A.P. Møller - Mærsk

(Section ESRS 2 GOV-1, Corporate governance / ESG governance model) A.P. Møller - Mærsk describes a two-tier structure of a Board of Directors and an Executive Board. The Executive Board comprises Vincent Clerc (CEO) and Patrick Jany (CFO), supported by the Executive Leadership Team. The Board has 10 non-executive members and 0 executive members, with 2 employee representatives, 50% independent members, 30% women and 70% men (30/70 split). Responsibility for ESG and sustainability is anchored with the Board, which endorses the ESG strategy. Three Board committees cover ESG aspects: the ESG Committee (established 2023) oversees strategic ESG direction and meets quarterly; the Audit Committee oversees external ESG reporting, data quality and internal controls, including the CSRD double materiality assessment; and the Remuneration Committee reviews sustainability-linked targets. At executive level, dedicated ELT sponsors are allocated to material ESG categories (for example Rabab Boulos for climate change, Susana Elvira for human capital, Caroline Pontoppidan for business ethics). The Board holds around four teach-in sessions per year, and in 2024 held a dedicated session on CSRD and the DMA with input from an external company and an independent audit firm.

(Section ESRS 2 GOV-2, Corporate governance / ESG governance model) Maersk describes how sustainability information reaches its administrative, management and supervisory bodies. The Board of Directors endorses the ESG strategy, and three Board committees address ESG matters: the ESG Committee acts as a sounding board for the Executive Leadership Team and meets quarterly to discuss selected ESG topics, the Audit Committee oversees external ESG reporting and internal controls, and the Remuneration Committee reviews sustainability-linked incentive targets. At the executive level, the Risk and Compliance Committee (RCC) is the main executive governance forum for ESG and other risk and compliance topics, and its charter was updated in 2024 to strengthen central governance over the strategic ESG categories of climate, safety and diversity, equity and inclusion. ESG progress updates are compiled quarterly for strategic and prioritised targets and KPIs and biannually across all ESG categories, and are overseen at quarterly RCC meetings and, where relevant, discussed with the full ELT. ESG topics are also integrated into Commit, Maersk's internal governance framework, and into the enterprise risk management process, which is overseen by the RCC and the Audit Committee.

(Section ESRS 2 GOV-3, Remuneration report) Maersk reports on the integration of sustainability performance into incentive schemes and states that this information is incorporated by reference and set out in full in the Remuneration Report. The company explains that its long-term incentive plan continues to include ESG targets within the overall executive remuneration structure, reflecting the importance of sustainability alongside financial performance. The strategic ESG categories, which carry the highest level of ambition, are tied to executive remuneration as part of the long-term incentive programme. The ESG Committee approves the ESG KPIs that are part of the long-term incentive programme, and the Remuneration Committee reviews the sustainability-linked targets proposed by the ESG Committee. A subset of Maersk's strategic ESG targets is linked to executive remuneration through the long-term incentive plan. Detailed information on the specific sustainability-linked remuneration, the KPIs used and the remuneration methodology is provided in the Remuneration Report rather than in the sustainability statement.

(Section ESRS 2 GOV-4, Approach to due diligence, page 69) Maersk provides a statement on due diligence and maps its processes to the core elements of due diligence. It states that due diligence is integrated into multiple internal processes and programmes to identify, prevent and mitigate negative impacts arising from its operations and value chain, including supplier management, mergers and acquisitions processes, and requirements embedded in the Commit governance framework. Its long-standing human rights due diligence approach is founded in the company's Purpose and Core Values and based on the UN Guiding Principles on Business and Human Rights, applying a risk-based approach. The disclosure sets out how the elements of due diligence are addressed: embedding responsible business conduct through the Employee and Supplier Codes of Conduct; identifying and assessing adverse impacts through the DMA, informed by the corporate human rights assessment and stakeholder engagement; ceasing, preventing or mitigating impacts through ESG categories and cross-topical programmes; tracking implementation and results against strategic targets, including quarterly ESG updates to the ELT; communicating how impacts are addressed; and providing for remediation when appropriate, with access to remedy noted as a salient human rights issue. Maersk acknowledges it will need to further mature these processes in coming years.

(Section ESRS 2 GOV-5, Corporate governance, page 48) Maersk describes the risk management and internal controls over its integrated (financial and sustainability) reporting. The Board of Directors, the Audit Committee and the Executive Board regularly assess material risks and internal controls associated with the integrated reporting process, including sustainability reporting. During 2024 the company worked to mature its ESG KPIs, focusing on improving and implementing controls to support the completeness and accuracy of reported ESG data. Maersk notes that, as 2024 is the first year of CSRD reporting, the control environment is less mature than for financial reporting. At least once a year, the Board and Executive Board undertake a general identification and assessment of enterprise risks, including fraud risks and sustainability reporting risks, addressing risks of incompleteness and inaccuracy of ESG data through clear definitions, procedures, process maps, risk assessments and internal controls. Specific control activities for integrated reporting risks are defined and implemented for each business segment, including controls over ESG KPIs. Monitoring occurs at different levels, with material weaknesses, omissions and violations reported to the Executive Board, and reports from the Executive Board and Group Internal Audit provided to the Board and Audit Committee, including on ESG reporting.

(Section ESRS 2 SBM-1, Business model page 13 / Strategy page 19 / value chain mapping page 68) Maersk describes itself as an integrated logistics company that connects and simplifies its customers' supply chains, with 100,000+ customers, 100,000+ employees across around 170 nationalities, operating in almost 130 countries. Its business model spans three integrated segments: Ocean (700+ container vessels serving over 500 ports, 12.4m FFE per annum, seven large dual-fuel methanol vessels delivered in 2024), Logistics & Services (8,800k+ sqm warehousing across 500+ sites, 6.8m FFE First Mile volumes) and Terminals (54 operating facilities across 29 countries, 13.1m moves, 13,980+ vessel calls). Value creation is described for customers, people, society, the planet and shareholders. Operational excellence is enabled by ESG, Technology and People, with customer and operational synergies across the three businesses. Maersk states it is a significant emitter of greenhouse gases and is committed to reaching net-zero emissions by 2040 across the entire supply chain. The value chain mapping covers the upstream value chain (shipyards, fuel suppliers, equipment manufacturers, freight forwarders, third-party logistics providers, manning agencies) and the downstream value chain (retailers, manufacturers, freight forwarders, customs and regulatory authorities, port operators and distribution providers), as well as affected communities and value chain workers.

