Governance framework

As a publicly listed company, Ørsted is subject to the recommendations on corporate governance issued by the Danish Committee on Corporate Governance.

Compliance with corporate governance recommendations

We comply with all the Danish corporate governance recommendations. A separate overview describing our compliance with each of the recommendations can be found here.

Shareholders and general meetings

The Danish State is our majority shareholder with a 50.1 % ownership share. The Danish State exercises its ownership interest in Ørsted in accordance with the ordinary governance set-up in Danish companies.

The shareholders of Ørsted exercise their right to vote at the general meeting through a one-share-one-vote principle. The general meeting adopts decisions in accordance with the ordinary Danish rules. Due to our majority ownership by the Danish State, we have a bespoke quorum requirement, as proposals to amend our articles of association or dissolve the company require that the Danish State participates in the general meeting and supports the proposals.

The general meeting appoints a board of non-executive directors (the Board of Directors), who, together with the executive directors appointed by the board (the Executive Board), is responsible for the management of the company.

Board of Directors

The Board of the Directors is, together with the Executive Board, responsible for the management of the company.

Each year at the annual general meeting, the shareholders elect six to eight board members. In addition, our employees may elect members corresponding to half of the board members elected by the general meeting pursuant to Danish mandatory rules.

Our Board of Directors currently comprises ten members, six members elected by the general meeting and four members elected by the employees. In 2024, the election of employee-elected board members covered all employees globally for the first time.

The Board of Directors is responsible for the overall strategic management of the company. The Board of Directors lays down the company's strategy and makes decisions concerning major investments and divestments, the capital base, key policies, control and audit matters, risk management, and significant operational issues.

The Board of Directors monitors and oversees performance on material sustainability impacts, risks, opportunities, progress related to our sustainability priorities, and achievement of our sustainability targets, including our net-zero carbon reduction targets for scope 1-3 emissions. ESG and sustainability priorities are an integral part of the decision-making governance of the Board of Directors, and an update on our sustainability targets and progress is presented to them annually. Read more about our sustainability governance on pages 63-64.

The Board of Directors reviews the required competences for its composition annually. The list of required competences can be found at orsted.com/competences-overview.

We have a diverse Board of Directors. As three out of the six board members elected by the general meeting and two out of four board members elected by the employees are women, we have a fully equal representation on the board.

The age of our board members spans from 49 to 70 years old among the board members elected by the general meeting and from 30 to 57 years old among board members elected by the employees.

Our board members have different educational backgrounds within finance, economics, geophysics, and engineering and professional experience from diverse industries, private equity, private investments, and academia. A description of the individual board members, including any other managerial positions, independence, and the contribution of the individual board members to the required board competences, can be found on the following pages.

The Board of Directors evaluates its performance annually. In 2024, the board evaluation was conducted by distributing a customised online survey to all members of the Board of Directors and the Group Executive Team, and findings were subsequently discussed at a board meeting. The overall score, although slightly lower than in 2023, was satisfactory. The board evaluation identified relevant focus areas for the Board of Directors, which among other things included how to further strengthen the visibility of succession planning to the board.

The general meeting determines the remuneration for the members of the Board of Directors for the financial year in which the general meeting is held. In the separate remuneration report, you can read more about the remuneration of the Board of Directors.

Important tasks 2024 – managed by the Board of Directors

Investments, acquisitions, and divestments

Final investment decisions on the offshore wind project Sunrise Wind, the battery energy storage systems co-located with the Hornsea 3 Offshore Wind Farm and with the Old 300 Solar Center, respectively, and preparation for the FID on Baltica 2 early 2025.

Build-out of our offshore wind portfolio, including bids in tenders in the UK, the US, and Taiwan and the acquisition of the remaining 50 % share of the Sunrise Wind offshore wind project from Eversource.

Divestment of 12.45 % of four operational UK offshore wind farms to Brookfield and a partial divestment of four operational US onshore wind farms to Stonepeak, farm-down of the offshore wind farm Greater Changhua 4 in Taiwan to Cathay Life Insurance, a partial divestment of the solar farm Mockingbird to Energy Capital Partners, and an agreement to partially divest the solar farm Sparta Solar and the battery storage project Eleven Mile Solar Center to Energy Capital Partner, with closings expected in 2025.

Decision to enter into partnership with Nordsøfonden and Equinor to explore the possibility of storing CO₂ in the subsurface.

Decision to cease development of the Swedish e-fuels project FlagshipONE.

Other tasks

Decision to update our business plan, financial targets, and financial policies.

Decision to update the executive management structure, including the appointment of a Deputy CEO and Chief Commercial Officer (CCO), a new CFO, and a new Chief Operating Officer (COO).

Establishment of the Asset Project Committee, which assists the Board of Directors in overseeing the planning, execution, and delivery of asset projects.

Oversight of recurring portfolio reviews and actions to improve capital structure.

Issuance of green subordinated bonds to proactively manage the hybrid capital portfolio and finance renewable energy projects in accordance with our 'Green finance framework'.

Oversight of financial results and guidance, including impairments.

Oversight of sustainability performance and reporting, including double materiality results.

Oversight of the results from the 2024 employee satisfaction survey, including the focus areas identified by the Group Executive Team.

Board committees

The Board of Directors has established three committees, consisting of members appointed by and among the members of the Board of Directors: The Audit & Risk Committee, the Nomination & Remuneration Committee, and the Asset Project Committee.

Audit & Risk Committee

Dieter Wemmer (Chair), Peter Korsholm, and Annica Bresky are the members of this committee.

The tasks of the committee include overseeing the integrity of the financial and sustainability reporting (including key accounting estimates and judgements), funding, liquidity, and capital structure development, financial and business-related risks, compliance with statutory and other requirements from public authorities, internal controls, nomination of external auditors, and IT security in operational and administrative areas and in cybersecurity. Moreover, the committee approves the framework governing the work of Ørsted's external and internal auditors (including limits for non-audit services), evaluates the external auditors' independence and qualifications, and monitors the company's whistleblower scheme.

In 2024, the committee reviewed impairments on our property, plant, and equipment with a high attention to our US offshore wind projects, monitored the development in provisions for onerous contracts and cancellation fees, continued working on strengthening the 'Risk management framework', and continued the work on implementing CSRD. Furthermore, the committee worked on strengthening the internal control framework, continued to assess the claim made by the Danish Tax Agency requiring double Danish taxation of certain of our British offshore wind farms, and lastly, reviewed the progress in IT security.

Our Internal Audit function reports to the committee and is independent of our administrative management structures. Internal Audit enhances and protects the organisational value by providing risk-based and objective assurance, advice, and insight. The focus for Internal Audit is to audit and advise on our core processes, governance, risk management, control processes, and IT security.

The Chair of the Audit & Risk Committee is responsible for managing our whistleblower scheme. Internal Audit receives and handles any reports submitted.

Our employees and other associates may report serious offences, such as cases of bribery, fraud, and other inappropriate or illegal conduct, to our whistleblower scheme or through our management system. In 2024, 14 substantiated cases of inappropriate or unlawful behaviour were reported through our whistleblower scheme. A total of ten cases related to good business conduct policy violations, while three cases concerned the workplace environment, and one case was classified as 'other'. None of the reported cases were critical to our business, nor did they cause adjustments to our financial results. Additionally, no cases required reporting to the police.

Whistleblower cases are taken very seriously, and we continuously enhance the awareness of good business conduct through education and awareness campaigns to minimise future similar cases.

Nomination & Remuneration Committee

Lene Skole (Chair), Andrew Brown, and Julia King are the members of this committee.

The committee assists the Board of Directors in matters regarding the composition, remuneration, and performance of the Board of Directors and the Group Executive Team.

In 2024, the committee reviewed the executive management structure and discussed the appointments of Rasmus Errboe as Deputy CEO and Chief Commercial Officer (CCO), Trond Westlie as new Chief Financial Officer (CFO), and Patrick Harnett as new member of the Group Executive Team and Chief Operating Officer (COO). The committee also reviewed the structure and KPIs used in the variable pay for Executive Board members as well as an update of the peer group used in the long-term incentive scheme.

Asset Project Committee

In May 2024, the Board of Directors established the Asset Project Committee. Andrew Brown (Chair), Julia King, and Annica Bresky are the members of this committee.

The committee assists the Board of Directors with overseeing the planning, execution, and delivery of asset projects to ensure they meet the company's strategic objectives, budget, and timelines.

In 2024, the committee reviewed and discussed several updates on our asset projects. These updates included our project and operating model, project top risks, portfolio risks, risk management, supply chain status, bid submissions, project specific costs and schedule updates, and final investment decisions.

Executive Board and Group Executive Team

The Executive Board is appointed by the Board of Directors and is in charge of the day-to-day management of Ørsted through the Group Executive Team in accordance with the guidelines and instructions given by the Board of Directors.

Rasmus Errboe (Group President and CEO), Trond Westlie (CFO), and Henriette Fenger Ellekrog (Chief HR Officer) are members of the Executive Board and registered as executives with the Danish Business Authority. All members of the Executive Board are also part of the Group Executive Team, which in addition consists of Patrick Harnett (Chief Operating Officer).

By February 2025, female representation constitutes 33.3 % of our Executive Board. We have not set a target to increase gender diversity among 'other managerial levels' as defined under Danish law. The Danish rules regarding gender diversity among 'other managerial levels' do not apply to us, as the average number of full-time employees in Ørsted A/S did not exceed 50 in 2024.

Management committees

The Group Executive Team is supported by committees whose members are appointed by the Group Executive Team. The committees are the QHSE Committee, the Compliance Committee, and the Cybersecurity Committee.

Ørsted has also established three supportive decision forums to support the Group Executive Team on sustainability matters. See pages 63-64 for a detailed description of our sustainability governance.

Sustainability commitment

The Group Executive Team sets the strategic direction on sustainability and is accountable for oversight and performance on sustainability impacts, risks, and opportunities. Moreover, they present proposals for sustainability targets to the Board of Directors for approval. The Group Executive Team is involved in all major decisions and is updated regularly on progress. Each Group Executive Team member is accountable for sustainability topics relevant for their line of business and is responsible for driving progress. Read more on pages 63-64.

Internal controls environment

We have established internal control systems to identify and mitigate risks in financial and sustainability reporting by setting up targets, policies, manuals, procedures, and controls.

We conduct an annual risk assessment to identify risks of material misstatements in financial reporting based on materiality, process complexity, and the probability of errors and omissions.

In preparation for the CSRD, a plan was established to perform walkthroughs to identify risks, reassess existing controls, and identify additional controls for sustainability reporting. This initiative started in 2024 and will continue until the end of 2025.

We have established a unified governance for financial and sustainability reporting. The Audit & Risk Committee monitors our financial and sustainability reporting processes, including a review of the risk assessment, the internal controls, and their operating effectiveness.

We are committed to ensuring the accuracy of our financial and sustainability reporting. Our financial reporting is audited by an independent audit firm elected at the annual general meeting. Our sustainability data is subject to limited assurance by the same independent auditor. All observations in the external auditor's long-form report and management letter are addressed by action plans with allocation of responsibilities and deadlines, and we regularly follow up on and review them.

Management committees appointed by the Group Executive Team

QHSE Committee

This committee oversees that we live up to our QHSE (quality, health, safety, and environment) priorities, and it reviews our QHSE strategy and policy. In addition, the committee reviews our integrated management system, 'way we work', conducts the management review as required by our ISO certifications, and monitors the performance of our QHSE programmes to ensure compliance with rules and regulations as well as agreed international standards.

The committee consists of the Chief Operating Officer, the Head of QHSE, the Head of Procurement, the Head of Engineering, the Head of Project Services, the Head of Region Europe Generation, and the Head of Global Stakeholder Relations. The QHSE Committee, chaired by the Chief Operating Officer, meets six times a year.

Compliance Committee

This committee oversees our group-wide legal compliance programmes. It provides instructions to our Chief Compliance Officer and compliance officers for each of the legal compliance programmes on management's risk tolerance, reviews recommendations regarding the legal compliance programmes, and appoints the compliance officers.

The committee's members are the CEO, the CFO, the Chief HR Officer, the Chief Compliance Officer, and the Head of Internal Audit. The Compliance Committee, chaired by the CEO, meets at least twice a year.

Cybersecurity Committee

This committee oversees and guides our strategy, our global risk tolerance, and our investment choices within cybersecurity and information security. It supports significant global initiatives and oversees the compliance with cybersecurity and information security laws and regulations, including the European Network & Information Security 2 Directive.

The committee is cross-functional and consists of the CFO, the Chief Operating Officer, the Chief Information Officer, the Chief Information Security Officer, and the Head of Legal. The Cybersecurity Committee, chaired by the CFO, meets four times a year.

Sustainability Governance

In 2024, our sustainability governance was redesigned to provide clearer executive accountability for sustainability matters across Ørsted. The revised governance comprises new supportive decision forums for our strategic priorities, decarbonisation, biodiversity, and community impact, and a Human Rights Task Force to support compliance with the upcoming EU directive CSDDD. The forums will assist the accountable persons in the Group Executive Team in progressing according to set roadmaps. For additional details, please refer to pages 63-64.

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.

Integration of sustainability-related performance in incentive schemes

Roles covered

Executive Board:

• CEO (Group President and Chief Executive Officer)
• CFO (Chief Financial Officer)
• CHRO (Chief HR Officer)
• CCO (Deputy CEO and Chief Commercial Officer)
• COO (Chief Operating Officer) - Member of Group Executive Team only

All members of the Executive Board are part of the Group Executive Team.

Sustainability KPIs tied to remuneration

The Executive Board participates in a variable short-term incentive scheme (STI), which consists of 70% shared financial and ESG KPIs aligned with strategic targets:

Financial metrics (45%):

• EBITDA
• Capital planning

ESG metrics (25%):

• CDP climate score
• Relative scope 1 and 2 GHG emissions
• Employee satisfaction
• Gender diversity
• Safety

The remaining 30% of the STI consists of individual business and leadership targets.

The Executive Board is eligible to participate in a long-term share-based incentive scheme (LTI), which consists of 100% total shareholder return (TSR) performance benchmarked against ten industry peers.

Weighting and performance structure

Short-term incentive (STI):

• 45% Financial KPIs
• 25% ESG KPIs
• 30% Business & leadership (individual targets)

Long-term incentive (LTI):

• 100% TSR performance vs industry peers

Climate-specific performance integration

A key financial metric linked to executive remuneration is EBITDA. In 2024, 91% of EBITDA is taxonomy-aligned, generated through activities that contribute to climate change mitigation under the EU taxonomy framework.

Beyond financial performance, a portion of executive remuneration is linked to climate-specific considerations, including the scope 1-2 emissions intensity target. The proportion of recognised remuneration linked to climate-specific considerations was:

• CEO: 1.9%
• CCO: 1.6%
• CFO: 1.4%
• CHRO: 1.5%

In 2024, the short-term bonus programme includes metrics linked to scope 1 and 2 emissions reductions and the external climate rating from the Carbon Disclosure Project (CDP).

Performance period and target structure

STI: Annual performance period

LTI: Multi-year performance and vesting period. The LTI that vested in April 2024 resulted in no shares being settled, as Ørsted was ranked last when benchmarked on TSR against ten comparable energy companies.

Payout against sustainability KPIs in reporting period

The Executive Board's shared STI score ended at 31% in 2024.

The LTI which vested in April 2024 resulted in zero payout, as Ørsted was ranked as the last when benchmarked on TSR against ten comparable energy companies.

Total remuneration awarded

Executive Board (aggregate):

Group Executive Team:

Remuneration of the Group Executive Team in 2024: DKK 64 million (2023: DKK 134 million, Δ -52%)

Governance and oversight

The Nomination & Remuneration Committee oversees remuneration matters. The committee had:

• 3 members in 2024 (unchanged from 2023)
• 4 meetings in 2024 (3 in 2023)
• 100% attendance in both years

The general meeting determines the remuneration for members of the Board of Directors. Detailed methodology on how climate-related performance is factored into remuneration can be found in the separate remuneration report.

Risk assessment is carried out on an ongoing basis in all business segments and regions as part of our daily business operations. 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. We will also continue our work to manage future breakaway profiles for asset projects by scrutinising financial commitments before taking final investment decision (FID).

Our strategic aspiration is to be the world's leading green energy major. This aspiration builds on three strategic pillars: 1) One of the world's leading developers, constructors, and generators of renewable assets, 2) The leading talent platform in renewable energy, 3) Globally recognised sustainability leader. 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. For more details on our business model, see pages 65-66.

Interests and views of stakeholders

Stakeholder engagement approach

Ørsted's 'Stakeholder engagement policy' underscores the company's commitment to actively listen to and engage with stakeholders. Through ongoing dialogue, Ørsted gains insight into stakeholder positions, concerns, and expectations. These insights inform the company's due diligence processes and double materiality assessment, allowing alignment of sustainability priorities, projects, and processes with stakeholder interests and views.

The policy is guided by principles of openness, transparency, and integrity, adhering to international norms and codes including:

• UN Guiding Principles on Business & Human Rights
• UN Declaration on the Rights of Indigenous Peoples
• IFC Performance Standards on Social & Environmental Sustainability

Ørsted ensures that the views and interests of affected stakeholders regarding sustainability-related impacts, risks, and opportunities are regularly communicated to the relevant accountable person in the Group Executive Team through periodic meetings.

