...[S]ince the start of the invasion, the bulk of Russian exports are handled by Greek shipowners, of which DTM is a significant part.10 In January 2023, forty per cent of tankers tracked at key Russian oil export ports were owned by Greek companies. DTM was identified by Lloyd's List as one of the shipowners most exposed to Russian energy commodities trades, with 31 tankers and 4.4m dwt.

While there is no evidence that DTM is violating sanctions at this point, there are indications that the company might be at risk of breaching them in the future. For example, the Sovereign, a crude oil tanker owned by DTM, sailed from Tua Tuapse, Russia, in December, and was due to arrive in Greece on December 24, when the European Union’s measures on Russian oil were due to begin, highlighting a lingering risk for ships of falling foul of EU sanctions. Moreover, The Karolos tanker, managed by Dynacom, loaded Russian crude at Russia's Ust-Luga port in January and was due to discharge the oil in Sikka, India by February 3. These practices might also potentially raise criminal issues in the future, as well as ethical and moral issues that arise from contributing to the economy of an aggressor state...

We seek to understand how DTM has conducted and continues to conduct heightened human rights due diligence and how the findings of such a process has resulted in these continued business activities and relationships...