(Section ESRS 2 SBM-2, Stakeholder engagement, pages 70-74) Maersk describes engagement with seven prioritised stakeholder groups: employees, contingent workers and value chain workers; customers; authorities, regulators and standard setters; suppliers and business partners; investors and analysts; local communities and nature; and civil society organisations. For each group the company sets out stakeholder expectations, key engagement channels and how input is used. Channels include daily manager and colleague interactions, engagement and inclusion surveys, grievance mechanisms, union engagement, supplier audits, the Strategic Customer Council, customer satisfaction surveys, earnings calls, roadshows, investor surveys and ESG ratings, and Environmental and Social Impact Assessments. Stakeholder engagement supports identifying existing or emerging impacts and risks as part of the double materiality assessment, and insights are used to shape strategy, targets and decisions. Perspectives raised by investors and customers are presented to the Executive Leadership Team. Labour-rights engagement is anchored with the Employee Relations and Labour Rights team under the Chief People Officer, and safety engagement with the Safety and Resilience team under the Chief Operating Officer. During 2024 Maersk worked to strengthen the format for collecting and documenting external stakeholder perspectives, beginning with an in-depth mapping of its engagement approach, and conducted an Inclusion Survey to gather views from vulnerable or underrepresented groups.

(Section ESRS 2 SBM-3, Double materiality assessment, pages 66-67 and 77) Maersk reports the material impacts, risks and opportunities identified through its 2024 double materiality assessment and their interaction with strategy and the business model. The assessment, aligned with the LEAP assessment for nature-related issues and scenario-based modelling for risk quantification, identified 29 individual IROs. The material topical ESRS standards are E1 Climate change, E2 Pollution, E4 Biodiversity and ecosystems, E5 Resource use and circular economy, S1 Own workforce, S2 Workers in the value chain, S3 Affected communities and G1 Business conduct. E3 Water and marine resources was found not material, with the DMA showing water use is important but not material, though Maersk continues to monitor and reduce water consumption in water-stressed areas. S4 Consumers and end-users was not material, as no IROs were identified given the business-to-business model of providing logistics services. Two climate-related risks are identified, transitional and physical. Entity-specific topics not covered by topical ESRS include data and AI ethics and responsible tax. Human rights are not called out as standalone IROs because they are integrated across environmental, social and governance topics. The material ESG topics are tied to Maersk's strategic and prioritised ESG categories and its strategic ESG targets.

(Section ESRS 2 IRO-1, Double materiality assessment methodology, page 68) Maersk describes the process used to identify and assess material impacts, risks and opportunities. The 2024 corporate-level DMA is aligned with ESRS requirements, approved by ELT sponsors and endorsed by the Audit Committee. Value chain mapping covered all operations and the value chain, using industry analysis, scientific research and stakeholder knowledge where data were limited. Time horizons follow ESRS 1: short-term is the reporting year, medium-term covers 1 to 5 years, and long-term is beyond 5 years, with emerging impacts and risks also identified. To assess impact materiality, a scoring sheet was developed and validated by internal subject-matter experts for each of the 10 topical ESRS standards. Severity, based on scale, scope and irremediable character, is assessed on a scale of 1 to 5, with severity and likelihood each weighted 50/50; for human rights-related topics severity is weighted higher at 75% versus 25% for likelihood. A threshold of 3 out of 5 is applied to capture very significant or critical impacts for external reporting. Environmental impacts are informed by a LEAP assessment performed in 2024. Financial risks are assessed on magnitude and likelihood, aligned with the ERM framework, using scenario-based modelling, with a lower quantitative threshold than the ERM process to capture a broader range of ESG risks.

(Section ESRS 2 IRO-2, Index tables, pages 57-59) Maersk provides an index of the disclosure requirements and datapoints covered by its sustainability statement, allowing users to locate ESRS disclosures across the report. The statement is prepared in accordance with the ESRS and applies an incorporation by reference method, where some required disclosures are stated outside the sustainability statement in other parts of the Annual Report or in the Remuneration Report. One index table lists disclosure requirements incorporated by reference, showing the disclosure requirement, datapoints, paragraph and page (for example GOV-1 datapoints to Corporate governance page 47, GOV-3 and the CEO pay ratio to the Remuneration Report, GOV-4 to Approach to due diligence page 69, GOV-5 to Corporate governance page 48, and SBM-1 business model and value chain to Business model page 13). Further index tables map the ESRS 2 general disclosures and the material topical standards to their locations, cross-referencing sections such as ESG governance model (pages 64-65), Double materiality assessment (pages 66-67 and 77), the DMA methodology (page 68) and Stakeholder engagement (pages 70-74). The index also flags entity-specific disclosures and datapoints stemming from other EU legislation such as SFDR.

(Section ESRS E1-1, Climate change p 79) Maersk has committed to reaching net-zero greenhouse gas emissions by 2040 across its own operations and value chain, covering end-to-end ocean, land and air logistics. In 2024 Maersk announced validation of its climate targets by the Science Based Targets initiative (SBTi), the first in the shipping industry to be aligned with a 1.5 degree pathway for 2030 and the 2040 net-zero standard. The near-term 2030 targets are a 35% absolute reduction in total scope 1 emissions, 100% renewable electricity sourcing and a 22% absolute reduction in total scope 3 emissions, all from a 2022 base year. The transition plan rests on two decarbonisation drivers, efficiency measures (network and asset efficiency) and energy shifts (electrification and a fuel shift to biodiesel, green methanol and biomethane). To reach net-zero by 2040 Maersk expects around 6.2m tonnes of residual GHG emissions annually that it will need to neutralise in line with SBTi net-zero criteria.

