General
ESRS 2 – General Disclosures
10 disclosure requirements
GOV-1
The role of the administrative, management and supervisory bodies
Banco SabadellSpain
The governance system and the organisation of the different decision-making levels are both being continuously improved and adapted to the needs that are emerging from the new sustainability environment.
Board of Directors
With the exception of matters reserved to the Annual General Meeting, Banco Sabadell's Board of Directors is the most senior decision-making body of the company and its consolidated Group as it is responsible, by law and pursuant to the Articles of Association, for the management and representation of the Bank. The Board of Directors acts mainly as an instrument of supervision and control, delegating the management of the Institution's ordinary business matters to the Chief Executive Officer.
The Board of Directors is subject to well-defined and transparent rules of governance, in particular to the Articles of Association and the Regulation of the Board of Directors, and it conforms to best practice in the area of corporate governance. To ensure better and more diligent performance of its general supervisory duties, the Board is directly responsible for approving the Institution's general strategies. It also approves its policies and is therefore responsible for establishing principles, commitments and objectives in the area of sustainability, and for including them in the Institution's strategy.
As at 31 December 2024, the Board of Directors is made up of fifteen members. Of these, two are Executive Directors (13.33% of the total Board) and thirteen are Non-Executive Directors, while ten are Independent Directors (66.67% of the total Board), two are Other External Directors (13.33% of the total Board) and one is a Proprietary Director (6.67% of the total Board). There is no trade union representation on the Board.
As at 2024 year-end, there were six female directors, including five female Independent Directors out of a total of ten Independent Directors and one female Other External Director. Women represent 40% of the full Board of Directors, thus bringing forward the fulfilment of the Bank's commitment stated in Sabadell's Commitment to Sustainability and achieving early compliance with the provisions of Organic Law 2/2024 of 1 August on equal representation and balanced presence of women and men.
[Matrix of competences and diversity shown]
When defining the general strategy, the business objectives and the risk management framework of the Institution, the Board of Directors considers aspects related to sustainability, including climate-related, environmental, social and governance risks, and it also effectively oversees them.
In April 2024, the Board of Directors revised its Sustainability Policy, which incorporates ESG parameters into the activities and organisation of Banco Sabadell Group. This policy establishes the core principles that guide Banco Sabadell Group in its task of addressing the challenges of sustainability, defining the management parameters, as well as the organisation and governance structure needed for its correct implementation.
In relation to the management and control of environmental risk, the Board is ultimately responsible for embedding it into the general strategy and for establishing the necessary mechanisms for its review. Its duties range from monitoring environmental risk to approving and reviewing the organisational and functional framework for managing, controlling and reporting on this risk, approving the associated policies and reviewing them on an annual basis. Lastly, it is worth noting that the Board of Directors has received specific training on climate risk management, the impact deriving from those risks, policies and regulations in that regard, as well as measurement metrics such as the carbon footprint and decarbonisation pathways.
Board Committees
The Board Strategy and Sustainability Committee was set up in 2021 and is chaired by the Chairman of the Board of Directors, in the capacity of Other External Director. It is formed of five Directors: three Independent, one Other External and its Chair. This Board Committee met 15 times in 2024.
This Board Committee is responsible for analysing and reporting to the Board of Directors on environmental risk policies and for reporting to the Board of Directors on any amendments or periodic updates of the environmental risk strategy. It is also responsible for supervising the model for identifying, controlling and managing risks and opportunities in relation to sustainability including, where applicable, environmental risks.
Banco Sabadell continues to move forward with its activities and organisation to support and accelerate the important economic and social transformations that contribute to sustainable development and the fight against climate change.
Firm in its resolve, the Bank maintains its Commitment to Sustainability, approved in 2022, which sets out an action framework that integrates a forward-looking vision, for the period 2025-2050, of Environmental, Social and Governance (ESG) commitments in the Bank's strategy, aligns the Bank's business objectives with the Sustainable Development Goals (SDGs), and establishes levers to activate the transformation and promotion of initiatives in this area.
[Details about other Board Committees and Internal Committees follow]
Organisation
The Sustainability and Efficiency division was created in 2021 and is the unit responsible for defining and managing Banco Sabadell Group's responsible banking strategy, including the cross-cutting implementation of ESG criteria across all of the Bank's business units, affiliates and subsidiaries. The Sustainability and Efficiency Director is a General Manager who forms part of the Institution's Management Committee and reports directly to the Chief Executive Officer.
At the end of 2024, certain internal organisational changes were approved, applicable as from 1 January 2025, as a result of which the Sustainability division is to be integrated within the People division. The Director of the People and Sustainability division is a General Manager who forms part of the Institution's Management Committee and reports directly to the Chief Executive Officer.
The Sustainability division is a cross-cutting structure that has an overview of all new initiatives to be implemented in the Bank, collaborating in their definition, promoting them and taking charge of their monitoring.
[Details about three lines of defence organization continue]
BarcoBelgium
The role of the administrative, management and supervisory bodies
Barco's organization is set up in three divisions, serving three different end-markets: Healthcare, Enterprise and Entertainment. Each division comprises two business units, which handle marketing and communications, sales, product management and R&D, while more general functions (services, sales support, operations, digitization, finance, HR, legal and Barco Labs) are managed on a global level.
In 2024, Charles Beauduin moved from co-CEO to Chairman. The transition was exceptionally seamless. As planned from the beginning, Charles stepped down as Barco's co-CEO in September last year, following a period of significant transformation. Charles' dedication to Barco continues now in a different role, as chairman of the board, where he will keep focusing on value creation for the company.
An Steegen became the sole CEO, following the board's trust in her to lead the company. The board of directors maintains oversight responsibility for corporate strategy and sustainability matters.
BBVASpain
BBVA's Corporate Governance system is made up of a set of principles, rules and mechanisms that integrate and regulate the structures and operation of its corporate bodies. The System is configured, mainly, by the provisions of the Statutes, the regulations of its different corporate bodies and the general policies of the Bank approved by the Board of Directors. As of December 31, 2024, BBVA's Board of Directors comprises 15 members, two of whom were executive and 13 are non-executive directors. BBVA's Board of Directors has a balanced composition, with high levels of independence and diversity. At the close of the 2024 fiscal year, BBVA's Board of Directors comprises 46.66% women and 53.34% men. In terms of independence, BBVA's Board of Directors includes ten independent directors, representing 66.66% of the total Board members. The Board of Directors has the powers established at any time by applicable legislation and the Bylaws and has the power to approve the general policies and strategies of the Entity. The Board carries out, directly or through its Committees, the monitoring of the decisions adopted, including the supervision of the implementation of general policies, and the supervision of the management of the Company and its Group.
Danica PensionDenmark
Danica's Board of Directors and Executive Board consider questions on sustainability. Board members complete the statutory board leadership course, and the Rules of Procedure for the Board of Directors stipulate that, based on the Danish FSA's requirements as to the knowledge and experience of board members in life insurance companies, the Board of Directors must once a year discuss and assess whether the relevant skills and expertise are represented on the Board. ESG is included as a parameter in this assessment. In addition, Danica is strengthening its sustainability expertise across the organisation to better integrate sustainability throughout the business. Danica's top management consists of the Executive Board and the Board of Directors. At 31 December 2024, the Board of Directors had nine members: five elected at the annual general meeting, three elected by the employees and one external member appointed by the Danish Minister for Finance. The board members elected at the annual general meeting are up for election every year, and board members elected by the employees are elected for a period of four years, as prescribed by the applicable legislation. One of the five board members elected at the annual general meeting (20%) is independent, i.e. is not employed by the Danske Bank Group, and 20% of the members of the Board of Directors, i.e. one out of the total of five members elected at the annual general meeting, is a woman.
DemantDenmark
The overall responsibility for risk management lies with the Executive Leadership Team, but risk management activities are carried out throughout the organisation on a day-to-day basis. Risk management is an integral part of the management of the Demant Group. Risks to which business areas, markets and operations are exposed are identified, monitored and mitigated at all management levels. Through frequent and transparent reporting, these measures ensure that key risks are escalated to the business area leadership, to functional boards, to the Executive Leadership Team, and if relevant, to the audit committee and ultimately the Board of Directors. We have established a number of functional boards to ensure focus on governance, development and risk management in key areas globally, i.e. IT, Finance, HR, Sustainability and Legal & Compliance. The functional boards are responsible for risk management in their respective areas and for ensuring that policies, guidelines and processes are established to monitor risks and new legislation. The audit committee oversees the risk management processes related to financial risks, including sufficient and efficient internal controls.
DSBDenmark
DSB is an independent public institution owned by the Danish State. DSB is managed by a Board of Directors composed of representatives appointed by the Danish Ministry of Transport and employee representatives. The Board of Directors is responsible for the overall management of DSB and for ensuring that DSB's activities are conducted in accordance with the purpose, strategy and the financial and operating targets laid down by the owner. The Board of Directors appoints the Executive Management and defines the framework for the Executive Management's work. The Board of Directors meets at least six times a year.
Gjensidige ForsikringNorway
The role of administrative, management and supervisory bodies
The Risk Committee, the Audit Committee and the Organisation and Remuneration Committee consist of members of the Board. The Chair of the Board has broad expertise of sustainable development from several sectors, and has completed several courses and certifications in sustainability. Several members of the board have completed Gjensidige's sustainability course in 2022 and 2023. Many of the board members have also completed other courses and have experience of sustainability work through directorships in other companies. We believe that the board has sufficient sustainability competencies.
THE NOMINATION COMMITTEE
Responsible for ensuring that the board has the necessary expertise and experience
THE BOARD
Adopts sustainability goals and strategy (management responsibility), and follows up the status of measures and their effect (supervisory responsibility), and is responsible for everything that is dealt with in the subcommittees.
THE RISK COMMITTEE
Reviews proposals for sustainability targets, discusses identified influences, risks and opportunities, and ensures that risk appetite includes sustainability topics and risk exposure.
THE AUDIT COMMITTEE
Reviews quarterly sustainability report, internal control over non-financial reporting, sets materiality threshold and reviews the double materiality analysis. The committee determines the process for processing the annual report, including the sustainability report, and pre-processes the report for decision by the board.
THE ORGANISATION AND REMUNERATION COMMITTEE
Prepares the scorecard for the CEO, where the operationalization of several sustainability topics occurs and is measured. The Committee shall provide advice on matters relating to remuneration, and annually discuss with the CEO principles and specific frameworks for determining the remuneration of other senior executives.
CEO
Responsible for delivering on the goals set by the board, and setting sustainability goals downwards in the organization through the scorecards of the executive vice presidents
EVPS AND MANAGING DIRECTORS OF SUBSIDIARIES
Executive vice presidents and executives of subsidiaries implements sub-goals and action plans to deliver on the sustainability goals.
Board members: 10
Executive board members: 3
Non-executive board members: 7
Employee representatives on the Board: 3
Nationalities represented on the Board: 2
Gender distribution on the Board (men/women): 50/50
Independent board members, non-executive: 100%
GN Store NordDenmark
Board and Leadership described on page 36. The Board of Directors' role includes oversight of risks managed across the value chain. Risk governance at GN is overseen by the Board of Directors, who ensure risks are managed across the value chain. A comprehensive risk report, reviewed and prioritized by the Executive Leadership Team, is presented to the Board of Directors annually for approval. The information security management system is being reviewed and approved on an annual basis by the Board of Directors and Executive Management.
KoneFinland
KONE's governance model for sustainability and corporate responsibility within the organization is designed to ensure that sustainability is embedded into all levels of decision-making, from strategic oversight to operational execution. The key governance bodies for sustainability at KONE include the Board of Directors, the President and CEO and the Executive Board, Sustainability Disclosure Board, Safety, Quality and Sustainability Board, and Global Sustainability Forum. The Board of Directors holds the overall responsibility for overseeing the company's sustainability strategy. The Board regularly reviews sustainability performance, addresses potential risks, impacts and opportunities, and ensures that the company complies with all relevant regulations and standards. The Board members' strong conviction in the strategic importance of sustainability for KONE's business places significant weight on it in KONE's overall strategy. The board is well-versed in key sustainability matters relevant to the industry and products, such as carbon neutrality. The Board of Directors consists of non-executive members with a gender ratio of 67% male and 33% female. The Vice Chair of the Board, Jussi Herlin has a separate employment contract for his role as Executive Vice Chair of the Board at KONE. There are no other separate employment contracts for the members of the Board of Directors. Of the Board members, 78% are independent of the Corporation and 67% are independent from significant shareholders. The President and CEO is responsible for integrating the sustainability strategy approved by the Board of Directors into the company's daily operations. The Executive Board implements the sustainability strategy across all business units. Each executive member is responsible for embedding sustainability within their respective areas, ensuring that initiatives are effectively executed and aligned with the company's overall objectives.
LundbeckDenmark
Governance framework: The Board of Directors is accountable to the shareholders for the management of the company and is responsible for the overall strategy, supervision of management and ensuring that the company is organized and managed in a sound and prudent manner. The Executive Management is responsible for the day-to-day management of the company in compliance with strategy, policies and guidelines laid out by the Board of Directors. The Board of Directors consists of between five and eight members elected at the Annual General Meeting for terms of one year. The Executive Management consists of the President and CEO and other members as appointed by the Board of Directors.
MapfreSpain
The MAPFRE S.A. Board of Directors is the most senior management and supervisory body for the entire Group. It includes a Steering Committee that acts within all of its powers, except those that cannot be ceded by law, bylaws, or the regulations of the Board of Directors, and three delegate committees (Audit and Compliance, Appointments and Remuneration, and Risk and Sustainability). The Executive Committee exercises direct supervision over management of the Business Units and coordinates the various Areas and Units across the Group. The Transformation and Innovation Committee reports to the Executive Committee and has decision-making powers in relation to all transformation and innovation initiatives within MAPFRE. Additionally, the Global Business Committee is tasked with analyzing the development of the Group's global insurance and service businesses, monitoring adherence to established plans, and proposing corrective or improvement actions. The management, coordination and supervision of the activities of the different Units and Areas are carried out, according to their respective remit, by the local, regional and business unit Management Committees as well as the Executive Committee.
Norsk HydroNorway
Hydro is a leading aluminium and renewable energy company committed to a sustainable future. Hydro's purpose is to create more viable societies by developing natural resources into products and solutions in innovative and efficient ways. The company has 32,000 employees, at more than 140 locations in 42 countries, more than 30,000 suppliers, and serves more than 30,000 customers around the world.
Novo NordiskDenmark
The shareholders of Novo Nordisk exercise their rights at the Annual General Meeting, which is the supreme governing body of the company. The general meeting, inter alia, adopts the company's Articles of Association, approves the Annual Report and elects the Board of Directors. Any shareholder has the right to raise questions at general meetings. Resolutions can generally be passed by a simple majority. However, resolutions to amend the Articles of Association require two-thirds of the votes cast and capital represented, unless other adoption requirements are imposed by the Danish Companies Act. Novo Nordisk has a two-tier management structure consisting of the Board of Directors and Executive Management. The governance structure and rules of Novo Nordisk are further described in our Articles of Association and our Corporate Governance Report. Novo Holdings A/S, a Danish company wholly owned by the Novo Nordisk Foundation, holds the majority of votes at Novo Nordisk A/S' general meetings.
NykreditDenmark
The Nykredit Group's governance structure is based on a clear separation of responsibilities between the Board of Directors and the Executive Board. The Board of Directors is responsible for the overall and strategic management of the company while the Executive Board is responsible for the day-to-day management. Following the Annual General Meeting held on 21 March 2024, the Board of Directors includes Merete Eldrup as Chair and Preben Sunke as Deputy Chair as well as John Christiansen, Michael Demsitz, Per W. Hallgren, Jørgen Høholt, Torsten Hagen Jørgensen, Vibeke Krag, Mie Krog and Lasse Nyby. In addition, the Board of Directors includes the staff-elected members Olav Bredgaard Brusen, Rasmus Fossing, Kathrin Helene Hattens, Peter Kofod and Inge Sand. The Group Executive Board includes Michael Rasmussen, Tonny Thierry Andersen, David Hellemann, Anders Jensen and Pernille Sindby. The Board of Directors and the Executive Board together form the management of Nykredit.
ØrstedDenmark
The Board of Directors oversees our risk management in general and have delegated the oversight of our enterprise risk management risks to the Board's Audit & Risk Committee. The Board of Directors has established an Asset Project Committee, which has regular updates on project execution and monitoring of risks as its key focus. Risk reviews are being carried out for selected projects and reported to the Group Executive Team and the Board of Directors. Overall ownership for all mitigating actions for individual risks identified as part of the annual risk assessment rests with a member of the Group Executive Team.
