Governance

G1Business Conduct

6 disclosure requirements

G1-1

Business conduct policies and corporate culture

15 companies
Banco SabadellSpain
G1-1: Corporate culture and business conduct policies and corporate culture [Note: The text indicates this section exists on page 147 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]
BarcoBelgium
Business conduct policies and corporate culture We cultivate reliable and responsible business - We cultivate responsible and reliable business practices. Barco places great emphasis on building a company culture where ethical conduct and compliance with our policies and applicable regulations are at the core of how we do business. We demand the same from our business partners. More specifically, we aim to strengthen our product and service reliability, enhance our efforts for a responsible and resilient supply chain, and foster customer and partner intimacy. Employees trained in product quality, safety, security, ethics, compliance and sustainability: 98% of heads in 2024, compared to 99% in 2023 and 99% in 2022 TARGET: 100%
BBVASpain
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 (e.g., financing), and the structure of business transactions. BBVA's strategy and operations incorporate the concepts of integrity and business ethics through the reinforcement of control mechanisms, including policies and measures adopted to ensure the protection of whistleblowers, as well as the management of reputational and regulatory risks associated with corruption, bribery, and money laundering. The material IROs identified include: Contribution to socio-economic well-being through measures to prevent money laundering and terrorist financing, aligned with the principles of good corporate governance; Risk of legal sanctions, litigation and reputational damage associated with unethical practices, such as corruption, fraud or bribery; Risk of legal or regulatory sanctions that BBVA may suffer as a result of non-compliance with applicable legislation regarding the prevention of money laundering and the financing of terrorism or the use of BBVA products and services for illicit purposes; Risk of legal penalties, litigation and reputational damage associated with inadequate or inaccessible claim mechanisms.
Danica PensionDenmark
Under G1, Danica reports on corporate culture, as employee engagement surveys indicate a high degree of satisfaction and motivation among employees. Accordingly, Danica's culture is considered to have a positive impact. The most significant datapoints relate to the degree of completion of eLearning courses and the employee engagement survey, in which Danica meets the target of an employee score of at least 80 out of 100 on satisfaction and motivation. Danica is also committed to following ethical guidelines and implementing anti-corruption actions. To this end, Danica has adopted policies and guidelines for the prevention of financial crime as well as policies to ensure that customers and employees are treated fairly.
DemantDenmark
Business ethics are an integral part of conducting business in a global world with many stakeholders. We continuously expand and improve the Group's business ethics programme to reflect our all-important commitment to a high level of business ethics, including our Code of Conduct, a global whistleblower scheme as well as global policies and guidelines on business ethics. We are committed to a high level of business ethics.
GN Store NordDenmark
Business conduct policies described on pages 103-105. We are committed to doing things the right way, demonstrating the highest level of ethics and integrity in our business dealings. Our Nordic roots permeates the company fabric – how we innovate and collaborate, how we look at customers and technology, how we care for each other and the world in which we live. GN has policies and procedures to ensure ethical business conduct across all operations.
LundbeckDenmark
Business ethics compliance: 100% Share of employees who completed the annual e-learning on our Code of Conduct, compared to 99.9% in 2023. The 100% completion rate of our annual e-learning on our Code of Conduct is a testament to this.
MapfreSpain
MAPFRE has consistently and decidedly striven from the start to adopt the best corporate governance practices. MAPFRE's good governance practices are oriented toward creating sustained financial and social value over the long-term. The company's objective is to ensure financial stability and safeguard the interests of shareholders, maximizing the positive impact on society as a whole. MAPFRE is governed by the Recast Text of the Spanish Companies Act and has a series of Institutional, Business and Organizational Principles in place that have been approved by the Board of Directors of MAPFRE S.A., which, together with its Bylaws, the Annual General Meeting's Regulations, and the Board of Directors' Regulations, define the structure, composition and functions of each of its governing bodies and make up the minimum mandatory compliance framework for all of the companies in the MAPFRE Group and their respective governing bodies. In addition, MAPFRE has a group of corporate policies and standards that complement its governance system. Regarding the Spanish National Securities and Exchange Commission (CNMV) Good Governance Code of Listed Companies as of December 31, 2024, MAPFRE complies fully with 90.62% and fully or partially with 96.87%% of the recommendations. Our commitment is supported by the following Values, which help us execute on the company's purpose and achieve its vision: Solvency: The financial, technical, and professional strength to respond to commitments undertaken with sustainable results. Integrity: Ethics, respect for human rights, and honesty among MAPFRE professionals in their relations with all our stakeholders. Service: Continual improvement in the development of all our activities in order to satisfy the needs of our customers. Innovation: As a means to transform and set us ourselves apart, offering solutions to our customers and anticipating their needs.