(Section ESRS E1-2, Climate change pp 78-88) Maersk states that its transition plan is underpinned by policies and governance addressing both climate mitigation and the social implications of decarbonisation. Its Fleet Management and Technology policy statement covers environmental commitments such as improving energy efficiency and preserving ecological balance and biodiversity across the fleet. The lifecycle analysis of current and possible future green fuels for ocean shipping is governed by three publicly available policies: Maersk green fuel requirements, Maersk biofuel sustainability requirements, and a related requirement covering proof of sustainability. Maersk's Green Finance Framework is described as essential to funding the transition plan, allowing use of various financial instruments and aligning closely with the EU Taxonomy across new-build and retrofitted vessels, warehouses, terminals and electrified equipment. Sustainability due diligence focuses on environmental and social impacts including human rights and social safeguards, and Maersk has reserved rights for independent audits as part of methanol offtake agreements.

(Section ESRS E1-3, Climate change pp 78-88) Maersk's climate actions follow two levers: efficiency measures and energy shifts. On efficiency, it improved the Energy Efficiency Operational Indicator (EEOI) to 11.1 gCO2e/t nm in 2024 (from 11.7 in 2023), a record low, supported by the StarConnect AI fleet energy efficiency platform processing 2.5bn data points annually from more than 700 vessels, and by the new Gemini network with Hapag-Lloyd. On fuel shift, Maersk deployed seven large dual-fuel green methanol vessels in 2024 and retrofitted the Maersk Halifax as the world's first retrofitted dual-fuel methanol vessel; 11 large (16,000-17,000 TEU) dual-fuel vessels are scheduled for delivery in 2025 and six smaller (9,000 TEU) in 2026-2027. In 2024 Maersk invested USD 1.2bn in new dual-fuel vessels and retrofits (of which USD 1.2bn EU Taxonomy aligned) and sourced green fuels valued above USD 250m. It anticipates spending in the range of USD 2-8bn on green fuels until 2030 and expects to need 10-20% green fuels by 2030.

(Section ESRS E1-4, Climate change p 79) Maersk's SBTi-validated targets use a 2022 base year. The near-term 2030 targets are a 35% absolute reduction in total scope 1 emissions, 100% renewable electricity sourcing (scope 2), and a 22% absolute reduction in total scope 3 emissions. The long-term 2040 net-zero targets are a 96% absolute reduction in total scope 1 and scope 2 emissions and a 90% absolute reduction in total scope 3 emissions. Sub-targets cover maritime operations, including a 35% reduction by 2030 (96% by 2040) in scope 1 and scope 3 well-to-wake emissions from own container shipping operations, and a 17% reduction by 2030 (97% by 2040) for subcontracted container shipping operations. Other (non-maritime) operations carry a 42% reduction target for scope 1 and scope 2 emissions from all other sources and a 90% reduction by 2040. Maersk reports these are gross targets, meaning GHG removals, carbon credits or avoided emissions are not currently counted toward the reductions.

(Section ESRS E1-5, Climate change performance data pp 89-100) For 2024 Maersk reported total energy consumption of 121,008 GWh, up 4% from 116,272 GWh in 2023, driven mainly by higher fuel consumption from the re-routing around the Cape of Good Hope. Fossil energy consumption was 117,664 GWh and renewable energy consumption was 3,344 GWh, up 37% year on year mainly from increased green fuels use and more terminals procuring renewable electricity. Within renewables, green fuels were 3,034 GWh, renewable electricity 303 GWh, and self-generated non-fuel renewable energy 7 GWh. The share of renewable energy consumption was 3% and the share of fossil fuel sources was 97% in 2024. Energy intensity was 2.18 GWh/USDm, down from 2.28 in 2023, reflecting a higher increase in revenue than in energy consumption. All of Maersk's energy consumption is treated as related to high climate impact sectors. Renewable energy production from on-site solar installations was 9 GWh.

(Section ESRS E1-6, Climate change performance data pp 89-100) For 2024 Maersk reported gross scope 1 GHG emissions of 33,939 thousand tonnes CO2e (up 5% on 2023; 34,416 in the 2022 base year), of which 16% came from regulated emission trading schemes. Gross location-based scope 2 emissions were 431 thousand tonnes CO2e and gross market-based scope 2 emissions were 356 thousand tonnes CO2e. Total gross indirect scope 3 GHG emissions were 49,232 thousand tonnes CO2e (up 10% on 2023). The largest scope 3 categories were upstream transportation and distribution at 23,759 and use of sold products at 9,699 thousand tonnes CO2e. Total GHG emissions were 83,602 thousand tonnes CO2e location-based and 83,528 thousand tonnes CO2e market-based, both up 8% on 2023, mainly reflecting additional fuel consumption from the extended re-routing around the Cape of Good Hope. Biogenic emissions not included in scope 1 were 828 thousand tonnes CO2e.

(Section ESRS E1-8, Embedding the transition plan into business strategy and financial planning pp 81-82) Since 2021 Maersk has applied an internal shadow price of USD 75 per tonne of GHG for investment decisions. The price was set in 2021 based on an analysis of existing abatement costs and expectations of future carbon taxes. It is not applied to actual emissions but is used for projections to ensure future regulations and carbon costs are considered in all investment committee decisions. Reaching Maersk's climate ambitions is described as core to its ESG strategy and part of the annual business planning process, with the required CAPEX and OPEX to pursue the climate targets and roadmap allocated within the business strategy and financial planning of the relevant segments, for example financing the new fleet of green methanol dual-fuel vessels, ongoing fleet renewal and battery-electric container handling equipment. Progress against strategic KPIs is reviewed quarterly by the Executive Leadership Team and the Board of Directors, and responsibility for the transition plan rests with the Chief Operating Officer.