PandoraDenmark
The shareholders exercise their rights at the Annual General Meeting, which is the supreme governing body of the company. During the Annual General Meeting, among other duties, the shareholders elect the members of the Board of Directors (the Board), approve the Annual Report and adopt any proposed changes to the company's Articles of Association. Pandora has a two-tier management structure composed of the Board and Executive Management. The Board outlines the overall vision, strategy and objectives of Pandora's business activities, supervises the performance of Executive Management and is responsible for overseeing the execution of Pandora's sustainability strategy, performance and targets. In addition, the Board is responsible for adopting the sustainability-related policies. This includes reviewing sustainability reporting and overseeing performance related to Pandora's strategic sustainability priorities and targets. Members of Executive Management are appointed by the Board. Executive Management is responsible for the day-to-day management and for the execution of Pandora's strategy. Furthermore, Pandora has an Executive Leadership Team (the ELT), comprised of one woman and seven men, representing seven different nationalities. The team members are responsible for the day-to-day operations of their respective business areas and serve as a part of Pandora's overall leadership. Selected ELT members are also part of Pandora's Sustainability Board. The Board is comprised of seven members, all elected at the Annual General Meeting for a one-year term. Currently, the Board consists of four women and three men, representing five different nationalities. In accordance with section 139c of the Danish Companies Act, this is considered equal gender representation on the Board. In accordance with the Danish Recommendations on Corporate Governance, 86% of the Board members are regarded as independent. Christian Frigast, due to his more than 12-year tenure on the Board, no longer maintains independence status. The composition of the Board is intended to ensure relevant and complementary competencies and diversity. This approach is instrumental in supporting Pandora's strategic goals and vision, while ensuring well-considered, diverse and judicious decision-making. Each year, the Board conducts a board review focusing on its effectiveness and skills. The ideal mix of skills and experience required of Board members includes: Board experience, Executive management, Sectoral experience, Marketing and brand, Retail, Digitalisation, Sustainability, Finance, Governance.
Royal SchipholNetherlands
The administrative, management and supervisory bodies play a crucial role in Schiphol Group's governance structure. As stated on page 3, Pieter van Oord assumed the role of CEO of Royal Schiphol Group on 1 June 2024, succeeding Ruud Sondag who stepped down on 1 March. From March until June, CFO Robert Carsouw served as interim CEO. The CEO and management team are responsible for strategic decision-making and operational oversight. Board biographies are provided on page 64, detailing the backgrounds and qualifications of leadership team members. The governance structure includes oversight of sustainability matters, with the Board responsible for RSG's long-term ambition outlined in Vision 2050 to create the world's most sustainable, high-quality airports.
Stora EnsoFinland
The Board and the President and CEO are responsible for the management of the Company. The duties of the various bodies within Stora Enso Oyj are determined by the laws of Finland and by the Company's corporate governance policy, which complies with the Finnish Companies Act and the Finnish Securities Market Act. The decision-making bodies responsible for managing the Company are the Board and the CEO, while the Group Leadership Team (GLT) supports the CEO in managing the Company. The day-to-day operational responsibility rests with the GLT members supported by divisional and function teams. The Board of Directors convenes a shareholders' meeting by publishing a notice of the meeting at the Company's website not more than three months before the last day for advance notice of attendance mentioned in the notice of the meeting and not less than three weeks before the date of the meeting.
TrygDenmark
Corporate governance - Tryg focuses on managing the company in accordance with the principles of good corporate governance and generally complies with the Danish recommendations prepared by the Committee on Corporate Governance. The Supervisory Board is responsible for the central strategic management and financial control of Tryg and for ensuring that Tryg's business setup is robust. This is achieved by monitoring targets and frameworks based on regular and systematic reviews of strategy and risks. The Executive Board reports to the Supervisory Board on strategies and action plans, market developments and Group performance, capital requirements and risks, etc. The Supervisory Board holds an annual strategy seminar to decide on and/or adjust the Group's strategy to sustain value creation in the company. Each year, the Supervisory Board reviews and an annual cycle for its work. The Supervisory Board specifies its activities in a set of rules of procedure.
VestasDenmark
Vestas has governance structures that support its corporate strategy and sustainability ambitions. The Board of Directors and Executive Management regularly evaluate our capital structure and assess how we fund our operations and growth to ensure these efforts align with shareholder interests and support our corporate strategy. Our financial management goal is to ensure flexibility, financial headroom, and an optimal cost of capital throughout the business cycle. We aim to meet our long-term financial ambitions while delivering value to customers and maximising returns for shareholders. The Board's intention is to recommend 25–30 percent of the company's annual net result after tax as shareholder dividends, which will be paid out following shareholder approval at the Annual General Meeting.
GOV-2
Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies
Banco SabadellSpain
The material Impacts, Risks and Opportunities (hereinafter, IROs) have been identified using the double materiality analysis and are set out in detail in section 3.3 SBM-3: Material impacts, risks and opportunities and their interaction with strategy and business model. In this respect, the material IROs have been grouped into a total of six topics: Climate change mitigation and adaptation, Energy, Own workforce, Access to products and services and non-discrimination, Cybersecurity and data protection, and Business conduct. In this vein, the Management Committee is the highest level executive committee and is regularly informed of material impacts, risks and opportunities at top-level committee meetings.
The governance process for each of the above-mentioned topics is described below:
Climate change mitigation and adaptation
All matters related to climate change (mitigation and adaptation) are regularly reviewed by the Sustainability Committee. The Management Committee, for its part, engages in regular monitoring of the Sustainable Finance Plan and updates to the regulatory framework.
In addition, those that concern business lending are submitted to the relevant Business Committees of the Institution, while those that relate to the measurement of borrowers' climate-related and environmental risks are relayed to the Technical Risk Committee.
As for the Board Committees, in relation to that to which each topic refers:
• Board Strategy and Sustainability Committee: Carries out regular monitoring of the Institution's progress in ESG matters through the review of the Corporate Sustainability Report, which contains information about the overall ESG environment in the context of the macroeconomic and regulatory environment, and about the Institution's ESG outlook, the integration of ESG risks into management arrangements and the priority indicators of Sabadell's Commitment to Sustainability.
• Board Risk Committee: One of the main responsibilities of the Board Risk Committee is that of putting forward the proposed Risk Appetite Statement (RAS) to the Board of Directors for its approval. It should be noted that the RAS has been strengthened over the past year through the inclusion of new environmental risk metrics linked to credit risk.
• Delegated Credit Committee: Approves or reports favourably to the Board of Directors, as applicable, on decisions concerning credit risk acceptance, credit risk refinancing and restructuring, and sales of foreclosed assets, according to the assumptions and limits established by the Board of Directors, following analysis by the Board Committee to ensure that the companies that are the subject of such decisions take sustainability indicators into account.
• Board Audit and Control Committee: During the year, in accordance with the duties incumbent upon it, the Board Committee has monitored and analysed the sufficiency, clarity and integrity of all financial and related non-financial disclosures published by the Bank.
• Board of Directors: Responsible for approving the Institution's policies, for establishing principles, commitments and objectives in the area of sustainability, and for including them in the Institution's strategy.
[Detailed governance processes for Energy, Own workforce, Access to products and services, Cybersecurity and data protection, and Business conduct topics follow]
BBVASpain
The Corporate Bodies promote that Sustainability, which includes environmental, social and governance aspects (hereinafter "ESG"), is integrated into all the Group's small businesses and activities, from a global perspective, and that the material impacts, risks and opportunities arising from it are adequately managed. The impacts, risks and opportunities arising from the different aspects of Sustainability that are of material importance to the Bank are taken into consideration in the various decisions approved by the Board of Directors. In particular, they find a place in the Strategic Plan, which incorporates Sustainability as one of the strategic priorities, in the Budget, which sets annual targets for strategic indicators, among others, related to Sustainability, and in the Risk Appetite Framework, which includes mentions of Sustainability in the Risk Appetite Statement, as well as specific metrics related to Sustainability. In 2024, the Corporate Bodies have periodically received specific reports from the Global Sustainability Area, through which they have been able to monitor the different aspects of the strategy related to Sustainability and the objectives established in this area, as well as the main projects and lines of work of the Group in this area.
Danica PensionDenmark
Danica has prepared a Process for revision of and reporting on the sustainability strategy and a Process for reporting on carbon sector targets towards 2025 and temperature targets towards 2030 in Danica. The process description for revision of and reporting on the sustainability strategy comprises an internal and an external track. The internal track covers reporting via a quarterly KPI dashboard, which is distributed to internal stakeholders in Danica. The external reporting includes reporting on the sustainability strategy, which is incorporated in Danica's annual report (CSRD) and interim report. It also includes an annual status report on selected areas of Danica's sustainability strategy in Danske Bank's annual report (CSRD). Both are distributed to external financial stakeholders, but a number of internal stakeholders are also involved. The sustainability topics that Danica's Executive Board and Board of Directors considered in 2024 included: Status of the sustainability strategy towards 2025, Review of Danica's material sustainability risks, Introduction to and presentation of the CSRD project, Inspection of sustainable investments with the Danish FSA, Taxonomy reporting, Responsible Investment Policy, Active Ownership Policy and Sustainability Policy, Climate target status for investments.
GN Store NordDenmark
Sustainability governance is described on page 44. GN's approach to sustainability is driven by a desire to create real and lasting value for all stakeholders. Sustainability is integrated into how we run our company, as a consideration in key decisions on how we design our products and run our operations. We have not set up a separate sustainability governance structure but use our existing business processes to drive this agenda.
KoneFinland
The Board of Directors holds the overall responsibility for overseeing the company's sustainability strategy. The Board regularly reviews sustainability performance, addresses potential risks, impacts and opportunities, and ensures that the company complies with all relevant regulations and standards. The Board members are experienced in addressing sustainability-related impacts, risks, and opportunities, for instance related to carbon neutrality and health and safety topics, within the company's industry, products and operating environment. The Board's annual review cycle and governance structure are established to ensure continuous monitoring of progress towards sustainability targets, associated risks and opportunities as well as development of relevant skills. These reviews are conducted by KONE's or external subject matter experts. Areas and global functions are owners of the key risks and opportunities relevant to the objectives of their organization. They are ultimately accountable that the risks are managed appropriately and shall allocate resources and delegate responsibility to efficiently manage the risks. The Board of Directors and the President and CEO are jointly responsible for overseeing impacts, risks, and opportunities, with this responsibility further delegated to committees focused on safety, quality, sustainability, and global compliance, along with their respective members. KONE's Global Risk Management function facilitates sustainability risk assessments, including double materiality analysis (DMA) and the assessment of impacts, risks and opportunities (IROs), which are reviewed and managed jointly with relevant functions. The Executive Board and the President and CEO receive updates on material IROs or other relevant risk assessments bi-annually by the global risk management function. The Board of Directors are informed on the material risks and opportunities on an annual basis by the General Counsel.
Novo NordiskDenmark
Executive remuneration is linked to financial performance as well as non-financial performance (e.g. innovation and sustainability). Novo Nordisk has prepared a separate Remuneration Report describing the remuneration awarded or due during 2024 to the Board of Directors and Executive Management members registered with the Danish Business Authority. The Remuneration Report is submitted to the Annual General Meeting for an advisory vote.
ØrstedDenmark
The Board of Directors has established an Asset Project Committee, which has regular updates on project execution and monitoring of risks as its key focus. Risk reviews are being carried out for selected projects and reported to the Group Executive Team and the Board of Directors. We regularly report the status on project execution progress and project risks to the newly established Asset Project Committee.
PandoraDenmark
The Board held nine meetings in 2024. Its primary focus was to navigate Pandora carefully through uncertain macro-economic circumstances, including the implications from increased commodity prices and complex socio-political environments. Additionally, the Board ensured Pandora remains aligned with the next phase of the Phoenix strategy, announced during Pandora's Capital Markets Day in October 2023, which focuses on transforming the company into a full jewellery brand. Furthermore, the Board has overseen the integration of sustainability into relevant processes in Pandora, ensuring alignment with our strategic priorities and the sustainability targets. Two subject-specific committees (the Responsible Sourcing Committee and the Responsible Marketing Committee) and two task forces (Low Carbon & Nature Task Force and Corporate Sustainability Reporting Directive (CSRD) Task Force) oversee key sustainability areas on responsible sourcing, responsible marketing, our work on environmental impacts, CSRD implementation and compliance within the company. They convene regularly and report to the Sustainability Board. In 2024, we updated our double materiality assessment, as part of the requirements of the CSRD. The double materiality results were approved by Pandora's Sustainability Board, with the Board providing oversight to ensure alignment with strategic goals.
Royal SchipholNetherlands
Information provided to administrative, management and supervisory bodies includes sustainability matters as part of the strategic framework. As outlined in the Vision and strategy section, RSG's strategy is reviewed every five years, with a new strategic plan process started in August 2024 to be completed in 2025. The Board addresses material sustainability topics identified through the double materiality assessment, including climate change mitigation, climate change adaptation, air pollution, soil pollution, biodiversity, resource use and circular economy, affected communities and noise, employment practices, safety, security, cybersecurity, business ethics and corporate culture, and supplier and procurement practices. The Board oversees Top Performance Indicators (TPIs) that measure progress on sustainability objectives, including CO2e emissions reduction targets and other environmental and social metrics.
Stora EnsoFinland
Shareholders may exercise their voting rights and take part in the decision-making process of Stora Enso by participating in shareholders' meetings. Shareholders also have the right to ask the Company's management and Board of Directors questions at shareholders' meetings. Major decisions are taken by the shareholders at Annual or Extraordinary General Meetings. At a shareholders' meeting, each A share and every ten R shares carry one vote. Shareholders may also exercise their decision-making rights by means of pre-voting, which has been offered by the Company as a means of exercising voting rights since 2020.
TrygDenmark
The Executive Board reports to the Supervisory Board on strategies and action plans, market developments and Group performance, capital requirements and risks, etc. The Supervisory Board holds an annual strategy seminar to decide on and/or adjust the Group's strategy to sustain value creation in the company. The Executive Board works with the Supervisory Board to ensure that the Group's strategy is developed and monitored. The Supervisory Board ensures that the necessary skills and financial resources are available for Tryg to achieve its strategic targets. The Supervisory Board is regularly informed about the dialogue with investors and other stakeholders.
VestasDenmark
An assessment of our sustainability-related goals, broken down into key products, services and geographies, is presented to the Executive Management and the Board on a quarterly basis, or, in the case of scope 3 and community engagement, on an annual basis. The Corporate strategy is underpinned by a foundation of 'Sustainability in everything we do'. All of our sustainability-related goals are applicable to all products, services, geographies, and customer categories.
GOV-3
Integration of sustainability-related performance in incentive schemes
Banco SabadellSpain
Banco Sabadell Group's Remuneration Policy is consistent with the goals of the risk and business strategy, the corporate culture, the protection of shareholders, investors and customers, the values and long-term interests of the Group, as well as with customer satisfaction and the measures taken to prevent conflicts of interest without providing incentives for excessive risk-taking.
To that end, Banco Sabadell Group's Remuneration Policy is based on the following principles:
1. Promote business and social sustainability in the medium-long term and ensure alignment with Banco Sabadell Group's values. This involves:
• Aligning remuneration with shareholders' interests and with the creation of long-term value.
• Implementing rigorous risk management, considering measures to prevent conflicts of interest.
• Aligning with Banco Sabadell Group's long-term business strategy, objectives, values and interests.
2. Ensure a competitive and fair remuneration system (external competitiveness and internal fairness) that:
• Is able to attract and retain the best talent.
• Rewards professional experience and responsibility, irrespective of the employee's gender. In this respect, Banco Sabadell Group's Remuneration Policy is based on equal pay for male and female employees for equal work or for work of equal value.
• Is aligned with market standards and is flexible, so that it can be adapted to changes in the environment and sector requirements.
3. Reward performance, thereby aligning remuneration with individual results and the level of risk taken:
• Finding an adequate balance between the various remuneration components.
• Considering current and future risks and results, without providing incentives for excessive risk-taking beyond Banco Sabadell Group's tolerated threshold.
• Implementing a simple, transparent and clear-cut remuneration scheme. The Group's Remuneration Policy should be easy to understand and easy to communicate to the entire workforce.
The Banco Sabadell Group Remuneration Policy, in its entirety, includes information about the integration of sustainability risks. In particular, in terms of sustainability, the following aspects are taken into consideration:
• The remuneration policy and practices integrate sustainability risks and information in that regard is published on the Group's website. The remuneration policy and practices shall encourage behaviour consistent with the Group's risk-based approaches related to climate and the environment, as well as with the commitments voluntarily undertaken by the Group. In addition, they shall promote a long-term approach to the management of climate-related and environmental risks.
• Remuneration components must contribute to the promotion of environmental, social and governance actions in order to make the business strategy sustainable and socially responsible.
The specific operation of variable remuneration will be described in the Banco Sabadell Group companies' regulations. In any case, variable remuneration will be linked to results, in such a way that its total amount will be based on an assessment that:
• Combines the results of the Group, entity, business unit or division in which activities are carried out and/or those of the employee.
• Takes into account both financial and non-financial criteria, aligned with the strategic planning, budget and risks taken or indicators in the fields of environment, society, diversity and gender equality.
• In terms of long-term remuneration, multi-year targets will also be considered, based on quantitative criteria linked to a period long enough to properly reflect the risk taken.
Within the Group's objectives, the Synthetic Sustainability Indicator (SSI) has a weight of 10% in employees' variable remuneration and includes ESG metrics and indicators. In the case of the Executive Directors, this indicator has a weight of 14% for the CEO and 13% for the CRO. In terms of its composition, it is structured in four blocks: Green loans or sustainability-linked loans (40% weight); gender diversity indicators (percentage of female representation in management, 20% weight); indicators linked to the attainment of the Sustainable Finance Plan (20% weight); and score given by ESG rating agencies (20% weight).