Identified stakeholder groups and engagement mechanisms

Employees (Own workforce)

How engagement is organised:

• Employment relations and occupational health and safety representatives
• Inclusion and enterprise social networks
• Employee-elected board members
• Personal development dialogues
• Employee satisfaction surveys, workplace assessments, and town halls

Purpose of engagements:

• Understanding employees' perceptions, experiences, challenges, and suggestions for improvement
• Raising awareness of internal policies and changes
• Contributing to a sustainable workplace and working life, including physical and psychological health and safety
• Increasing employee retention and attraction

Examples of outcomes:

• Internal policy updates, e.g. labour and employment rights policy
• Global initiatives and campaigns for e.g. employee well-being

Suppliers (Value chain workers)

How engagement is organised:

• Interviews and assessments for supplier due diligence
• Workshops and industry collaborations, e.g. DecomBlades

Purpose of engagements:

• Ensuring compliance with code of conduct
• Promoting responsible sourcing, incl. of minerals and metals
• Protecting human and labour rights of workers
• Ensuring a respectful working environment
• Decarbonising the value chain and promoting circular solutions for resource use
• Understanding supplier needs and concerns

Examples of outcomes:

• Streamlined supplier expectations
• Supplier improvement plans to comply with code of conduct
• Informed procurement decisions
• Investments in test pilots and early offtake agreements for low-carbon solutions

Local communities (Affected communities)

How engagement is organised:

• Consultations, public forums, and informational events
• Direct communication through project staff and liaison officers
• Interviews during environmental and social impact assessments
• Whistleblower Hotline and other grievance mechanisms

Purpose of engagements:

• Addressing community concerns, questions, and feedback
• Building trust and relationships with local stakeholders affected by renewable energy projects
• Ensuring community benefits and social license to operate

Examples of outcomes:

• Design of tailored community benefits and projects
• Support of local projects for job creation, economic development, and environmental preservation

Corporate customers

How engagement is organised:

• Customer support inquiries
• Periodic reviews and meetings with account managers
• Assessments for business partner due diligence

Purpose of engagements:

• Understanding customer needs and expectations
• Building trust and providing transparency
• Enabling customers to achieve their renewable energy targets

Examples of outcomes:

• Product or service improvements for e.g. power purchase agreements (PPAs)
• Adaptation of marketing strategies, e.g. by providing ESG rating scorecards for customers

Investors

How engagement is organised:

• ESG ratings and assessments
• One-on-one investor relations meetings, questionnaires, and inquiries
• Quarterly earnings calls
• Capital market days and annual general meetings

Purpose of engagements:

• Understanding investor concerns and addressing questions
• Building trust and demonstrating long-term value of renewable energy investments
• Discussing performance, risk management, and strategic direction

Examples of outcomes:

• Action plans to improve ESG performance
• Increased disclosure to ESG rating agencies
• Alignment of investment strategy with sustainable finance frameworks, e.g. the EU taxonomy

Governments, policy-makers, and regulators

How engagement is organised:

• Participation in public hearings and regulatory processes
• Consultations and policy roundtables
• White papers, studies, and thought leadership related to renewable energy deployment

Purpose of engagements:

• Ensuring compliance with regulatory frameworks and standards
• Promoting a sustainable build-out of renewable energy
• Addressing climate-related transition risks and opportunities

Examples of outcomes:

• Operational adjustments to ensure compliance
• Informed decisions for renewable energy deployment and financing

Civic and non-profit organisations

How engagement is organised:

• Collaboration and consultations on community projects and impact assessments
• Contributions to research projects

Purpose of engagements:

• Contributing to local initiatives
• Ensuring transparency and responsiveness to public concerns
• Understanding local license to operate and public expectations
• Pooling efforts to address supply chain challenges, e.g. decarbonisation and human rights

Examples of outcomes:

• Informed project planning and site-specific initiatives, e.g. for biodiversity conservation or community development
• Alignment of projects with best practice for community engagement

Industry and sustainability associations

How engagement is organised:

• Workshops, knowledge sharing, and industry conferences
• Joint initiatives and industry research on e.g. biodiversity impact or life cycle assessments
• Consultations with trade unions on e.g. worker welfare and rights

Purpose of engagements:

• Enabling the industry to engage policymakers and promoting the build-out of renewable energy
• Developing industry standards for sustainability
• Pooling efforts to decarbonise hard-to-abate sectors in the supply chain
• Understanding the views of value chain workers' representatives

Examples of outcomes:

• Industry-led life cycle assessment methodology for offshore wind farms
• Launch of the Responsible Renewables Infrastructure Initiative
• Design of tailored initiatives for value chain workers through unions

Integration into strategy and business model

Stakeholder insights are integrated into Ørsted's strategy and business model through:

1. Double materiality assessment: Continuous stakeholder dialogues inform the identification of material impacts, risks, and opportunities. In-house subject-matter experts serve as a valid proxy for bringing the interests and views of stakeholders into the DMA.

2. Due diligence processes: Stakeholder feedback shapes risk assessments and supplier engagement strategies, particularly for value chain workers and affected communities.

3. Project planning: Community engagement during planning, development, construction, and operation phases ensures that local concerns are addressed and community benefits are aligned with local interests.

4. Policy development: While stakeholder input has not been systematically incorporated into all policy development, Ørsted aims to enhance outreach and dialogue when revisiting and updating global policies.

5. Governance: Views and interests of affected stakeholders regarding sustainability-related impacts, risks, and opportunities are regularly communicated to the relevant accountable person in the Group Executive Team through periodic meetings.

Distinction between affected stakeholders and users of sustainability information

Affected stakeholders (those impacted by the business):

• Employees
• Value chain workers (suppliers' and contractors' workers)
• Local communities
• Indigenous Peoples

Users of sustainability information (investors and lenders):

• Investors engaged through ESG ratings, investor relations meetings, earnings calls, and capital market days
• Focus on understanding long-term value, performance, risk management, and strategic direction

Use of stakeholder input in the double materiality assessment

Ørsted used in-house subject-matter experts with extensive insight and knowledge into each ESRS standard as a valid proxy for bringing the interests and views of stakeholders into the DMA. These experts were informed by:

• Publicly available evidence
• Continuous engagement activities in communities where Ørsted is present
• Professional judgement based on ongoing dialogues with stakeholders

The company acknowledges that it has not engaged directly with value chain workers or their representatives when developing policies, and aims to address this gap by enhancing outreach and dialogue when revisiting and updating global policies going forward.

Material impacts, risks, and opportunities (IROs)

Overview of our material IROs

In the following tables, we list our IROs that were identified and assessed as material in our DMA, i.e. they were scored with either a 'crucial' or 'significant' level of materiality. Within each ESRS topic, we specify which sub-topics the IROs relate to, e.g. in ESRS 'E1 Climate change', the sub-topics are 'climate change mitigation', 'climate change adaptation', and 'energy'.

Brief descriptions of the material IROs are also included in the tables, alongside an indication as to whether the IROs are in our own operations (OO) or value chain (VC). For impacts, we also show whether they are positive (+), negative (-), actual (A), or potential (P). More information on each IRO, including how we manage them, is included in the topical sections under 'Environment', 'Social', and 'Governance'.

Inherent risks and impacts

Our DMA is based on inherent risks and impacts but also accounts for actions that have been fully integrated in our governance, management, and daily operations to reduce or mitigate their effects.

E1 Climate change

E4 Biodiversity and ecosystems

The positive impact and opportunity also fall under the sub-topic 'Impacts on the state of species'.

E5 Resource use and circular economy

S1 Own workforce

S2 Workers in the value chain

S3 Affected communities

G1 Business conduct

Legend:

• I = Impact
• R = Risk
• O = Opportunity
• + = Positive
• - = Negative
• A = Actual
• P = Potential
• OO = Own operations
• VC = Value chain

In 2024, we conducted a double materiality assessment (DMA) to identify and assess our material sustainability-related impacts, risks and opportunities (IROs). 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. Based on the DMA performed in 2024, the magnitude of the identified sustainability-related financial risks were below the magnitude of the enterprise risks. See pages 67-74 for detailed methodology and results.

ESRS disclosure requirements covered by the undertaking's sustainability statement

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).

Cross-cutting standards

ESRS 2 · General disclosures (incl. incorporation by reference)

Environmental standards

ESRS E1 · Climate change (incl. incorporation by reference)

Entity-specific data points

• Energy consumption and mix
• Gross scope 1, 2, 3, and total GHG emissions
• Overview by country
• Renewable capacity
• Generation capacity
• Energy business drivers
• Energy generation and sales
• Total heat and power generation by source

SUS · pages 93-95, 97-102

ESRS E4 · Biodiversity and ecosystems

ESRS E5 · Resource use and circular economy

Social standards

ESRS S1 · Own workforce

Entity-specific data points

• People
• Group Executive Team and Board of Directors
• Diversity and pay gap
• Safety

SUS · page 133-136

ESRS S2 · Workers in the value chain

Entity-specific data points

• Supply chain due diligence

SUS · page 144

ESRS S3 · Affected communities

Governance standards

ESRS G1 · Business conduct (incl. incorporation by reference)

Entity-specific data points

• Whistleblower cases

SUS · page 156

Immaterial ESRS standards

We have omitted all the disclosure requirements in the topical standards ESRS 'E2 Pollution', ESRS 'E3 Water and marine resources', and ESRS 'S4 Consumers and end-users', as these topics were deemed immaterial in our DMA. For ESRS E2 and ESRS E3, we identified and assessed impacts, risks, and opportunities following the same methodology and process steps as for the topics deemed material. This was informed by environmental impact assessments, risk registers, reported data, and other documentation, such as asset-specific conditions for management of pollution and water imposed by local authorities, which is particularly relevant for our CHP plants. However, none of the identified IROs were assessed as material for these two topics due to the high minimum environmental requirements imposed by authorities in the countries where we operate our assets.

Key:

• BP: Basis for preparation
• GOV: Governance
• SBM: Strategy and business model
• IRO: Impacts, risks, and opportunities
• MR: Management's review
• SUS: Sustainability statements
• REM: Remuneration report

Transition plan for climate change mitigation

Scope of the plan

Ørsted's transition plan covers:

• Entities and geographies: All sites owned and operated by Ørsted globally, including offshore and onshore wind, solar PV, bioenergy, and CHP plants across multiple countries (Denmark, Germany, Taiwan, the US, the UK, Netherlands, and others)
• Value chain segments: The plan addresses scope 1, 2, and 3 emissions across own operations and upstream/downstream value chains, with specific focus on:
  • Direct operations (energy generation)
  • Upstream supply chain (materials extraction, manufacturing, steel production)
  • Downstream gas sales activities (locked-in emissions)

Target years for net zero / carbon neutral

Net-zero target: 2040 for scope 1-3 emissions

Interim milestones:

• 2025: 99% renewable share of energy generation
• 2030: Key interim targets for decarbonisation pathways

Scope 1, 2, 3 reduction milestones with baseline years

Scope 1-2 emissions intensity target (baseline year: 2018):

• 93% reduction by 2025
• 96% reduction by 2030
• Previous baseline (2006) showed 98% reduction target

Scope 1-3 emissions intensity target (excluding gas sales):

• ~77% reduction by 2030 from 2018 baseline

Scope 3 emissions from gas sales (absolute target, baseline year: 2018):

• ~67% reduction by 2030
• ~90% reduction by 2040

Historical performance:

• Between 2018 and 2024: 88% reduction in scope 1 and 2 emissions intensity achieved

Alignment with 1.5°C / SBTi validation status

SBTi validation: In 2024, the Science Based Targets initiative (SBTi) validated Ørsted's interim 2030 targets. The SBTi's target validation team classified the ambition of these targets across scopes 1-3 as aligned with a 1.5°C trajectory, reflecting alignment with the most ambitious goal of the Paris Agreement.

Ørsted became the first energy company to set a science-based net-zero target covering scope 1-3 emissions by 2040 in 2021.

Paris-aligned benchmark: As of 31 December 2024, Ørsted is not excluded from the Paris-aligned Benchmark (PAB).

Key levers / decarbonisation pillars

The transition plan is structured around four decarbonisation levers:

Decarbonisation lever 1: Deploying renewable energy

• Growth in renewable capacity: Reached 18.2 GW of installed capacity in 2024
• Pipeline: 7.6 GW of decided (FID'ed) capacity under construction
• Targets: Build-out ambition to reach 22 GW by 2026
• Key milestones in 2024:
  • Greater Changhua 1 and 2a (900 MW)
  • South Fork (132 MW)
  • Sparta Solar (250 MW)
  • Mockingbird (471 MW)
  • Eleven Mile Solar Center (300 MW solar + 300 MW/1,200 MWh battery storage)

Decarbonisation lever 2: Reducing emissions from operations

• Key action 2.1: Phasing out coal - Shut down last coal-fired combined heat and power plant in Esbjerg, Denmark in 2024, marking a major milestone
• Action 2.1: Electric vehicle fleet - 73% electrification of vehicle fleet achieved in 2024, targeting 100% by end of 2025
• Action 2.2: Heavy-lift (cargo) drones for offshore maintenance - Deployed at Borssele 1 & 2 in 2024, reducing GHG emissions by minimizing vessel journeys

Decarbonisation lever 3: Reducing emissions from supply chain

• Key action 3.1: Company-wide decarbonisation roadmap - Initiated project in 2024 to update roadmap supporting 2040 net-zero ambition with clear interim milestones
• Key action 3.2: Offtake agreements for lower-emissions steel - Long-term partnership with Dillinger for lower-emissions heavy plate steel, with first production expected 2027-2028 for monopile foundations
• Key action 3.3: Supplier engagement and procurement strategy - Engaging key high-impact suppliers representing over 50% of procurement spend to:
  • Adopt science-based targets (through SBTi)
  • Provide transparent climate reporting (through CDP)
  • Transition to renewable electricity
  • Meet climate requirements integrated into standard contracts and tender criteria
• Action 3.1: Uniform methodology for product carbon footprint (PCF) - Continued collaboration with Carbon Trust in 2024 to develop standardised carbon footprint methodology for offshore assets across full life cycle

Decarbonisation lever 4: Beyond value chain mitigation

• Action 4.1: Nature-based projects in the Gambia - Planted approximately 40 million mangrove propagules in 2024 (equivalent to ~4,000 hectares) for carbon removal and ecosystem restoration, in partnership with Gambia Department of Parks & Wildlife Management and three local NGOs

CapEx / investment commitments

2024 capital allocation:

• Total CAPEX allocated to taxonomy-aligned activities: DKK 46,800 million
• Capital alignment with climate goals: 99% of CAPEX in 2024 classified as sustainable under EU Climate Delegated Act, including:
  • DKK 37,867 million for offshore and onshore wind capacity deployment
  • DKK 6,097 million for solar PV and energy storage technologies
  • DKK 2,836 million for hydrogen, carbon capture and storage, and bioenergy activities

2025 outlook:

• Gross investments expected: DKK 50-54 billion, mainly driven by Offshore (Sunrise Wind, Greater Changhua 2b and 4, Revolution Wind, Hornsea 3, Baltica 2, and Borkum Riffgrund 3)

Financial policies:

• Dividend payments paused for financial years 2023-2025 to support solid investment grade rating
• Target to reinstate dividend from financial year 2026
• FFO/adjusted interest-bearing net debt target: above 30%

Locked-in emissions and stranded asset analysis

Locked-in emissions from gas sales:

Ørsted recognises the importance of tackling impacts from legacy business, as locked-in emissions pose a significant transition challenge. Future emissions result from existing infrastructure tied to gas sales activities, primarily due to binding contractual obligations for offtake volumes of natural gas from the gas fields operated by the Danish Underground Consortium (DUC).

Mitigation approach:

• Set absolute emissions reduction target for scope 3 emissions from gas sales: ~67% by 2030 and ~90% by 2040 (baseline 2018)
• Measurable performance: Track and disclose progress towards absolute reduction targets aligned with 1.5°C pathway
• Avoiding additional locked-in emissions: Do not enter into new gas sourcing agreements that would contribute to additional locked-in emissions
• Expected increase in scope 3 emissions from gas sales in 2025 due to more gas delivered under DUC contract following gradual reopening of Tyra gas field in 2024

Use of carbon credits / removals

Nature-based carbon removal projects:

While not a substitute for reducing scope 1-3 emissions, Ørsted finances and develops nature-based projects that contribute to climate action outside the value chain:

• Gambia mangrove restoration project: Planted approximately 40 million propagules in 2024 (equivalent to around 4,000 hectares) in partnership with Gambia Department of Parks & Wildlife Management and three local NGOs
• Ensures carbon credits meet additionality (project would not occur without financial support) and permanence (mangroves remain intact)
• Provides dedicated team and financial backing to ensure project integrity

Approach to carbon credits: These efforts complement and reinforce the commitment to achieving emissions reductions as part of a holistic approach to climate action, supporting both climate mitigation and ecosystem restoration.

Governance and oversight

Board-level oversight: Matters related to the transition plan are addressed within the sustainability governance framework

Executive incentives: Climate-related KPIs incorporated in remuneration framework of the Group Executive Team:

• Short-term bonus programme in 2024 includes metrics linked to scope 1 and 2 emissions reductions
• Metrics linked to external climate rating from Carbon Disclosure Project (CDP)
• EBITDA as key financial metric (91% from wind and solar PV assets)

Disclosure and shareholder engagement: Elements of transition plan fully disclosed in annual report, presented to shareholders for approval at annual general meeting (AGM), providing opportunity for feedback

Resilience analysis

Ørsted employs a comprehensive approach to assessing and managing climate-related transition and physical risks:

Transition risks and opportunities: Managed through Enterprise Risk Management (ERM) framework and double materiality assessment. Key risks include:

• Insufficient political or regulatory support for renewable energy deployment (particularly relevant in the US)
• Changes in investment conditions, reductions in subsidies, or shifting policy priorities
• 80% of expected revenue from wind and solar PV assets in 2025 is inflation-indexed or fixed nominal; remaining 20% exposed to power price fluctuations

Physical climate risks: Assessed from two perspectives:

1. Design safeguards: Ensure structural integrity and resilience of assets against climate hazards using region-specific data for offshore, onshore, and bioenergy assets that have reached FID
2. Business case impacts: Conducted at asset-by-asset level under SSP5-8.5 worst-case scenario

Time horizons:

• Financial materiality: short term (current year + 1 year), medium term (to 5 years), long term (>5 years)
• Physical risk assessment: Focus on 2030s-2040s for chronic risks; acute events assessed continuously

Climate advocacy and policy engagement

Active engagement with policymakers, industry stakeholders, and communities to support renewable energy transition. Advocacy aligned with Paris Agreement goal, as detailed in first climate advocacy report, including assessment of industry associations' alignment with 1.5°C goal.