(Section ESRS E1-9, Climate change p 88) In 2022 Maersk assessed the physical impact of climate change on its business, selecting 107 assets (terminals, warehouses, data centres and third-party property) mapped against hazards such as heatwaves, flooding, windstorms and water stress across multiple time horizons and climate scenarios. Estimated loss values reflect property damage and disruption costs but exclude the resulting effect on the network. Under a middle-of-the-road SSP2-4.5 scenario (+2.5 degrees by 2100), most financial impact is concentrated in five terminals, with estimated total annual revenue loss and asset damage in 2050 of USD 49.9m (APM Terminals Maasvlakte II, Rotterdam), USD 11.7m (APM Terminals Pier 400, Los Angeles), USD 9.8m (APM Terminals Elizabeth, New Jersey), USD 4.6m (Suez Canal Container Terminal) and USD 3.7m (Aqaba Container Terminal). SSP5-8.5 and SSP1-1.9 scenarios were also considered. Maersk states it has not developed a corporate policy or overall measurable targets but continues to assess the need for mitigative actions at site level.

(Section ESRS E2-1, Environment and ecosystems pp 101-106) Maersk's Environment & Ecosystems Policy Architecture is a cross-topic document guiding employees on minimising material impacts by adhering to the principles of its environmental management systems and global policies, including on pollution. Maersk is committed to avoiding and reducing pollution to air, land and sea across its operations. The pollution approach relies on a management framework and guidelines for preventing and responding to pollution across daily land and sea operations, including air quality management measures, chemical handling protocols, spill prevention standards and detailed emergency response manuals. In its Ocean business, pollution is regulated through the International Convention for the Prevention of Pollution from Ships (MARPOL) and International Maritime Organization (IMO) regulations. Suppliers are required to adhere to the environmental standards in Maersk's Supplier Code of Conduct. The policy document is supported by internal business and issue-specific standards, requirements and policies, and is made available to relevant stakeholders via the intranet.

(Section ESRS E2-2, Environment and ecosystems pp 101-106) Maersk collaborates with key industry stakeholders to tackle air pollution, such as the Alliance for Clean Air, aiming to reduce air pollution across the value chain through innovative solutions, increased reporting transparency and investigating target-setting methodologies. To mitigate the risk of lost containers at sea, in 2024 Maersk introduced a heavy weather monitoring and alert technology giving shore-based teams real-time notifications to vessels at risk of extreme weather, plus a parametric roll risk management solution helping crews optimise route planning. Maersk uses a combination of low sulfur fuel oil and open-loop scrubbers to comply with mandatory IMO 2020 sulfur regulations, and engages with the World Shipping Council and IMO on scrubber challenges. It engages with the TopTier Joint Industry Project on lost containers and shared findings through the IMO. Maersk also made a USD 2m investment to improve HSSE performance across 220+ warehouse sites, including spill kits, updated waste containers, water infrastructure improvements, refrigerant retrofits and environmental site assessments.

(Section ESRS E2-3, Environment and ecosystems pp 101-106) In relation to pollution, Maersk does not have measurable targets in place. However, it strives to prevent spills through operational controls and to monitor and respond immediately to mitigate impacts of spills. In 2024, Maersk had no significant (above 10 m3) hydrocarbon spills. Maersk also strives to avoid the loss of any containers at sea; in 2024, five containers were lost overboard from the time-chartered vessel Celsius Brickell near the port of Mombasa, Kenya, all empty, with the incident resulting in no pollution or injuries.

(Section ESRS E2-4, Environmental performance data pp 107-108) Maersk reports air pollutant emissions besides GHG emissions. For 2024 (1,000 tonnes): SOx 97 (2023: 90), NOx 704 (2023: 672), NMVOCs 16, CO 80, PM10 58, PM2.5 40 and Black Carbon 3. For 2024, air pollutant emissions increased as a result of and generally in line with increased fuel oil consumption caused by the extended distance linked to the Red Sea situation and re-routing of vessels around the Cape of Good Hope throughout 2024. Black Carbon emissions remained on par with 2023, a result of generally higher engine load contributing to more efficient combustion. On environmental incidents, Maersk recorded no oil spills above 10 m3, making 2024 the third consecutive year without a significant oil spill, and five containers lost at sea (2023: 52). Air pollutants are prepared based on the first version of the Stockholm Environment Institute's reporting guide, with Black Carbon and PM10 for the fleet based on IMO methods (MEPC 75/7/15).

(Section ESRS E2-6, Environment and ecosystems p 107) As part of the double materiality assessment, Maersk identified material financial risks to its business related to hydrocarbon spills and lost containers. Maersk reports operating expenditures (OPEX) in conjunction with major incidents and deposits of USD 2m in 2024. These operational expenditures relate to major environmental incidents and cover clean-up and salvage operation costs that are not covered by insurance in conjunction with significant oil spills (above 10 m3) and containers lost at sea from Maersk-owned vessels incurred during the financial year. The 2024 expenditures are linked to the clean-up and salvage operation following the loss of 46 containers in the North Sea in December 2023, relating to additional costs not covered by insurance.

(Section ESRS E4-1, Environment and ecosystems pp 101-106) In 2024, Maersk performed an initial assessment using the LEAP (Locate, Evaluate, Assess and Prepare) framework created by the Taskforce on Nature-related Financial Disclosures (TNFD) to identify and assess its main nature-related issues, aiming to strengthen the foundation for environmental initiatives across its global operations and align commitments and actions with global standards, following the United Nations Kunming-Montreal Global Biodiversity Framework. The LEAP assessment helped inform the double materiality assessment. Maersk does not yet present a full transition plan; as part of the LEAP work, its objective for the coming 1-2 years is to further refine its understanding of links to biodiversity-sensitive areas, enabling prioritisation, target-setting and action plans as well as overall transition planning and resilience analysis. Ocean transportation was excluded from the 2024 analysis, as vessel navigation platforms do not currently include sensitivity layers; Maersk expects to include impacts from vessels in coming years. An emerging risk beyond five years is increased water dependency in the supply chain for e-fuel production.