Norsk HydroNorway
Hydro's values of care, courage and collaboration, reflect how the company aims at interacting with its employees, local communities, customers and suppliers. Care - We act with respect for people and the environment, and place safety at the heart of our operations. Courage - We break new ground and take measured risks with agility, accountability, and foresight. Collaboration - We work as partners internally and externally to unite competencies and create win-win opportunities.
Novo NordiskDenmark
In Novo Nordisk, we have an ethics and compliance programme which comprises of a code of conduct (OneCode), requirements (The Ethics Navigator), processes and awareness and capability building as stipulated in the seven elements of an effective compliance programme. Data privacy is a key component in our ethical principles, ensuring guardrails are in place to manage and mitigate risks, thus safeguarding our patients and society at large. We have also adopted a set of principles for data and artificial intelligence (AI) ethics to support ethical decision-making. We have initiated building our AI Ethics & Compliance framework, incorporating elements such as principles, requirements and risk assessments, as well as building AI literacy training and capabilities.
PandoraDenmark
Pandora's Code of Conduct sets out the ethical business practices and standards of behaviour, and all employees and partners are expected to adhere to these. Awareness initiatives are in place for all employees. Substantial efforts go into ensuring adherence to applicable regulations, implementing internal policies and growing a compliance culture. In Pandora, we have a zero-tolerance policy for bribery and corruption. To mitigate the risk hereof, we have a dedicated compliance programme built up around our Code of Conduct, the Anti-Bribery and Corruption Policy, the Gifts and Entertainment Standard, the Conflict-of-Interest Policy and the Global Donation Standard.
RandstadNetherlands
Our core values, established in the company's early days, represent the foundation of our culture. We use them to guide every decision we make and every action we take. to know: We are experts. We know our clients, talent, suppliers and other business partners, and we know that it's often the details that count the most. to serve: We succeed through a spirit of excellent service, exceeding the core requirements of our industry. We act in service to talent and clients. to trust: We are respectful. We value our relationships and treat people well. We build life-long relationships with our expertise and empathy. simultaneous promotion of all interests: We see the bigger picture and take our social responsibility seriously. Our business should always benefit society as a whole. striving for perfection: We always seek to improve and innovate.
Royal SchipholNetherlands
RSG upholds the highest standards of integrity through a robust compliance and integrity programme designed to monitor employee behaviour and effectively mitigate compliance and integrity risks. The company's Ethics Annual Plan details new developments and preventive measures, including promotion of ethical behaviour and evaluation of culture. In line with corporate strategy, RSG pioneers a vision for sector-wide integrity and social safety in aviation. Business conduct policies focus on maintaining ethical standards across operations and creating a culture of integrity. The company's governance structure includes oversight of business ethics and corporate culture as material topics identified through the double materiality assessment.
Stora EnsoFinland
Stora Enso complies with the Finnish Corporate Governance Code 2025 issued by the Securities Market Association. Stora Enso also complies with the Swedish Corporate Governance Code, with certain deviations due to differences between Swedish and Finnish legislation, governance code rules and practices. 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 corporate governance policy is approved by the Board of Directors. Our Purpose 'Do Good for the People and the Planet' and our Values 'Lead' and 'Do What's Right' underline our commitment to conducting business responsibly. We have a zero-tolerance policy for discrimination, harassment, or bullying.
TrygDenmark
Business conduct policies and corporate culture - 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. Tryg has adopted a number of policies describing the relationship between different stakeholders. A number of internal guidelines ensure that the disclosure of price-sensitive information complies with legislation and stock exchange codes of conduct.