[Table showing parameter definitions and weights]
Furthermore, to reinforce the alignment of remuneration with the Group's sustainability commitment, in 2023 a synthetic sustainability indicator was included in the multi-year targets set by the Group, directly linked to long-term remuneration, weighted at 20%. Its composition is structured around the synthetic indicator related to Sustainable Business (green & social loans, sustainability-linked loans, and other mobilised funds) and to Diversity (percentage of women in the management team).
In long-term remuneration, in addition to the annual targets established for short-term variable remuneration, the multi-year targets must be met. For the period 2024-2026 the multi-year target indicators are: shareholder value creation (relative Total Shareholder Return or TSR), weighted at 40%; profitability (Return On Tangible Equity or ROTE), weighted at 40%; and Sustainability (the above-mentioned synthetic sustainability indicator), weighted at 20%.
Additionally, some job functions have been assigned sustainability targets as part of their individual targets.
Targets will be set in such a way that the assignment of variable remuneration includes all current and future types of risk, with either annual and multi-year targets or with ex-ante adjustments to variable remuneration.
Banco Sabadell Group annual and multi-year targets, their weighting and their scale of achievement will be approved by the Board of Directors, based on a proposal by the Board Remuneration Committee. Guidelines on target setting and their weights for all staff members are approved by the Board Remuneration Committee. The individual targets of each staff group will be detailed in the corresponding remuneration policies.
BBVASpain
BBVA has a Remuneration Policy for BBVA Directors approved by the General Shareholders' Meeting on March 17, 2023. The short-term incentive includes financial and non-financial indicators, both with an annual measurement period, which are aligned with the most relevant management metrics and with the Group's strategic priorities. The indicators for calculating the annual variable remuneration include several non-financial or Sustainability-related indicators - Net Promoted Score (NPS), Target Clients, Sustainable Business Channeling, Decarbonization of the Portfolio and Percentage of Women in Management Positions - which together represent 32.8% of the target annual variable remuneration. For the short-term incentive for 2024: Net attributable profit (20%), RORC (20%), Efficiency ratio (20%), Net Promoted Score (NPS) (15%), Target customers (15%), Sustainable business channel (10%). For the long-term incentive: Tangible Book Value per share (TBV per share) (40%), Relative Total Shareholder Return (Relative TSR) (40%), Portfolio decarbonization (15%), Percentage of women in management positions (5%). To promote the achievement of the objectives, the following are included in BBVA's variable remuneration system: Promoting new business through sustainability with Annual Variable remuneration linked to the promotion of sustainable business for all employees, including executive directors and Senior management of BBVA, and incentives linked to sustainable business specific to the commercial network. Achieving net zero emissions: since 2023, long-term variable remuneration has been linked to certain decarbonization target for members of the collective, including executive directors and Senior management of BBVA.
Danica PensionDenmark
Sustainability-related KPIs, including climate-related KPIs, are integrated into the Danske Bank Group's, and consequently Danica's, performance management framework to ensure that remuneration programmes reflect the Group's sustainability ambitions. The KPIs for remuneration programmes are approved by the Board of Directors after being reviewed by the Board of Directors Remuneration Committee. The incentive schemes do not apply to members of the Board, as they do not receive variable remuneration. For Danica's Executive Board, KPI agreements are prepared by the CEO, and the KPI agreement applying to the CEO is made with the chairman of Danica's Board of Directors. In 2024, ESG aspects made up 10% of the Executive Board's incentive programme.
KoneFinland
KONE drives sustainability performance also through compensation. KONE's long-term incentive plan, approved and updated by the Board of Directors, emphasizes sustainability alongside profitable growth to ensure a strong focus in driving transformation towards the achievement of KONE's sustainability ambitions. KONE's Sustainability KPIs have a total 20% weight in the long-term incentive plan and are related to KONE's targets to reduce its Scope 1, 2 and 3 carbon emissions (10% weight), as well as diversity and safety related targets (10% weight).
Novo NordiskDenmark
Moreover, our commitment to sustainability is reflected in our incentive programmes, which incorporate our Strategic Aspirations 2025 into both individual and corporate performance targets. This highlights our dedication to driving sustainable growth and creating long-term value for all stakeholders. Executive remuneration is linked to financial performance as well as non-financial performance (e.g. innovation and sustainability).
NykreditDenmark
Information about remuneration is provided on page 155. Nykredit has clear internal procedures for managing upcoming or new regulation with the aim of ensuring a well-defined division of tasks and responsibilities across the organisation and providing timely, appropriate involvement of Nykredit's various management levels.
PandoraDenmark
The Remuneration Committee is responsible for incentive schemes and remuneration, including those related to sustainability. More information can be found in the Remuneration Report.
GOV-4
Statement on due diligence
Banco SabadellSpain
The Group takes into account sustainability risks in its assessment, management and control processes through the activities carried out.
In this respect, Banco Sabadell Group has a Sustainability Policy, which aims to provide a framework for all of the Institution's activity and organisation within ESG parameters. The Policy incorporates environmental, social and governance factors in decision-making and, at the same time, based on those factors, it responds to the needs and concerns of all of its stakeholders. The Sustainability Policy sets out the core principles on which the Group bases its approach to tackling the challenges of sustainability, and defines the corresponding management parameters, as well as the organisation and governance structure required for their optimal implementation.
Effective integration of environmental, social and governance risks into management arrangements requires a strategy and set of regulations that establish the guidelines, targets and limits required at different points of the credit approval workflow. The Bank therefore attaches great importance to the assessment of the climate-related and/or environmental, social and/or governance risks of its counterparties.
Specifically, climate-related and/or environmental risks are set out in detail in section 5.1.4.1 ESRS 2 IRO-1: Description of the processes to identify and assess material climate-related impacts, risks and opportunities.
In terms of social risks, various social factors are considered, such as those related to rights, well-being, and the interests of people and communities. The risk of loss arising from any negative financial impact on counterparties stemming from the current or prospective impacts of social factors is also included. To that end, a series of actions linked to the process for identifying, measuring and managing social risk for both retail and business customers have been implemented. Although it is true that many of these actions apply to both types of customers, the Due Diligence Policy as regards the granting of credit is geared towards retail customers, while the Defence Sector Policy, the Eligibility Guide and the IRCA are actions mostly aimed at corporates.
The Group therefore has an Environmental and Social Risk Framework that consolidates the set of applicable criteria (sectoral standards) that are intended to limit the financing of customers or projects that the Institution considers to be contrary to the transition to a sustainable economy or that lack alignment with international regulations or best practices in the industry.
The above-mentioned Framework also integrates compliance with the rules and standards at the level of social risk, some sector-specific (e.g. in the energy and agricultural sectors, special consideration is given to the negative impact they may have on society and local communities), and others of general application, such as the International Labour Organisation (ILO) Conventions and the UN Guiding Principles on Business and Human Rights. In this regard, the Framework has the same thresholds and scopes of application and the same mechanisms for effective implementation as those described in section 5.1.4.1 ESRS 2 IRO-1: Description of the processes to identify and assess material climate-related impacts, risks and opportunities, including the dispute screening tool provided by a reputable third-party supplier. Specifically, the general exclusions limiting the financing of companies with a high level of social risk, regardless of the sector to which the borrower belongs, are:
a. Companies for which Banco Sabadell has sufficient reason to believe that they employ child labour or forced labour, as defined in the ILO conventions, or that have participated in human rights violations and/or that do not follow the principles of the Institution's human rights policy.
b. Companies involved in the resettlement of indigenous or vulnerable groups without their free, prior and informed consent, or that otherwise infringe the rights of those groups.
c. Companies for which Banco Sabadell has sufficient reasons to believe that they are in material breach of applicable laws and regulations in relation to human rights and the environment, even if the circumstances in question do not constitute a breach of the local legislation of each country.
d. Companies that do not have health and safety policies in place to protect their workers, such as OHSAS 18001 or ISO 45001.
On the other hand, the Group has a Human Rights Policy and a related Due Diligence Procedure, both approved in 2021, which are reviewed annually and are applicable to all Group companies. They establish basic principles of action, as well as the mechanisms required to identify, prevent, mitigate and/or remedy any potential negative impacts on human rights that the Bank's activities and processes may entail, in particular with regard to granting finance to companies, or in relation to its human resources management model or supplier engagement processes. They also establish the need for employees to receive training in all of these areas. The principles governing the Human Rights Policy take into consideration the impact and relationship with four main stakeholder groups: Group employees, customers, suppliers and commercial partners, and the communities or environment in which the Group conducts its business and operates.
The Group also has a new version of the Group Code of Conduct, first approved in 2021 by the Board of Directors, which underwent an in-depth review to adapt it to regulatory requirements, supervisory guidelines and specifications, and to market standards. Every member of the Group's workforce was required to read and expressly accept the new version of the Group's Code of Conduct.
BBVASpain
BBVA aims to contribute to the respect for Human Rights. This is why it frames this willpower in the Group's General Sustainability Policy and aligns it with its Code of Conduct. Since 2018, the BBVA Group has carried out two global Human Rights Due Diligence exercises with the aim of preventing, mitigating and remedying potential impacts on human rights (such as human trafficking, forced labor, child labor, freedom of association and collective bargaining and, equal pay or discrimination). Through it, BBVA has analyzed the following aspects: Identification of the main issues or potential impacts of operations. Improvements within BBVA to try to prevent and mitigate these impacts. The availability of channels and processes that facilitate grievance mechanisms. The Group ensures compliance with all applicable laws and respect for internationally recognized human rights in all its relations with employees, customers, shareholders, suppliers and, in general, with the communities in which it conducts its businesses and activities. The policy is aligned with the International Bill of Human Rights, the Guidelines of the Organization for Economic Cooperation and Development (OECD) for Multinational Business, or the fundamental conventions of the International Labor Organization.
Danica PensionDenmark
As part of the Danske Bank Group, Danica supports a number of international sustainability initiatives and standards. These include: the 2030 Agenda and the UN Sustainable Development Goals, the UN Global Compact, the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights, the UN-supported Principles for Responsible Investment, the UN Environment Programme Finance Initiatives, the ILO Declaration on Fundamental Principles and Rights at Work, the Universal Declaration of Human Rights, the Paris Pledge for Action, the Poseidon Principles, the Responsible Ship Recycling Standards, the UN Principles for Responsible Banking, the Net-Zero Asset Owner Alliance, the Finance for Biodiversity Pledge, FAIRR. Danica regularly performs sustainability due diligence processes, for example in relation to responsible investments, employee engagement, human rights, etc.
KoneFinland
KONE integrates due diligence into its governance and strategy by adhering to the Finnish Corporate Governance Code and embedding sustainability into its operations. The company's due diligence and its integration to key processes are supported by KONE Global Management System, Health and Safety Policy Statement, Environmental Policy Statement, Human Rights Policy, Code of Conduct, and Supplier and Distributor Codes of Conduct, which are detailed in the policy sections of the material sustainability topics. KONE emphasizes engagement with stakeholders, including employees, suppliers, and communities. Supporting KONE's sustainability due diligence, the continuous assessment and identification of impacts, risks, and opportunities is embedded into its processes and policies. More information is presented in the corresponding material topics throughout this Sustainability Statement in the following sections: Material impacts, risks and opportunities, Policies, Engaging with the affected stakeholders, Remediating negative impacts, Actions, and Metrics. In addition to complying with applicable laws, rules, and regulations, KONE has established internal requirements to uphold high environmental and social standards in global activities, as well as for its suppliers and partners.
ØrstedDenmark
To strengthen a successful integration of sustainability into the business, we updated our sustainability governance with a clear accountability and leadership focus at the Group Executive Team level. We continued to push for the further integration of sustainability into our business – to support that sustainability impacts, risks, and opportunities are consistently considered in decisions, ranging from what we source to how we develop, construct, operate, and decommission our projects. As part of this, we began to further detail and develop roadmaps – to break down our ambitions into structured short- to medium-term actions and milestones. Going forward, this will support that all relevant business functions have a strong understanding of their roles in and responsibilities for executing on sustainability.
GOV-5
Risk management and internal controls over sustainability reporting
Banco SabadellSpain
The main function of the Internal Controls over Sustainability Reporting (hereinafter, ICSR) unit is the design and implementation of the general control framework corresponding to Banco Sabadell Group's Sustainability Report.
This includes the identification of significant quantitative data generation processes involved in generating the quantitative information contained in the Sustainability Report. A data generation process is considered to be one which generates quantitative indicators associated with the Impacts, Risks and Opportunities (IROs) stemming from the double materiality analysis and one which comprises common elements, such as a data origination source and the processing and analysis of those elements prior to final disclosure.
The ICSR unit analyses those data generation processes, through a thorough analysis with the expert areas involved, and identifies the risks associated with those processes, which are related to the content of the Comisión Nacional del Mercado de Valores (CNMV) guidance that serves as the frame of reference, and controls are designed and incorporated, jointly with those responsible for the data, to mitigate the previously identified risks.
The resulting matrix of risks and controls provides a holistic view of the processes and systems involved in producing the Sustainability Report. The matrix can be consulted to identify the executor and the reviewer of the control, the data that it covers and the process to which it belongs, among other fields.
Furthermore, with the entry into force of the new European Corporate Sustainability Reporting Directive (CSRD), the ICSR unit has identified risks and designed controls over the new double materiality exercise in order to ensure the correct execution of this exercise and its completeness.
Based on the above-mentioned Directive, content controls have been established over the qualitative information disclosed throughout the Sustainability Report in relation to policies, actions, metrics and targets, as these are considered to constitute sensitive information and there are risks involved in their disclosure to the markets.
With regard to the assessment of the established controls, which mitigate the associated risks through their prevention or detection, this is carried out using the Bank's Governance, Risk and Compliance (GRC) tool, which is managed by the ICSR unit, where the areas responsible complete assessment forms accompanied by evidence supporting each of the controls.
Having completed the assessment, the GRC tool managed by the ICSR unit has a certification module that can be accessed by members of Senior Management. The certification process is based on the hierarchical and organisational ratification, at three levels, of the result achieved in the assessment of the controls.
The Board of Directors delegates the supervisory function regarding the internal control systems to the Board Audit and Control Committee. Every six months, the current situation of the ICSR as a result of new applicable regulatory requirements is reported to the Board Audit and Control Committee and to the Technical Committee on Accounting and Financial Disclosures. In addition, every year after the end of the tax year, the result of the assessment of the controls and the conclusions derived from it are escalated to the Board Audit and Control Committee.
BBVASpain
The Risk and Compliance Committee supports the Board in integrating Sustainability into the analysis, planning and management of the Group's financial and non-financial risks, and in supervising their execution. The Audit Committee supervises the process of preparing and the content of the information that must be formulated by the Corporate Bodies in matters of Sustainability for publication, as part of the public information of the Group. With regard to the area of ESG public disclosure, the Group has an ESG Reporting Committee. The Committee serves as a coordination and support body at executive level aimed at ensuring that the information to be disclosed on Sustainability matters that is to be formulated by the corporate bodies of the BBVA Group reflects the Sustainability objectives and strategy, risk management model and relevant quality standards. The Committee is led by the Finance area and the following areas participate in it: Global Sustainability Area, Global Risk Management, Regulation & Internal Control, Legal Services, General Secretary, Data, Chair Office, Talent & Culture, and Internal Audit. The information contained in the NFIS has been subject to a limited review by Ernst & Young Auditores, S. L., in its capacity as an independent verification services provider, with the scope indicated in its Verification Report.
Danica PensionDenmark
As part of Danica's sustainability reporting process, governance structures and processes have been established to ensure that risk management and controls are implemented. Danica has established a working group and a steering committee to manage day-to-day decisions related to sustainability reporting. Danica's Audit Committee receives regular project status updates, and the project is also closely monitored by the internal and external auditors and Compliance. Danica's Board of Directors is responsible for approving sustainability reporting before its publication. In relation to quantitative data, an audit tool has been developed that provides an overview of datapoints, data sources, data quality, data use, calculations, documentation, a description of risk and control environments, etc. Mitigating data controls include spot checks and four-eyes controls. Danica will work continually to improve risk management and controls in order to improve data quality over time. In the coming years, Danica will invest in and improve existing controls, for example by implementing a higher degree of automation.
DemantDenmark
The audit committee oversees the risk management processes related to financial risks, including sufficient and efficient internal controls. Risk management is an integral part of the management of the Demant Group. Risks to which business areas, markets and operations are exposed are identified, monitored and mitigated at all management levels. We have established a number of functional boards to ensure focus on governance, development and risk management in key areas globally, i.e. IT, Finance, HR, Sustainability and Legal & Compliance. The functional boards are responsible for risk management in their respective areas and for ensuring that policies, guidelines and processes are established to monitor risks and new legislation.