(Section ESRS E4-2, Environment and ecosystems pp 101-106) Maersk's Environment & Ecosystems Policy Architecture is a cross-topic document guiding employees on minimising material impacts, including on ecosystems health and biodiversity. Maersk strives to protect habitats and biodiversity and actively participates in restoring ocean and land health in critical habitats. Environmental and social impact assessments are performed for all new Logistics & Services and APM Terminals projects to proactively identify environmental risks and impacts, using defined screening criteria including global and regional data sources to predict and mitigate biodiversity and ecosystems risks and assess community impacts. In marine contexts, Maersk adheres to relevant standards and regulations and strives to minimise disturbances to marine wildlife. Maersk does not currently use biodiversity offsets to address its impacts. It has a zero-tolerance policy towards transporting illegal wildlife and timber, zero tolerance for transporting any products of shark and whale origin, and enforces internal controls to prevent misdeclaration and unauthorised transboundary movement of hazardous waste. Suppliers must adhere to environmental standards in the Supplier Code of Conduct.

(Section ESRS E4-3, Environment and ecosystems pp 101-106) As part of the LEAP assessment, in 2024 Maersk identified critical business segments across its operations and value chain, analysing impact drivers and dependencies. To evaluate its presence in biodiversity-sensitive areas, it used data from the World Databases of Protected Areas and Key Biodiversity Areas. Maersk complies with international conventions to perform pest control and, as of 2024, reached the target of 100% of its vessels having ballast water treatment systems installed, well in line with the deadline set by the Ballast Water Management Convention. Maersk is improving its StarConnect AI-powered fleet energy efficiency platform to monitor presence in marine protected areas and particularly sensitive sea areas and to add whale zones based on the World Shipping Council Whale Chart, with implementation in 2025. Maersk actively engaged with regulators, state entities, shipping associations and NGOs on revised Underwater Radiated Noise (URN) Management guidelines in line with IMO guidelines, including URN measurements of fleet vessels to develop a baseline and an action plan.

(Section ESRS E4-4, Environment and ecosystems pp 101-106) At present, Maersk does not have group-wide targets specifically addressing ecosystem health and biodiversity (or waste management). However, it continuously monitors its performance across both landside and ocean operations to gain a clearer understanding of its impacts. Maersk's objective for the coming 1-2 years is to further refine its understanding of links to biodiversity-sensitive areas, enabling prioritisation, target-setting and action plans as well as overall transition planning and resilience analysis. As of 2024, Maersk reached the target of 100% of its vessels having ballast water treatment systems installed, in line with the Ballast Water Management Convention deadline.

(Section ESRS E4-5, Environment and ecosystems pp 101-106) To evaluate its presence in biodiversity-sensitive areas, Maersk utilised data from the World Databases of Protected Areas and Key Biodiversity Areas. Initial findings based on the geolocations of its sites as per 31 October 2024 indicate that 48 terminals, 471 inland logistics facilities and 269 offices are in potential biodiversity-sensitive sites. Further analysis in coming years will confirm whether these sites and assets negatively impact such areas or significantly depend on local ecosystem services. Ocean transportation was excluded from the 2024 analysis, as vessel navigation platforms do not currently include sensitivity layers enabling the assessment; Maersk expects to include impacts from vessels in the analysis in coming years.

(Section ESRS E5-1, Environment and ecosystems pp 101-106) Maersk's Environment & Ecosystems Policy Architecture is a cross-topic document guiding employees on minimising material impacts, including through resource use and circular economy topics such as responsible ship recycling and the sourcing of critical resources like steel and fuels. Waste management aims to reduce the waste footprint across operations and contribute to a circular economy. Responsible ship recycling standards set stringent requirements to prevent, reduce, minimise and, to the extent practicable, eliminate accidents, injuries and other adverse impacts on human health and the environment from recycling operations, aligned with the IMO's Hong Kong Convention. Policies for sourcing steel and green fuel are also set out in the Policy Architecture, including specific green fuel sustainability requirements and an approach to understanding the steel value chain and mitigating its negative impacts. Suppliers must adhere to environmental standards in the Supplier Code of Conduct. In Ocean operations Maersk complies with MARPOL Annex V and maintains a strict zero-dumping policy.

(Section ESRS E5-2, Environment and ecosystems pp 101-106) In 2024 Maersk finalised a landside environmental roadmap defining strategy and focus areas for 2024-2026, including stronger digital tools for tracking compliance and reporting. It started a fleet-wide pilot to improve visibility into waste categories and disposal requirements, which when fully implemented will track garbage landed at end destinations. A global waste assessment across Logistics & Services and APM Terminals developed a baseline understanding of waste generation and management; an updated global waste standard with compliance tools and training will enable future target-setting on waste and landfill diversion. Maersk continued a recycled mooring rope pilot with C-Loop, landing recycled ropes in Europe for the first time in 2024. On ship recycling, Maersk completed recycling of Maersk Patras (Alang, India) and Jeppesen Maersk and Alexander Maersk (Aliaga, Turkey) with zero safety or environmental incidents, and signed a July 2024 memorandum of understanding with Kingdom of Bahrain ministries to develop local post-Panamax recycling capacity. Under the SteelZero initiative Maersk worked with the Climate Group on lower emission steel standards and continued green fuel sourcing dialogue with Goldwind and LONGi.

(Section ESRS E5-3, Environment and ecosystems pp 101-106) Maersk reports that it does not currently have group-wide targets specifically addressing waste management. With regard to waste it is working to enhance the granularity of data on waste generation and disposal across land and sea, including establishing accurate baselines, as groundwork to set meaningful commitments in future. For ship recycling, Maersk actively monitors the effectiveness of its policies and actions towards a qualitative target to increase global capacity for the responsible recycling of post-Panamax vessels. For sourcing of critical resources, beyond GHG emissions Maersk does not currently have targets to address the wider environmental impacts from the steel and fuel value chains. Through the SteelZero initiative it has committed to transition to using 50% lower emission steel by 2030 and to set a pathway to using 100% net-zero steel by 2040.

