Corporate governance is the foundation of our operations. We are dedicated to upholding transparency, accountability, and high ethical standards, ensuring fairness and responsibility across the organization. Our governance framework ensures compliance with legal and regulatory standards while promoting sustainable and responsible business practices.

Governance Structure & Responsibilities

Our governance structure is built to support efficient decision-making and proactive risk management. With clearly defined roles and responsibilities, we ensure that all aspects of our operations are conducted with integrity and meet the highest standards. This approach allows us to consistently meet stakeholder expectations and drive sustainable growth.

See Danaos Organizational Chart

Corporate Governance Manual & Training

Danaos Shipping has developed a comprehensive Corporate Governance Manual that provides guidance on governance principles, decision-making processes, and ethical standards. The manual is available to all employees, ensuring consistent adherence to governance best practices across the organization.

Our internal training programs, led by the Internal Audit Department, ensure that employees receive ongoing education on governance, ethical decision-making, compliance, and risk management. These programs are continuously updated to reflect industry developments and regulatory changes, helping to maintain our high standards.

Corporate Policies

Danaos Shipping operates within a robust framework of policies that guide ethical behavior and regulatory compliance at all levels of the organization. These policies form the foundation for our business practices:

• Code of Business Conduct & Ethics: Defines the standards of behavior expected from all employees.
• Ethics & Compliance Policy: Our whistleblowing policy provides confidential channels for reporting concerns related to unethical behavior.
• Anti-Fraud Policy: Outlines protocols to prevent, detect, and respond to fraudulent activities.
• Insider Trading Policy: Implements measures to prevent the misuse of confidential information.
• Anti-Bribery & Corruption (ABAC) Policy: Ensures compliance with international anti-corruption laws, reinforced through regular training and oversight.
• Anti-Money Laundering Policy: Protects our operations from being exploited for money laundering activities.
• Stakeholder Engagement Policy: Encourages open, transparent communication with stakeholders, addressing their needs and expectations.
• Health, Safety, Quality, Environmental & Energy Efficiency Policy: Demonstrates our commitment to ensuring a safe working environment. Promotes sustainability by reducing environmental impact across our operations.

We ensure that all employees are well-informed and possess the necessary skills to comply with these policies, which are regularly reviewed to remain current and effective.

Commitment to Anti-Corruption & Responsible Business Conduct

Danaos Shipping is committed to conducting all business ethically and in full compliance with applicable anti-corruption laws and international standards. Our Anti-Bribery & Anti-Corruption (ABAC) Policy sets out clear principles for preventing bribery and ensuring integrity across all operations.

As an active member of the Maritime Anti-Corruption Network (MACN), we promote transparency and collective action to eliminate corruption in the maritime industry.

Through ongoing training programs and awareness initiatives, employees are equipped to recognize and prevent corrupt practices. Danaos maintains a zero-tolerance approach to bribery and corruption, supported by confidential and anonymous reporting channels available under our Whistleblowing & Reporting framework.

Whistleblowing & Reporting

At Danaos, we emphasize transparency and responsibility by providing secure channels for stakeholders to report concerns about our Codes, Policies, or any violations of laws and regulations.

Our whistleblowing system forms part of the Company’s Ethics & Compliance framework and is designed to handle all reports confidentially and fairly.

Reports may concern any suspected violation of law, regulation, or Company policy, or any activity inconsistent with Danaos’ values.

They may relate to, but are not limited to, the following matters:

• Integrity, ethics, and compliance concerns
• Bribery, corruption, and fraud
• Money laundering or sanctions violations
• Accounting irregularities or internal-control weaknesses
• Insider trading or market abuse
• Human-rights or labor-rights violations
• Health, safety, or workplace-wellbeing issues
• Discrimination, harassment, or unfair treatment
• Supply-chain or third-party misconduct
• Environmental risks or violations
• Information-security or cybersecurity incidents
• Data-privacy or confidentiality breaches
• Any breach of the Company’s Codes, Policies, or Procedures

For employees, the Company also provides an Internal Grievance Form to raise workplace-related issues such as discrimination, harassment, or unfair treatment.

Both mechanisms protect anonymity for those who wish to remain anonymous, while allowing contact details to be provided if the reporter prefers direct follow-up.