GN Store NordDenmark
Risk management described on pages 29-32. Effective risk management is a cornerstone in GN's strategy, ensuring that GN remains resilient, agile, and competitive in an ever-changing global environment. Risk governance at GN is overseen by the Board of Directors, who ensure risks are managed across the value chain. Risks are identified and governed by a risk department and the Executive Leadership Team for each division and selected functions. Risks are evaluated based on their impact and likelihood. A comprehensive risk report, reviewed and prioritized by the Executive Leadership Team, is presented to the Board of Directors annually for approval.
KoneFinland
KONE's sustainability reporting is based on the group-level principles of risk management and internal control. The aim of risk management is to identify risks and opportunities in relation to the achievement of sustainability objectives and assess the likelihood and magnitude of the impacts these may have, as well as to identify actions to manage the impacts. The identified risks and opportunities are managed through KONE's sustainability, risk management and internal control governance models. KONE's internal control framework is built and based on corporate values, the KONE Code of Conduct, a culture of honesty and high ethical standards. The framework is supported by a dedicated leadership, training programs, a positive and diligent corporate culture and working environment as well as by attracting and promoting dedicated and competent employees. Global and local policies and principles are a key part of the internal control framework. KONE's internal controls are designed to manage relevant sustainability reporting risks, as part of KONE's processes and employee job roles. Internal controls over sustainability reporting are supported by global and local policies and principles that are continuously maintained by incorporating changes and developments from the business operations and information systems. KONE's Global Risk Management function facilitates risk assessments which includes the assessment of risks and opportunities in relation to sustainability reporting. Dedicated sustainability risk and impact or materiality assessments are conducted to ensure systematical identification, assessment, and treatment of risks, impacts and opportunities. Risks and opportunities are prioritized according to KONE's Risk Management Policy which applies to sustainability reporting. The Executive Board reviews and evaluates the risk assessment results minimum twice a year and agrees on risk management priorities. The Executive Board members for Areas and global functions are owners of the key risks and opportunities relevant to the objectives of their organization. They are ultimately accountable that the risks are managed appropriately and shall allocate resources and delegate responsibility to efficiently manage the risks. The Board of Directors and the President and CEO are jointly responsible for overseeing impacts, risks, and opportunities, with this responsibility further delegated to committees focused on safety, quality, sustainability, and global compliance, along with their respective members. KONE integrates the findings of its risk assessment and internal controls to business practices and processes through management systems and considers those in the sustainability related processes and reporting. This is done by appointing identified risks, opportunities, actions and controls with relevant risk owners and responsible stakeholders. These actions and controls vary from corporate business risks and climate change related mitigation strategies to operational and location specific environmental mitigation actions. Internal control activities to manage the identified material risks related to the accuracy and timeliness of sustainability reporting are adopted as part of KONE's processes that produce sustainability information. The Board of Directors monitors and evaluates the effectiveness of KONE's risk management systems according to their role defined in KONE Risk Management Policy, in addition to the review of key risks and action plans. The Board's Audit Committee monitors the efficiency and functioning of the internal control environment, including internal controls over sustainability reporting. The management is responsible for establishing and maintaining adequate internal controls and for monitoring their effectiveness as part of operative management. The Board's Audit Committee is informed on internal control findings on an annual basis.
ØrstedDenmark
Our 'Enterprise risk framework' sets out the general principles, the roles and responsibilities, and the main processes by which all risks must be identified, assessed, managed, monitored, and communicated throughout the Group. This framework is being strengthened to support consistent processes for managing risks at Ørsted and to enable informed decisions on risk-taking to be made. Risk assessment is carried out on an ongoing basis in all business segments and regions as part of our daily business operations. In addition, we have performed an annual risk assessment with the overall objective of identifying and reporting on our most significant risks. This is carried out through an assessment of the main risks across all business segments, regions, and selected staff functions. An assessment is made of the potential financial impact of the main risks, which are then consolidated and evaluated at Group level.
PandoraDenmark
The Board and Executive Management are responsible for Pandora's internal control and risk management systems in relation to the financial and sustainability reporting process. The Group's internal control framework identifies key processes, inherent risks and control procedures to reduce and mitigate financial and sustainability risks and ensure reliable financial and sustainability reporting. The Audit Committee assists the Board in supervising the financial and sustainability reporting process and monitoring the effectiveness of the internal control and risk management systems. Executive Management is responsible for maintaining and strengthening the overall control environment, identifying weaknesses and ensuring necessary steps are taken to mitigate financial and sustainability risks through standardisation and process optimisation. A central Internal Audit and Compliance Controlling (IACC) function has been established to help Pandora accomplish its objectives by bringing a systematic and disciplined approach to evaluating and improving the effectiveness of internal control, compliance and governance processes. In 2024, the head of the IACC function reported to Pandora's Senior Vice President, Corporate Finance, with a dotted reporting line to the Audit Committee Chair. In 2025, the reporting line will be changed to the Chief Financial Officer, still with a dotted reporting line to the Audit Committee Chair. The Board and Executive Management assess risks on an ongoing basis, including risks related to the financial and sustainability reporting, and they assess measures to manage, reduce or eliminate identified risks. The IACC function assists Executive Management and the Audit Committee in identifying and monitoring financial and sustainability risks in the reporting process. Sustainability risks are assessed on a quarterly basis and insights from the 2024 double materiality assessment have been incorporated into the enterprise risk management calibration process and reporting. We do not consider sustainability risks to be among our top risks. As part of our climate risk assessment, we evaluate risks across various criteria, with key risks reviewed by the Board. In 2022, we conducted a scenario analysis aligned with our risk management matrix to explore climate risks and opportunities across our value chain, identifying areas crucial to transitioning to low-carbon operations. Insights from an on-site risk assessment conducted at the end of 2024 at our crafting sites in Thailand, will enable us to proactively implement tangible recommendations to mitigate potential future supply chain disruptions caused by climate change.
Royal SchipholNetherlands
Risk management and internal controls over sustainability reporting are managed through RSG's integrated approach to risk management. As outlined in the Risk management and internal control section on page 76, RSG maintains comprehensive risk management processes. The company has embraced the Corporate Sustainability Reporting Directive (CSRD) voluntarily in 2024, implementing appropriate systems and controls for sustainability data collection and reporting. The double materiality assessment process ensures systematic identification and assessment of sustainability-related risks and opportunities. RSG's Integral Safety Management System (ISMS) provides structured oversight of safety-related sustainability matters, while compliance and integrity programmes monitor environmental and social performance across operations.
Stora EnsoFinland
The Stora Enso group prepares Consolidated financial statements and interim reports conforming to International Financial Reporting Standards (IFRS Accounting Standards). The Company's sustainability statement is prepared in accordance with the European Sustainability Reporting Standards. The annual financial statement, the Report of the Board of Directors including the sustainability statement and interim reports are published in Finnish and English. Stora Enso prepares its financial statements in accordance with the Finnish Accounting Act. Stora Enso has one statutory auditor elected by the shareholders at the Annual General Meeting. The governance bodies include Internal Audit, Risk management, Internal control, Ethics and Compliance functions.
VestasDenmark
Vestas maintains risk management and internal controls over sustainability reporting. We were, again, ranked 'the most sustainable energy solutions company in the world' by Corporate Knights in early 2025. Vestas operates as a global company with approximately 35,000 employees. In the area of sustainability, we work in both matrix and project structures with representatives from many different departments.
SBM-1
Strategy, business model and value chain
Banco SabadellSpain
The Institution's business model is geared towards profitable growth that generates value for shareholders. This is achieved through a strategy of business diversification based on criteria related to profitability, sustainability, efficiency and quality of service, together with a conservative risk profile, while maintaining high standards of ethics and professional conduct combined with sensitivity to the interests of all stakeholders.
[Business model diagram and key figures shown]
The Group's strategy promotes sustainable financing and investment to drive forward the transition towards a more sustainable model and a low-carbon economy, offering customers and investors the best possible solutions. Thus, the Bank committed to mobilise €65bn in sustainable finance between 2021 and 2025. Up to December 2024, more than €57.9bn had been mobilised, €19bn of them during this year.
To honour this commitment, the Bank is taking further action to raise awareness and offer advice across all sectors of the business fabric, offering solutions to finance the investments required for this transition.
• Sustainable financing solutions:
• Financing solutions in the different business lines:
To bring processes for loan approval, portfolio management and reporting tasks in line with international standards on sustainable financing (the Green Loan Principles and Sustainability-Linked Loan Principles issued by the Loan Market Association and the Green Bond Principles and Sustainability-Linked Bond Principles issued by the International Capital Market Association, ICMA), in 2020 the following types of financing were defined, according to the intended use of the funds:
• Green and Social Loans (GSLs), in which the use of the funds is the main criterion for determining the green, social or sustainable nature. This type of financing is closely related to Banco Sabadell's Sustainable Financing Framework, whose main references are the EU Taxonomy and the best practices in the market such as the Green Loan Principles, and to the green bonds issued by the Bank in recent years under the SDG Bond Framework.
To promote GSL transactions, the Bank has approved discounts that allow it to offer better prices to customers.
The rollout of the Next Generation EU Recovery Funds is expected to significantly boost this type of financing (the section "Next Generation EU" provides more details about the actions that the Bank is taking in relation to the aforesaid funds).
• Sustainability-Linked Loans (SLLs), which relate to the type of financing that incentivises the achievement of sustainability targets, linking the transaction price to the evolution of one or more KPIs. This category does not require the funds to be used for any specific purpose. It is considered essential that the selected indicators be relevant for customers, as this enables their sustainability strategy to gain more traction.
[Detailed sections follow for Corporate & Investment Banking, Business Banking, Retail Banking, and additional business lines including sustainable savings and investment solutions, Sinia Renovables, and Mexico operations]
BarcoBelgium
Strategy, business model and value chain
Barco offers advanced visualization, collaboration and networking technologies for professionals in mission-critical environments. We combine this with a commitment to innovation and sustainability.
Our mission: Our visualization and collaboration technology helps professionals accelerate innovation in the healthcare, enterprise, and entertainment markets.
Barco's strategy comprises three levers: Capture profitable and efficient growth, Innovate for impact and Sustainable impact journey. These are the priorities we want to focus on to remain relevant and flourish in the short, mid- and long term. They help us prioritize our business activities.
Value Creation Model: At Barco, we are constantly thinking about how we can create long-term value for all our stakeholders in the short, medium and long term. The value creation model visualizes our approach. It articulates the mission of our company and links it to our strategy and the markets we cover.
The Barco ecosystem contains key internal and external stakeholder groups across the value chain: Board of Directors and senior management, Shareholders & investors, Employees, Distributors, resellers, partners, and integrators, Customers and end-users, Suppliers. The ecosystem also includes Society representatives, Government & public authorities, Academics, industry associations, NGOs, key opinion leaders, Press & general public, Banks & analysts.
BBVASpain
BBVA has defined sustainability as one of its six strategic priorities, covering three dimensions: Climate (business opportunities related to global warming: electric transport, energy efficiency, renewable energy, etc.), Natural Capital (business opportunities related to nature: water, land, biodiversity, and waste and pollution), and Inclusive growth (business opportunities related to inclusive economic growth: inclusive infrastructures, financial inclusion, entrepreneurship, job creation, access to basic goods and services). The execution of this strategy is based on the achievement of two main objectives: promoting new business through sustainability with a target of 300 billion euros in sustainable business channeling for the period 2018-2025, and achieving net zero emissions by 2050 with decarbonization targets for 11 high-emission sectors. BBVA Group's value chain has been categorized into three elements: upstream (supply chain providers), own operations (employees and real estate assets), and downstream (banking, insurance, and asset management customers). As a result of the double materiality analysis, no material impacts, risks, and/or opportunities exclusively associated with insurance and asset management activities have been identified.
Danica PensionDenmark
Danica is owned by Danske Bank and is one of the largest life insurance and pension providers in Denmark. The Board of Directors holds overall responsibility for decisions about Danica's business model to balance the interests of customers and owners. Danica's business model applies to Danica Livsforsikringsaktieselskab. Pension savings products: Danica offers pension savings products and various risk products, including life and disability insurance. Danica focuses particularly on investments that reflect environmental, social and governance (ESG) factors. Risk products: Customers have a choice of various risk products including cover for loss of earning capacity, waiver of contribution, covers on death and spousal covers. The insurance rules are intended to provide a balance between the desired return and the related risk. Danica also offers risk products through Forenede Gruppeliv as well as health insurance and health packages. Customer segments and sales channels: Danica writes pension schemes for customers, mainly in Denmark, within these two categories: 1. Personal customers with individual agreements 2. Personal customers with an agreement under a framework agreement with Danica, e.g. PFS (Pension for Selvstændige) or employees of an undertaking that has entered into a company pension agreement. Sales are made according to a multi-channel distribution strategy via Danica's own sales force, brokers, partners and in collaboration with Danske Bank. Investment and financial risk management: Danica focuses on generating competitive investment returns for its customers. Consequently, the objective of its investment strategy is to achieve systematically high net returns.
DemantDenmark
Our PURPOSE is to create life-changing differences through hearing health. Our AMBITION is as the leading hearing healthcare company to improve as many lives as possible. Our PRIORITISATION is to support the entire journey to better hearing by focusing on personalised care and innovative solutions. The Demant Group develops, manufactures and sells products and equipment that help people with hearing loss connect and communicate with the world around them. We operate a focused hearing healthcare company, consisting of three business areas: Hearing Aids, Hearing Care and Diagnostics. The Hearing Aids business area engages in the development, manufacturing and wholesale of hearing aids, developing innovative and leading technological solutions that create life-changing hearing health. The Hearing Care business area comprises the Audika Group, which is a global retail company that provides personalised hearing care to customers worldwide through several strong local brands. The Diagnostics business area consists of a group of international companies and is the global market leader in hearing and balance assessment solutions used by audiologists, ENT doctors and balance clinics worldwide. Our operating model is designed to steer us in operating our three business areas – Hearing Aids, Hearing Care and Diagnostics – in a setup that is ensuring that we remain focused on excelling in each business area, while leveraging synergies across the Group through strong collaboration. With our business areas' common understanding of technology, innovation is at the core of our operating model. We will continue to focus on value-adding collaboration between the R&D functions of our individual business areas. Furthermore, our resilient manufacturing set-up across the value chain within R&D, production and distribution ensures supply chain agility and resilience. Our operating model is founded on a robust internal infrastructure, encompassing IT, HR, finance, sustainability as well as legal systems and processes. With sales companies and hearing care clinics all over the world, the Group benefits from a strong global distribution set-up, which enables us to continuously increase our reach to a variety of countries, markets and customer segments, thereby expanding our business. This global network ensures that we can raise awareness and make our diagnostic equipment, hearing aids and personalised hearing care and treatments accessible to those in need, thereby enhancing patient care and improving lives.
DSBDenmark
Our purpose is: A sustainable way forward with room for all of us. Guided by this phrase, we seek to add value for our customers as well as for Denmark at large. In other words, we proactively live up to our corporate social responsibility. Sustainability is a central part of our strategy and day-to-day operations. We are actively working to reduce our environmental footprint through investments in energy-efficient electric trains and in endeavours to minimise the use of resources. DSB is committed to attracting and retaining dedicated, competent and highly qualified employees who help ensure that we achieve our strategic goals. DSB is Denmark's largest provider of public transport and owned by the people of Denmark through the Ministry of Transport's ownership. In pursuing our business activities, DSB collaborates with various stakeholders, including our customers and local communities, NGOs, disability organisations, suppliers, business partners and other public transport market players. Our strategy is Market-oriented DSB. This implies that we must be 'As attractive to our customers and as competitive and sustainable as the best operators in Europe'. Our strategy unfolds in three areas: • Attract more customers and improve customer satisfaction • Deliver a competitive and sustainable DSB • Develop employees and corporate culture. DSB's business model is built around the ambition to provide a seamless travel experience for customers. The timetable has been prepared to support growth and deliver the best possible customer experience with the available railway infrastructure. DSB operates train services on infrastructure that is owned and managed by Banedanmark and Sund & Bælt, among others. DSB manages and develops almost 200 stations across Denmark. DSB Service & Retail operates 61 7-Eleven stores at our stations. DSB enters into joint venture partnerships for the development of sites to the benefit of urban regeneration.
Gjensidige ForsikringNorway
Strategy, business model and value chain
Gjensidige creates value by carrying risk for customers and compensating losses that arise. One of our core competencies is thus assessing risk. Throughout our history, it has been natural for us to focus on preventing damage, and we advise customers and society at large on how to avoid or limit losses.
Our business is conducted within the framework of our strategy, our ethical principles and strict compliance with laws and regulations in the countries in which we operate. We mainly perform all core processes ourselves. Sustainability is integrated into the strategy and our core processes.
Our business model can be described through the following five core processes, in line with the UN Principles for Sustainable Insurance (UN PSI):
RISK ASSESSMENT AND MANAGEMENT
We need to understand the risk we take on and set the right price to cover future compensation for losses that may and will occur. We must also have sufficient capital to meet our obligations. Risk assessment is therefore a core competence in general insurance. We use this expertise to advise customers and society at large on damage prevention.