(Section ESRS E5-4, Environmental performance data pp 107-108) Maersk reports resource inflows for steel. The total weight of steel consumed in 2024 was 73,394 tonnes (EFRAG ID E5-4_02). Maersk procures and uses steel for manufacturing containers. It notes that significant additional amounts of steel are used by suppliers and partners in the value chain to produce vessels, cranes and other heavy assets used in Maersk's operations, but it only reports the weight of steel it directly procures and uses to manufacture containers. Per its accounting policy, total weight of steel consumed is the weight of steel used for producing containers during the year, calculated based on the number of containers produced and the bill of materials related to those containers.

(Section ESRS E5-5, Environmental performance data pp 107-108) Maersk reports resource outflows primarily through waste generated (EFRAG ID E5-5_07). Total waste in 2024 was 556 thousand tonnes, up from a restated 517 thousand tonnes in 2023, an increase of approximately 8% mainly driven by an increased number of vessels in Maersk's operations. The prior years were 553 thousand tonnes (2022), 357 thousand tonnes (2021) and 289 thousand tonnes (2020). The ESRS content index also references non-recycled waste under E5-5. Waste is bifurcated into hazardous and non-hazardous types. The report does not present separate product or material output metrics beyond steel inflow; the main outflow disclosure is waste generation and its hazardous/non-hazardous split.

(Section ESRS E5-5, Environmental performance data pp 107-108) Maersk reports total waste generated of 556 thousand tonnes in 2024, of which 236 thousand tonnes was hazardous waste (E5-5_15) and 320 thousand tonnes was non-hazardous waste (E5-5_10). This is an increase of approximately 8% versus a restated 517 thousand tonnes in 2023, driven mainly by an increased number of vessels. The 2023 waste and non-hazardous figures were restated from 533k and 315k tonnes due to an incorrect unit conversion. Non-hazardous waste primarily consists of municipal and industrial waste such as food waste, pallets, cardboard, general trash and metal and wood scrap. Waste data combines actual numbers and estimates; land-based waste comes from billing, accounting or procurement systems, with FTE-based estimates for minor sites, while vessel waste is extrapolated from MARPOL Annex V garbage conversion factors applied to a sample of 30 vessels across three size groups. The report does not quantify waste diverted from versus directed to disposal or an overall recycling rate. For ship recycling, Maersk reports that over the 2017-2024 period 17 vessels were responsibly recycled at six yards in Alang, India, engaging more than 1,200 workers, and highlights zero spills and hazardous materials incidents in its Alang engagement, but does not provide a tonnage of ship recycling waste.

(Section ESRS S1, Our workforce pp 111-118; Grievance and remedy pp 73-74) Maersk sets out several policies covering its own workforce, anchored in its Purpose, Core Values and a commitment to the UN Guiding Principles on Business and Human Rights, formalised in the Human Rights Policy Statement on Maersk.com. Diversity, equity and inclusion rests on two main policies: a diversity, equity and inclusion policy and an anti-discrimination, harassment, bullying and violence policy, both publicly available. Health, safety and security is codified in the HSSE Policy, which applies globally to all entities, employees and everyone working under Maersk's supervision, including contracted workers. Employee relations and labour rights are governed by the Commit Rule on Global Employees and Labour Relations for own employees and by the Maersk global standards on third-party labour, aligned with the UN ILO core conventions and the UN Global Compact and covering forced and child labour, adequate housing and sanitation, wages and working hours. A Code of Conduct sets out a zero-tolerance, non-retaliation stance and encourages a speak-up culture.

(Section ESRS S1-2, Stakeholder engagement pp 70-74) Maersk lists employees, contingent workers and value chain workers among seven prioritised stakeholder groups. Their expectations include meaningful work, fair treatment and wages, safe working conditions, a sense of belonging and good development opportunities. Key engagement channels for this group are daily manager and colleague interactions, engagement and inclusion surveys, grievance mechanisms, engagement with unions and interest groups, and supplier audits. Input is used to shape ESG programmes, actions and improvement plans. Engagement with own workforce is anchored with relevant business functions: labour-rights focused engagement sits with the Employee Relations and Labour Rights team headed by the Chief People Officer, and safety engagement with the Safety and Resilience team headed by the Chief Operating Officer. Management receives regular updates on topics raised. Maersk performs a biannual employee engagement survey, conducted a second organisation-wide inclusion survey across 126 countries in 2024, and held high-level talks with the International Transport Workers' Federation on contracted labour.

(Section ESRS S1-3, Grievance and remedy pp 70-74) Maersk fosters a speak-up culture enshrined in its Code of Conduct with a zero-tolerance, non-retaliation policy. Multiple channels are available for employees and other stakeholders to raise concerns. The whistleblower programme, anchored in the Commit framework, has been available for decades, is independently managed on a third-party platform, maintains complete confidentiality with the option of anonymous reporting, and is supported by independent, objective and impartial investigators. The whistleblower site is accessible in all countries where Maersk operates, with phone lines in 75 languages, and is open to employees, suppliers and other external affected stakeholders. Additional internal channels include direct management or leaders, the Compliance, People or Ombuds functions and an employee assistance programme. The Ombuds function is a neutral, independent, informal and confidential resource. Maersk is committed to providing remedy where it has caused or contributed to an adverse impact and collaborates with both judicial and non-judicial mechanisms. For own employees it ensures 24-hour availability of an assistance programme offering psychological, legal and financial support.

(Section ESRS S1, Our workforce pp 111-118; Grievance and remedy pp 70-74) Maersk takes action across its People strategy focus areas of human capital, DE&I, safety and security, and employee relations and labour rights. In 2024 it strengthened its performance culture through the MPACT framework, launched the Maersk Academy attracting over 750,000 visits, expanded mentoring to 2,400 participants and introduced coaching. On DE&I it ran a second inclusion survey across 126 countries, developed a programme for over 5,000 colleagues identified as having diverse abilities, expanded talent sponsorship for underrepresented groups and reached almost 6% female seafarers versus a 2% industry average. On safety it conducted 15,000 Gemba walks, completed a one-time HSSE assessment of 354 logistics sites closing 95% of improvement actions, launched a three-year warehouse and depot campaign and set up a global HSSE assurance team. On labour rights it broadened rollout of the global standards on third-party labour, completed a company-wide labour rights assessment, launched a tracking app, and assessed adequate wages across own employees finding none paid below the applicable benchmark. Remediation is delivered through the whistleblower programme, Ombuds function and access-to-remedy mechanisms.