The way forward

Vision: To create a world that runs entirely on green energy

Strategic focus:

• Continue leveraging advanced technologies and scalable solutions to optimise renewable energy integration and supply chain decarbonisation
• Remain attuned to market environment shaped by national climate ambitions, regulatory developments, and sustainability impacts
• Proactively identify and manage material sustainability impacts, risks, and opportunities
• Address interlinkages between rising global temperatures, biodiversity loss, resource scarcity, and affected communities

Commitment to inclusivity: Guided by 'Just transition policy', safeguarding workers, supporting communities, and protecting ecosystems while advancing global energy transformation through collaboration with local communities to create opportunities and foster socio-economic growth.

Policies related to climate change mitigation and adaptation

Ørsted does not have a stand-alone climate policy. The company's commitment to mitigating climate change, deploying renewable energy, and promoting efficient energy systems is embedded in its Sustainability Commitment.

Sustainability Commitment

Policy name: Sustainability Commitment

Year introduced: 2016

Scope and approach:

• Reflects a systems-based approach to addressing climate change
• Recognizes that social and governance factors are critical to successfully delivering reliable and modern energy systems to society
• This perspective is applied across the organisation and is also reflected in the 'Code of Conduct for Business Partners'

Governance and oversight:

• Overseen by the Group Executive Team

Key content and principles:

• The commitment to mitigating climate change
• Deploying renewable energy
• Promoting efficient energy systems
• Set the direction for the company's first transition wave: shifting away from fossil fuels

Implementation and monitoring:

• Climate-related KPIs are incorporated in the remuneration framework of the Group Executive Team
• The short-term bonus programme (2024) includes metrics linked to scope 1 and 2 emissions reductions and the external climate rating from the Carbon Disclosure Project (CDP)
• Progress tracked through relevant KPIs, with the need for policy development assessed continuously

Public availability: Not explicitly stated where the policy can be accessed

Link to international standards: The sustainability commitment does not explicitly outline links to international standards or guidelines in the excerpts provided

Rationale for no stand-alone climate policy:

The company states that climate change mitigation efforts have been at the core of operations for many years, eliminating the necessity for a stand-alone climate policy. The focus is on delivering measurable change through setting internal targets, milestones, and decision-making mechanisms, tracked through relevant KPIs.

Actions and resources in relation to climate change policies

Ørsted has structured its climate-related actions around four decarbonisation levers, each containing specific initiatives to address climate change mitigation.

Decarbonisation Lever 1: Deploying renewable energy

Key action 1.1: Installed renewable capacity

• Description: Build-out of renewable energy projects at scale
• Scope: Own operations
• Time horizon: Long-term strategic ambition
• Outcomes (2024):
  • Expanded renewable energy portfolio to 18.2 GW of installed capacity in 2024
  • Advanced pipeline to a total of 7.6 GW in decided capacity (FID), with 1.8 GW added in 2024
  • Reached commercial operations for several major projects:
    • Greater Changhua 1 and 2a (900 MW) - offshore wind
    • South Fork (132 MW) - offshore wind
    • Sparta Solar (250 MW)
    • Mockingbird (471 MW)
    • Old 300 (73 MW)
    • Eleven Mile (300 MW solar + 300 MW/1,200 MWh battery storage)
• Target: Strategic ambition to reach 22 GW installed renewable capacity by 2026; 99% share of renewable energy generation by 2025
• Resources allocated (2024): DKK 46,800 million in capital expenditures to taxonomy-aligned activities
• Link to policy: Core business strategy aligned with vision to create a world running entirely on green energy

Decarbonisation Lever 2: Reducing emissions from operations

Key action 2.1: Phasing out coal

• Description: Shut down of last coal-fired combined heat and power plant in Esbjerg, Denmark
• Scope: Own operations
• Time horizon: Completed 2024
• Outcomes: This marks the last big milestone in transforming energy generation to renewable energy; eliminates impact from coal from 2025
• Link to target: Supports science-based target to reduce scope 1-2 GHG emissions intensity by 98% compared to 2006; already achieved 99% green share of energy generation by 2025; between 2018-2024, reduced scope 1 and 2 emissions intensity by 88%, on track to achieve SBTi-validated target of 93% reduction in 2025

Action 2.1: Electric vehicle fleet

• Description: Transition of company vehicle fleet to fully electric vehicles
• Scope: Own operations (global)
• Time horizon: Target end of 2025
• Outcomes (2024): Achieved 73% electrification of vehicle fleet
• Resources: Strategic decision to discontinue acquisition or leasing of fossil fuel-powered vehicles
• Link to target: Target to achieve fully electric vehicle fleet by end of 2025

Action 2.2: Heavy-lift (cargo) drones for offshore maintenance

• Description: Deployment of heavy-lift cargo drones at offshore wind farms to enhance maintenance efficiency
• Scope: Own operations (offshore assets)
• Time horizon: Deployed 2024; medium-term initiative
• Outcomes (2024):
  • Deployed at Borssele 1 & 2 Offshore Wind Farm
  • Drones can transport cargo up to 100 kg
  • Cargo delivered directly to nacelle in 4 minutes vs. ~6 hours using conventional methods
  • Tasks completed 10-15 times faster
  • Eliminates need to shut down turbines during delivery
• Expected outcomes: Significant cost and time savings; reduces GHG emissions by minimising vessel journeys; improves operational efficiency and safety

Innovative installation method (supplementary)

• Description: Lower-noise installation method successfully tested on three monopile foundations at Gode Wind 3 (Germany)
• Scope: Own operations (offshore wind)
• Time horizon: Testing completed 2024; industrialisation expected by 2030
• Expected outcomes: Noise reduction protecting marine life; step change in efficiency providing more cost-effective installation of offshore wind foundations once adopted at scale

Decarbonisation Lever 3: Reducing emissions from supply chain

Key action 3.1: Continued improvement of company-wide roadmap

• Description: Update of company-wide decarbonisation roadmap to support net-zero emissions ambition by 2040
• Scope: Own operations and value chain
• Time horizon: Initiated 2024; ongoing medium to long-term
• Expected outcomes: Provides clear interim milestones; identifies potential new areas for immediate progress; ensures measurable progress and targeted actions
• Link to target: Supports 2040 science-based net-zero target (SBTi-validated)

Key action 3.2: Offtake agreements for lower-emissions steel

• Description: Long-term offtake agreement with Dillinger, Europe's largest heavy steel plate producer, for lower-emissions heavy plate steel for offshore wind monopile foundations
• Scope: Upstream value chain (supply chain)
• Time horizon: Agreement signed 2024; procurement expected 2027-2028; long-term partnership
• Resources: Long-term offtake agreement; Ørsted receives first offer; ensures more diversified supply and secure capacity
• Expected outcomes: Decarbonises critical components of offshore wind monopile foundations; supports Dillinger's efforts to decarbonise steel production; strengthens supply chain resilience
• Link to policy: Aligns with 2040 net-zero target and supply chain decarbonisation efforts

Key action 3.3: Supplier engagement and procurement strategy

• Description: Engagement with key high-impact suppliers to drive decarbonisation integration into their strategies and operations
• Scope: Upstream value chain (supply chain)
• Time horizon: Ongoing initiative; no fixed end date; evolves with project portfolio growth
• Outcomes (2024):
  • Nearly doubled the number of key suppliers actively engaged since implementation
  • Broadened focus to include circularity alongside decarbonisation
  • Introduced climate requirements into standard contracts and tender criteria for selected high-impact segments
• Expectations set for suppliers:
  • Adopt science-based targets (through SBTi)
  • Provide transparent climate reporting (through CDP)
  • Transition to renewable electricity for energy needs
• Expected outcomes: Drives progress toward 2040 net-zero target; contributes to supply chain resilience
• Link to target: Supports science-based scope 3 emissions reduction targets

Action 3.1: Uniform methodology for product carbon footprint (PCF) for offshore assets

• Description: Collaboration with Carbon Trust to develop standardised carbon footprint methodology for offshore assets across full life cycle
• Scope: Own operations and industry-wide
• Time horizon: Continued work in 2024; medium-term initiative
• Expected outcomes: Sector-specific guidance for international PCF and life cycle assessment standards; consistent approach to measuring environmental impact from material sourcing to decommissioning; enhances transparency; drives improvements across industry

Reuse and recycling of blades and towers (supplementary)

• Description: Reuse and recycling of turbine components and materials from decommissioned wind farms
• Scope: Own operations (decommissioning phase)
• Time horizon: Ongoing; demonstrated in 2024
• Outcomes (2024): At Owenreagh 1 (Northern Ireland), turbine towers sent for reuse while blades sent for recycling
• Expected outcomes: Lower emissions and costs; diversifies supply; reflects commitment to not send blades to landfill

Decarbonisation Lever 4: Beyond value chain mitigation

Action 4.1: Nature-based projects in the Gambia

• Description: Mangrove reforestation project to achieve carbon removal beyond value chain
• Scope: Beyond value chain (nature-based carbon removal)
• Time horizon: Medium-term (3-5 years for impact materialisation); ongoing
• Outcomes (2024):
  • Planted approximately 40 million propagules in the Gambia
  • Equivalent to around 4,000 hectares restored
  • Partnership with Gambia Department of Parks & Wildlife Management and three local NGOs
• Expected outcomes: Carbon removal from atmosphere supporting efforts to limit global warming to 1.5°C; restoration of vital ecosystems; climate change mitigation
• Carbon credit agreements:
  • Microsoft: Agreement to sell additional 1 million tonnes of carbon removal over ten-year period from Avedøre Power Station (builds on existing 2.67 million tonnes commitment)
  • Equinor: Agreement to sell credits for removal of 330,000 tonnes of CO₂ over ten-year period
• Link to policy: Complements emission reduction efforts; not a substitute for direct emission reductions; supports broader climate action and sustainability objectives; addresses potential positive impact related to carbon removal

Resources Summary

Capital allocation (2024):

• DKK 46,800 million allocated to taxonomy-aligned activities
• 1.8 GW of new projects reached final investment decision (FID)

Operational capacity (2024):

• 18.2 GW installed renewable capacity
• 7.6 GW decided (FID) capacity in pipeline
• 5.2 GW awarded capacity

Organisational structure:

• Dedicated sustainability governance with clear accountability at Group Executive Team level
• Global Stakeholder Relations organisation including Global Sustainability function
• Dedicated procurement team for sustainable procurement

Integration and Governance

• Biodiversity measurement framework: Launched in 2024 to ensure capture of all potential impacts/risks to biodiversity and ecosystems when developing new renewable energy projects starting from 2024
• Sustainability governance update (2024): Updated with clear accountability and leadership focus at Group Executive Team level
• Roadmap development: Began to detail and develop roadmaps to break down ambitions into structured short- to medium-term actions and milestones
• Executive remuneration: Climate-related KPIs incorporated in 2024 short-term bonus programme (scope 1 and 2 emissions reductions; CDP external climate rating)

Political Engagement (supporting climate transition)

Political initiatives engaged in (2024):

• EU Clean Industrial Deal
• UK Beyond 2030 strategy
• Market design initiatives in Denmark, Sweden, Germany, UK
• US federal and state-level investment policy implementation
• Taiwan auction design improvements

Resources allocated to political influence and lobbying (2024):

• Total: DKK 44 million
  • US: DKK 23 million (lobbying firms: DKK 12m; trade associations: DKK 8m; NGOs: DKK 3m)
  • Europe: DKK 21 million (trade associations: DKK 17m; lobbying firms: DKK 3m; think tanks: DKK 1m)
• Key industry associations: WindEurope, Green Power Denmark, American Clean Power

E1-4 Targets related to climate change

Delivering on our 2040 net-zero ambition

In 2021, we became the first energy company to set a science-based net-zero target covering scope 1-3 emissions by 2040. Since then, we have made measurable progress and remain on track to meet our near-term scope 1-2 emissions intensity target.

To provide a more detailed trajectory for our decarbonisation efforts, we developed a portfolio of new near-term targets for 2030, using the same KPIs as our 2040 targets. In 2024, the Science Based Targets initiative (SBTi) validated our interim 2030 targets.

The SBTi's target validation team classified the ambition of these targets across scopes 1-3 as aligned with a 1.5 °C trajectory, reflecting alignment with the most ambitious goal of the Paris Agreement. This validation underscores the credibility of our approach and further reinforces our commitment to leading the energy transition towards a net-zero future.

Our portfolio of climate targets outlines a clear pathway to reducing emissions across our value chain. It also includes a cap on emissions from natural gas sales, building on the reductions we have already achieved.

Delivering on our strategic ambition: renewable energy deployment

We remain dedicated to advancing the global shift toward renewable energy. We are on course to achieve a 99 % share of renewable energy generation in 2025. This commitment is further supported by our strategic focus on expanding renewable energy capacity, with an ambition of reaching installed renewable capacity of 22 GW by 2026.

Climate-related targets

SBTi-validated climate targets

¹ As part of the SBTi validation process of our interim targets, we updated the baseline year for our scope 1-2 emissions intensity target from 2006 to 2018.

Other climate targets

Business driver target

² Renewable capacity installed by Ørsted accumulated over time and not adjusted for divestments

Energy consumption and mix

Total energy consumption

2024: Not disclosed in a standard format

Ørsted does not provide a standard ESRS E1-7 disaggregated energy consumption table in the excerpts reviewed. The company reports extensively on energy generation (output) rather than energy consumption (input).

Energy generation data (output metrics)

The company reports the following generation metrics, which do not constitute E1-7 energy consumption disclosure:

Energy consumption reference (limited)

The only direct reference to energy consumption appears in the ESRS content index (page 61), which lists:

• E1-5: Energy consumption and mix (reference: SUS pages 93, 102)
• Entity-specific data points: Energy consumption and mix

However, pages 93 and 102 in the excerpts provided focus on:

• Energy generation by source (offshore wind, onshore wind, solar, CHP)
• GHG emissions (scope 1-3)
• Business drivers (installed capacity, generation capacity, load factors)

No disaggregated table of energy consumption (fuel consumption, purchased electricity/heat/steam, self-generated non-fuel renewable energy) following the ESRS E1-7 structure is presented.

Scope note

As a renewable energy generator, Ørsted's business model centres on producing and selling energy rather than consuming it as an input to manufacturing. The company's material energy flows are:

• Inputs: Biomass and natural gas for CHP plants (mentioned but not quantified in E1-7 format)
• Outputs: Electricity and heat sold to customers (extensively reported)

The absence of standard E1-7 disclosure may reflect:

1. Phase-in provisions (energy sector specifics)
2. Interpretation that generation metrics fulfil the requirement
3. Disclosure in sections not included in excerpts

Conclusion: No ESRS E1-7 compliant energy consumption table is disclosed in the reviewed excerpts.

Gross Scopes 1, 2, 3 and Total GHG emissions

Greenhouse gas emissions intensity (scopes 1 and 2)

The greenhouse gas emissions intensity from heat and power generation and other operating activities (scopes 1 and 2) was 16 g CO₂e/kWh. The decrease was driven by lower coal-based generation at the CHP plants.

Greenhouse gas emissions intensity (scopes 1-3, excluding gas sales)

Including scope 3 (excluding gas sales), the greenhouse gas intensity was 127 g CO₂e/kWh. The increase in GHG intensity was due to more projects reaching COD, particularly scope 3 emissions from commissioned assets (capital goods). In 2024, we commissioned four major solar farms in the US and three offshore wind farms in Taiwan and the US.

Scope 3 greenhouse gas emissions

Our scope 3 greenhouse gas emissions were 9.0 million tonnes CO₂e. The increase in emissions was mainly a result of an additional 2.4 GW renewable asset capacity being commissioned in 2024.

We expect more gas delivered under our contract with The Danish Underground Consortium (DUC), following the gradual reopening of the Tyra gas field in 2024. Therefore, we expect an increase in our scope 3 emissions from gas sales.

Five-year summary of GHG emissions

Quarterly GHG emissions data (2023-2024)

Science-based targets

Ørsted has a science-based 2040 net-zero target, validated by SBTi. The company has achieved a 99% renewable share of energy generation by 2025, remaining on track to achieve the SBTi-validated target. The greenhouse gas emissions from heat and power generation (scopes 1 and 2) decreased by 54% in 2024 compared to 2023, mainly due to a decrease in the use of fossil fuels, primarily coal, at CHP plants.

Methodology notes

All greenhouse gas emissions (GHG scopes 1-3) are reported based on the Greenhouse Gas Protocol. The data is consolidated according to the same principles as the financial statements, comprising the parent company Ørsted A/S and subsidiaries controlled by Ørsted A/S. Joint operations are included with Ørsted's proportionate share. For the reporting of absolute scope 1 and 2 GHG emissions, the company also reports the difference between total scope 1 and 2 GHG emissions using operational control of the sites they operate as consolidation principle compared to scope 1 and 2 totals using standard financial consolidation of the entities, as per ESRS disclosure requirement E1-6, data point 50.

For scope 3 GHG emissions reporting, the company uses estimates combining activity data with emissions factors. It is not feasible to obtain accurate supplier-specific data and emissions factors for all scope 3 GHG emissions categories. Therefore, in some cases, broader, more generic activity data or emissions factors are used and extrapolated to cover data gaps.

E1-9 Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Climate change mitigation

Renewable energy deployment

Positive impact (own operations)
Opportunity (own operations)

The positive impact and opportunity arise from our deployment of renewable energy. Generally, risks associated with the transition to a low-carbon economy present opportunities for Ørsted, as our vision and long term ambitions are closely aligned with this transition.

We create environmental and societal benefits by developing and operating renewable energy assets, which are critical technologies for decarbonising society and limiting global warming to 1.5 °C.

How do we manage the IRO?
Deploying renewable energy is at the core of our business, and we address this ­material opportunity and positive impact through our business model and strategy.