PRODUCTS AND SERVICES
We develop and offer insurance that covers customers' need for peace of mind, and develop related services for, among other things, damage prevention and claims processing. We generally distinguish between property and liability insurance, often called general insurance, and accident and health insurance. Property insurance compensates the financial loss the customer suffers if an insured object is damaged or lost. Compensation involves either repairing or replacing the damaged object with a similar object, or by the customer receiving a payment. Liability insurance compensates third parties for damage caused by the customer. The largest product groups in the property and liability category are motor vehicle and property insurance. Accident and health insurance compensates the customer's or next of kin's financial loss in the event of accidents, illness or death. Examples of such insurance include life insurance, disability insurance and medical treatment insurance.
DISTRIBUTION AND SALES
Our customer service centres account for most of our distribution, but we also sell insurance through partners, agents and brokers. All our sales representatives and advisers are well trained and certified in accordance with industry standards. We have an established culture of deep customer orientation and seek to foster long-term customer relationships.
CLAIMS HANDLING
Our customers shall receive the correct claims settlement as soon as possible after a loss has occurred. We increasingly use automated processes to achieve quick and precise settlements, while our experienced and competent claims handlers process complex cases. We keep accounts of GHG emissions from claims handling and work systematically on circular solutions to reduce emissions.
RESPONSIBLE INVESTMENTS
We manage substantial capital assets to ensure that we are able to meet our obligations to customers and other stakeholders at all times. The capital is managed with low risk exposure and with as high a return as the risk profile allows. We comply with internationally recognised principles for responsible investments, and have adopted a target of net zero emissions for the portfolios by 2050.
Our corporate strategy follows from our mission to 'safeguard life, health and assets'. We have been doing that for more than 200 years, based on our vision to 'know the customer best and care the most'.
Our overarching ambition is to be a leading general insurance company in the Nordic region. We will achieve this through continued profitable growth driven by three strategic focus areas:
• Strong customer orientation throughout the value chain
• Being the best at general insurance
• Being an attractive alliance partner in larger ecosystems
GN Store NordDenmark
Business model and strategy described throughout pages 8-17. GN's purpose is Bringing People Closer. GN develops, manufactures, and markets innovative hearing aids for people with hearing loss; headsets, speakerphones, and video equipment for collaboration at work; and a broad range of gear for gaming aficionados. Our products support how we communicate with other people and increasingly also how we communicate by use of voice and hearing with technology solutions that assist us in our everyday life and work. We combine innovative software and hardware solutions to help people seamlessly interact and experience the world around them – enhancing hearing, speech, and sight. Value chain described on page 48. GN operates across hearing, enterprise communications, and gaming equipment markets. GN has R&D centers in Denmark, the United States, the Netherlands, Poland, France, Italy, and China. GN has its own central and regional manufacturing sites for hearing aids and accessories in Australia, China, Denmark, Japan, Malaysia, South Korea, Spain, and the United States. GN's enterprise audio and video collaboration equipment and its gaming products are produced by carefully selected manufacturers mainly in Asia.
KoneFinland
In 2024, KONE launched a new strategy 'Rise' for years 2025–2030 where leading in sustainability is part of the strategic ambition and 'Cut Carbon' is one of the four strategic shifts. In this strategic shift, the focus is both on reducing KONE's own emissions as well as on helping KONE's customers to decarbonize with sustainable solutions. Sustainability continues to also be one of KONE's core principles together with safety and quality. Progress toward the sustainability-related strategic ambition is measured using an internal sustainability index. Under the 'Cut Carbon' strategic shift, KONE measures emission reductions in the value chain, revenue from sustainable solutions, and market share in sustainable opportunities. More concretely, KONE aims to radically cut down emissions from its products and solutions by adopting and developing energy efficient technologies, exploring new low-carbon materials and innovating together with its suppliers and partners. In services, sustainability advancements are achieved through leveraging digitalization to reduce unnecessary callouts and for smart planning of the service operations. With the new strategy, KONE remains committed to provide the most sustainable solutions to its customers and help them decarbonize throughout the buildings' life cycle with the following key objectives: • Overall reduction of product related Scope 3 emissions: Reducing emissions related to the materials used and lifetime energy consumption per product ordered • Smart use of materials and circularity: Optimizing material use and reducing the materials, energy, and other resources used in KONE's solutions and operations • Extending product lifetime: Extending lifetime of equipment through service and modernization including intelligent KONE 24/7 Connected Services and predictive maintenance • End-user safety: Having safety as KONE's top priority in all operations • Accessibility: Providing accessible, safe, and convenient solutions for all groups of End-users KONE has a lifecycle business model where it provides elevators, escalators, building doors and related smart solutions for buildings and urban mobility. KONE maintains and modernizes the equipment to ensure the longevity, safety, and efficient operation of equipment, thereby contributing to sustainability by extending the product life cycle. By offering energy-efficient and sustainable products, KONE aims to reduce environmental impact throughout the entire product life cycle, from raw material sourcing to end-of-life. Furthermore, KONE requires that its supply chain partners adhere to sustainability requirements, including ethical sourcing and minimizing environmental impact. A significant part of the value KONE creates is the result of collaboration with the large network of customers, partners, and suppliers, as well as through the use of elevators and escalators manufactured and/or maintained by KONE. Key customer groups include construction companies, building owners, facility managers, developers, and housing associations. Architects, authorities, and consultants are also key influencers in the decision-making process regarding elevators and escalators. In KONE's value chain, upstream activities are related to component and raw material production, and downstream activities related to the use of KONE's products and to the disposal and recycling of equipment at the end of the building's life cycle. KONE creates value to its customers by providing innovative, safe, and energy-efficient solutions that enhance the flow of people in urban environments. The company's digital solutions, such as predictive maintenance and smart elevators, offer improved user experience, safety and uptime. KONE strives to ensure health and safety for employees through high safety standards and practices. For its employees, KONE promotes diversity, inclusion, and continuous learning within its workforce. For its shareholders, KONE creates value through its resilient, sustainable and capital light business model, which creates strong and stable cash flow. KONE has identified the following strategic inputs that are crucial in creating value for customers, shareholders and society: • Competent and engaged people and strong leadership • Innovative sustainable offering and global processes and systems • Best partners • Efficient manufacturing and delivery chain • A solid financial position • Environmentally sustainable operations • High safety record, strong brand, solid reputation and commitment to safety • Life cycle business model and the existing maintenance base KONE ensures the availability of key inputs in its value chain through a combination of strategic sourcing, supplier management, and risk mitigation. To secure key talent, KONE invests in continuous employee development, diversity and inclusion, and retention through a supportive and innovative culture.
LundbeckDenmark
At Lundbeck, we discover, develop, and commercialize treatments that make a difference to people affected by psychiatric and neurological disorders. We cover the full value chain: We have more than 70 years of experience in neuroscience and in improving the lives of people with brain disorders. We research to build a strong pipeline consisting of promising molecules and antibodies. We develop our drug candidates into new medicines. We manufacture medicines at highly advanced production sites and continue to supply our drugs to patients in need. We make our medicines available through healthcare systems in more than 100 countries. We focus our innovation within psychiatry and neurology: We are one of the few biopharmaceutical companies in the world working exclusively within neuroscience. Psychiatry covers psychotic disorders like schizophrenia, mood and anxiety disorders like depression, bipolar disorder, and post-traumatic stress disorder. Neurology covers disorders like migraine, dementia, and movement disorders like Parkinson's disease, epilepsy, and multiple system atrophy (MSA). Neuroscience is an exciting growing area with large unmet medical needs. We see growth and rapidly evolving technologies and methodologies. We are around 5,600 highly specialized employees across +50 countries. We ensure positive outcomes to people and societies: Everywhere we operate, we strive to create long-term value and make a positive contribution to people and societies. +7 million patients around the world are helped by our medicines daily. We reinvest around 20% of our revenue in R&D to continue our development of new, innovative drugs. Throughout our value chain, we incorporate patient insights by talking to and learning from those with lived experiences. We create shareholder value ensuring sustainable and profitable growth. We work in partnerships to fight stigma and address the large unmet medical needs. We act to improve health equity for the patients we serve and the communities we are part of.
MapfreSpain
At MAPFRE, we hold leading positions in most of the markets we operate in. We have achieved this thanks to deploying a proprietary and highly differentiating management model, designed to achieve profitable growth founded on several factors: Transformation and innovation, Geographic diversification, Customer focused, for both private and business sectors, Customer service via multiple channels, Offering a wide variety of products and services, A deep commitment to caring for people. Our highly diversified business model, both geographically and in terms of product, enables us to achieve sustainable growth over the medium and long term, while successfully navigating the evolving challenges in each market. Our Vision at MAPFRE is to be 'YOUR TRUSTED INSURANCE COMPANY', the insurer of choice for all our customers worldwide, with a global presence and a comprehensive range of insurance, financial, reinsurance, and service products. We aim to become a leader in the markets in which we operate through a sustainable, proprietary, and differentiated business model based on transformation and innovation. It is designed to achieve profitable growth with clear and decisive focus on the customer, both private and corporate, creating relationships based on equity and transparency, with a multi-channel approach and a firm vocation for service. Our corporate Purpose, the essence of our day-to-day operations, is best expressed when we tell our clients: 'We are by your side every step of the way, accompanying you to move forward with peace of mind, contributing to the development of a more sustainable and supportive society.' In other words, we support them not just today, but also in the future, because we're prepared to offer what they need now and what they may need tomorrow—just as we have been doing for over 90 years. In a world of uncertainty, we are defined by the dedication of over 230,000 employees, partners, and providers who deliver exceptional service, remain close to our customers, innovate, adapt to their needs, and are always there when they need us.
Norsk HydroNorway
Hydro is present throughout the global aluminium value chain, from energy to bauxite mining and alumina refining, primary aluminium, aluminium extrusions and aluminium recycling. Hydro Bauxite & Alumina represents the first two steps in the aluminium value chain through bauxite mining and alumina refining. Hydro Aluminium Metal is a leading supplier of extrusion ingots, sheet ingots, foundry alloys, wire rods, forge stock and high purity aluminium with a global production network. Hydro Extrusions delivers tailored aluminium components and solutions to customers around the world. Hydro Energy is a major renewables producer, market operator and developer of businesses for the energy transition. Hydro is changing the aluminium game to provide greener materials to products crucial for sustaining the world's rapid development.
Novo NordiskDenmark
At Novo Nordisk, our purpose is clear: driving change to defeat serious chronic diseases. Through our life-changing innovations, we are building a healthier future for generations to come. We are dedicated to reinforcing our leadership in diabetes and obesity, securing a leading position in rare diseases and establishing ourselves as a key player in cardiovascular disease. Additionally, we are actively building our presence in the treatment of metabolic dysfunction-associated steatohepatitis, chronic kidney disease and Alzheimer's disease. We create value on multiple fronts. Through the Novo Nordisk Way, we ensure our employees thrive in a supportive and innovative environment. We operate as a responsible business, striving to address environmental and social impacts, to create value for society and fulfil our financial commitments to shareholders, ensuring sustainable growth and success. Our value chain is similarly comprehensive, encompassing every stage from the initial concept of a new treatment to its final delivery to people living with serious chronic diseases. This includes our own operations in R&D and manufacturing, as well as collaborations with suppliers to source materials and distribute our treatments effectively.
NykreditDenmark
Nykredit is a Danish financial services group serving personal customers, business customers and institutional customers in Denmark. The Group's business activities are predominantly in Denmark and comprise banking, mortgage lending, estate agency services, administration and management of investment funds, leasing and insurance mediation. A central part of our business model and value chain is our partnerships through Totalkredit and Sparinvest. Together with the business partners in the Totalkredit partnership, Nykredit arranges mortgage loans across the country. In Sparinvest, Nykredit collaborates with a large number of banks across Denmark on the distribution of wealth and investment products to personal and business customers. The Group's upstream value chain includes a number of suppliers of goods and services for the daily operation of Nykredit's offices, such as IT systems. The Nykredit Group strives to have a strong capital structure and wants to be able to maintain its business activities throughout Denmark regardless of fluctuations in economic trends. Nykredit's 3,900 employees are tasked with the development and sale of financial products as well as customer advisory services. Being customer-owned, Nykredit differs significantly from other Danish SIFIs as the Group pays dividend to its owners, including our main owner, Forenet Kredit. Forenet Kredit can then make contributions to the Nykredit Group, which Nykredit and Totalkredit can give back to their customers. It is our customer-ownership structure that sets the Nykredit Group apart from other comparable financial institutions by highlighting our unique business model and approach to value creation.
ØrstedDenmark
We create value by developing, constructing, operating, and owning renewable assets and by providing sustainable energy products to our customers. Our portfolio includes offshore and onshore wind farms, solar farms, energy storage, and heat and power plants. We develop our pipeline of renewable assets, we construct them based on thorough supplier selection and local content adherence, and we operate our large portfolio. We enter into long-term power purchase agreements with strategic partners, and we manage and optimise our large portfolio of renewable assets and partnerships. We have made it a core commitment to develop, construct, and operate our renewable assets in an environmentally and socially sustainable way, which helps de-risk projects, enhance our license to operate, and drive lasting, positive change for society – through employment opportunities, community support, and enhancing nature. Ørsted's vision is to create a world that runs entirely on green energy. Our strategic aspiration is to be the world's leading green energy major. This aspiration builds on three strategic pillars: to be one of the world's leading developers, constructors, and generators of renewable assets; the leading talent platform in renewables; and globally recognised sustainability leader.
PandoraDenmark
Pandora is one of the world's most valuable brands, owning the space of jewellery with a meaning. Our unique business model builds on the Pandora brand and our in-house excellence. This translates into a fully integrated ecosystem, with both crafting and distribution at an unparalleled scale. With a strong commitment to sustainability, we deliver industry-leading growth and profitability while minimising our environmental footprint and supporting the communities we touch. Acknowledging both positive and negative impacts, as well as risks and opportunities, we have conducted a double materiality assessment, detailed on page 50. Our key resources include: An average of 37,000 employees globally, State-of-the-art crafting facilities powered by 100% renewable electricity, Recycled silver and gold and lab-grown diamonds, Water, energy and other raw materials. Value created includes: Safe and engaged workplace with an employee Net Promoter Score (eNPS) that puts us in the top 5% in the consumer sector globally, 865 million customer visits to our stores and online channels with more than 3 pieces sold every second, DKK 1.7 billion paid in corporate income taxes, DKK 5.5 billion in dividends and share buybacks to shareholders. Our operations span: Innovative Design, Responsible Sourcing, High-Quality Jewellery Crafting, Global Brand and Marketing, Packaging and Distribution, Omnichannel Retail, Product Reuse and Repair. In 2024, Core made up 74% of revenue and delivered stable like-for-like growth of 2%. The Core segment, centred around charms and carriers, remains the core of our brand. Pandora Moments, which has been established as a key Pandora icon over two decades, is still by far the largest collection and contributes to growth with solid like-for-like growth of 3%. Fuel with more made up 26% of revenue, up from 22% in 2023, as a result of strong like-for-like growth of 22%. The US remains our largest market in terms of revenue, with a share of business of 31% in 2024. In Rest of Pandora, Pandora continued to demonstrate the broad-based appeal of the brand across numerous geographies where brand penetration is still building with a long runway ahead. Like-for-like growth was strong at double-digit levels of 13%, which reflected broad-based growth with strong contributions from many markets. Rest of Pandora ended 2024 with a revenue of DKK 10.6 billion. Sustainability remains a fundamental pillar of the Phoenix strategy. In 2024, we continued progress on our three strategic sustainability priorities: low-carbon business, circular innovation and inclusive, diverse and fair culture.
RandstadNetherlands
Randstad is the world's leading talent company, a partner of choice to talent and clients. We are committed to providing equitable opportunities to people from all backgrounds and help them remain relevant in the rapidly changing world of work. We have a deep understanding of the labor market and help our clients to create the high-quality, diverse and agile workforces they need to succeed. Randstad was founded in 1960 and is headquartered in Diemen, the Netherlands. Randstad operates via an extensive global network, ensuring both best-in-class local services as well as global delivery. We leverage the best expertise for talent and client needs. We execute our Randstad Operational and Randstad Professional solutions via our vast market network and our Randstad Digital and Randstad Enterprise solutions via our global delivery model, supported by our digital marketplaces seamlessly connecting clients and talent.
Royal SchipholNetherlands
RSG's strategy, business model and value chain are comprehensively described starting on page 10. RSG is the owner and operator of Amsterdam Airport Schiphol (AAS), Rotterdam The Hague Airport and Lelystad Airport, with a majority stake in Eindhoven Airport (51%) and stake in Maastricht Aachen Airport (40%). The business model is concentrated within three business areas: Aviation, Schiphol Commercial and Alliances & Participations. As one of the largest hub airports within Europe, RSG serves a range of market segments to sustain societal value for the Netherlands and beyond. Revenue sources include aeronautical revenue from airlines, concession fees from retail operators, rental revenues from real estate, parking fees, advertising revenue and income from international alliances and participations. The value chain includes four sectors: 1. aviation, 2. construction and real estate, 3. retail, food & beverage and 4. services and transport, with three value chain scopes: upstream impacts, airport location impacts, and downstream impacts. RSG's core activities connect cultures, families, holidaymakers and business travellers, contributing to broader prosperity and the Netherlands' open economy.