To ensure effective use of these mechanisms, periodic training and awareness sessions are provided to all employees on how to identify, report, and address potential issues internally or externally through the available reporting channels.

We uphold a strict non-retaliation policy, ensuring that no one faces adverse action for reporting a concern or cooperating in an investigation in good faith.

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Business Risk Management

At Danaos Shipping, effective risk management is central to achieving our strategic objectives and building resilience in a dynamic business environment. Our Business Risk Management Procedure is designed to proactively identify, evaluate, and address risks that could affect our operations, reputation, and long-term success.

Our approach emphasizes:

Proactive identification: Engaging all levels of the organization to recognize current and emerging risks, using systematic methods, management discussions, and industry insights to ensure timely awareness of potential exposures.

Risk evaluation and prioritization: Assessing risks based on their likelihood and impact to focus resources on the most significant threats, consistent with our strategic goals and risk appetite.

Targeted mitigation: Developing and implementing actions to address key risks, strengthen internal controls, and incorporate lessons learned from prior reviews and audits.

Continuous monitoring: Using performance metrics and conducting regular reviews of the company’s overall risk exposure, at least annually, to remain responsive to change and ensure the continued effectiveness of our controls.

Clear accountability: Defining roles and responsibilities across all levels and supporting them with focused training programs that promote ownership, transparency, and a strong culture of risk awareness.

ESG commitment: The ESG Working Team (ESGWT) identifies and reviews key ESG and emerging risks during its quarterly meetings, ensuring that Danaos’ risk management remains aligned with regulatory changes, stakeholder expectations, and long-term sustainability objectives.

Independent review and assurance: Conducting internal audits of the risk management process as part of a dynamic, risk-based Internal Audit Plan that adapts to evolving risks. The review of the risk management process is performed at least every two years to assess its effectiveness and identify opportunities for improvement. The outcomes of these reviews are reported to senior management and the Audit Committee of Danaos Corporation to ensure effective oversight and alignment with corporate governance standards.

Commitment to transparency and improvement: Regularly refining our procedures to meet industry standards, regulatory requirements, and good practice.

For a full view of our risk management framework, governance structure, and priority risk areas, please refer to our Risk Management Strategy for 2025.

Data Governance, Security, and Privacy

At Danaos Shipping, we recognize that data is a critical corporate asset and a foundation for safe, efficient, and transparent operations. We are committed to managing data responsibly, securely, and in full compliance with applicable laws and international standards.

Our approach to Data Governance and Ethics is based on transparency, accountability, and integrity. We ensure that information is collected, processed, and used responsibly and in line with our corporate values. Oversight of data governance and protection matters rests with the Danaos Shipping's Cybersecurity and Data Protection Working Committee, which includes Executive Management, Departmental Directors, and the Chief Information Security Officer (CISO). This Committee reviews emerging risks, ensures that controls remain effective, and guides our strategy to align with technological and regulatory developments.

Building on this foundation, protecting information and maintaining operational resilience are top priorities at Danaos. Our Information Security and Cybersecurity framework adheres to international standards and regulations, including GDPR, NIS2, and NIST guidelines, to uphold the confidentiality, integrity, and availability of data. While information security covers all forms of information—whether digital, physical, or procedural—cybersecurity focuses specifically on safeguarding our digital systems, networks, and data against evolving threats. The Company’s Information Security Policy defines robust measures for data protection, risk mitigation, and compliance. Together, these disciplines form a unified defense framework built on prevention, detection, response, and recovery, supported by:

• The Cybersecurity Incident Response Plan (CIRP) for timely detection, containment, and resolution of incidents;
• Regular risk assessments, vulnerability scans and analysis, and penetration testing to identify and mitigate potential threats;
• The Business Continuity Plan that defines the company’s approach to redundant infrastructure, disaster recovery, and secure remote access controls; and
• Continuous employee awareness and training programs that strengthen our security culture and resilience.

Danaos Shipping is ISO 27001:2022 certified, underscoring our commitment to international best practices and the highest standards of information security and cybersecurity governance.

We are equally committed to Data Privacy and Protection, ensuring that personal information entrusted to us by employees, customers, and business partners is handled with care and in accordance with applicable data protection laws. Danaos maintains two complementary Data Privacy Policies:

• A public Data Privacy Policy, available on our website, which explains how we collect, use, and safeguard the personal data of external stakeholders; and
• An internal Data Privacy and Protection Policy, available to all employees through the company's intranet, which provides practical guidance on handling personal data within the organization.