Climate-related transition risks due to changes in political support for the renewable energy build-out

Risk (own operations)

This climate-related transition risk arises due to possible changes in the political and regulatory landscape, which could result in insufficient support for renewable energy deployment or the removal of existing subsidies and incentives.

This risk specifically concerns investment subsidies (e.g. capital grants) and production subsidies (e.g. feed-in tariffs or tax credits). It could impact our operations, potentially influencing project viability.

How do we manage the IRO?
We are actively engaged in climate-­related advocacy, calling our stakeholders to action for activities that will accelerate the renewable energy build-out and help manage this risk.

We continuously monitor emerging or evolving geopolitical and macroeconomic risks.

Climate change adaptation

Climate-related physical risks (chronic and acute)

Risk (own operations)

The chronic physical risks relate to the dependency of renewable energy generation on natural resources, such as wind patterns, and the acute physical risks relate to a potential increase in the severity and frequency of extreme weather events.

How do we manage the IRO?
We assess the resilience of all new assets towards the occurrence of climate-related hazards.

Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Integration of biodiversity in strategy and business model

At Ørsted, we believe that transitioning to renewable energy can be part of a solution to the biodiversity crisis, provided it is done correctly. As we continue our renewable energy build-out, we are determined to leave nature as a whole in a better state than we found it.

When developing renewable energy projects, we always adhere to local and national regulations and policies, including those related to biodiversity. This helps ensure that we are also taking our local stakeholders and their interests into consideration.

Biodiversity targets

Our ambition is to take direct action to be able to achieve a net-positive biodiversity impact from projects commissioned from 2030 onwards. In 2024, we took the first steps towards this by launching our 'Biodiversity measurement framework', further aligning our efforts with global public policy targets like the Global Biodiversity Framework.

Biodiversity measurement framework and approach

A key outcome of our biodiversity programme has been the development of our 'Biodiversity measurement framework', which will ensure that we can capture all potential impacts and risks to biodiversity and ecosystems when developing new renewable energy projects starting from 2024 and thus avoid the majority of impacts and risks to our operations.

By following the steps of our new measurement framework, conducting environmental assessments, implementing appropriate mitigation measures, and applying our 'Biodiversity policy', we will be able to avoid any impacts related to the deterioration of biodiversity or natural habitats within our own operations.

We adhere to the mitigation hierarchy in the development of new projects, prioritising to avoid biodiversity impacts wherever feasible. For impacts that cannot be entirely avoided, we focus on minimising and mitigating them to the extent possible. An example of this is avoiding sensitive habitats during the routing of and installation of cables for offshore projects. Post construction, any residual impacts that could not be fully mitigated are addressed through species-specific or habitat-specific restoration. These efforts aim to restore biodiversity and habitat functioning to at least pre-construction baseline levels and are our measures towards achieving a net-positive impact.

This means that the majority of our impacts on biodiversity occur during the construction phase, and are appropriately mitigated, while during the operational phase, we have very limited impact on biodiversity that we are not able mitigate.

Geographic and value chain scope

The 'Biodiversity policy' addresses the direct impacts from our operations on biodiversity, ecosystem protection, and sustainable ocean practices. The scope of the policy covers all of Ørsted's renewable energy assets, both offshore and onshore, and includes our initial steps towards addressing biodiversity in our value chain and the associated dependencies.

In total, we have 63 operational sites across our portfolio of renewable energy assets (i.e. offshore and onshore wind, solar PV, and power stations) that currently overlap with or are adjacent to protected areas or KBAs. This is the majority of our assets and is connected to the fact that a buffer zone has been applied (25 km for offshore assets, 10 km for onshore assets).

We have completed a mapping to help us understand potential negative impacts to biodiversity that we may have in our value chain. We continue to explore ways to identify and mitigate impacts across our value chain, including our first attempt at mapping impacts from high impact commodities (HICs) in our upstream value chain.

Use of TNFD framework

Our continuous work to identify and assess these impacts help us to understand how we can continue to strengthen resilience across our operations, which we also assess using the methodology of the Taskforce on Nature-related Financial Disclosures (TNFD).

Ørsted provides alignment with TNFD recommendations across Governance, Strategy, Risk and impact management, and Metrics and targets (see full alignment table on page 115).

Linkage to nature-related risk assessment

During the project development phase of all our offshore and onshore assets where we are responsible for development, we conduct early risk screenings and develop environmental impact assessments (EIAs) or equivalent plans to assess the potential impacts on biodiversity and ecosystems at the locations of potential new assets. This is then followed by the legally required impact assessment processes, providing data on the biodiversity and ecosystems present at the site location. Based on these findings, we can develop action plans to mitigate our impacts and outline restoration measures. Insights from the early risk screenings inform the biodiversity and ecosystem-related impacts, risks, dependencies, and opportunities identified and assessed in the DMA for sites in our own operations. This process highlights the importance of early assessments at the beginning of each of our projects to avoid and mitigate potential impacts on biodiversity and ecosystems.

We have completed an assessment of all our operational assets in collaboration with The Biodiversity Consultancy, using their Biodiversity Risk Screening Kit (BRiSK). This assessment focused on biodiversity- and ecosystem-related impacts, risks, dependencies, and opportunities at an asset level, helping us to better understand which sites are material in this respect. It takes a variety of factors into account that indicate impacts on biodiversity on a scale ranging from low over medium to high. These factors include species, designated areas (including protected areas and key biodiversity areas (KBAs)), ecoregion intactness, water pollution, and marine habitats, amongst others.

The assessment highlights a list of matters, indicating that there are potential negative impacts on biodiversity if nothing is done to avoid or mitigate these. From that output, we have found that the majority of the identified risks have already been identified through our EIA or equivalent processes as well as mitigated as a part of our biodiversity action plans. Therefore, we are taking all necessary steps to limit risks and negative impacts on biodiversity and ecosystems at all our site locations.

Risk assessment conclusions

We have not identified any material dependencies on biodiversity and ecosystems, although soil stability at our sites constitutes the most significant dependency. Regarding our transitional and physical risks, we have mapped out our exposure and have not found significant risks from biodiversity and ecosystems that are not already covered in our mitigation processes and biodiversity action plans.

Additionally, we have not identified any systemic risks to our business model that are not addressed through our established practices or the implementation of measures to reach our biodiversity ambition.

We have not completed an assessment of how systemic risks to society have been considered in the assessment of biodiversity and ecosystems-related risks yet. However, we have begun the work of understanding the correlation of these risks, how they impact our projects, and what we can do to mitigate them.

The assessment of our upstream value chain that was completed in 2022 using the Global Biodiversity Score tool is still relevant today. The results provided an overview of impacts based on our most used materials (incl. minerals and metals) and how each material impacts the environment, focusing on biodiversity. The assessment did not include an assessment of how the biodiversity impacts from our upstream value chain affect local communities, but it did provide an essential first step in our work with the Science Based Targets Network (SBTN) framework and our progress towards being ready to set science-based targets for nature.

Management of vulnerable species and critical habitats

Vulnerable species and critical habitat types are identified during the early screening phase of a project, allowing us to plan our project development around these factors, implementing the mitigation hierarchy and ensuring we are undertaking the actions needed to avoid and mitigate impacts on biodiversity.

When we identify overlaps with e.g. an IUCN Red-listed species, an action plan is developed to ensure that we do no significant harm to this species, nor any threatened species, both during construction and the operational phase.

At an asset level, we prefer to always have a biodiversity action plan in place, which helps us map out our negative impacts and plan out our mitigating actions accordingly. When we identify overlaps with e.g. an IUCN Red-listed species, an action plan is developed to ensure that we reduce harm to this species or any threatened species.

Operational phase impacts

One example of an impact that we are sometimes unable to mitigate during the operational phase of an offshore wind farm, which we have assessed as immaterial, is the collision of airborne mobile species, such as birds or bats, with wind turbine blades. In cases where this impact cannot be mitigated through location or design, operational management plans are put in place, for example through enhanced monitoring campaigns, often in conjunction with local stakeholder groups.

We have found no negative impacts related to land degradation during the operational phase of our projects, including desertification or soil sealing. Any potential impacts on land degradation are mitigated during the construction phase.

Policies related to biodiversity and ecosystems

Biodiversity policy

Ørsted has a 'Biodiversity policy' that was updated in 2024.

Scope:

• Applies to all sites owned and operated by Ørsted, including sites in or near biodiversity-sensitive areas
• Covers all of Ørsted's renewable energy assets, both offshore and onshore
• Includes initial steps towards addressing biodiversity in the value chain and associated dependencies
• Specifically engages with tier 1 suppliers on their progress on working with biodiversity
• Does not currently cover impacts on biodiversity and ecosystems from raw material extraction in the upstream value chain, though Ørsted is committed to working with suppliers through its 'Supply chain sustainability programme' on mitigating their impacts on biodiversity

Policy objective and content:

• Outlines the importance of biodiversity to Ørsted and how biodiversity is a key part of a sustainable project life cycle
• Explains the steps taken to protect biodiversity throughout an asset's life cycle, aiming to avoid potential impacts and risks to biodiversity – from planning and development, through construction, over operation and maintenance, and finally to the decommissioning and potential repowering phases
• Addresses the direct impacts from operations on biodiversity, ecosystem protection, and sustainable ocean practices
• Follows the mitigation hierarchy: avoid harmful action at the outset, minimise impacts, and take restorative measures where impacts cannot be avoided; compensate for any residual adverse impacts that cannot be restored (while recognising that certain environmental features are irreplaceable)

Governance:

• Accountability of the policy lies with the Chief Commercial Officer (CCO)
• The policy includes an overview of the governance structure to support its implementation
• Includes specific third-party standards that support the work, e.g. the EU taxonomy for sustainable economic activities

Implementation and stakeholder engagement:

• Biodiversity management is integrated into the business model and decision-making processes throughout the full life cycle of projects, from early-stage site selection and planning, over project design, construction, operations, and eventually to decommissioning
• Local communities, NGOs, and academia are included in stakeholder engagement steps during the various phases of an asset's life cycle
• Indigenous knowledge is integrated in the new 'Biodiversity measurement framework' and will be incorporated going forward

Public availability: Not explicitly stated in the excerpts.

Link to international standards:

• The policy references the EU taxonomy for sustainable economic activities

Monitoring:

• In 2024, Ørsted launched a biodiversity measurement framework to measure, track, and report both positive and negative impacts on biodiversity
• The framework is science-based and contributes to the achievement of Ørsted's biodiversity ambition
• The scope covers biodiversity activities for own operations across all geographies
• Continuous monitoring across biodiversity pilot projects is in place
• Ørsted has completed the first two of five steps of the Science Based Targets Network (SBTN) methodology to better understand how to prioritise efforts in managing impacts on nature, including biodiversity

Supply chain sustainability programme

While not a standalone biodiversity policy, Ørsted's 'Supply chain sustainability programme' addresses biodiversity impacts in the value chain.

Scope:

• Ørsted engages with tier 1 suppliers on mitigating their impacts on biodiversity
• Currently engages with tier 1 suppliers; further tiers down in the value chain remain more challenging

Content:

• Supplier dialogues on biodiversity impacts
• Continued work towards a more sustainable supply chain
• Aim to implement mitigating actions for biodiversity in the supply chain in the future

Actions and resources related to biodiversity

Launching our biodiversity measurement framework

Description: In 2024, Ørsted publicly launched its biodiversity measurement framework – a science-based framework to measure, track, and report both positive and negative impacts on biodiversity.

Scope: Own operations across all geographies

Time horizon: Launched 2024, supports 2030 net-positive ambition

Resources allocated: Collaboration with the World Economic Forum (WEF) to launch the Responsible Renewables Infrastructure initiative (RRI). First version of impact pathway initiatives expected to be completed in 2025.

Expected outcomes:

• Allows setting baselines for priority biodiversity features for upcoming assets
• Provides means to effectively measure net gains and losses on biodiversity
• Contributes to achieving biodiversity ambition of net-positive impact from all new renewable energy projects commissioned from 2030 onwards

Link to policy/target: Directly supports the 2030 net-positive biodiversity ambition and the 'Biodiversity policy'

Piloting net-positive solutions

Description: Global portfolio of innovative biodiversity projects demonstrating a wide range of ideas to enhance nature.

Scope: Own operations, global portfolio

Time horizon: Ongoing, with specific pilots progressing in 2024-2025

Resources allocated: Non-financial resources including partnerships with:

• Wageningen University (Netherlands, for cod pipes research)
• Research and development for coral cultivation (Taiwan)
• Technology development partners for noise reduction technology

Specific projects:

1. Taiwan coral cultivation

• Cultivating corals in labs since 2021 to grow on offshore wind turbines
• Finalised preparations in 2024 and ready to deploy first ones in 2025 at Greater Changhua 1 Offshore Wind Farm

2. Borssele cod pipes (Netherlands)

• Placed cod pipes to simulate reefs in 2022
• Published research paper in 2024 (with Wageningen University)
• Found to be highly successful in improving local cod population

3. Noise reduction technology for offshore wind foundations

• New method to install offshore wind foundations, reducing noise levels by up to 99%
• Represents one of the greatest advancements in protective measures for marine life
• Successfully tested in Germany at Gode Wind 3 offshore wind farm
• Expected to be industrialised in 2030
• Once industrialised, will provide more efficient and cost-effective installation

Expected outcomes:

• Proof of effectiveness of biodiversity enhancement initiatives
• Significant reduction in temporary negative impacts during construction
• Valuable learnings to achieve net-positive ambition

Link to policy/target: Supports net-positive biodiversity ambition from 2030 and 'Biodiversity policy'

Humber Estuary restoration project (UK)

Description: Coastal ecosystem restoration project contributing to carbon sequestration and natural habitat restoration.

Scope: Own operations, UK

Time horizon: Completed in 2024

Resources allocated:

• Partnership with Yorkshire Wildlife Trust
• Partnership with Lincolnshire Wildlife Trust
• Community engagement and collaboration

Expected outcomes:

• Carbon sequestration through nature-based solution
• Restoration of natural habitat to improve biodiversity
• Local community engagement in biodiversity actions

Link to policy/target: Supports 'Biodiversity policy' and positive impact opportunity related to biodiversity restoration, research, and innovation initiatives

Science Based Targets Network (SBTN) methodology

Description: Completed first two of five steps of SBTN's methodology to better understand how to prioritise efforts in managing impacts on nature, including biodiversity.

Scope: Own operations and upstream value chain

Time horizon: Ongoing, first two steps completed in 2024

Resources allocated: Non-financial resources for methodology implementation and analysis

Process steps completed:

• Step 1: Initial assessment to locate impacts on nature (including biodiversity) across upstream value chain and direct impacts
• Step 2: Prioritise top impacts to assess which to work towards setting science-based targets for

Expected outcomes:

• Setting time-bound science-based targets for nature and biodiversity
• Enhanced understanding of priority impacts across value chain

Link to policy/target: Will support future target-setting for biodiversity beyond 2030 net-positive ambition

Biodiversity Action Plans at asset level

Description: Implementation of biodiversity action plans at all assets to map and mitigate negative impacts.

Scope: Own operations, all assets (63 operational sites, 12 under construction in 2024)

Time horizon: Ongoing throughout asset life cycle (planning, construction, operation, decommissioning)

Resources allocated:

• Environmental Impact Assessments (EIAs) at all sites where Ørsted is responsible for development
• Early risk screenings during project development phase
• Species-specific and habitat-specific restoration measures
• Enhanced monitoring campaigns
• Collaboration with local stakeholder groups

Management approach:

• Follow mitigation hierarchy: avoid, minimise, restore, compensate
• Example: avoiding sensitive habitats during cable routing and installation for offshore projects
• When overlaps with IUCN Red-listed species identified, action plan developed to ensure no significant harm
• Operational management plans (e.g. enhanced monitoring) where impacts cannot be mitigated through location or design

Expected outcomes:

• No negative impacts on biodiversity at operational sites through effective mitigation
• Residual impacts addressed through restoration to at least pre-construction baseline levels
• Measures towards achieving net-positive impact

Link to policy/target: Implements 'Biodiversity policy' and mitigation hierarchy; supports 2030 net-positive ambition

Engagement with tier 1 suppliers on biodiversity

Description: Engaging with tier 1 suppliers on their progress on working with biodiversity and mitigating their impacts.

Scope: Upstream value chain

Time horizon: Ongoing

Resources allocated: Supplier engagement through 'Supply chain sustainability programme'

Expected outcomes:

• Mitigation of biodiversity impacts in upstream value chain
• Improved supplier performance on biodiversity

Link to policy/target: Supports 'Biodiversity policy' scope covering value chain and dependencies

Community benefit fund (UK)

Description: Launched community benefit fund distributing up to GBP 7 million over ten years to invest in the region's future.

Scope: Affected communities, UK

Time horizon: 10 years (2024-2034)

Resources allocated:

• Financial: GBP 7 million over 10 years
• Non-financial: Advisory panel formed of local representatives

Expected outcomes:

• 21 social and environmental groups selected in 2024 as first recipients
• Investment in local social and environmental benefits

Link to policy/target: Supports broader sustainability objectives and stakeholder engagement

Assessment pilots to measure community engagement effectiveness

Description: Completed three different pilots to measure the effectiveness of local social value delivered.

Scope: Affected communities

Time horizon: Completed in 2024

Expected outcomes:

• Results will help target investments to areas that drive greatest local benefits
• Optimised impact of community engagements

Business for Nature (BfN) approval

Description: Ørsted's broader nature strategy approved by Business for Nature, making Ørsted one of the first 25 companies globally to receive this approval.