Stora EnsoFinland
As a leading provider of renewable packaging, biomaterials, and wooden construction, and one of the largest private forest owners globally, we actively contribute to the circular bioeconomy focusing on climate change, circularity, and biodiversity. Our low-carbon and recyclable fiber-based products support our customers in choosing renewable options. The forest is at the heart of Stora Enso and we believe that everything made from fossil-based materials today can be made from a tree tomorrow. Our value creation has its foundation in the forest, where wood represents the largest part of our raw material. The forest is a value accretive real asset and functions as a long-term fiber supply for our products. Sustainable forest management ensures that new generations of trees replace those that are harvested. We are positioned in the following growing segments: Renewable packaging – is driven by high demand for circular packaging. We hold leading global market positions in consumer board segments with high barriers-to-entry. Sustainable building solutions – is driven by a growing wooden buildings market. We are a leading global supplier of building solutions, offering alternatives to fossil-intense construction materials. Biomaterials innovation – our agenda targets new applications in fiber products, lignin and biochemicals, focusing on novel products that replace fossil-based materials.
TrygDenmark
Strategy, business model and value chain - Tryg at a glance: As the world changes, we make it easier to be tryg. Leading market position - Tryg is the leading non-life insurer in Scandinavia. We are the largest player in Denmark, the third-largest in Sweden and fourth-largest in Norway. Around 6 million customers - Our 6,621 employees provide peace of mind for around 6 million customers and handle approximately 2.2 million claims on a yearly basis. Strong Scandinavian footprint with Revenue distribution: Denmark 47%, Norway 31%, Sweden 22%. Market positions: Denmark 1st position with 12.9% market share, Norway 4th position with 24.4% market share, Sweden 3rd position with 16.5% market share. United Towards '27 - Tryg hosted a Capital Markets Day on 4 December 2024, unveiling its 2027 financial and strategic targets under the theme 'Leveraging Scale to Drive Technical and Commercial Excellence'. Strategic pillars supporting the targets: Scale & Simplicity, Technical Excellence, and Customer & Commercial Excellence, focus on leveraging Tryg's size and scaling best practices across the Group. These pillars aim to increase the insurance service result by DKK 1bn by 2027.
VestasDenmark
Our vision is to become the Global Leader in Sustainable Energy Solutions. By leading across our four business areas, Onshore, Offshore, Service, and Development, we aim to lead the energy transition forward. Our business model supports the wind energy transition with a comprehensive range of high-capacity onshore and offshore turbines, tailored to various wind conditions and geographic needs. We also offer extensive after-sales services, including operations and maintenance, performance optimisation, and repowering to ensure the longevity and efficiency of wind installations. In addition to our core products, we develop wind power projects, thereby expanding market opportunities and supporting the growth of global partners. We operate globally with a track record of 189 GW capacity installed in 88+ countries. Our full suite of wind energy solutions ensures we can grow market presence in regions with significant wind potential, serving a wide array of customers across multiple regions, including Europe, North & South America, and Asia Pacific, while expanding our offshore wind capabilities to new markets. Our main customers are utility companies, which seek to integrate renewable energy into their power grids. We also work with independent power producers that develop and operate wind farms relying on our technology to deliver consistent energy output. Viewed through the lens of sustainability and the ESRS, the key outputs and outcomes of our business model are wind turbines installed. The value we create for our employees, investors, customers, and other stakeholders is salaries, EBIT margin before special items, total recordable injuries and GHG emissions avoided. Viewed through the lens of sustainability and the ESRS, our key inputs are raw materials, capital employed, energy, and employee working hours. We gather these inputs through business relationships in the supply chain and in our own operations spanning from own workforce to contractors. Development and securing of the inputs is primarily through continuous improvement efforts, formal contractual agreements and risk mitigation frameworks taking into account any potential disruption of operations.
SBM-2
Interests and views of stakeholders
Banco SabadellSpain
Banco Sabadell Group is firmly committed to ensuring sustainability across all its dimensions and, as a financial institution, it is aware of the important role that it plays in its economic, social and environmental surroundings, fostering care for the environment, supporting social progress and upholding a model of good governance, aligned with international best practice.
The Group, in keeping with its commitment, has been conducting materiality assessments of topics related to sustainability, aligning with best practice in relation to sustainability and transparency. Specifically, in 2022, the double materiality approach was included for the first time and the concept of impact included in the 2021 review of GRI standards was introduced.
In line with this development and with the entry into force of the new European Corporate Sustainability Reporting Directive (CSRD), a new double materiality exercise has been carried out in order to identify the material impacts, risks and opportunities related to sustainability. To that end, the guidelines set out in the European Sustainability Reporting Standards (ESRS) created by the European Financial Reporting Advisory Group (EFRAG) and adopted by the European Commission have been taken into account. This analysis, as established in the aforesaid standards, serves as a basis for determining the Institution's material topics and, consequently, those that should be included in the Group's Sustainability Report. Under the double materiality approach, this exercise includes assessing the effect of different sustainability topics from two points of view:
1. Impact materiality: referring to the Bank's effects on the environment and society through its activities, both directly and indirectly.
2. Financial materiality: referring to the effects of the environment and society on the Bank's financial position.
Methodological phases:
The methodological performance of the double materiality analysis carried out comprises four key phases:
1. Definition of the perimeter under analysis
2. Impact materiality assessment
3. Financial materiality assessment
4. Definition of materiality thresholds
The first phase of the process is described below, as the following three phases are described in section 4.1 Double materiality, which meets the requirements of "IRO-1: Description of the processes to identify and assess material impacts, risks and opportunities".
Definition of the perimeter under analysis:
The aim of this first phase is to outline the Double Materiality analytical framework. This phase involved determining:
a. The key sustainability topics for the Institution:
To identify the possible material topics to be evaluated in the double materiality exercise, an analysis was carried out to identify those topics that are, in principle, more important for the Institution from an ESG perspective.
In this respect, the topics referred to in the ESRS were comprehensively analysed, in addition to the topics deemed to be material in previous materiality exercises and the Principles for Responsible Banking, among others.
Based on these priority topics, a process then took place to rule out or discard the less material topics, applying expert criteria, merging those with synergies between them and keeping those that were thought to have priority. To perform this discarding process, the following analyses were taken into consideration: (i) other regulatory references and questionnaires from ESG rating agencies, (ii) analyses of other stakeholder groups (internal information about the opinions of investors, customers and NGOs), and (iii) comparative analyses of the sector's ESG disclosures.
b. Stakeholder groups to be involved in the exercise and definition of channels to listen to what they have to say:
The Bank's main stakeholder groups were identified by reviewing previous exercises, analysing recommendations included in the CSRD, and analysing peer group entities. The groups identified for the double materiality exercise were the following:
• Financial Community: investors, shareholders and rating agencies
• Employees: Banco Sabadell Group workforce
• Suppliers: main suppliers that might be more affected by ESG topics
• Customers: retail and business customers
• Bodies and Institutions: regulators of the domestic and European framework
• Society: citizens, communities and organised civil society
• Peers: comparable institutions in the sector
[Detailed description of stakeholder engagement methods follows]
BarcoBelgium
Interests and views of stakeholders
Barco attaches great importance to stakeholder engagement: outside and inside views help us identify and prioritize emerging trends and align our strategy, policies, and actions with the interests of our broad ecosystem – from the Board of Directors, shareholders, and employees through to distributors, customers, suppliers, and others.
Sustainability is a joint effort. To ensure our products shape the healthcare, entertainment, and collaboration of tomorrow in a sustainable manner, we consider the impact of every step in our value chain, across the lifecycle of our products, from the sourcing of raw materials to the disposal of our products.
Rather than merely consulting our stakeholders, we collaborate with them. We team up with business partners, academics, industry associations, etc. to deliver sustainable impact. In addition, we actively participate in targeted external global initiatives that promote sustainability, such as the Science Based Targets initiative, Carbon Disclosure Project, EGN, etc.
To truly understand what topics matter most to all our stakeholders, Barco launched a first comprehensive single materiality assessment in 2020. Over the years, we have kept it up to date to make sure it reflects the latest developments in our business, markets, and ecosystem. In 2023, we stepped up this exercise, conducting a double materiality assessment.
Approaching the assessment as a strategic project to capture valuable input from our wide ecosystem, we questioned internal and external stakeholders across the value chain via surveys, interviews, and focus groups. Their input was scored, consolidated, and plotted on a matrix.
BBVASpain
The General Sustainability Policy identifies BBVA's main stakeholders and other groups (customers, employees, shareholders and investors, suppliers, regulators and supervisors, as well as investment in the community) and the different areas of action. The Board of Directors has incorporated Sustainability as one of the Bank's strategic priorities. The Group has analyzed various sources of information to identify stakeholders within the value chain, including: Sustainability related objectives and how they may affect stakeholders within the value chain, Business model and identification of key dependencies in terms of products or services, Markets and customer segments, Main stakeholder groups with which it interacts, as well as the identification of impacts, risks, and opportunities that could arise from such interaction, Number of employees and their geographical distribution. The double materiality analysis incorporated the principles of the CSRD and ESRS, as well as the implementation guide for the assessment of materiality issued by the European Financial Reporting Advisory Group (EFRAG). In 2024, supervisory activities related to climate risk have become highly relevant. BBVA has actively participated in working sessions with various supervisory bodies, such as the European Central Bank (ECB), the Bank of Spain, the Banking Regulation and Supervision Agency (BRSA) of Turkey and the Mexican authorities.
Danica PensionDenmark
Danica has interviewed several stakeholders to gain a better insight into the stakeholders view of Danica's sustainability efforts, to validate the double materiality assessment and to exchange experience. The interviewees were an employee, a key customer, an NGO and an industry association. The stakeholders feedback confirmed that the outcome of the double materiality assessment largely met the stakeholders expectations. Moreover, Danica received inputs for its future work on the sustainability strategy, including inspiration for new employee initiatives, the green transition, trends in real estate investment and on maintaining focus on returns and financial security. The stakeholders inputs will be taken up at steering committee meetings and in other relevant forums and will also be a natural part of Danica's regular reviews of the sustainability strategy. In addition, inputs will also be included in work on the revised sustainability strategy to be developed during 2025.
DSBDenmark
In pursuing our business activities, DSB collaborates with various stakeholders, including our customers and local communities (for instance in the form of meetings with commuter clubs and an annual commuter rally), NGOs, disability organisations, suppliers, business partners (for instance Banedanmark as regards the common traffic information) and other public transport market players. We involve local communities in and around the station improvements. In connection with our major civil engineering and construction projects, we minimise the risks of nature and biodiversity impacts through engagement of local communities in the form of public meetings and collaboration with the authorities on EIA processes and local development plans.
GN Store NordDenmark
Stakeholder engagement described on page 46. GN engages with various stakeholders including customers, employees, shareholders, suppliers, partners, hearing care professionals, distributors, resellers, regulators, and communities. Key stakeholders include: Customers - through direct engagement and partnerships; Employees - through engagement surveys and development programs; Shareholders - through investor relations activities and regular communication; Suppliers and partners - through strategic partnerships and collaborative relationships; Hearing care professionals - through support and partnership programs; Regulators - through compliance and engagement on regulatory matters.
KoneFinland
Sustainability is embedded into KONE's strategy and business model. The table Stakeholder engagement summarizes KONE's key stakeholders, their interests, and KONE's engagement with them. KONE collaborates and maintains an active dialogue with its stakeholders to understand their needs and expectations, also related to human rights matters, and to provide input for KONE's planning processes as well as to the continuous improvement of KONE management system, thus creating a predictable business environment for everyone. Applicable administrative, management and supervisory bodies are informed about the outcomes by the responsible topic owners and subject matter experts through various channels, and appropriate actions are taken to address the material impacts. Stakeholder views have been considered as part of the strategy setting process. To enable employee's participation and to ensure employee consultation in health and safety matters, KONE runs and participates in local safety forums and councils with employees and their representatives. To represent the interests of employees and actively involve them in shaping the company, an employee engagement survey 'Pulse' is conducted annually. The learnings from the various stakeholder engagement activities including the employee engagement and customer surveys were taken into account in strategy development by lifting the key findings to the relevant Executive Board discussions. The views of employees, value chain workers and equipment users are also collected through KONE management system which harmonizes safety management practices across KONE and sets minimum requirements to protect the health and address the safety of KONE equipment users, employees and anyone else KONE works with. KONE considers the interests, views, and rights of its value chain workers in KONE's strategy and business model as feasible, mainly through management level discussions.
LundbeckDenmark
Our key stakeholders: Patients are an integral part of Lundbeck's full value chain ecosystem and fundamental to our patient-centric go-to-market approach. Their lived experiences and ability to point to unmet medical needs enable us to drive focused innovation across all aspects of our business. While patients are the end-users of our pharmaceutical products, Lundbeck's customers are healthcare professionals (HCPs), including physicians and specialists, as well as authorities, such as regulatory bodies, and public and private healthcare providers. Our customers play an important role across our value chain, where HCPs are the point of contact with patients in the downstream value chain, and the authorities are regulating our access to the market. Operating in a highly regulated industry, Lundbeck has strong procedures and internal processes in place to ensure compliance with pharmaceutical regulations, achieve operational excellence and instill trust across our value chain. Leveraging our key partnerships across the value chain, including R&D, commercial and other types of partnerships, e.g., civil society and NGOs enables Lundbeck to drive our business, increase awareness and ensure societal impact. As a listed company with many investors and shareholders, Lundbeck is committed to communicating a consistent message and delivering sustainable growth. To pursue all these goals and serve people affected by brain disorders and society at large, Lundbeck relies on highly qualified and specialized employees. Furthermore, suppliers and the workers in the value chain are key to providing the fundamental inputs to produce Lundbeck's high-quality products.
Novo NordiskDenmark
The Novo Nordisk Foundation has two objectives: to provide a stable basis for the commercial and research activities of Novo Nordisk, Novonesis and additional companies in Novo Holdings' investment portfolio; and to support scientific, humanitarian and social causes. Our foundation ownership supports the overarching imperative to be both commercially successful and responsive to the wider needs of society. We focus on creating lasting value for society and our business with a strong commitment to financial, environmental and social responsibility. Following the Novo Nordisk Way, we are dedicated to delivering long-term value for people living with serious chronic diseases, our employees, partners, shareholders and society at large.
NykreditDenmark
Key stakeholders include Politicians, civil servants and authorities through formal and informal written enquiries, meetings etc, preparation of consultation responses, and collaboration with authorities and politicians on new initiatives, studies and reports when they request views and knowledge etc from Nykredit. Trade organisations through coordination of shared viewpoints and advocacy via Nykredit's representation on boards, committees, working groups etc of trade organisations, cooperation on joint initiatives and proposals, and sectoral collaboration on joint solutions. Through interest representation, Nykredit will contribute constructively to the drafting of new regulation (such as acts, technical standards, executive orders, guidelines and supervisory decisions or market standards). For this purpose, Nykredit is in close, ongoing dialogue with policymakers and authorities, ensuring that Nykredit is aware of their expectations and requests for Nykredit's business. Nykredit participates in representing shared interests on behalf of the Danish financial sector in areas where, as part of the sector, Nykredit can make a positive contribution to society. Ongoing coordination takes place across Nykredit's organisation and management in order to provide information on the views and interests of the relevant stakeholders. Nykredit has clear internal procedures for managing upcoming or new regulation with the aim of ensuring a well-defined division of tasks and responsibilities across the organisation and providing timely, appropriate involvement of Nykredit's various management levels.
ØrstedDenmark
Local people and businesses have a vital role to play in the growth of the renewable energy industry. In the US, we developed a workforce development programme that has provided 335 union workers with the necessary credentials for working offshore. In connection with the construction of Hornsea 3 in the UK, we have launched a community benefit fund that will distribute up to GBP 7 million over ten years to invest in the region's future. In 2024, 21 social and environmental groups were selected by an advisory panel formed of local representatives as the first to receive grants. We consistently work to learn from and optimise the impact of our community engagements. We completed three different pilots to measure the effectiveness of the local social value we deliver. The results will help us target investments to the areas that drive the greatest local benefits.
Royal SchipholNetherlands
RSG engages with various stakeholder groups and considers their interests and views in strategy development and operations. Key stakeholders include shareholders (Dutch state 69.8%, municipality of Amsterdam 20.0%, municipality of Rotterdam 2.2%, with 8% held as treasury shares), local communities affected by airport operations, employees across the value chain, passengers, airlines, and regulatory bodies. RSG conducts social dialogues with unions, executives and companies in security, cleaning, cargo and temporary employment sectors. The company organised social dialogues in 2024 to discuss progress on Social Agreements from 2022 and 2023. Community engagement includes addressing noise disturbance concerns through the Minder Hinder programme partnership with Air Traffic Control the Netherlands (LVNL). The Environmental Fund, successor to the Schiphol Quality of Life Foundation, provides 10 million euros annually through 2030 for measures to improve quality of life in surrounding areas. Stakeholder feedback influences RSG's approach to balancing aviation activities with community well-being and environmental protection.