G1-2

Management of relationships with suppliers

11 companies
Banco SabadellSpain
G1-2: Management of relationships with suppliers [Note: The text indicates this section exists on page 154 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]
BarcoBelgium
Management of relationships with suppliers Responsible & resilient supply chain is one of our material topics. We enhance our efforts for a responsible and resilient supply chain as part of cultivating responsible and reliable business practices. Suppliers scored on sustainability performance: 77% of production spend in 2024, compared to 81% in 2023 and 71% in 2022. Balancing sourcing of essential components (e.g. semiconductors) by launching new products and redesigning existing ones for greater flexibility in component substitution throughout the product's lifecycle. Insourcing production of critical subassemblies.
Danica PensionDenmark
Management of relationships with suppliers is included as part of Danica's overall business conduct and due diligence processes.
GN Store NordDenmark
Management of relationships with suppliers described on pages 103-105. GN manages supplier relationships through: Strategic partnership approaches; Supplier assessments and due diligence; Collaborative improvement programs; Long-term partnership development; Supply chain responsibility initiatives including human rights safeguarding.
MapfreSpain
Details of the payments made by the Group's fully consolidated Spanish companies to providers in the financial years 2024 and 2023 are provided in the following tables. Average provider payment period: 2024: 5.8 days, 2023: 6.4 days. Ratio of paid operations: 2024: 5.6 days, 2023: 6.2 days. Ratio of operations pending payment: 2024: 20.6 days, 2023: 17.8 days. Total payments made: 2024: 1,851.8 million euros, 2023: 1,781.9 million euros. Total pending payments: 2024: 26.1 million euros, 2023: 32.7 million euros. Information regarding invoices paid in a period of time less than the maximum established in the late payment regulation is shown in the accompanying table. Monetary volume paid: 2024: 1,851.8 million euros, 2023: 1,781.9 million euros. Percentage over total monetary payments to providers: 2024: 98.6%, 2023: 98.2%. Number of invoice paid: 2024: 265,211, 2023: 263,421. Percentage over total number of invoices paid to providers: 2024: 98.7%, 2023: 98.9%.
Novo NordiskDenmark
To date, more than 1,800 suppliers have already committed to make the switch. At the same time, we acknowledge that these measures will not be enough to meet our target, and will therefore investigate additional levers – including new technologies – to close this gap. Added 13,030 employees bringing Novo Nordisk's total workforce to 77,349, while supporting job-creation amongst our suppliers.
RandstadNetherlands
Share of sustainable procurement spend: 50% (2023: 43%)
Royal SchipholNetherlands
RSG manages relationships with suppliers through comprehensive procurement practices that integrate sustainability and quality of work considerations. The company actively integrates quality of work-related minimum requirements and award criteria in tenders for labour-intensive services such as cleaning, security and taxi services. Examples include requirements for attractive and adequate income, predictable work schedules, and working conditions contributing to safe, healthy and attractive work. Service companies must commit to these principles and are assessed partly on quality of work. RSG encourages sustainable cooperation with contractors who support the vision of being a socially responsible employer. Supplier and procurement practices are identified as a material topic, reflecting the importance of responsible supply chain management in RSG's operations.
Stora EnsoFinland
With over 20,000 contractors, sub-contractors and suppliers, we prioritise responsible raw material sourcing and foster long-term relationships with key partners. Active cooperation with forest owners and stakeholders near our harvesting sites helps to promote sustainable sourcing, share knowledge, and gain social acceptance. In addition to sourcing wood from its own forests and tree plantations, Stora Enso purchased wood from approximately 21,000 private forest owners during the year.
TrygDenmark
Management of relationships with suppliers - Tryg will develop and expand practices for repairs and the recycling of materials through close collaboration with suppliers. Tryg will continue to address carbon emissions in claims handling and in its supply chain with a target of a 6% average emissions reduction per claim.
VestasDenmark
We are enhancing engagement and integration with our supply chain partners, such as Maersk, ZF and ArcelorMittal, ensuring transparency on how our business and the market evolves. In the long term, reduced costs and inventory across the supply chain will benefit both Vestas and our supplier partners. Competent partners for a complex supply chain: Our manufacturing model is complex, with both a product and project side. The product side seeks repeatability, and the project side flexibility. By shifting our industrial system from push to pull, we aim to optimise resource use and supply chain lead time.