Scope: Company-wide nature strategy

Time horizon: Strategy launched and approved in 2024

Expected outcomes:

• Recognition as leader in nature-positive approaches
• Alignment with global best practices

Link to policy/target: Validates overall approach to biodiversity and nature

Construction phase mitigation measures

For the 12 assets under construction in 2024 (9 offshore wind, 3 solar PV) with temporary material impacts:

Offshore wind sites:

• Manage impacts from monopile piling (noise pollution)
• Manage impacts from cable laying (disruption to benthic and intertidal habitats)
• Manage impacts from increased vessel traffic (noise pollution)

Solar PV sites:

• Manage impacts from land clearing and cable laying (habitat disruption, species displacement)
• Manage impacts from machinery operation (noise pollution)

Scope: Own operations at construction sites in Germany, US, and Taiwan

Resources allocated: Measures agreed through impact assessment and permitting processes

Expected outcomes: All impacts appropriately managed or mitigated during construction phase

Link to policy/target: Implements 'Biodiversity policy' and mitigation hierarchy

Targets related to biodiversity and ecosystems

Biodiversity ambition

In 2021, Ørsted adopted an ambition to achieve a net-positive biodiversity impact from all new renewable energy projects that are commissioned from 2030 onwards.

Progress:

• The company is on track to meet this ambition with the launch of its biodiversity measurement framework in 2024, which allows it to start setting baselines for priority biodiversity features for upcoming assets and providing the means to effectively measure net gains and losses on biodiversity.

Target status:

• Currently, Ørsted has not adopted any targets for biodiversity that follow the mandatory minimum disclosure requirements defined in ESRS 2.
• The company is in the process of utilising the methodology from Science Based Targets Network (SBTN) to map out where its main impacts are across its own operations and upstream value chain on nature (with a broader scope beyond biodiversity).
• Once this work is complete, the company will proceed with setting targets for biodiversity.

SBTN methodology progress:

• Ørsted has completed the first two of the five steps of SBTN's methodology:
  • Step 1: Locating impacts on nature, including biodiversity, across upstream value chain
  • Step 2: Locating impacts on nature across operations
  • Step 3 (planned): Measuring a baseline across impacts, which will then be used to set time-bound targets

Scope:

• Own operations across all geographies
• New renewable energy projects commissioned from 2030 onwards

Impact metrics related to biodiversity and ecosystems change

Land use and site locations

Ørsted has 63 operational sites across its portfolio of renewable energy assets (offshore and onshore wind, solar PV, and power stations) that currently overlap with or are adjacent to protected areas or key biodiversity areas (KBAs). These overlaps are identified using a buffer zone of 25 km for offshore assets and 10 km for onshore assets.

Through mitigation planning and restoration of impacts, Ørsted reports no negative impacts on biodiversity and ecosystems at these operational sites.

Construction sites in or near protected areas/KBAs (2024)

Ørsted had 12 assets under construction in 2024 with temporary material impacts on biodiversity-sensitive areas:

Total construction footprint (2024): 101,046 hectares (including buffer zones)

Species impacts

Ørsted identifies IUCN Red-listed species overlaps during early screening phases and develops action plans to ensure no significant harm to threatened species during construction and operational phases. Specific species population size impacts or number of Red List species affected are not quantified in the disclosure.

The company notes that construction activities cause temporary displacement of species or, in some instances, loss of species through adverse impacts on foraging, breeding, and wintering areas.

Restoration and positive impact initiatives

Specific hectares restored are not quantified. However, Ørsted reports several biodiversity restoration and enhancement initiatives:

• Humber Estuary restoration project (UK): Coastal ecosystem restoration completed in collaboration with Yorkshire Wildlife Trust and Lincolnshire Wildlife Trust
• Coral cultivation (Taiwan): Corals cultivated in labs since 2021, with first deployment planned for 2025 at Greater Changhua 1 Offshore Wind Farm
• Cod pipes (Netherlands): Installed at Borssele offshore wind site in 2022 to simulate reefs; research published in 2024 showed high success in improving local cod population
• BioReef partnership: Collaboration with DTU Aqua and WWF Denmark to establish biogenic reefs in the Danish North Sea

Accounting methodology

Data covers offshore and onshore wind farms and solar farms as well as their cable routes within buffer zones. Data is recognized from the date of final investment decision (FID), and the area in hectares is shown for the asset in its entirety. The data is sourced from the Integrated Biodiversity Assessment Tool (IBAT) using 25 km buffer zones for offshore assets and 10 km for onshore assets. The tool provides overlaps with protected areas and key biodiversity areas within the project site and buffer zone.

Policies related to resource use and circular economy

Ørsted has adopted three policies to govern resource use and circular economy matters, addressing both upstream impacts related to virgin material use and downstream impacts related to waste generation.

Resource management policy

Objective and content: The policy aims to ensure that Ørsted minimises the use and depletion of virgin resources by developing circular value chains together with suppliers, where feasible, and guides efforts on sustainable sourcing. The policy addresses adherence to the waste hierarchy, prioritising waste avoidance by reducing and reusing before recycling.

Scope: Covers all of Ørsted's activities and locations.

Governance: Responsibility for the resource management policy lies with the senior vice president for the QHSE department.

Purpose: To govern the identified risk and negative value chain impact from using virgin materials.

Sustainable forest biomass policy

Content: Ørsted is committed to continuously improving practices to mitigate any potential negative impacts related to the use of biomass. All biomass sourced for CHP plants must comply with internal procurement strategy requirements.

Application to straw: In addition to biomass, Ørsted uses Danish straw at CHP plants at Studstrup and Avedøre. The straw is a residue from cereal production and complies with EU and national sustainability criteria addressing soil quality, soil carbon storage, and biodiversity. Ørsted is audited yearly by an independent third party to document that straw complies with relevant sustainability criteria.

Waste management policy

Objective and content: The policy outlines waste management processes and provides detailed definitions of key aspects of waste management assurance. It is the steering document for internal way of working with waste and contains detailed guidance on waste handling and data reporting for global waste operations.

Scope: Covers all of Ørsted's activities and locations.

Governance: The QHSE department is responsible for ongoing implementation.

Purpose: To address the negative impact of materials wasted.

Availability: The policy is only accessible internally.

Integration with strategy: Together, these policies address Ørsted's identified impacts and risks relating to both the upstream and downstream parts of the value chain and operations. Actions are closely linked to decarbonisation efforts, given that manufacturing of materials constitutes a key source of GHG emissions.

E5-2 Actions related to resource use and circular economy

To support and obtain the underlying objectives of the policies that we have in place to manage our material resource-related impacts and risks, we are continuously working to identify new actions as well as progressing on the ones we have already commenced. In 2024, our focus has been on the continued development of partnerships and testing of innovative solutions to integrate circularity efforts into our operations. As some of our oldest renewable assets reach their end-of-life stage, we continue to explore and progress on actions related to the avoidance, reduction, and recycling of wasted materials.

Each action listed relates to the identified impacts and risks related to resource use and circular economy but are also closely linked to our decarbonisation efforts and actions as outlined in the ESRS 'E1 Climate Change' chapter, given that the manufacturing of our materials constitutes a key source of GHG emissions.

Key actions related to resource inflows

Associated with our use and depletion of virgin materials impact, we include a quantitative breakdown of the key materials that enter our business through use in our renewable energy assets. This is an important first step in understanding how we can gradually increase the use of secondary materials in our assets.

Working with our key suppliers on increasing secondary materials in our assets

We engage with our key suppliers on decarbonisation matters as part of our supplier engagement and

Targets related to circular economy

Overview

Ørsted has not yet adopted formal targets related to resource use and circularity. The company acknowledges in the E5-3 section:

"Based on our identified impacts and risk related to the matter of resource use and circularity, we have revisited our ways of tracking the effectiveness of our policies and actions in 2024. Our location in the value chain of renewable energy assets implies that we rely heavily on upstream value chain partners to understand and quantify the impact we have, which challenges the foundation for setting measurable, outcome-oriented, and time-bound targets. Consequently, we have not yet adopted a formal target related to our impacts on and risk from resource use and circularity."

Commitments tracked

While no formal quantified targets are disclosed, the company tracks performance on the following commitments:

These are presented as commitments and performance tracking metrics rather than formal time-bound targets.

E5-4 Resource Inflows

Technical Materials for Construction of New Assets

Ørsted discloses resource inflows based on technical materials used in the construction of new offshore and onshore renewable energy projects (offshore wind, onshore wind, solar PV, and battery storage assets) above 100 MW. Material inflows reflect assets currently under construction within the reporting year 2024.

Material Composition Overview

An illustrative example of the material composition for an average Ørsted offshore wind farm shows:

• 63% Steel
• 26% Concrete
• 4% Glass fibre and plastics
• 4% Critical raw materials (3% copper and 1% other materials)
• 3% Iron

Secondary Materials in Steel Production

Approximately 80% of the steel sourced for production of steel plates for foundations comes from Europe, where supplier data indicates that, on average, 35% of the material used in these plates derives from scrap. While Ørsted accounts for geographic variability (reflected in the range of 20-35%), current estimates place the company at the upper end.

Sustainable Biomass

Ørsted sources certified sustainable wooden biomass for use as fuel at CHP plants. In 2024, 100% of wooden biomass was certified sustainable (baseline in 2016: 61%). In addition to wooden biomass, the company uses residual straw sourced from Danish agriculture as a waste product from local farms.

Methodology

The technical materials data is tracked through in-house LCA analysis (highest maturity for offshore assets), supplemented with external verified studies for BESS, solar PV, and onshore wind. Material usage is accounted for when main components are recognised as installed. For offshore wind projects, foundations are recognised when fitted, and wind turbine generators (WTGs) are recognised at time of takeover certification (TOC). For solar assets, materials are mapped to the installation of solar panels. For battery storage systems, materials are recognised upon installation of battery packs.

Resource outflows

Ørsted reported on the recyclability of its renewable energy assets:

Recyclability of offshore wind farms:

• Calculated the recyclability rate of materials embedded in a representative sample of offshore wind farms to understand which materials and components can be processed for recycling upon retirement
• Specific recyclability percentages were not disclosed in the report

Design and end-of-life approach:

• Renewable assets are built of highly durable materials
• Working to ensure reuse and recycling of materials where feasible
• Resource management policy covers developing circular value chains with suppliers
• Strategic approach focused on: (i) using fewer virgin resources, (ii) using resources better and longer, and (iii) recirculating resources upon end of life
• For all projects, developing decommissioning or waste management plans to ensure maximal reuse or recycling at end-of-life in accordance with the waste hierarchy

Specific initiatives:

• In the decommissioning of wind farm Owenreagh 1 in Northern Ireland, turbine towers were sent for reuse while blades were sent to be recycled, reflecting commitment to not send blades to landfill
• Investigating opportunities and partnerships to improve the degree of recyclability of assets while working on actions that allow for replacement of non-recyclable content

Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities

Resource use as part of our wider transition

Our resource use is a key driver not only of GHG emissions, but also of costs, implying that both financial and climate performance are impacted by how we manage our resource use-related impacts and risks. Thus, our ability to measure, track, and report high-quality information related to our resource use and circularity efforts is the focus of this chapter, illustrating our work with resource use, efficiency, sourcing, and treatment at end-of-life.

Waste

Total waste generated (2024):

Waste diverted from disposal:

Waste directed to disposal:

Waste management approach:

Ørsted has a 'Waste management policy' covering all activities and locations. The policy outlines waste management processes and provides detailed definitions of key aspects of waste management assurance. The QHSE department is responsible for its ongoing implementation.

The company follows the waste hierarchy to address the negative impact of materials wasted. Total waste generated increased by 7% from 2023 to 2024, primarily due to an increase in non-hazardous waste. Waste diverted from disposal increased by 11%, while waste directed to disposal decreased by 1%.

As of 2024, 71% of total waste generated was diverted from disposal, with recycling accounting for 51% of total waste. The company is working on actions related to the avoidance, reduction, and recycling of wasted materials as assets reach end-of-life stage.

Policies related to own workforce

Ørsted has disclosed several policies covering own workforce matters, aligned with international human rights and labour standards.

Global Human Rights Policy

Key content:
This policy aligns with the UN Guiding Principles on Business & Human Rights (UNGPs), the OECD Guidelines for Multinational Enterprises, the International Bill of Human Rights, and the ILO Declaration on Fundamental Principles & Rights at Work. It explicitly highlights dedication to ensuring freedom of association, the right to collective bargaining, the elimination of forced, trafficked, or compulsory labour, the effective abolition of child labour, and the elimination of discrimination in employment and occupation, among other critical issues.

Scope:
Covers all employees across Ørsted's global operations.

Governance and oversight:
Accountability for this policy rests with the Chief Operating Officer (COO). The Board of Directors has approved this policy. It is available for all employees on the company intranet and many policies are also available at orsted.com.

Monitoring:
Policy monitoring is generally conducted through external risk ratings, controversy reports, and adherence to the minimum safeguards of the EU taxonomy for sustainable activities, which are also subject to limited assurance by external auditors.

International standards:
Aligned with UNGPs, OECD Guidelines for Multinational Enterprises, International Bill of Human Rights, and ILO Declaration on Fundamental Principles & Rights at Work.

Global Labour and Employment Rights Policy

Key content:
This policy articulates Ørsted's commitments to actively safeguard labour, employment, and human rights standards within its own workforce, as described in relevant legislation as well as in the International Bill of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work. The policy covers social dialogue and collective bargaining agreements, respect for employees' rights to freedom of association and to join or refrain from joining labour unions and workers' councils without fear of discrimination, harassment, intimidation, retaliation, or violence in accordance with national laws. Where the right to freedom of association and collective bargaining is restricted or prohibited under national law, Ørsted will not hinder employees from developing alternative mechanisms to express their grievances and protect their rights regarding working conditions and terms of employment.

Scope:
All employees globally.

Governance and oversight:
Approved by the Board of Directors. Available for all employees on the intranet.

International standards:
Aligned with International Bill of Human Rights and ILO Declaration on Fundamental Principles and Rights at Work.

Global Working Hour Commitment

Key content:
Describes maximum working hours across jurisdictions with inspiration from UN Global Compact guidelines.

Scope:
All employees globally.

Governance and oversight:
Board of Directors approved. Accountability rests with People & Culture organisation.

Monitoring:
In 2024, Ørsted initiated activities to support people leaders with enhanced and easier accessible data and analytics to promote ongoing monitoring of sustainable working hours in compliance with individual employment terms, local laws, and the global working hour commitment. Several geographies have started to track recorded time using analytics products; these will be expanded to all geographies in 2025.

International standards:
Inspired by UN Global Compact guidelines.

Global Guidelines on Flexible Workplace

Key content:
The policy supports Ørsted's ambition to make Ørsted an increasingly flexible workplace. The Group Executive Team provides direction and support to work in a flexible and inclusive manner, and people leaders and employees are empowered to successfully manage flexible working plans.

Scope:
Global employees, supplemented by country-specific guidelines to comply with local requirements and regulation.

Governance and oversight:
Approved by the Board of Directors. Owned by People & Culture organisation, with the Chief HR Officer overall accountable.

Global Parental Leave Policy

Key content:
Introduces global minimum standards on parental leave entitlement: 18 weeks for primary caregivers and 12 weeks for secondary caregivers, irrespective of gender or marital status. Also offers various other paid or unpaid family-related leaves according to country provision, local market practice, and potential collective bargaining agreements.

Scope:
All employees globally.

Governance and oversight:
Owned by People & Culture organisation, with the Chief HR Officer overall accountable. Board of Directors approved.

Global Policy for Quality, Health, Safety, and Environment (QHSE)

Key content:
Sets standards for protecting and ensuring the well-being of employees and the sustainability of operations. Ørsted aims to incorporate quality, health, safety, and environment in all decisions and actions, and has implemented workplace accident prevention procedures to ensure the safety and well-being of employees. All (100%) of employees are covered by this health and safety management system. Ørsted complies with various ISO standards, including ISO 9001 (quality management system), ISO 14001 (environmental management system), and ISO 45001 (occupational health and safety management system).

Scope:
Covers all employees and facilities.

Governance and oversight:
Accountability rests with the Head of QHSE. Board of Directors approved. Available for all employees on intranet.

Monitoring:
Health and safety performance is discussed frequently at all levels of the organisation, including within the Board of Directors, Group Executive Team, QHSE Committee, and by local works councils and cooperation committees. Frequent health and safety reports are shared internally, weekly incident updates are communicated, dashboards are constantly updated, and a list of top QHSE enterprise risks and a dynamic risk register are ongoingly updated and monitored.

International standards:
ISO 9001, ISO 14001, ISO 45001.

Internal Policy on Mental Well-being

Key content:
Focuses on enhancing the mental well-being of the workforce, mitigating mental strain such as work-related stress and anxiety, and providing guidance to employees and leaders on addressing these concerns. Ørsted offers employees health insurance, including access to psychologists and other mental health professionals and crisis counsellors, as well as support on topics such as stress, relationships, family issues, and lifestyle management.

Scope:
All employees.

Governance and oversight:
Accountability rests with the Chief HR Officer.

Monitoring:
In 2024, several activities were implemented to improve mental well-being, including development of new well-being tools and guidelines, relaunch of the tool 'Howdy', and roll-out of well-being seminars for people leaders. Several local initiatives were also completed in 2024.

Global Diversity and Inclusion Policy

Key content:
Emphasises equal opportunities for all employees at Ørsted. The policy specifically calls out identities such as ethnic background, race, religion, age, gender, disability, sexual orientation, outlook, or social status because these groups have been historically marginalised or disadvantaged (protected characteristics). Key contents include: 'Women in management' (working towards increasing the share of women in executive and managerial positions); 'Sexual orientation and gender identity' (Ørsted adopted the UN's LGBTI Standards of Conduct for Business in 2018); 'Nationality' (aiming to create an inclusive environment that attracts and retains talented people from all backgrounds and cultures); and 'Recruitment' (all people leaders are equipped with non-discriminatory tools and guidelines for objective recruitment to mitigate unconscious bias).

Scope:
All employees globally.

Governance and oversight:
Accountability rests with the Chief HR Officer. Board of Directors approved. Available for all employees on intranet.

International standards:
Aligned with UN LGBTI Standards of Conduct for Business.