(Section ESRS S1, Our workforce pp 111-118) Maersk reports several targets for its own workforce. On human capital it aims to reach an employee engagement survey score in the 75th percentile of Gallup's global norm by 2025; the second 2024 survey reached the 65th percentile, up from 60th at the end of 2023, and employee turnover was 11% in October 2024. On diversity it targets above 40% women in management by the end of 2025, at 35% in 2024 (on par with 2023), and above 30% diverse (non-OECD) nationalities of executives, which rose by 1 percentage point in 2024. It also introduced a diversity in teams metric, scoring 58% on gender and 85% on nationality in 2024. On safety it targets 100% of learning teams completed following a high potential incident, ending 2024 at 99%. On labour rights it targets training 100% of in-scope employees on employee relations and labour rights, with 94% completion at the end of 2024, and maintains the 100% target for 2025.

(Section ESRS S1-6, Social performance data pp 119-125) At year-end 2024 Maersk employed 108,160 employees (headcount), with an average of 106,626 during the year. By gender, 70,100 were recorded as male, 37,459 as female, 3 as other and 598 as not disclosed. By contract type, 87,906 were permanent and 20,254 temporary; Maersk employs no employees on non-guaranteed hours contracts, and the majority of the workforce is on permanent contracts. By country, India had 16,159 employees, Denmark 15,820, China 11,908 and the USA 11,126; India, China and the USA each represented more than 10% of the total workforce, and Denmark is listed because the seafarer population, totalling more than 12,000 employees, is employed by a Danish legal entity. By region, Asia Pacific was 25%, Europe 30% and the Indian subcontinent, Middle East and Africa 22%, with Latin America and North America combined accounting for 22%. The employee turnover rate was 11%, with 11,835 employees leaving during the year. Maersk employs 100,000+ people across almost 130 countries.

(Section ESRS S1-9, Social performance data pp 119-125) In 2024 Maersk reported 340 women in leadership (job level 6+), representing 27% of headcount at those levels, and 6,405 women in management (job level 4+), representing 35%; both were on par with 2023. Target nationalities in executive leadership (job levels 8 and 9) stood at 21% of headcount. Its diversity in teams metric, covering leaders at the CEO-1 and CEO-2 layers, scored 58% on gender and 85% on nationality. Seafarers are excluded from the women in leadership and women in management calculations because they do not share the same job level categories. By age, 23,909 employees (22%) were under 30 years old, 71,946 (67%) were between 30 and 50, and 12,305 (11%) were over 50. On seafarer gender diversity, of a total 12,168 seafarers, 719 were female (6%), including 29 female senior officers (1%), 89 female junior officers (3%), 372 female cadets (21%) and 229 female ratings (4%); Maersk reached almost 6% female seafarers across the fleet versus a 2% IMO industry average.

(Section ESRS S1-10, Social performance data pp 119-125) For 2024 Maersk's assessment shows that no employees in any country are paid below the applicable adequate wage benchmark, reporting 0% of employees below the benchmark. The assessment was based on the guidance from the European Sustainability Reporting Standards and available benchmarks. In the European Economic Area, the minimum wage is set in accordance with Directive (EU) 2022/2041 on adequate minimum wages in the European Union; until that directive enters into force, where no applicable minimum wage exists, Maersk uses a benchmark from a neighbouring country with a similar socio-economic status or a commonly referenced international norm such as 60% of the country's median wage and 50% of the gross average wage. Outside the EEA, wage levels are set by existing legislation, official norms or collective agreements, national or sub-national minimum wages, or the Living Wage benchmark provided by Wage Indicator. Excluded from the calculation are learners, interns, graduates, students, cadets, long-term assignees and inactive employees on unpaid or garden leave. Maersk is developing a framework for assessing adequate wage levels for contracted employees.

(Section ESRS S1-14, Social performance data pp 119-125) In 2024 Maersk recorded 1 fatality, down from 4 in 2023, 9 in 2022, 4 in 2021 and 1 in 2020. The 2024 fatality involved a contracted colleague in a warehouse in the Philippines on 26 December 2024. In addition, one fatality involving a value chain worker on a construction site within Maersk's premises was recorded, though that individual was employed by the construction company and not working under Maersk's responsibility. Lost time incidents (LTIs) totalled 493, up from 376 in 2023, and the lost time incident frequency (LTIf) rate rose to 1.53 from a restated 1.14 in 2023 (previously reported 1.11); the LTIf was 0.93 in both 2022 and 2021 and 1.22 in 2020. LTIs and LTIf include both own and non-employee (contracted) workers working under Maersk's responsibility. The rise was driven by increased LTIs in Logistics & Services (about a 50% year-over-year increase reflecting improved reporting culture) and APM Terminals. Learning teams completed following a high potential incident stood at a 99% completion rate, on par with 2023.

(Section ESRS S1-16, Social performance data pp 119-125) For 2024 Maersk's first company-wide gender pay gap analysis showed a 5% difference in average pay between female and male employees, calculated as the difference in average annual total remuneration expressed as a percentage of the average annual total remuneration of male employees. The annual total remuneration ratio for 2024 was 205, calculated by comparing the annual total remuneration of the highest paid employee with the annual median total remuneration of the rest of Maersk's own employees. Both metrics use a fully loaded cost index, calculated per job level and country, that estimates benefits, guaranteed allowances, employer liabilities, on-target short-term incentives, on-target long-term incentives and recognition costs for 2024, based on headcount and estimated annual total remuneration at 31 December. Excluded from the calculation are learners, interns, graduates, students, cadets, long-term assignees and inactive employees on unpaid or garden leave. Maersk notes it will continue to refine its approach in coming years, which may affect the outcome of these KPIs.