G1-3

Prevention and detection of corruption and bribery

8 companies
Banco SabadellSpain
G1-3: Prevention and detection of corruption and bribery [Note: The text indicates this section exists on page 157 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]
BBVASpain
BBVA's strategy and operations incorporate the concepts of integrity and business ethics through the reinforcement of control mechanisms, including policies and measures adopted to ensure the protection of whistleblowers, as well as the management of reputational and regulatory risks associated with corruption, bribery, and money laundering. The Group has identified material risks including: Risk of legal sanctions, litigation and reputational damage associated with unethical practices, such as corruption, fraud or bribery; Risk of legal or regulatory sanctions, significant financial or reputational losses that BBVA may suffer as a result of non-compliance with applicable internal or external legislation and regulations regarding the prevention of money laundering and the financing of terrorism or the use of BBVA products and services for illicit purposes related to money laundering and/or terrorist financing. The Group has also identified a positive impact: Contribution to socio-economic well-being through measures to prevent money laundering and terrorist financing, aligned with the principles of good corporate governance.
Danica PensionDenmark
Danica is committed to following ethical guidelines and implementing anti-corruption actions. To this end, Danica has adopted policies and guidelines for the prevention of financial crime as well as policies to ensure that customers and employees are treated fairly. This includes standards of anti-corruption and anti-bribery and protection of whistleblowers.
Novo NordiskDenmark
In Novo Nordisk, we have an ethics and compliance programme which comprises of a code of conduct (OneCode), requirements (The Ethics Navigator), processes and awareness and capability building as stipulated in the seven elements of an effective compliance programme.
PandoraDenmark
In Pandora, we have a zero-tolerance policy for bribery and corruption. To mitigate the risk hereof, we have a dedicated compliance programme built up around our Code of Conduct, the Anti-Bribery and Corruption Policy, the Gifts and Entertainment Standard, the Conflict-of-Interest Policy and the Global Donation Standard.
RandstadNetherlands
As a signatory to the UN Global Compact, we uphold its Ten Principles on human rights, labor rights, environmental protection, and anti-corruption.
Royal SchipholNetherlands
RSG's prevention and detection of corruption and bribery is managed through its robust compliance and integrity programme. The programme is designed to monitor employee behaviour and effectively mitigate compliance and integrity risks. The Ethics Annual Plan details preventive measures and promotes ethical behaviour throughout the organisation. RSG upholds the highest standards of integrity as part of its robust organisation enabler. The company evaluates its culture regularly and implements measures to prevent corruption and bribery across all operations and business relationships.
Stora EnsoFinland
The governance bodies include Internal Audit, Risk management, Internal control, Ethics and Compliance functions.

G1-4

Incidents of corruption or bribery

3 companies
Banco SabadellSpain
G1-4: Confirmed incidents of corruption or bribery [Note: The text indicates this section exists on page 157 but the provided content appears to be cut off. Based on the table of contents, this disclosure requirement is included in the report but the full content is not visible in the provided excerpt.]
DemantDenmark
Whistleblower reports: 87 in 2024, 90 in 2023, 47 in 2022, 48 in 2021.
Norsk HydroNorway
Substantiated claims of corruption: Zero substantiated claims of corruption. Ambitions and targets: Zero substantiated claims of corruption. 2024: 1, 2023: 0, 2022: 0.

G1-5

Political influence and lobbying activities

3 companies
Danica PensionDenmark
Political influence and lobbying activities are managed as part of Danica's overall governance framework and business conduct policies.
TrygDenmark
Political influence and lobbying activities - Setting the public agenda on climate protection: Tryg's CEO, Johan Kirstein Brammer, spearheaded advocating for increased climate protection. In an interview with a Danish newspaper, Tryg's CEO emphasised the urgent need for political involvement and common solutions across Danish society to address the expected increasing frequency and intensity of extreme weather events in the long term. The motivation for Tryg's engagement in this topic stems from clear documentation of climate changes impacting many customers. Tryg is focused on contributing to helping customers adapt to more severe weather.
VestasDenmark
Finally, we will lead the transition to a world powered by sustainable energy by setting a strong example of a responsible and sustainable company and taking a leading role in shaping global energy policy to accelerate the global energy transition, with renewable energy at its core. As one of the leading voices in the industry, Vestas launched the 'This is not a wind farm' initiative in 2024, to highlight the growing gap between 'say' and 'do'. Launch of our 'This is not a windfarm' campaign, highlighting the need for having windfarm auctions redesigned and translated into real action.

G1-6

Payment practices

1 company
Danica PensionDenmark
Payment practices are managed as part of Danica's standard business operations and supplier relationship management.