Global Bullying, Harassment, and Discrimination Policy

Key content:
Supplemented by country-specific guidelines (which often include mandatory training), and supported by a global employee guide and a global people leader guide on how to create an inclusive culture, outlining proactive measures to prevent bullying, discrimination, and harassment. The policy covers situations where an employee feels subject to bullying, discrimination, or harassment from another employee or from an external consultant working under Ørsted supervision. It describes acts of bullying, discrimination, and harassment in the workplace and covers the following grounds for discrimination: sex, race, nationality, sexual orientation, gender identity, religion, size, ability status, pregnancy status, age, ethnic origin, belief, and marital status. Also includes a statement on non-retaliation.

Scope:
All employees globally.

Governance and oversight:
Accountability rests with the Chief HR Officer. Board of Directors approved.

Monitoring:
Monitored through the People Matter survey and through case handling.

Grievance and Complaints Handling Policy

Key content:
Outlined within the Global Labour and Employment Rights Policy. Employees have the right to make a complaint or raise a grievance without fear of retaliation. All concerns and complaints raised to People & Culture are taken seriously and handled confidentially to the extent possible. Employees can use various mechanisms for raising concerns or complaints: going to their direct people leader, reaching out to the People & Culture organisation via an HR business partner or a local representative, or using the Whistleblower Hotline.

Scope:
All employees globally.

Governance and oversight:
Part of the Global Labour and Employment Rights Policy, accountable to People & Culture organisation.

Monitoring:
The Audit & Risk Committee receives quarterly overviews of all inappropriate and illegal misconduct cases across jurisdictions. A dedicated team in People & Culture sends Internal Audit an anonymous global overview. A dedicated system is used to confidentially report on cases, ensuring country-by-country access protection and only to authorised employees. For GDPR compliance, all data on employee cases are anonymous. In 2024, there were 5 substantiated cases of discrimination, including harassment. In 2024, there were zero severe human rights incidents connected to employees.

Sustainability Commitment

Key content:
Outlines Ørsted's commitment to upholding human rights.

Scope:
Global operations and workforce.

Governance and oversight:
Board of Directors approved.

Stakeholder Engagement Policy

Key content:
Guided by principles of openness, transparency, and integrity. Adheres to international norms and codes, including the UN Guiding Principles on Business & Human Rights, the UN Declaration on the Rights of Indigenous Peoples, and the IFC Performance Standards on Social & Environmental Sustainability. Ensures that the views and interests of affected stakeholders regarding sustainability-related impacts, risks, and opportunities are regularly communicated to the relevant accountable person in the Group Executive Team through periodic meetings.

Scope:
Covers engagement with own workforce among other stakeholder groups.

Governance and oversight:
Chief Commercial Officer (CCO) is accountable for implementation. Board of Directors approved. Available at orsted.com.

International standards:
Aligned with UNGPs, UN Declaration on the Rights of Indigenous Peoples, IFC Performance Standards on Social & Environmental Sustainability.

Just Transition Policy

Key content:
Ensures that adequate management systems are in place to identify, prevent, mitigate, and remedy any potential adverse human rights impacts, with a focus on ensuring a just transition to renewable energy.

Scope:
Global workforce and value chain.

Governance and oversight:
Chief Commercial Officer (CCO) is accountable for implementation. Board of Directors approved.

International standards:
Aligned with UN Global Compact (UNGC) and ILO Declaration on Fundamental Principles and Rights at Work.

Code of Conduct (for employees)

Key content:
Incorporated in mandatory e-learning that includes guidance on the grievance and complaints handling policy.

Scope:
All employees.

Governance and oversight:
Board of Directors approved.

Monitoring:
Code of conduct training is mandatory for all employees.

S1-2 Processes for engaging with own workforce and workers' representatives about impacts

At Ørsted, we work actively to ensure a safe and inclusive workplace where all employees can thrive. We engage with the employees through various channels and have an open and transparent culture. We are focused on development of our employees' skills and competences and follow up on the general well-being of employees through performance dialogues at individual level and other measures.

Processes to remediate negative impacts and channels for own workforce to raise concerns

Engagement with employees

At Ørsted, we work actively to ensure a safe and inclusive workplace where all employees can thrive. We engage with the employees through various channels and have an open and transparent culture. We are focused on development of our employees' skills and competences and follow up on the general well-being of employees through performance dialogues at individual level and other measures.

Monitoring and mitigation measures

Work-induced stress

We monitor work-induced stress on an ongoing basis and have several measures in place to mitigate this impact. We have a 'Global working hour commitment', describing our position on working hours.

Voluntary turnover and organizational changes

To address challenges related to organizational restructuring and potential voluntary turnover, we are focused on our internal communication and change management, strengthening our focus on good leadership and mental health and reaffirming our commitment to transparency and the well-being of our workforce.

Health and safety

We have a robust health and safety management system, which is fundamental to us and covers all of our employees and contractors working at our sites. We have a strong safety culture, monitor safety performance on a monthly basis, and include safety targets in bonus schemes.

S1 Own workforce

Our material impacts, risks, and opportunities (IROs)

Working conditions

Flexible working conditions

Positive impact (own operations)

Material IRO description: This positive impact relates to our flexible working culture, creating additionality within the many markets where we operate and particularly in the US and APAC, as our global standards go beyond the norm in many countries outside of Northern Europe.

A flexible working culture, with initiatives to continuously enhance it, is anchored in a strategic decision to keep Ørsted a great place to work. This has a positive impact on our own workforce as it gives employees the agency/autonomy to make the work-life balance decisions that work best for them, their team, and their people leader.

How do we manage the IRO? We work continually to make Ørsted an increasingly flexible workplace. This is part of our ambition to power and create a working environment where everyone can thrive, perform, and grow. This is implemented globally and governed by our internal guidelines on flexible workplace.

Work-induced stress

Negative impact (own operations)

Material IRO description: This negative impact relates to employees experiencing stress at work because they are requested to perform working hours beyond the contractual terms or in other ways experience anxiety and unbalances at work.

Work-induced stress can cause medical treatment and months away from the job.

How do we manage the IRO? We monitor work-induced stress on an ongoing basis and have several measures in place to mitigate this impact. We have a 'Global working hour commitment', describing our position on working hours.

Possible work-related injuries and fatalities

Potential negative impact (own operations)

Material IRO description: This potential negative impact relates to physical work-related injuries and fatalities. Due to the nature of the utility industry, we recognise this potential impact to our employees. It concerns all employees and contractors working at our sites.

Injuries can cause medical treatment and days or months away from the job. This potential negative impact can occur across the short, medium, and long term.

How do we manage the IRO? We have a robust health and safety management system, which is fundamental to us and covers all of our employees and contractors working at our sites. We have a strong safety culture, monitor safety performance on a monthly basis, and include safety targets in bonus schemes.

Increased voluntary turnover

Risk (own operations)

Material IRO description: This risk is a specific 2024 short-term risk and relates to employees potentially leaving the company due to an increase in uncertainties following organisational restructuring.

Although the organisational restructuring was a managed process, such large organisational changes can be a cause of uncertainty and job insecurity, which can trigger employees into leaving the company pre-emptively. This can lead to an increase in the voluntary turnover rate for employees who might choose to pursue other opportunities.

How do we manage the IRO? To address these challenges, we are focused on our internal communication and change management, strengthening our focus on good leadership and mental health and reaffirming our commitment to transparency and the well-being of our workforce.

Equal treatment and opportunities for all

Unequal gender distribution in management

Negative impact (own operations)

Material IRO description: This negative impact relates to the unequal gender distribution we have in leadership roles, where we have a target of 40:60 (women:men). The impact concerns all employees and is particularly linked to the three layers of our target.

If we do not succeed in integrating diversity considerations into our succession planning, promoting a balanced representation of men and women in leadership positions, we will not achieve our gender diversity targets.

How do we manage the IRO? We have a dedicated talent management team to ensure implementation of actions.

This includes e.g. promoting diversity considerations into our succession planning and promoting a balanced representation of men and women in leadership positions.

Management approach

At Ørsted, we work actively to ensure a safe and inclusive workplace where all employees can thrive. We engage with the employees through various channels and have an open and transparent culture. We are focused on development of our employees' skills and competences and follow up on the general well-being of employees through performance dialogues at individual level and other measures.

Our 'Global parental leave policy' goes far beyond the US and APAC norm. For instance, according to a report by New America's Better Life Lab, the median length of leave for fathers in the US is just one week, compared to 11 weeks for mothers. This disproportionate leave highlights the need for more equitable policies, and our approach seeks to address that imbalance by offering substantial leave for all parents, aligning more closely with global best practices.

For our employees in APAC, entitlements such as industry-leading leave and flexible working hours go beyond labour and similar companies' standards. As a testament to this, Ørsted Taiwan has received a special recognition in the form of the 2024 Work-Life Balance Award presented by Taiwan's Ministry of Labor, specifically in consideration of our wide-ranging and industry-leading policies, supporting the work-life balance of our employees. This award is one of the highest Taiwanese recognitions from the Ministry, and it honours Ørsted among 251 other companies, where Ørsted is the only energy company to receive the award twice, with special recognition of our mission to create a greener future, whilst also creating a positive impact for society and employees.

In 2024, Ørsted navigated a rapidly evolving industry landscape, necessitating organisational adjustments, including redundancies, to maintain our competitive edge. While both satisfaction and motivation levels as well as voluntary turnover remain healthy compared to industry benchmarks, the changes have had a noticeable impact on employee satisfaction and motivation and our voluntary turnover trend. This poses a short-term risk of increased voluntary turnover and lower morale, satisfaction, and heightened stress.

To address these challenges, we are focused on our internal communication and change management, strengthening our focus on good leadership and mental health and reaffirming our commitment to transparency and the well-being of our workforce.

All employees in our own workforce are included in the scope of our disclosures. Our own workforce does not include self-employed people or people provided by third-party undertakings, primarily engaged in employment activities. Lastly, due to the nature of our operations and the jurisdictions covering our workforce, we are not at risk of either forced labour incidents or child labour incidents.

Policies

Our commitments to our own workforce as well as employee obligations are outlined via global employee policies, country-specific policies, and employee handbooks.

Through the adopted policies, we describe our commitments and positions in place for our employees as well as obligations expected from employees. The objective and key content per policy is unfolded below. These policies are owned by the People & Culture organisation, with our Chief HR Officer being overall accountable for them. All our policies have been approved by the Board of Directors. They are available for all employees on our intranet, and many of these policies are available at orsted.com.

Regarding specific groups, our global policies are applicable to all Ørsted employees globally, unless the nature of the policy constitutes a limited eligibility scope, such as e.g. our global parental leave applicable for parents or local variances in policies to reflect local legislation or local market practice.

Policies for human and labour rights

Human rights

We see human rights as fundamental principles for protecting people's dignity and ensuring freedom and respect both in our own operations, in the companies with whom we work, and in the communities where we operate. Our commitment to upholding human rights is outlined in our 'Sustainability commitment', 'Global human rights policy', 'Global labour and employment rights policy', 'Stakeholder engagement policy', and 'Just transition policy'.

Our 'Global human rights policy' aligns with the UN Guiding Principles on Business & Human Rights (UNGPs), the OECD Guidelines for Multinational Enterprises, the International Bill of Human Rights, and the International Labour Organisation's (ILO) Declaration on Fundamental Principles & Rights at Work.

The policy explicitly highlights our dedication to ensuring freedom of association, the right to collective bargaining, the elimination of forced, trafficked, or compulsory labour, the effective abolition of child labour, and the elimination of discrimination in employment and occupation, among other critical issues.

Material impacts and risks related to own workforce

At Ørsted, all employees are part of a safe working environment where impacts are identified and managed, including impacts related to physical injuries and well-being of employees. Due to the nature of our industry, we recognise the impact to employees of potential injuries and fatalities, primarily during the construction and operation phases of our assets. Furthermore, we recognise the present impact of work-related stress and anxiety experienced among employees on a global level.

Ensuring transparent and fair working conditions are rooted in our employer value proposition, where fair and competitive rewards and employment terms as well as a flexible working culture, are foundational factors. Our flexible working culture is creating additionality within many of the markets where we operate, and particularly in our US and APAC regions, as our global policies go beyond the norm.

Characteristics of the undertaking's employees

Total headcount and FTE

Employee data is recognised based on records from the Group's ordinary registration systems and is determined as the number of employees at the end of the reporting period. Employees who have been made redundant are recognised until the expiry of their notice period, regardless of whether they have been released from all or some of their duties during their notice period. The number of FTEs is determined as the number of employees converted to full-time equivalents.

Headcount by region

Other countries in 2024: Singapore (18), Korea (14), Spain (9), Vietnam (9), Sweden (7), Norway (4), Japan (1).

Headcount by gender and contract type

Employees on permanent contracts include all employees on permanent, non-time-bound contracts. Employees on temporary contracts include all employees on time-bound contracts. No employees within Ørsted are employed on a non-guaranteed hour basis.

Gender data reflects the binary options of 'male' and 'female' as captured by data systems. Many of these options are based on sex as recorded in official documents and do not fully represent the diversity of gender identities.

Headcount by age group

Gender balance

Ørsted has a gender diversity target of 40:60 (women:men) across three levels: senior directors and above, people leaders, and all employees, to be achieved by 2030.

Employee turnover

The employee turnover rate is calculated as the number of permanent employees who have left the company (excl. divestments) relative to the average number of permanent employees in the financial year.

Additional metrics

Sickness absence is calculated as the ratio between the number of sick days and the planned number of annual working days.

Employment type (full-time/part-time)

Not disclosed in the available excerpts.

Characteristics of non-employees in the undertaking's own workforce

Number of non-employee workers

Ørsted reports on contractor employees in the context of safety metrics but does not provide a comprehensive headcount or FTE breakdown of non-employee workers (contractors, agency workers, self-employed) in its own workforce as required by ESRS S1-7.

Available data on contractor employees (Safety context only)

From the Safety section (page 137):

Scope and methodology notes

From page 133:

• "All employees in our own workforce are included in the scope of our disclosures. Our own workforce does not include self-employed people or people provided by third-party undertakings, primarily engaged in employment activities."

From page 137 (Safety accounting policies):

• "The scoping and consolidation of safety data entails that we include 100% of injuries, hours worked, etc., from all operations where Ørsted is responsible for HSE safety, including the safety of our contractors."
• Hours worked for contractor employees: "For suppliers, the actual number of hours worked is recognised on the basis of data provided by the suppliers, access control systems at locations, or estimates."
• "Contractor employees are considered part of our value chain workers, as defined by the ESRS."

Analysis

Ørsted explicitly states that its own workforce does not include self-employed people or people provided by third-party undertakings primarily engaged in employment activities. The company treats contractor employees as part of its value chain workers rather than its own workforce.

Safety metrics track contractor hours worked (16.8 million hours in 2024), but this does not translate to a headcount or FTE figure, nor does it provide a breakdown by type of non-employee worker (contractor vs agency vs self-employed) as required by ESRS S1-7.

Collective bargaining coverage and social dialogue

Commitments and approach

Ørsted has adopted a 'Global labour and employment rights policy' which articulates the company's commitment to social dialogue and collective bargaining agreements. The company respects employees' rights to freedom of association and to join or refrain from joining labour unions and workers' councils without fear of discrimination, harassment, intimidation, retaliation, or violence in accordance with national laws.

Where the right to freedom of association and collective bargaining is restricted or prohibited under national law, Ørsted will not hinder employees from developing alternative mechanisms to express their grievances and protect their rights regarding working conditions and terms of employment.

Ørsted does not seek to influence mechanisms or activities of employee representatives while they carry out their functions in ways that are not disruptive to regular company operations.

Social dialogue structures

Engagement and employee representation through formal bodies, such as works councils and employment relations representatives, are generally regulated by local legislation or locally agreed with the respective employee representation body. The frequency of engagement includes both regularly recurring meetings and extraordinary ones, summoned to discuss important topics related to the workforce.

In Q1 2024, Ørsted successfully completed its first-ever global employee election for the employee-elected members to the Board of Directors of Ørsted A/S, with participation of employees across the global footprint.

Employees have multiple engagement channels including:

• HR business partners
• Occupational health and safety representatives
• Different local works councils
• Cooperation committees
• Employment relations representatives
• Personal development dialogues

Quantitative coverage

No specific percentage of employees covered by collective bargaining agreements (overall, EEA, or non-EEA) is disclosed.

No specific percentage of employees covered by workers' representatives is disclosed.

Accountability

The overall operational responsibility for engagement via formal representation bodies such as works councils depends on the specific country in scope. In general, this responsibility rests with the Chief HR Officer together with the country manager of the respective country.

For occupational health and safety representatives, the operational responsibility rests with the Head of QHSE.

Gender balance (women:men): 34:66 in 2024, compared to 35:65 in 2023 and 33:67 in 2022. In 2024, 37% of all new hires were women. Gender balance in the Board of Directors and the Group Executive Team: 40% women, 60% men. Gender balance target: 40:60 women:men in our total workforce by 2030.

Social protection

Ørsted provides social protection to employees through global minimum standards and country-specific provisions, covering major life events including sickness, unemployment, employment injury, parental leave, and retirement.

Coverage scope

All employees in Ørsted's own workforce are included in the scope of disclosures. The own workforce does not include self-employed people or people provided by third-party undertakings, primarily engaged in employment activities.

Global policies are applicable to all Ørsted employees globally, unless the nature of the policy constitutes a limited eligibility scope, such as the global parental leave applicable for parents, or local variances in policies to reflect local legislation or local market practice.

Parental leave

Global minimum standards:

• Primary caregivers: 18 weeks
• Secondary caregivers: 12 weeks

The global parental leave policy introduces global minimum standards on parental leave entitlement for all employees, irrespective of gender or marital status. Additional paid or unpaid family-related leaves are offered according to country provision, local market practice, and potential collective bargaining agreements, such as marriage leave, compassionate leave, childcare leave, and nursing care leave.