Both policies are aligned with GDPR and international best practices, ensuring lawful, fair, and transparent processing. Oversight of privacy and data protection compliance is exercised through Cybersecurity and Data Protection Working Committee, which coordinates with the Legal Department to ensure adherence to applicable laws and regulations. The Legal Department is responsible for interpreting regulatory requirements, maintaining contractual and confidentiality frameworks, and advising on data protection obligations. The Internal Audit function provides independent assurance on the effectiveness of these governance and control processes. Regular internal and external audits, together with periodic policy reviews, ensure that our practices remain current and compliant with evolving legal and regulatory developments. Our data privacy framework is fully integrated into the organization’s overall risk and compliance management system, ensuring consistent oversight and accountability across all business functions. Failure to comply with our Data Privacy Policies may result in disciplinary action, up to and including immediate termination of employment or termination of a Third Party’s relationship with the Company.

With suppliers and subcontractors, Danaos applies the same high standards for data protection and privacy. Before entering any agreement, both parties sign a Non-Disclosure Agreement (NDA) that defines confidentiality obligations and data-handling provisions consistent with the Internal Data Privacy and Protection Policy and applicable privacy laws. These agreements ensure that external partners safeguard information with the same diligence expected internally, reinforcing the company’s commitment to responsible data management.

Sustainable Procurement

Sustainable procurement is integral to Danaos Shipping’s Environmental, Social, and Governance (ESG) strategy. We collaborate closely with suppliers to ensure they meet the high standards of ESG performance, focusing on human rights, anti-corruption policies, carbon reduction, and safe working conditions.

Our Supplier Code of Conduct, aligned with the United Nations Global Compact and other international standards, sets clear expectations for responsible behavior and compliance. We are committed to working with our suppliers to continuously improve their ESG performance and achieve full alignment with our code of conduct.

Industry Associations and Responsible Engagement

Danaos Shipping Co. Ltd. does not make political donations, campaign contributions, or lobbying expenditures. The company’s external engagements are limited to memberships in national and international maritime trade and industry associations that promote regulatory dialogue, compliance, safety, and best practices across the shipping sector.

These include the Union of Greek Shipowners (UGS), Cyprus Union of Shipowners (CUS), Malta International Shipowners Association (MISA), INTERCARGO, BIMCO, Nautical Chamber of Greece (NEE), American Hellenic Chamber of Commerce, Liberian Shipowners’ Council, Methanol Institute, Global Maritime Forum (GMF) and the Ammonia Energy Association.

Membership fees to these organizations are administrative and non-political. They support technical cooperation, sustainability initiatives, and regulatory compliance. No portion of these payments is directed toward political or legislative advocacy.

All memberships are reviewed annually by the Compliance Officer to ensure continued alignment with Danaos’ Code of Conduct, Anti-Bribery and Anti-Corruption Policy, and overall ESG commitments.

Climate Alignment and Oversight

Danaos Shipping Co. Ltd. does not engage in political lobbying or policy advocacy activities. The company’s participation in trade and industry associations focuses on technical collaboration, safety, and sustainability in the maritime sector.

As part of its governance and compliance processes, Danaos periodically reviews its trade association memberships across all jurisdictions in which it operates, to ensure that they remain consistent with the company’s environmental objectives and commitment to the goals of the Paris Agreement. The ESG Working Team (ESGWT) receives any updates or decisions issued by these organizations and reviews their alignment with Danaos’ strategic objectives, including its decarbonization and sustainability commitments. Following each review, the ESGWT informs the Chief Operating Officer (COO) of any relevant updates, and together they decide on the appropriate course of action to ensure continued alignment.

Danaos supports the transition toward decarbonized and sustainable shipping, consistent with the IMO’s Greenhouse Gas Strategy, the EU Emissions Trading System (EU ETS), and the FuelEU Maritime Regulation. The company engages only with organizations that share these objectives or actively work towards them, such as INTERCARGO, BIMCO, the Methanol Institute, and the Ammonia Energy Association.

Wherever material differences in climate-related positions arise, Danaos engages constructively within these associations to promote Paris-aligned approaches to maritime decarbonization.