Stora EnsoFinland
Close relationships and engagements with both our customers and employees are crucial, and I am pleased that we continue to attain high scores in customer satisfaction and employee engagement, reflecting the strengths of Stora Enso. Our annual employee engagement survey, conducted in November 2024, had both a high response rate and an overall strong engagement rate, exceeding the industry benchmark. We prioritise open and transparent relationships with stakeholders to discuss the impact of our operations, build trust, and address concerns. We have a long history of engaging with local communities in diverse settings and cultures. The form and frequency of our engagement vary based on the local context. This may involve interaction through community representatives or direct and inclusive contact. With over 20,000 contractors, sub-contractors and suppliers, we prioritise responsible raw material sourcing and foster long-term relationships with key partners. Our investments in energy, raw material efficiency, and product development enable customers to achieve their climate and circularity goals. By partnering with customers and other stakeholders, we create sustainable, valuable products that enhance our customer relationships and market share.
TrygDenmark
Interests and views of stakeholders - Dialogue between Tryg, its shareholders and other stakeholders: Tryg's Investor Relations (IR) department maintains regular contact with analysts and investors. Together with the Executive Board, the Investor Relations team organises investor meetings, conference calls and participates in conferences in Denmark and abroad. The Supervisory Board is regularly informed about the dialogue with investors and other stakeholders. Tryg has an IR policy which states that all company announcements may be published in English only. All shareholders are encouraged to attend the general meeting. Shareholders may propose items to be included on the agenda for the AGM and may ask questions before and at the meeting. Furthermore, prior to the general meeting, Tryg invites shareholders to submit written questions to be considered at the general meeting.
VestasDenmark
Partnerships are integral to Vestas' strategy. By collaborating with customers, suppliers, governments, and communities, Vestas fosters innovation, optimisation of the supply chain, and drives joint growth. These partnerships allow Vestas to deliver reliable energy solutions and play a critical role in the successful global energy transition. In line with strengthening partnerships, our customer approach prioritises value creation over sheer volume, emphasising the delivery of high-quality, profitable solutions. Maintaining a commercial culture, we ensure that projects contribute to long-term earnings growth. Priority customers have global account managers within Vestas, and leading access to our siting capabilities and attractive projects from Vestas Development. To succeed, Vestas maintains close dialogues with its customers and suppliers and places high demands on its entire value chain.
SBM-3
Material impacts, risks and opportunities and their interaction with strategy and business model
Banco SabadellSpain
As a result of the double materiality exercise, the following material impacts, risks and opportunities have been identified:
[Comprehensive table showing sustainability topics, material impacts, and value chain positioning]
[Double materiality analysis results table showing impact materiality, financial materiality (risk and opportunity), and double materiality results for all ESRS topics]
Following the analysis, Banco Sabadell concluded that the current risks identified in the double materiality analysis (which include the risk of digital fraud, higher costs to adapt solutions to vulnerable groups and credit risk caused by the physical climate risks to which customers are exposed and which reduce their creditworthiness) currently product no significant effects.
This conclusion was reached after evaluating the impact that they currently have on the Bank's financial statements, such as the income statement and the balance sheet, having verified that they have no material significance. Assuming that these impacts may be following a growing trend, risks are being managed in order to minimise the potential extent of those impacts in the future.
In relation to current opportunities, including those related to a wider offer of sustainable finance solutions and improved advice for the climate transition, as well as those related to the opportunity to attract new customers through digital channels and increased cross-selling, it was concluded that they have material significance and the Institution is working to benefit from them and to continue developing the sustainable solutions that it offers to its customers.
Thus, the Bank committed to mobilise €65bn in sustainable finance between 2021 and 2025. Up to December 2024, more than €57.9bn had been mobilised, €19bn of them during this year.
As a result of the digitalisation strategy pursued by the Institution, over 150,000 customers were onboarded digitally in 2024 and this figure is expected to continue rising in the coming years, making it an increasingly significant source of income.
[Specific qualitative analysis of the financial materiality of environmental risks follows with detailed assessment tables and results]
Double materiality analysis evolution
During 2024, the double materiality analysis that was conducted in 2022 was updated. That update mainly consisted of bringing the framework of ESG topics and the methodology in line with the requirements and indications of the ESRS.
As a result, the matrix published in the previous year underwent some changes in terms of the prioritisation of certain topics, considering the ESRS in the methodology, as well as the increasing importance of ESG topics for the Bank's stakeholder groups.
BarcoBelgium
Material impacts, risks and opportunities and their interaction with strategy and business model
The double materiality assessment identified the following material topics that are ranked as high-impact material, high-financial material, or both:
• Climate change & energy
• Product life cycle management
• Innovation, new technologies & product portfolio
• Circular economy & waste
• Talent & career development
• Customer experience
• Diversity & Inclusion
• Product quality & safety
• Responsible & resilient supply chains
• Information security
• Corporate governance & strategy
• Business ethics
3 key takeaways from our double materiality assessment:
1. We are building on a strong foundation - Our stakeholders confirmed the importance of areas we have been focusing on in the past, such as sustainable lifecycle management, climate change, and customer experience. In addition, many entity-specific topics – closely tied to Barco's DNA – ranked high both from an impact and risk & opportunity perspective.
2. We will strengthen our focus on emerging priorities - Compared to our 2020 materiality assessment, we see new topics emerging or receiving a higher score, including circular economy, and Diversity & Inclusion. We will strengthen our commitment in these areas.
3. We will maintain excellence on low or medium material topics - Topics like community engagement & relations, health, safety & well-being, and information security were rated as low or medium material by our stakeholders. Still, we remain committed to upholding our high standards or further developing our actions in these areas.
The outcome of the double materiality assessment has been embedded into Barco's value creation model and resulted in a new sustainability strategy. It will guide us in focusing our sustainability ambitions, strategy, and actions for the coming years.
BBVASpain
BBVA has identified material impacts, risks and opportunities in several sub-topics, which in turn correspond to four general topics: 1. Climate change, 2. Own workforce, 3. Consumers and end-users, and 4. Business conduct. Material IROs linked to climate change and customers and end users are mainly concentrated in the downstream phase of the value chain, while those related to business conduct and employees originate in the Group's own operations phase. Climate change is material for BBVA because it has significant effects both on the environment and on its own operations. This consideration aligns with BBVA's strategy, which integrates climate action as one of its fundamental pillars. The key role of banks, and BBVA in particular, in financing the transition to a decarbonized economy has been considered. BBVA recognizes the importance of people as a fundamental pillar of its corporate strategy. The commitment to creating a positive and motivating work environment is material because employees contribute directly to achieving business objectives. Consumers and end users are a fundamental part of the Group activity. Their satisfaction and financial security have a direct impact on the Group's performance and reputation. The Group has identified IROs related to business conduct by considering the sector to which it belongs, as well as other factors such as geographical presence, the type of activity, and the structure of business transactions.
Danica PensionDenmark
Climate change and the transition to a net-zero economy present a number of risks and opportunities for the investment portfolio, which Danica seeks to minimise and benefit from in its efforts to protect and grow customers pension investments while supporting the transition. This promotes Danica's ambition to minimise the potential negative climate impacts of the investment portfolio. Danica has defined the following IROs as material under E1: Danica's scope 1, 2 and 3 emissions from the investment portfolio have a negative environmental impact, Danica's equity and credit bond investments are associated with temperature rises and thus have an environmental impact, Danica has investments in the fossil fuel sector, which may have a negative environmental impact, Danica's energy consumption (emissions from own operations) has a negative environmental impact.
DSBDenmark
Due to direct and indirect emissions from our energy consumption for traction and non-traction operations, we have a material climate impact. Most of our overall climate impact comes from our value chain (Scope 3), while primary cause our direct emissions is the use of our diesel-powered trains. Air pollution has an impact on the surrounding environment that derives from our train operations across the country. The direct impact is local and consists primarily of ultrafine and fine particulate matter connected with the burning of diesel for traction operations. DSB impacts biodiversity and ecosystems directly as well as indirectly. Our direct impacts arise from the fact that we carry on our activities in areas with a share of potentially valuable nature, which impacts local flora and fauna. The indirect impacts arise through the purchase of goods and services in our value chain. Climate change presents DSB with the greatest challenges when it affects the use of traffic infrastructure. Storms, capable of resulting in fallen overhead lines and trees blocking tracks, are the most frequent cause of disruption to services in Denmark. The more severe weather conditions caused by climate change are also expected to increasingly cause disruption to train operations.
GN Store NordDenmark
Material impacts, risks and opportunities described on pages 49-57. GN conducted a double materiality assessment to identify material impacts, risks and opportunities. Material topics identified include: Environment - Climate change, Pollution, Resource use and circular economy; Social - Own workforce, Workers in the value chain, Consumers and end-users; Governance - Business conduct. These material topics interact with GN's strategy through: Climate targets supporting product development that will help achieve 2030 climate goals and net-zero emissions by 2050; Sustainable design principles impacting product development; Supply chain responsibility integrated into operations; Workforce development supporting innovation capabilities.
KoneFinland
KONE's double materiality assessment (DMA) approach consisted of four phases to determine material topics and provide input for the strategy development. These phases included value chain mapping, impact assessment, financial assessment, and final materiality determination. The DMA was completed in 2024. The DMA results will be reviewed annually and updated when necessary. KONE's earlier materiality assessment, human rights impact assessment and third-party due diligence process, non-financial risk assessment, and climate change scenario analysis, which have been integrated into KONE's risk management processes, were used as a starting point for the DMA. As a result of the DMA, a comprehensive overview of KONE's IROs relating to each sustainability topic was formed. When an impact and/or risk or opportunity score of any topic exceeded a certain threshold, the topic was identified as material to KONE. The treatment of such IROs were prioritized to meet KONE's strategic sustainability objectives and ensure alignment with stakeholder expectations. In principle, all mandatory data points have been included and disclosed following the materiality principle of the ESRS standard. No material entity specific IROs were identified. Current financial effects of KONE's material risks and opportunities do not expose KONE's financial position, financial performance or cash flows to significant risks for material adjustments to the carrying amounts of assets and liabilities. During 2024, KONE's strategy and business models showed resilience in harnessing the material opportunities and addressing material impacts and risks stated in this report, mainly driven by healthy geographic and business line mix, supported by robust supply chain. The conclusion was supported by a qualitative assessment based on KONE reaching the set strategic targets and KPIs during the reporting period. Progress in strategy execution and performance in strategic sustainability KPI's is monitored and as part of quarterly reporting in line with KONE's governance structure. KONE Risk Management Policy defines the roles and responsibilities for The Executive Board and the Board of Directors. These roles and responsibilities apply when they oversee and monitor the material impacts, risks and opportunities related to KONE's strategy implementation and targets. KONE's material impacts, risks and opportunities have been considered thoroughly in the planning of the new strategy and during strategy implementation in 2024.
Novo NordiskDenmark
In an increasingly complex and unpredictable world, the intersection of climate change, health inequity and the rising prevalence of serious chronic diseases presents an unprecedented risk to both human and planetary health. Recognising the magnitude of these challenges, we are aiming to expand the reach and societal impact of our life-changing medicines and preventive health initiatives while striving to reduce our CO2e emissions, plastic footprint and impact on nature.
NykreditDenmark
Nykredit's ESG commitment is centred around the themes: 'A greener and prepared Denmark' (E), 'A customer-owned Nykredit' (S) and 'Responsible business practices' (G). Under the theme 'A greener and prepared Denmark', material impacts, risks and opportunities related to climate change mitigation and adaptation are addressed. Topics include Climate change mitigation, Climate change adaptation, Carbon emissions and energy consumption. Under the theme 'A customer-owned Nykredit', material impacts, risks and opportunities related to non-discrimination of customers and employees, privacy and the right to adequate housing are addressed. Topics include Home loans all across Denmark, Right to privacy, Equal treatment and opportunities for all. Under the theme 'Responsible business practices', material impacts, risks and opportunities related to Nykredit's efforts to promote a healthy corporate culture, combat financial crime and ensure due diligence in the value chain are addressed. Topics include Healthy corporate culture, Combating financial crime, Due diligence in the value chain.
ØrstedDenmark
We have identified seven of the ten ESRS topical standards under the CSRD to be material. These are 'Climate change' (ESRS E1), 'Biodiversity and ecosystems' (ESRS E4), 'Resource use and circular economy' (ESRS E5), 'Own workforce' (ESRS S1), 'Workers in the value chain' (ESRS S2), 'Affected communities' (ESRS S3), and 'Business conduct' (G1). Based on the DMA performed in 2024, the magnitude of the identified sustainability-related financial risks were below the magnitude of the enterprise risks. During 2025, we will further align the sustainability risk assessment between the DMA and enterprise risk framework.
Royal SchipholNetherlands
RSG has identified 16 material impacts, risks and opportunities through its double materiality assessment, which are integrated with strategy and business model considerations. Material topics include: Climate change mitigation and adaptation, Air pollution, Soil pollution, Biodiversity, Resource use and circular economy, Affected communities and noise, Employment practices own workforce, Diversity equity & inclusion own workforce, Employment practices value chain, Airports' attractiveness to consumers and end-users, Safety, Security, Cybersecurity, Business ethics and corporate culture, and Supplier and procurement practices. These material topics are linked to RSG's four strategic Qualities (Network, Life, Work, Service) and two enablers (Safety first, Robust organisation). The materiality assessment considers both impact materiality (significant impacts on people or environment) and financial materiality (risks and opportunities with financial effects). Key challenges include balancing connectivity needs with environmental constraints, noise disturbance management, climate change adaptation, and ensuring quality of work across the value chain while maintaining operational excellence and financial resilience.
Stora EnsoFinland
Our market for sustainable packaging is growing, fuelled by increasing environmental concerns and changes in consumer behaviour. Market uncertainties, along with fluctuations in demand and pricing, persisted throughout 2024. We faced several challenges in the market, including weak demand for consumer board, overcapacity in corrugated board, a volatile pulp market, a persistently weak construction sector, and continued tightness in wood markets. The biggest challenge has been the continued volatility and market weakness. However, our Group-wide cost-saving measures will continue to deliver results. The growing demand for bio-based materials, along with external factors such as climate change and geopolitical instability, may limit Stora Enso's access to wood-based raw materials. However, these challenges also create opportunities to innovate and identify alternative sources, potentially driving greater sustainability and efficiency in the industry. Climate change could pose challenges to Stora Enso's forests and operations, impacting resource availability. However, it also presents opportunities to innovate and adapt, leading to advancements in sustainable forestry practices. All the businesses in which we operate are in growing segments, driven by strong sustainability trends. Stora Enso holds leading market positions in renewable packaging, biomaterials, and sustainable construction segments, all of which are positioned for long-term growth.
TrygDenmark
Material impacts, risks and opportunities and their interaction with strategy and business model - In a world increasingly impacted by climate change, Tryg offers customers peace of mind, ensuring coverage in the event of claims. From a macroeconomic perspective, 2024 turned out to be another eventful year. Geopolitical tensions continued to affect the financial environment. Weather events in 2024: The weather events for the full year were in line with Tryg's annual expectations, even though 2024 had its fair share of weather-related claims. The first half of the year brought severe weather challenges to our customers. Heavy rainfall impacted Denmark, while Norway experienced a harsh winter with substantial snowfall. During 2024, Tryg launched new technology solutions to help further enhance the customer experience. Tryg's business is generally stable but may be subject to volatility due to weather events and large claims.
VestasDenmark
The sustainability matters that relate to our corporate strategy are mainly Climate change mitigation (E1), Circular economy and resource use (E5), Own workforce (S1), Affected communities (S3), and Political engagement (G1). The main challenges, critical solutions and projects are described under 'Impacts, risks and opportunities' and 'Actions and resources' in the respective topical sections. At the same time, with the growing demand for renewable energy, the industry has enormous potential, therefore Vestas is expected to scale. As we grow as an industry, we must do so sustainably, while accepting that it requires carbon emissions in our operations until we reach our ultimate emission reduction targets.
IRO-1
Description of the processes to identify and assess material impacts, risks and opportunities
Banco SabadellSpain
Identification and assessment of impact materiality
The double materiality analysis identified the main positive and negative impacts related to each sustainability-related topic that the Bank has or could have on society and the environment. Each of them are assessed according to their characteristics through the scale, scope, irremediable character and likelihood, the scale being the severity or benefit of the impacts on the environment and society, as well as the time horizon of potential negative impacts. In the case of a potential negative impact assessed as impacting human rights, severity prevails over likelihood.
During the assessment exercise carried out, 1,612 participants, broken down according to the chart below, were actively involved through ad hoc questionnaires and interviews with General Management:
[Stakeholder involvement chart shown]
The Bank's General Management has been involved in both the assessment of impact materiality (scale, irremediable character and likelihood, since the scope of the impact is set by means of an internal analysis) and of financial materiality (financial effects, likelihood and trend over time). On the other hand, retail customers, business customers, employees and suppliers took part in the impact materiality assessment through an analysis of the scale.
In that regard, 56 impacts were identified, which were assessed under the impact materiality perspective.
Identification and assessment of financial materiality
First, the main risks and opportunities of each sustainability-related topic that affects or could affect the Bank's financial statements were identified. These risks and opportunities were assessed in the short, medium and long term through their financial effects and likelihood of occurrence.