Illness and severe illness support

Ørsted has made a commitment to offer immediate assistance and financial security to employees facing severe illness, with a focus on facilitating a timely and responsible return to work.

All employees are offered health insurance, including access to psychologists and other mental health professionals and crisis counsellors, as well as support on topics such as stress, relationships, family issues, and lifestyle management.

Unemployment and disability

Aligned with local practices and statutory provisions, basic insurance for unemployment and disability ensures equitable compensation.

Retirement

Retirement benefits are incorporated in the overall remuneration package. Unless local laws dictate otherwise, all employees are enrolled in a pension scheme through their employment at Ørsted.

Scheme type

Social protection is provided through a combination of private schemes (health insurance, pension schemes) and compliance with local statutory provisions (unemployment, disability insurance). Country-specific employee handbooks are compliant with local legislation as a minimum, with Ørsted striving to follow market practice on employment terms and go above and beyond within the areas of flexibility and work-life balance.

Health and safety metrics

Coverage by health and safety management system

All (100%) of Ørsted's employees are covered by the company's health and safety management system, which is fundamental to operations and designed to secure a safe system of work.

Safety metrics

Days lost (S1-14, 88(e))

Not disclosed (phase-in).

Methodology notes

The scoping and consolidation of safety data includes 100% of injuries, hours worked, etc., from all operations where Ørsted is responsible for HSE safety, including the safety of contractors.

The lost-time injury frequency (LTIF) is calculated as the number of lost-time injuries per one million hours worked. LTIF includes lost-time injuries defined as injuries that result in an incapacity to work for one or more calendar days in addition to the day of the incident.

Total recordable injury rate (TRIR) is calculated in the same way as LTIF, but in addition to lost-time injuries, TRIR also includes injuries where the injured person is able to perform restricted work the day after the accident as well as injuries where the injured person has received medical treatment.

Contractor employees are considered part of the value chain workers, as defined by the ESRS.

Permanent disability cases are injuries resulting in irreversible damage with permanent impairment which is not expected to improve. Fatalities are included in both LTIs and TRIs.

Work-life balance metrics

Policies and entitlements

Ørsted has implemented a 'Global parental leave policy' which introduces global minimum standards on parental leave entitlement for all employees:

• Primary caregivers: 18 weeks
• Secondary caregivers: 12 weeks

The policy applies irrespective of gender or marital status.

In addition to parental leave, Ørsted offers various other paid or unpaid family-related leaves according to country provision, local market practice, and potential collective bargaining agreements, including:

• Marriage leave
• Compassionate leave
• Childcare leave
• Nursing care leave

Ørsted has established a global minimum standard of benefits for caregivers, irrespective of gender or marital status.

Quantitative metrics

No quantitative metrics are disclosed for:

• % of employees entitled to family-related leave
• % of entitled employees who took family-related leave (by gender)
• Return-to-work rates after parental leave (by gender)
• Multi-year comparisons

Recognition

Ørsted Taiwan received the 2024 Work-Life Balance Award from Taiwan's Ministry of Labor in recognition of wide-ranging and industry-leading policies supporting work-life balance of employees.

Compensation metrics

Pay gap

Ørsted reports a global gender pay gap of 14% (unadjusted). This figure is calculated based on data from nine countries where Ørsted operates with at least 50 employees: Denmark (49%), Germany (5%), Ireland (1%), Malaysia (9%), the Netherlands (1%), Poland (9%), the UK (15%), Taiwan (2%), and the US (9%).

The gender pay gap of 14% consists of individual gender pay gaps across these countries and reflects that differences in pay between men and women are impacted by differences in gender mix across career levels in the organisation. The share of women in higher-level leadership positions is significantly lower than in the remaining part of the organisation, resulting in average pay for women being lower than average pay for men in most countries.

Ørsted is committed to equal pay and has a constant focus on ensuring equal pay for equal positions and competences in relation to all aspects of salary-relevant processes from hiring to promotion.

Remuneration ratio

The CEO pay ratio for 2024 was 28:1. This ratio is calculated as the CEO's total awarded remuneration (fixed salary, including personal benefits such as company car and telephone, variable salary, and share-based payment at grant value) divided by the median annual base remuneration for all employees who have been employed for at least 12 months (excluding variable pay elements).

In 2024, the methodology for calculating the ratio changed slightly to better align with ESRS requirements, meaning the ratio now relies on the median annual base remuneration of employees.

Climate-related KPIs in CEO remuneration: Part of the remuneration paid to the CEO is based on climate-related KPIs. In 2024, 1.9% of the CEO's total remuneration was ascribed to climate-related KPIs.

Methodology

Gender pay gap methodology: The global gender pay gap is calculated based on individual gender pay gaps within countries where Ørsted has at least 50 employees. For each country, the difference of average pay levels between female and male employees has been calculated and is expressed as the percentage of the average pay level of male employees from that country. Each calculated country-specific ratio has been indexed to present one global gender pay gap. The gender pay gap shows the pay gap between men and women without adjusting for other factors impacting pay levels (e.g., career level and work experience).

The salaries are reviewed annually, and salary increases come into effect on 1 June. Employees who have been employed for 12 months on that date are included in the calculation.

CEO pay ratio methodology: The CEO pay ratio is calculated as the ratio between the CEO's total awarded remuneration and the median annual base remuneration for all employees who have been employed for at least 12 months (excluding variable pay elements). An alternative calculation based on average employee salary can be found in the remuneration report for 2024.

Incidents, complaints and severe human rights impacts

Incidents of discrimination

In 2024, the Audit & Risk Committee received quarterly overviews of all inappropriate and illegal misconduct cases across jurisdictions. This reporting includes incidents of discrimination, including harassment, which totalled 5 substantiated cases in 2024.

A dedicated team in People & Culture is responsible for sending Internal Audit an anonymous global overview. A dedicated system is used to confidentially report on these cases, ensuring country-by-country access protection and only to authorised employees. For GDPR compliance, all data on employee cases are anonymous.

Severe human rights incidents

In 2024, Ørsted had zero severe human rights incidents connected to employees.

Complaints filed through grievance mechanisms

Not disclosed in quantitative terms. The company describes various grievance mechanisms available to employees including:

• Direct people leaders
• People & Culture organisation (HR business partners or local People & Culture colleagues)
• Whistleblower Hotline for confidential reporting

All employees have the right to make a complaint or raise a grievance without fear of retaliation. All concerns and complaints raised to People & Culture are taken seriously and handled confidentially to the extent possible.

Fines, penalties and compensation

Not disclosed.

Status of complaints

Not disclosed in quantitative terms. The company states that cases are either managed or are in process locally, with quarterly reporting to the Audit & Risk Committee, but specific breakdowns by status (open/resolved/under investigation) are not provided.

Methodology note

The company uses a dedicated confidential reporting system with country-by-country access protection. All data on employee cases are anonymised for GDPR compliance. Reporting covers incidents across all jurisdictions and includes both cases that have been managed and those in process.

Targets related to own workforce

Gender balance targets

Ørsted has a gender target of a 40:60 women:men balance across Ørsted by 2030. This target is tracked at three levels:

Target year: 2030

Baseline: The target was set at executive level in 2021 as a strategic pillar. Baseline year not explicitly stated, but 2023 and 2024 progress data are provided.

Scope: All employees globally across Ørsted (own operations)

Type: Absolute percentage targets

Process: The target ensures careful consideration of gender balance when hiring and promoting talent, and when reviewing data on those leaving the organisation. Tracked through a dedicated dashboard available to all employees.

Employee satisfaction target

Target: Employee satisfaction and motivation should be in the top tier (top 25%) compared to external benchmark group

Target year: Not specified (ongoing ambition)

Progress 2024: Index 70 (vs benchmark top 25% of 77 and overall benchmark of 73)

Scope: Own workforce globally

Type: Relative performance target (benchmarked)

Safety target (TRIR)

Target: Total recordable injury rate (TRIR) target established annually

Target 2025: 2.5 injuries per million hours worked

Progress:

• 2023: 2.8
• 2024: 2.7

Scope: Own workforce and contractors working at sites

Type: Absolute rate (injuries per million hours worked)

Process: TRIR targets are proposed by different business areas, validated by the QHSE department, and approved by the Group Executive Team annually in Q4, based on past performance, expected impact of improvement initiatives, and expected level and complexity of activities.

Policies related to value chain workers

Ørsted's commitment to respect human rights, including labour rights, and protect value chain workers is outlined in four key policies: the 'Global human rights policy', 'Stakeholder engagement policy', 'Just transition policy', and 'Code of conduct for business partners'.

Global human rights policy

Key content and principles:

• Explicitly highlights dedication to ensuring freedom of association
• The right to collective bargaining
• The elimination of forced, trafficked, or compulsory labour
• The effective abolition of child labour
• The elimination of discrimination in employment and occupation

Alignment with international standards:

• Aligns with the UN Guiding Principles on Business and Human Rights (UNGPs)
• OECD Guidelines for Multinational Enterprises
• International Bill of Human Rights
• International Labour Organisation's (ILO) Declaration on Fundamental Principles and Rights at Work

Governance:

• The Chief Operating Officer (COO) is accountable for and oversees the implementation
• In practice, the policy is executed by several functions across the Global Stakeholder Relations organisation, including Global Sustainability and Regulatory & Public Affairs departments, regional Corporate Affairs functions, and onsite project staff

Availability:

• Publicly available on the company website
• Shared directly with stakeholders affected by activities or involved in implementation, including business partners
• Easily accessible through the website and other engagement platforms

Monitoring:

• Policy monitoring is conducted through external risk ratings, controversy reports, and adherence to the minimum safeguards of the EU taxonomy for sustainable activities
• Subject to limited assurance by external auditors

Stakeholder engagement policy

Governance:

• The Chief Commercial Officer (CCO) is accountable for implementation

Availability:

• Publicly available on the company website
• Shared directly with stakeholders affected by activities

Just transition policy

Alignment with international standards:

• Aligned with the UN Global Compact (UNGC)
• ILO Declaration on Fundamental Principles and Rights at Work

Governance:

• The Chief Commercial Officer (CCO) is accountable for implementation

Availability:

• Publicly available on the company website
• Shared directly with stakeholders affected by activities

Code of conduct for business partners

Key content and principles:

• Addresses key material impacts and risks related to working conditions and other work-related rights
• Adopted to ensure ethical practices, respect human rights, and promote sustainable employment conditions across the value chain

Scope:

• Covers all workers across the value chain, including those employed by suppliers, contractors, and business partners globally
• Particularly relevant and applicable in regions or industries considered high-risk, such as Asia
• Integrated part of agreements with suppliers and counterparties
• Further integrated in the evaluation process for joint venture partners and other strategic partners

Alignment with international standards:

• Adheres to the OECD Due Diligence Guidance
• Maritime Labour Convention
• IFC Performance Standards
• UN Guiding Principles on Business and Human Rights (UNGPs)
• OECD Guidelines for Multinational Enterprises
• International Bill of Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work

Availability:

• Publicly available on the company website
• Shared directly with business partners

Monitoring:

• Supplier performance evaluated through combination of risk screenings, extended risk screenings, and code of conduct assessments (conducted either via desktop analysis or onsite assessment)
• Assessments may occur both before and after contract signing
• Four-step process: (1) Commitment upon contract signing, (2) Risk screening based on country risk, category risk, and spend, (3) Assessment of adherence to expectations, (4) Improvement plans for identified gaps
• Regular assessments, risk-based audits, and stakeholder engagements to monitor and ensure compliance across the supply chain

Development process:

• Policies shaped with input from industry experts and leading organisations, including the Business and Human Rights Resource Centre
• Company has not engaged directly with value chain workers or their representatives when developing policies
• Ørsted aims to address this by enhancing outreach and dialogue when revisiting and updating global policies

Future governance enhancement:

• Company aims to strengthen governance by designating senior management accountability for these policies

S2-3 Processes to remediate negative impacts and channels for value chain workers to raise concerns

Policy key contents

Our commitment to respect human rights, including labour rights, and protect value chain workers is outlined in our 'Global human rights policy', 'Stakeholder engagement policy', 'Just transition policy', and 'Code of conduct for business partners'.

Our 'Global human rights policy' explicitly highlights our dedication to ensuring freedom of association, the right to collective bargaining, the elimination of forced, trafficked, or compulsory labour, the effective abolition of child labour, and the elimination of discrimination in employment and occupation, among other critical issues.

In addition, our 'Code of conduct for business partners' is an integrated part of our agreements with our suppliers and counterparties. It is further integrated in the evaluation process for our joint venture partners and other strategic partners.

How do we manage the IRO?

We focus on promoting responsible sourcing and respect for labour rights.

We conduct regular supplier assessments, risk-based audits, and stakeholder engagements, enabling us to monitor and evaluate performance relating to working hours across the supply chain and ensure fair working conditions.

We have particular focus on forced labour and supply chain traceability in our due diligence approach.

We conduct regular supplier assessments, risk-based audits, and stakeholder engagements, enabling us to monitor and evaluate our suppliers' conduct.

Taking action on material impacts on value chain workers

Overview of approach

Ørsted's actions to address material impacts on value chain workers are embedded within a comprehensive due diligence approach guided by the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights. The Sustainability Due Diligence & Compliance team ensures that business partners and suppliers adhere to Ørsted's 'Code of conduct for business partners', which sets requirements related to human rights, labour conditions, anti-corruption, and environmental protection.

Scope: Upstream and downstream value chain (suppliers, contractors, business partners globally, with particular relevance in high-risk regions such as Asia)

Governance: Human Rights Task Force oversees integration of due diligence across procurement, operations, and communities. Chief Procurement Officer holds senior operational responsibility for supplier engagement effectiveness.

Key actions undertaken in 2024

1. Human rights training

Description: Delivered human rights training for Marine Inspection team and QHSE site representatives, emphasising appropriate working conditions and addressing bullying, discrimination, harassment, and excessive working hours.

Scope: Own operations and value chain workers at project sites

Time horizon: 2024 implementation; expansion planned by 2025 to include all QHSE site representatives

Expected outcomes: Workers not subjected to undue stress; violations promptly detected and rectified

Link to policy: 'Global human rights policy' and 'Code of conduct for business partners'

2. Safety monitoring practices and training

Description: Concentrated on health and safety standards, delivering training for wind turbine technicians and offshore workers to reduce risk of injuries and fatalities. Conduct regular inspections of supplier performance focused on adherence to safety protocols.

Scope: Value chain workers (contractors, suppliers) across offshore and onshore operations

Time horizon: Ongoing; aim to make safety monitoring practices standard throughout all projects by 2025

Expected outcomes: Reduced workplace injuries and fatalities; safe working environments during full life cycles of renewable energy projects

Link to policy: 'Code of conduct for business partners'

3. Blockchain technology pilot project

Description: Implemented blockchain technology pilot project to track copper usage at Hornsea 2 offshore wind farm, improving visibility into copper sourcing to identify and address supply chain risks related to forced labour and other social/environmental risks related to copper mining.

Scope: Upstream value chain (minerals supply chain)

Time horizon: 2024 pilot; plan to extend from copper to other key materials (such as steel) in coming years

Expected outcomes: Enhanced traceability and accountability; improved ability to identify forced labour and human rights risks

Link to policy: 'Global human rights policy'; 'Code of conduct for business partners'

4. Partnership with Worker Welfare Group

Description: Participation in industry partnership focused on labour rights and worker welfare requirements within the marine construction sector. The group developed principles and guidelines to support Singapore marine construction sector in meeting international standards for worker rights, focusing on responsible recruitment, improved accommodation, better transport, and improved access to grievance mechanisms.

Scope: Upstream value chain (marine construction sector)

Time horizon: Ongoing partnership in 2024 and beyond

Resources: Partnership/collaboration (non-financial)

Expected outcomes: Systemic improvements in worker welfare; access to remedy for workers

Link to policy: 'Global human rights policy'

5. Engagement in International Responsible Business Conduct (IRBC) Agreement

Description: Collaboration with wind developers and industry partners through the IRBC Agreement for the Renewable Energy Sector to address risks and impacts to workers' rights in minerals and metals supply chains. Conducted maturity assessment against OECD guidelines; Ørsted recognised as industry leader.

Scope: Upstream value chain (minerals and metals supply chain)

Time horizon: 2024 and ongoing

Resources: Partnership/collaboration (non-financial)

Expected outcomes: Enhanced responsible business conduct; improved worker conditions in minerals/metals supply chains

Link to policy: 'Global human rights policy'; alignment with OECD Guidelines

6. Supplier engagement and procurement strategy

Description: Close engagement with high-impact suppliers (representing over 50% of total procurement spend) to drive integration of decarbonisation, resource use, and circularity into their strategies and operations. Extended expectations to adopt science-based targets (through SBTi), provide transparent climate reporting (through CDP), and transition to renewable electricity. Introduced climate requirements into standard contracts and tender criteria for selected high-impact segments.

Scope: Upstream value chain (key suppliers representing carbon-intensive supply chain segments)

Time horizon: Ongoing initiative; intended to establish firm set of circularity-related supplier requirements within 4-5 years

Resources: Dedicated organisational set-up for sustainable procurement (non-financial)

Expected outcomes: Supplier adoption of science-based targets; improved working conditions; reduced emissions; enhanced supply chain resilience. Number of key suppliers engaged has nearly doubled since strategy implementation.

Link to policy: 'Code of conduct for business partners'; climate targets (SBTi-validated)

Due diligence processes and corrective actions

Risk screenings and assessments: Perform risk screenings and code of conduct assessments to ensure business partners meet requirements. Process involves:

1. Commitment: Suppliers sign code of conduct upon contract
2. Risk screening: Prioritise business partners based on country risk, category risk, and spend
3. Assessment: Desktop reviews and interviews conducted by internal team or external auditors with local expertise
4. Improvement: Collaborate with suppliers on corrective action plans; regular follow-ups; right to terminate relationships for intentional failures or repeated neglect

Scope: All business partners and suppliers globally

Governance: Sustainability Due Diligence & Compliance team; improvements to evaluation of due diligence process implemented in 2024; optimisation planned for 2025 implementation

Partnerships: Collaborations with Initiative for Responsible Mining Assurance (IRMA), Ethical Trade Denmark, WindEurope, and IRBC Agreement for Renewable Energy Sector

Grievance mechanisms and remedy

Whistleblower Hotline: Value chain workers have access to Ørsted Whistleblower Hotline to confidentially report inappropriate or illegal conduct.

