United States are insufficient to satisfy the judgments. In addition, original actions or actions for the enforcement of judgments of U.S. courts with respect to civil liabilities solely under the federal securities laws of the United States may not be enforceable in England.

We may be exposed to fraudulent behavior, which may have a material adverse effect on our future performance, results of operations, cash flows and financial position.

The risk of fraud is inherent in all industries and is not specific to the shipping industry. However, historically, the shipping industry has experienced an increased risk of fraud and fraudulent behavior. Potential fraud risks include purposeful manipulation and misrepresentation of financial statements, misappropriation of tangible assets, intangible assets and proprietary business opportunities, cor