This assessment identified 42 risks and 21 ESG opportunities, which were assessed under the financial materiality perspective.
Definition of materiality thresholds and results
Based on the chart analysis of the normal distribution of the results obtained in the assessments of impact materiality and financial materiality, the Impacts, Risks and Opportunities (IROs) that stand out from the entire sample have been identified. The IROs belonging to the group of scores that are above the rest are classified as "material impacts, risks and opportunities".
Internal control processes for the double materiality analysis
As described in section "2.5 GOV-5. Risk management and internal controls over sustainability reporting", the Internal Controls over Sustainability Reporting (ICSR) unit identified risks and designed controls over the new double materiality exercise in order to ensure the correct execution of this exercise and its completeness.
The Board of Directors delegates the supervisory function regarding the internal control systems to the Board Audit and Control Committee. Every six months, the current situation of the ICSR as a result of new applicable regulatory requirements is reported to the Board Audit and Control Committee and to the Technical Committee on Accounting and Financial Disclosures. In addition, every year at the end of the tax year, the result of the assessment of the controls and the conclusions derived from it are escalated to the Board Audit and Control Committee.
[Detailed assessment of environmental degradation, social and governance risks follows, including biodiversity risk, Environmental and Social Risk Framework, and additional risk assessments]
BarcoBelgium
Description of the processes to identify and assess material impacts, risks and opportunities
Barco's double materiality assessment measures:
• The impact materiality: the actual and potential positive or negative impacts of Barco on society (inside-out)
• The financial materiality: the actual and potential risks and opportunities that have or may have financial effects on Barco (outside-in)
Approaching the assessment as a strategic project to capture valuable input from our wide ecosystem, we questioned internal and external stakeholders across the value chain via surveys, interviews, and focus groups. Their input was scored, consolidated, and plotted on a matrix.
To truly understand what topics matter most to all our stakeholders, Barco launched a first comprehensive single materiality assessment in 2020. Over the years, we have kept it up to date to make sure it reflects the latest developments in our business, markets, and ecosystem. In 2023, we stepped up this exercise, conducting a double materiality assessment.
The double materiality matrix shows the topics that are material and non-material for Barco. Material topics are topics that are ranked as high-impact material (y-axis), high-financial material (x-axis), or both.
BBVASpain
The BBVA Group's 2024 double materiality analysis is based on a review of the results of previous years and on the most accurate and up-to-date information available, integrating tools, standards and processes that are both internal and market benchmarks. The applied methodology has been structured into three phases: context analysis, identification and definition of IROs, and their subsequent evaluation. In the context analysis phase, internal documentation considered includes key policies, such as the general sustainability policy and those related to employees, suppliers, and corporate governance. Externally, information from regulators and supervisory entities has been reviewed, incorporating essential regulations. For identification and definition of IROs, BBVA has incorporated specialized tools including the UNEP-FI Impact Tool, human rights due diligence, Climate Change Risk Assessment, and Reputational and Non-Financial Risk matrices. IROs were defined and classified based on the following criteria: Actual/Potential, Time Horizons (Short-term: Up to 1 year, Medium term: From the end of the first year to four years, Long term: More than four years), Value Chain Phase (upstream, own operations, and downstream), ESRS Subtopic allocation. For evaluation, BBVA applied an internal methodology consistent with both the Implementation Guidance on Double Materiality Analysis issued by EFRAG and ESRS 1. Impact materiality assesses the positive or negative effects through severity (scale, scope, irremediable character) and probability. Financial materiality evaluates effects on the Group's financial position through likelihood of occurrence and magnitude of financial effects.
Danica PensionDenmark
In 2024, Danica performed a double materiality assessment on the basis of the following steps: 1. Preparation of the materiality assessment a. Identification of internal stakeholders b. Workshops (scoring of topics) c. Establishment of impacts, risks and opportunities (IROs) d. Financial materiality assessment e. Impact assessment of downstream activities f. Preparation of template 2. Review of materiality assessment a. Presentation of assessment to Executive Board and others Conclusion and methodology memo b. Adjustment of assessment c. Interviews with external stakeholders d. Documentation of the outcome and preparation of methodology memo. Impact materiality was assessed according to four parameters: Scale, Scope, Irremediable character and Likelihood. Scale is an assessment of the intensity of an impact, Scope is an assessment of how many people or how widespread an area is impacted, Irremediable character is an assessment of how easy/difficult it would be to mitigate an impact, and Likelihood is an assessment of how likely an impact is to occur. All four parameters were scored on a scale of 0-5. An impact with an overall average score of three or more across all parameters is considered material to Danica. Financial materiality was assessed according to two parameters: likelihood of occurrence and scope of financial impact.
DSBDenmark
DSB has carried out the first-time implementation of s. 99a of the Danish Financial Statements Act in relation to compliance with the ESRS. The sustainability reporting is based on our double materiality assessment (DMA) assessed for our own operations and DSB's value chain. All topics dealt with in the environment, social and governance sections have been assessed as material in our double materiality assessment. The data points presented for material topics have been selected in accordance with the disclosure requirements related to the specific sustainability matters in the corresponding topical ESRS.
GN Store NordDenmark
Process to identify and assess material impacts, risks and opportunities described on pages 49-51. GN conducted a double materiality assessment process involving: 1) Identification of potential sustainability topics based on ESRS standards and sector-specific considerations; 2) Impact assessment considering severity, scope, and likelihood of impacts; 3) Financial materiality assessment considering risks and opportunities that could influence cash flows, development, performance, position, cost of capital or access to finance; 4) Stakeholder input and validation; 5) Executive and Board review and approval of material topics. The process considered both positive and negative impacts across the value chain.
KoneFinland
KONE's double materiality assessment (DMA) approach consisted of four phases to determine material topics and provide input for the strategy development. These phases included value chain mapping, impact assessment, financial assessment, and final materiality determination. The DMA was completed in 2024. The DMA results will be reviewed annually and updated when necessary. KONE's earlier materiality assessment, human rights impact assessment and third-party due diligence process, non-financial risk assessment, and climate change scenario analysis, which have been integrated into KONE's risk management processes, were used as a starting point for the DMA. The results of the DMA including the material impacts, risks and opportunities (IROs) were reviewed by a management steering group consisting of KONE Executive Board members and other management members. These members were selected based on their ownership, roles and responsibilities in the area of sustainability and reporting. The results of the DMA were reported to the Audit Committee of the KONE Board of Directors. Internal control over the DMA process was ensured through the reviews of the results and the adopted systematic assessment methodology. In the initial phase of the DMA, KONE mapped its value chain and listed the main business activities across upstream, own operations, downstream, and cross-cutting activities through interviews with key internal stakeholders. The geographical locations and key external stakeholders affected by these activities were identified for each, in line with the reporting principles. Specific geographies, high-risk areas, and at-risk functions were taken into account. The impacts, risks, and opportunities were evaluated by KONE's subject matter expert teams on a scale from 1 to 5, aligning with the ESRS criteria. These results can be easily compared with KONE's risk management process and tool, allowing for the consideration of sustainability risks alongside other business risks in terms of relative position and priorities. The views of KONE's stakeholders were provided through summarized input by the involved subject matter experts through their interaction with affected stakeholders and engagement with the users of KONE's Sustainability Statement. During the impact assessment phase, KONE evaluated, scored, and prioritized the various impacts (positive or negative) and activities within its value chain that could affect people or the environment based on their scale, scope, likelihood, and irremediability, which was considered for negative impacts. In case of a potential negative human rights impact, the severity of the impact was prioritized over its likelihood. The financial assessment phase included identification of key risks and opportunities posing financial implications, together with an assessment of their magnitude and likelihood, as well as the timeframe. The connections between impacts, and dependencies with the risks and opportunities, were considered as part of the identification of IROs, mainly in relation to geographical locations and IRO contents in the subtopics, however not systematically cross-referencing all connections and dependencies. Each prioritized risk, opportunity or impact is assigned to a risk owner. The risk owner appoints a person in a relevant role to be responsible for the specific IRO. The responsible person implements the necessary IRO treatment actions, and reports regarding progress to the risk owner.
Novo NordiskDenmark
This year, in line with the CSRD, we have conducted a double materiality assessment to identify the sustainability matters that are most important to Novo Nordisk, considering both societal and financial implications. The essential topics identified include patient protection and quality of life, climate change, resource use and circular economy, and own workforce – reflecting our aspirations of progress towards zero environmental impact, being respected for adding value to society and being a sustainable employer.
ØrstedDenmark
The CSRD mandates reporting on environmental, social, and governance (ESG) practices and adherence to a double materiality assessment (DMA). These assessments are used to identify and disclose material sustainability impacts and financial risks and opportunities, inform areas for development, and track progress annually, ensuring sustainability-related financial risks are considered together with the broader risk portfolio. Managing and evaluating sustainability-related risks as part of ongoing risk management activities is essential for all companies, not least for those in the renewable energy sector. While we have worked with and reported on sustainability risks for many years, we support the added transparency and standardisation provided by the Corporate Sustainability Reporting Directive (CSRD) – and see it as a way of working in addition to being a reporting framework.
Royal SchipholNetherlands
RSG conducts a yearly materiality assessment to identify material topics, taking into account the entire consolidated Royal Schiphol Group. The company has fully embraced the CSRD and performed a double materiality assessment compliant with this framework. The double materiality assessment considers both impact materiality and financial materiality of sustainability matters, with impact materiality being the actual or potential significant impact Royal Schiphol Group has on people or the environment, and financial materiality being the risks and opportunities that may arise from a sustainability matter leading to a financial effect. The value chain analysis was used to identify impacts, risks and opportunities (IROs) within the value chain, serving as input for the double materiality assessment. The process involves systematic evaluation of upstream impacts, airport location impacts (encompassing both own operations and activities by third parties on premises) and downstream impacts across four sectors: aviation, construction and real estate, retail food & beverage, and services and transport. Results are presented in a butterfly figure with two axes representing impact and financial materiality at the topic level.
Stora EnsoFinland
During 2024, we continued to make progress on our sustainability targets, achieving reductions in carbon emissions across all three Scope categories. Our commitment to circularity involves reducing, reusing, and recycling materials in both production and consumption. We integrate circularity into our product development and collaborate with customers and partners to promote product recycling. Our biodiversity initiatives aim for a net positive impact, with action programmes in place until 2030 to enhance biodiversity at the species, habitat, and landscape levels. Stora Enso's Sustainability statement provides a comprehensive overview of the risks and opportunities arising from social, environmental, and governance issues, and on the impact of our activities on people and the environment.
TrygDenmark
Description of the processes to identify and assess material impacts, risks and opportunities - During the year, Motor claims frequencies have been challenging, although the trend was more pronounced at the beginning of the year compared to the end of the year. Additionally, a slightly higher average claims cost was also reported. This issue has been noted across geographies generally but was particularly evident in the Norwegian business, where most profitability actions to mitigate this trend have been taken. Capital markets developed positively during 2024 and most asset classes, with the noticeable exception of real estate, reported positive returns. Geopolitical tensions remained high, resulting at times in sudden shocks to capital markets.
VestasDenmark
With the aim of addressing the new Corporate Sustainability Reporting Directive requirements from the EU in a reader friendly way, we have addressed the requirements in the parts of the report where they fit into the context. This also means that throughout this report, you will find codes such as 'GOV-1' and 'SBM-3' which refer to specific disclosure requirements or data points from the European Sustainability Reporting Standards (ESRS). An index of the ESRS disclosure requirements and codes can be found on pages 212-213 and the definition of terms on page 210.
IRO-2
Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Banco SabadellSpain
Disclosure requirements addressed in the Sustainability Report
Once the material topics for the Bank have been identified, the sustainability information that is to be disclosed in the annual Sustainability Report is structured. Based on these material topics and the structure of the European Sustainability Reporting Standards (ESRS), this report covers environmental information first, followed by information on social aspects to finally conclude with information related to governance. Thus, the structure of the Sustainability Report follows the table of contents set out below:
[Comprehensive table showing all topical standards, disclosure requirements, and page numbers covered in the report]
BBVASpain
Following the double materiality analysis, BBVA has identified material topics that require disclosure under the ESRS: Climate change (E1), Own workforce (S1), Consumers and end-users (S4), and Business conduct (G1). Topics identified as not material include: Pollution (E2), Water and marine resources (E3), Biodiversity and ecosystems (E4), Use of resources and circular economy (E5), Workers in the value chain (S2), and Affected communities (S3). As a result of the double materiality analysis, no material impacts, risks, and/or opportunities exclusively associated with insurance and asset management activities have been identified. Consequently, no specific policies, actions, objectives, or metrics covering these activities are disclosed beyond those that inherently encompass them. BBVA, in accordance with the provisions of the ESRS, incorporates transition periods for some information requirements including: The identification and disclosure of certain quantitative aspects relating to the value chain; The anticipated financial effects concerning the material impacts, risks, and opportunities identified in the double materiality analysis; The financial effects related to revenue derived from activities affected by physical and transition risks; Specific characteristics of non-salaried workers; Information concerning public or private protection programs for salaried workers.
Danica PensionDenmark
Danica's Sustainability Statement was prepared on the basis of the double materiality assessment and the material ESRSs and sub-topics. Climate change: Under E1 Climate change, Danica assessed two sub-topics to be material: climate change mitigation and energy. Danica did not assess climate change adaptation to be material. This is due to the fact that the double materiality assessment primarily focuses on offices and real estate investments, and in this context, the impact of insufficient climate change adaptation is assessed to be low. Most office buildings are new, and in terms of real estate investments, Danica Ejendomme's objective is for all new projects in Denmark to be DGNB Gold-certified. In addition, an assessment is made of the level of climate resilience of all new projects.
DemantDenmark
All information related to the ESRS disclosure requirements is provided with the corresponding ESRS reference throughout the report. You can find an overview of all the disclosure requirements included and their location in the report on pages 110-115. Our sustainability reporting choices are guided by our double materiality assessment, detailed on page 57, where we outline the topics that have been identified as material.
GN Store NordDenmark
Disclosure requirements covered described in contents tables on pages 58-59. GN's sustainability statement covers the following ESRS disclosure requirements: ESRS 2 General Disclosures; E1 Climate change; E2 Pollution; E5 Resource use and circular economy; S1 Own workforce; S2 Workers in the value chain; S4 Consumers and end-users; G1 Business conduct. The company determined that E3 Water and marine resources, E4 Biodiversity and ecosystems, and S3 Affected communities are not material to the business.
KoneFinland
KONE's material ESRS topics based on the DMA process are presented in the table on the previous page. KONE has identified material risks and negative and positive impacts related to climate change and energy, negative health and safety impacts related to own employees, value chain workers and end-users, and positive impacts related to corporate culture, protection of whistle-blowers and corruption and bribery. IROs, relevant for each ESRS topic, are described in summary tables in the beginning of topical sustainability sections accompanied by the relevant information on time-horizon, value chain information and the management actions taken to address the IROs.
Novo NordiskDenmark
The Annual Report 2024 marks a significant step in the evolution of Novo Nordisk's integrated reporting. This year, our Sustainability statement is for the first time prepared according to the EU Corporate Sustainability Reporting Directive (CSRD) requirements. The outcomes of this assessment have provided us with key metrics to track our performance across our material sustainability topics. You can read more about our progress towards achieving our sustainability ambitions in the Annual review on page 12, while detailed breakdowns of our performance can be found in the Sustainability statement on page 46. Together, these sections make up this year's Management report.
NykreditDenmark
An overview of ESRS disclosure requirements is provided on pages 120-128. The Nykredit Group's statutory sustainability reporting is covered on pages 30-128.
Royal SchipholNetherlands
RSG's sustainability statement covers disclosure requirements from multiple ESRS standards based on the materiality assessment results. The company reports on ESRS 2 (General Disclosures), E1 (Climate Change) covering climate change mitigation and adaptation, E2 (Pollution) addressing air and soil pollution, E4 (Biodiversity and Ecosystems), E5 (Resource Use and Circular Economy), S1 (Own Workforce) including employment practices and diversity, S2 (Workers in the Value Chain), S3 (Affected Communities) particularly relating to noise impacts, S4 (Consumers and End-Users) covering airports' attractiveness, and G1 (Business Conduct) addressing business ethics, corporate culture and supplier practices. The sustainability statement provides detailed information and reporting on each material topic aligned with the CSRD framework, with cross-references to specific sections throughout the annual report where relevant disclosures are presented.
Stora EnsoFinland
Stora Enso's Sustainability statement provides a comprehensive overview of the risks and opportunities arising from social, environmental, and governance issues, and on the impact of our activities on people and the environment. The sustainability statement is prepared in accordance with the Corporate Sustainability Reporting Directive.
TrygDenmark
This annual report includes disclosures under ESRS framework as part of the sustainability statement covering material topics identified including climate change (E1), resource use and circular economy (E5), own workforce (S1), consumers and end-users (S4), and business conduct (G1).
VestasDenmark
The result of the double materiality assessment shows that Vestas considers the following ESRS topics material: Climate change (E1), Water and marine resources (E3), Biodiversity and ecosystems (E4), Circular economy and resource use (E5), Own workforce (S1), Workers in the value chain (S2), Affected communities (S3), and Business conduct (G1).