Time horizon: Working to establish global methodology for grievance management; plan to pilot grievance reporting channel for select supplier via digital solution by 2025

Expected outcomes: Standardised process for receiving, addressing, resolving, and providing remedies to value chain workers; enhanced awareness and trust in mechanisms

Link to policy: 'Good business conduct policy'; 'Whistleblower policy'; 'Code of conduct for business partners'

Targets related to value chain workers

Currently, we have not set time-bound and outcome-oriented targets that meet the criteria for effectively reducing negative impacts, advancing positive impacts, or managing material risks and opportunities related to value chain workers. However, we recognise the importance of establishing robust targets to drive meaningful progress in these areas.

We are working to establish a clear process that will involve engaging directly with value chain workers, their representatives, or credible proxies. In the meantime, we are focused on gathering data and assessing current practices to ensure that future targets are effective and aligned with stakeholder needs. We are not yet fully able to monitor how effectively our policies and actions address our material sustainability-related impacts and risks for workers in the value chain.

Policies related to affected communities

Ørsted has established four key policies that are relevant to affected communities, with specific provisions addressing Indigenous Peoples' rights, local communities' economic, social, and cultural rights, and engagement processes.

Global human rights policy

Key content and principles:

• Includes specific provisions to respect Indigenous land rights, cultures, and traditional practices
• Commits to engaging with Indigenous communities early in the planning process of renewable energy projects
• Ensures Indigenous input is considered and incorporated into project design and implementation
• Honours the principles of free, prior, and informed consent (FPIC) as fundamental to the engagement strategy
• Addresses key material impacts and risks related to Indigenous Peoples' rights and local communities' economic, social, and cultural rights

Scope:

• Covers operations and value chain
• Particularly relevant to specific regions such as the US and Australia where obtaining consent from Indigenous communities is significant

Governance:

• For governance information, refer to ESRS 'S2 Workers in the value chain' on page 140

Alignment with international standards:

• UN Declaration on the Rights of Indigenous Peoples, including the principles of FPIC
• UN Voluntary Guidelines on the Responsible Governance of Tenure of Land, Fisheries and Forests
• Aligns with relevant internationally recognised guidelines and standards relevant to Indigenous Peoples and other local stakeholders
• For detailed alignment information, see ESRS 'S2 Workers in the value chain' on page 140

Availability:

• See ESRS 'S2 Workers in the value chain' on page 140

Stakeholder engagement policy

Key content and principles:

• Commits to engage with communities
• Aims to go above minimum regulatory requirements regarding engagement with affected communities
• Ensures ongoing dialogue with community stakeholders and local organisations
• Ensures affected communities' voices are heard and considered in decision-making processes

Scope:

• Covers operations and value chain
• Certain aspects are especially relevant to specific regions

Governance:

• For governance information, refer to ESRS 'S2 Workers in the value chain' on page 140

Alignment with international standards:

• For alignment information, see ESRS 'S2 Workers in the value chain' on page 140

Availability:

• See ESRS 'S2 Workers in the value chain' on page 140

Just transition policy

Key content and principles:

• Adopted to prevent, mitigate, and remediate potential negative impacts on local communities near operations and value chain
• Addresses key material impacts and risks related to local communities' economic, social, and cultural rights

Scope:

• Covers operations and value chain
• Certain aspects are especially relevant to specific regions

Governance:

• For governance information, refer to ESRS 'S2 Workers in the value chain' on page 140

Alignment with international standards:

• For alignment information, see ESRS 'S2 Workers in the value chain' on page 140

Availability:

• See ESRS 'S2 Workers in the value chain' on page 140

Code of conduct for business partners

Key content and principles:

• Describes the approach to respecting Indigenous Peoples, minorities, and other vulnerable groups in line with international law and standards
• Describes the approach to respecting land rights of legitimate tenure rights holders
• Describes the approach to ensuring the safety and protection of defenders of human rights, the environment, or Indigenous Peoples
• Mandates that business partners take measures to protect environmental and human rights defenders and other interested parties who lawfully exercise their freedom of speech
• Encourages business partners and contractors to adopt similar channels for community engagement

Scope:

• Applies to business partners and contractors

Alignment with international standards:

• UN Declaration on the Rights of Indigenous Peoples, including the principles of FPIC
• UN Voluntary Guidelines on the Responsible Governance of Tenure of Land, Fisheries and Forests

Availability:

• See ESRS 'S2 Workers in the value chain' on page 140

Remedy and grievance mechanisms

Approach:

• Commits to provide and enable remedies for potential human rights impacts through accessible grievance mechanisms
• Grievance channels are user-friendly, confidential, and culturally appropriate
• Whistleblower Hotline enables individuals in affected communities to report inappropriate or illegal conduct confidentially
• Upon receiving a grievance, the company promptly investigates and engages with affected parties
• Provides appropriate remedies which may include compensation, restoration of rights, or preventive measures
• Individuals who use grievance mechanisms are protected from retaliation
• All whistleblower reports are handled confidentially, in line with 'Good business conduct policy' and 'Whistleblower policy'

Monitoring implementation:

• Works closely with materially affected communities to monitor issues raised and addressed
• Assesses effectiveness of grievance channels through ongoing dialogue with local stakeholders
• Working to establish a global methodology for aggregating community feedback and grievance management
• Plans to implement a standardised process for receiving, addressing, resolving, and providing remedies
• Responsibility for ensuring effective community engagement lies with local project managers and directors
• Working to improve global governance and oversight by implementing full accountability centrally
• Currently not fully able to effectively assess community engagement efforts, but collects feedback through regular follow-up meetings with community representatives

Interests of key stakeholders

For information about how the company incorporates the perspectives of key stakeholders into policies, see ESRS 'S2 Workers in the value chain' on page 140.

Processes to remediate negative impacts and channels for affected communities to raise concerns

Communities' economic, social, and cultural rights

Pollution from mining may affect communities' health

Potential negative impact (upstream value chain)

Air, soil, and water contamination from mining of minerals and metals may have adverse health effects on local communities living close to manufacturing or mining sites.

Particularly in regions where critical materials are sourced for the technologies we use, communities may face significant negative health impacts from pollution.

This potential negative impact can occur across the short, medium, and long term.

How do we manage the IRO?

We engage directly with impacted communities, listen to their concerns, and provide appropriate remedies to support their well-being and resilience.

We continuously work to strengthen our processes for providing or contributing to appropriate remediation to affected communities.

Rights of Indigenous Peoples

Indigenous Peoples' rights and livelihoods possibly disrespected or disrupted by suppliers

Potential negative impact (upstream value chain)

Indigenous Peoples' rights and livelihoods disrespected or disrupted during development and construction

Negative impact (own operations)

Suppliers and other actors further up in the value chain (e.g. in mining) may disrespect Indigenous Peoples' rights and disrupt their livelihoods. Furthermore, Indigenous Peoples are or can be affected by our development and construction activities or by our suppliers operating on or near Indigenous lands.

Some Native American tribes with traditional or cultural connections to the seabed have expressed dissatisfaction with the consultation process utilised by the federal government.

The potential negative impact in our upstream value chain can occur across the short, medium, and long term.

How do we manage the IRO?

We work to minimise these negative impacts, recognising the importance of protecting Indigenous rights, and we are engaging with affected Indigenous Peoples.

This e.g. takes place through our community liaison officers and project staff, employing different types of interaction, such as public meetings and consultations to facilitate open communication.

Consent of indigenous communities

Risk (own operations)

Failure to ensure consent from Indigenous communities through an adequate free, prior, and informed consent (FPIC) process, which can arise from insufficient engagement by authorities, business partners, or prior stakeholders, amongst others.

Securing the FPIC of Indigenous communities presents a risk, particularly in regions like the US and Australia, where Indigenous Peoples maintain strong cultural and ownership ties to their lands. It can result in project delays, added costs, and strained relationships that may limit future opportunities in these areas.

How do we manage the IRO?

We build trust with Indigenous communities by upholding their rights, committing to FPIC, addressing concerns early, ensuring meaningful engagement, and promoting shared benefits through co-ownership and inclusivity.

Taking action on material impacts on affected communities, and approaches to managing material risks and pursuing material opportunities related to affected communities, and effectiveness of those actions

Communities' economic, social, and cultural rights

Pollution from mining may affect communities' health

Potential negative impact (upstream value chain)

Air, soil, and water contamination from mining of minerals and metals may have adverse health effects on local communities living close to manufacturing or mining sites.

Particularly in regions where critical materials are sourced for the technologies we use, communities may face significant negative health impacts from pollution.

This potential negative impact can occur across the short, medium, and long term.

How do we manage the IRO?

We engage directly with impacted communities, listen to their concerns, and provide appropriate remedies to support their well-being and resilience.

We continuously work to strengthen our processes for providing or contributing to appropriate remediation to affected communities.

Local communities' resistance to and concerns with renewable energy projects

Risk (own operations)

Local community resistance to renewable energy projects – if not proactively addressed – can lead to delays in project timelines, increased costs from operational disruptions, potential legal costs from community lawsuits, and political or reputational risks.

How do we manage the IRO?

We have put a number of mitigation measures in place, including the incorporation of human rights due diligence in early project stages and the launch of a 'Community Impact Programme'.

Increasing local content and social impact requirements in tender processes

Risk (own operations)

Increasing preferences of authorities for local content as opposed to overall social impact in tender processes can pose a risk, as meeting these expectations requires significant engagement and resources which could, in a worst case scenario, lead to economically non-viable business cases for renewable project development.

How do we manage the IRO?

We have developed a people-positive framework and are working with World Economic Forum-led coalitions for socio-economic impact, and we are lobbying local governments to recognise the benefits of it.

Local jobs and educational opportunities

Positive impact (own operations)

We provide education and upskilling programmes to develop competences in renewable energy technologies, which enable community members who may be situated next to our operating sites to gain employment in our projects. We also invest in community infrastructure to enhance public facilities, e.g. ports, roads, and community buildings.

Communities can benefit from socio-economic impacts in terms of the creation of local jobs and educational opportunities as well as an improved standard of living through improvements to public infrastructure when renewable energy assets are constructed near them.

How do we manage the IRO?

We actively work to implement initiatives that foster community development in consultation with communities to best address local needs.

Rights of Indigenous Peoples

Indigenous Peoples' rights and livelihoods possibly disrespected or disrupted by suppliers

Potential negative impact (upstream value chain)

Suppliers and other actors further up in the value chain (e.g. in mining) may disrespect Indigenous Peoples' rights and disrupt their livelihoods. Furthermore, Indigenous Peoples are or can be affected by our development and construction activities or by our suppliers operating on or near Indigenous lands.

Some Native American tribes with traditional or cultural connections to the seabed have expressed dissatisfaction with the consultation process utilised by the federal government.

The potential negative impact in our upstream value chain can occur across the short, medium, and long term.

How do we manage the IRO?

We work to minimise these negative impacts, recognising the importance of protecting Indigenous rights, and we are engaging with affected Indigenous Peoples.

This e.g. takes place through our community liaison officers and project staff, employing different types of interaction, such as public meetings and consultations to facilitate open communication.

Indigenous Peoples' rights and livelihoods disrespected or disrupted during development and construction

Negative impact (own operations)

Indigenous Peoples are affected by our own operations, such as wind or solar farm development. They are particularly vulnerable and face heightened risks of harm due to their cultural heritage and traditional land rights.

How do we manage the IRO?

We work to minimise these impacts, recognising the importance of protecting Indigenous rights, and we are engaging with affected Indigenous Peoples through community liaison officers and project staff, employing different types of interaction, such as public meetings and consultations to facilitate open communication.

Consent of indigenous communities

Risk (own operations)

Failure to ensure consent from Indigenous communities through an adequate free, prior, and informed consent (FPIC) process, which can arise from insufficient engagement by authorities, business partners, or prior stakeholders, amongst others.

Securing the FPIC of Indigenous communities presents a risk, particularly in regions like the US and Australia, where Indigenous Peoples maintain strong cultural and ownership ties to their lands. It can result in project delays, added costs, and strained relationships that may limit future opportunities in these areas.

How do we manage the IRO?

We build trust with Indigenous communities by upholding their rights, committing to FPIC, addressing concerns early, ensuring meaningful engagement, and promoting shared benefits through co-ownership and inclusivity.

Targets related to affected communities

Currently, we have not set time-bound and outcome-­oriented targets that meet the criteria for effectively reducing negative impacts, advancing positive impacts, or managing material risks and opportunities related to affected communities. However, we recognise the importance of establishing robust targets to drive meaningful progress in this area.

We are working to establish a clear community engagement process that will involve engaging directly with the affected communities, their representatives, or credible proxies. In the meantime, we are focused on gathering data and assessing current practices to ensure that future targets are effective and aligned with stakeholder needs. We are not yet fully able to monitor how effectively our policies and actions address our material sustainability-related impacts, risks, and opportunities for affected communities.

Incidents of corruption or bribery

Confirmed incidents

Ørsted reported zero confirmed incidents of corruption or bribery in the reporting period. Specifically, the company stated:

"In 2024, we experienced no convictions and no fines for violation of anti-corruption and anti-bribery laws."

Additionally, in the whistleblower cases summary, the company noted:

"In 2024, 14 substantiated cases of inappropriate or unlawful behaviour were reported through our whistleblower scheme. Ten cases related to good business conduct policy violations, while three cases concerned the workplace environment, and one case was classified as 'other'. None of the reported cases were critical to our business, nor caused adjustments to our financial results. Additionally, no cases required reporting to the police."

Convictions and fines

Zero convictions and zero fines were recorded for violations of anti-corruption and anti-bribery laws in 2024.

Disciplinary actions

The company states that employees who fail to adhere to the Good Business Conduct (GBC) policy may face disciplinary actions, including immediate termination of employment, legal sanctions, and reporting to the police. However, no specific number of employees dismissed or disciplined due to corruption or bribery incidents was disclosed for 2024.

Contracts terminated

No information was disclosed regarding the number of contracts with business partners terminated or not renewed due to corruption or bribery.

Investigation procedures and speak-up mechanisms

Ørsted maintains a comprehensive whistleblower system:

• The Whistleblower Hotline is available for both employees and external stakeholders to report unethical behaviour or wrongdoings confidentially.
• The Chair of the Audit & Risk Committee is responsible for managing the whistleblower scheme.
• Internal Audit receives and handles any reports submitted.
• Whistleblowers who choose to remain anonymous cannot be tracked or identified.
• The system complies with applicable laws and regulations, including GDPR.
• The company has outlined its commitment to protecting whistleblowers against retaliation in its 'Good business conduct policy' and 'Whistleblower policy'.

The Audit & Risk Committee receives quarterly overviews of all inappropriate and illegal misconduct cases across jurisdictions.

Whistleblower cases summary

Political contributions

Ørsted's policy does not allow for in-kind political contributions. Total political influence and lobbying expenditures in 2024 were DKK 46 million, distributed across various regions and beneficiary types, primarily for climate-related advocacy and renewable energy sector support.

Political influence and lobbying activities

Political engagement approach

Ørsted engages in constructive political engagement through lobbying and climate advocacy efforts to promote the accelerated build-out of renewable energy and the goals of the Paris Agreement. The company's global and local Regulatory & Public Affairs teams perform these activities with accountability resting with the Chief Commercial Officer (CCO) and day-to-day oversight performed by the Senior Vice President of Global Stakeholder Relations and Vice President of Regulatory & Public Affairs.

Ørsted's lobbying activities primarily concern regulation of the energy sector with a view to accelerating the deployment of renewable energy in a way that underpins urgent climate action, security of supply, competitiveness, and nature enhancement. The company's main positions on these topics include support for climate policy agenda goals, namely limiting global heating to 1.5 °C as per the Paris Agreement and supporting the expansion of renewables and the phase-out of fossil fuels.

Ørsted's lobbying activities interact with material impacts, risks, and opportunities (IROs) related to climate change mitigation, both by helping to mitigate climate-related transition risks and by helping to leverage material opportunities related to renewable energy deployment.

EU Transparency Register

Ørsted is registered in the EU Transparency Register with identification number 870817015429-80.

Political contributions and lobbying expenditure

Ørsted discloses financial contributions made either directly or indirectly to beneficiaries related to material impacts, risks, and opportunities, which primarily concern climate-related advocacy. External expenses are included, while internal expenses such as salary for employees working within this area of expertise are excluded. The company's policy does not allow for in-kind political contributions.

A threshold of DKK 100,000 has been applied, meaning smaller contributions have not been reported. The data is gathered from invoices through the company's procurement spend data.

Political influence and lobbying activities by region (2024)

Focus areas and main advocacy activities

In 2024, Ørsted's main advocacy activities took place in Europe and the US:

Europe: The company contributed to the European industry associations WindEurope and Green Power Denmark, both significant industry representatives for the renewable energy sector towards policymakers who are important in climate advocacy. Outside Denmark, the main advocacy activities for the wind energy sector took place through contributions to industry associations in the UK, Germany, and the Netherlands.

United States: In the US, Ørsted primarily contributed to the trade association American Clean Power. In addition, the company's political influence and advocacy activities in the US took place through several lobbying firms in different states where the company promotes the accelerated build-out of renewable energy.

Ethical standards and governance

Ørsted does not make political contributions to political institutions. As shown in the table above, expenditure on political institutions is reported as zero (indicated by "-") in all regions.

The company has a zero-tolerance policy for all forms of bribery and corruption, which extends to its political engagement activities. These activities are governed by the company's 'Good business conduct (GBC) policy'.