(Section ESRS S1-17, Grievance and remedy pp 73-74) In 2024 Maersk received 1,387 whistleblower reports, a 20% increase from 1,154 cases in 2023, attributed to the success of its awareness initiatives. Of the cases received in 2024, 84% have been closed. Maersk saw an increase in HR-related matters, which made up 37% of reports received, followed by categories including fraud, HSSE, IT security, business integrity and sustainable procurement. Two cases of discrimination on protected grounds were substantiated, resulting in disciplinary action and policy/process review respectively. In 2024 Maersk also started tracking human rights incidents that are inherently severe, including cases related to forced labour, human trafficking or child labour; no such cases were recorded for 2024. Of the 1,170 closed cases in 2024, outcomes included substantiated, unsubstantiated, dismissal, disciplinary action, training, warning, policy/process review and no action necessary. A comprehensive whistleblower report is submitted annually to the Audit Committee and the Risk and Compliance Committee, covering measures such as the number of cases reported and closed, case types, outcomes and actions taken.

(Section ESRS S2-1, Sustainable procurement pp 130-131; Grievance and remedy pp 73-74) Maersk's policies for value chain workers centre on its updated 2024 Supplier Code of Conduct, aligned with the UN Guiding Principles and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. The Code sets expectations for suppliers to uphold responsible practices in ethics, human rights, working conditions and environmental standards, in compliance with applicable laws, and to implement the Code or similar requirements with their sub-suppliers. It is enforced through the Commit Sustainable Procurement Rule, communicated through internal channels, and publicly available on Maersk.com in 12 languages. The approach is founded on proactively managing supply chain risks as Maersk's licence to operate and on complying with an evolving regulatory landscape, including the upcoming Corporate Sustainability Due Diligence Directive. Human and labour rights are integrated into supplier due diligence. A speak-up culture is promoted through the whistleblower programme, enshrined in the Code of Conduct with a zero-tolerance, non-retaliation policy, open to suppliers and other external affected stakeholders and confidentially and independently managed on a third-party platform.

(Section ESRS S2-2, Stakeholder engagement pp 70-74) Maersk describes stakeholder engagement as supporting the identification of existing or emerging impacts and risks as part of its double materiality assessment. Value chain workers are engaged through suppliers and business partners, one of seven prioritised stakeholder groups. Engagement with key external stakeholders such as own workforce and value chain workers is anchored with relevant business functions: labour-rights focused engagement sits with the Employee Relations and Labour Rights team headed by the Chief People Officer, while safety engagement sits with the Safety and Resilience team headed by the Chief Operating Officer. Channels for suppliers and business partners include contract management, a supplier relationship management framework, supplier surveys, workshops and capability-building programmes, and industry forums and associations. Maersk states this helps build understanding of the effectiveness of supplier practices and enhances value chain visibility, including on fair working conditions and supplier ethical business conduct. It proactively seeks views through annual supplier surveys and conducts site visits and workshops with suppliers. Management receives regular updates on topics raised by stakeholders.

(Section ESRS S2-3, Grievance and remedy pp 73-74) Maersk fosters a speak-up culture, enshrined in its Code of Conduct with a zero-tolerance, non-retaliation policy. Its whistleblower programme, anchored in the Commit framework, has been available for decades and is open to everyone, including suppliers and other external affected stakeholders. Reporting is independently managed on a third-party platform with complete confidentiality and the option of anonymous reporting. The channel is accessible in all countries where Maersk operates, with phone lines in 75 languages, and is integral to both the Employee Code of Conduct and the Supplier Code of Conduct. Suppliers are required to communicate the whistleblower channel's existence and ensure their employees and subcontractors are made aware of it; each reported issue is investigated and, where necessary, appropriate remedies are provided. Investigations are led by independent, objective and impartial investigators following a standard procedure. Maersk is committed to providing remedy where it has caused or contributed to adverse impacts and continues strengthening processes for providing remedy to affected stakeholders, including workers in the value chain, collaborating with judicial and non-judicial mechanisms and using its leverage where directly linked to impacts through business relationships.

(Section ESRS S2-4, Sustainable procurement pp 130-131; Grievance and remedy pp 73-74) Maersk's actions focus on ESG integration across three priorities: value chain decarbonisation, human and labour rights, and safety and resilience. The Sustainable Procurement programme develops, deploys and monitors global standards on third-party labour and safety to promote fair working conditions, with human and labour rights integrated into supplier due diligence. Its supplier evaluation process includes pre-screening, desktop assessments, on-site audits and improvement plans to address gaps, focusing on high-risk categories including terminals, outsourced labour, shipyards and drydocks, covering over USD 2.5bn of high-risk supplier spend. Site visits and workshops are conducted, supported by dedicated safety superintendents running periodic on-site safety training. A green fuel sourcing due diligence framework is being developed for emerging risks. Key 2024 actions included updating the Supplier Code of Conduct, and planned actions include implementing Third-Party Labour Standards across the contracted labour category and developing supplier safety standards with pilot programmes for 2025. Maersk also monitors payment practices, striving for timely and fair payment and minimising the impact of late payments to small and medium-sized businesses.

(Section ESRS S2-5, Sustainable procurement pp 130-131) Maersk reports recurring annual targets relevant to value chain workers. It targets 100% of suppliers in scope committed to the Supplier Code of Conduct by 2024; 87% had signed by 2024 (95% in 2023), a decrease attributed to integrating additional supplier contracts into the compliance framework and improved KPI calculation methods. It targets more than 85% of tier 1 high-risk category suppliers undergoing ESG assessment by 2024; 47% was achieved (71% in 2023), a decrease of 24 percentage points attributed to digitising the reporting structure and an expanded addressable baseline. It targets more than 80% of high-risk category suppliers with an Improvement Plan successfully closed by 2024; 87% was achieved (79% in 2023), tracking above target. It also targets 100% of procurement staff trained in Sustainable Procurement by 2024; 99% completion was achieved (91% in 2023). To close gaps, Maersk is refining processes, deploying advanced digital tools, developing a digital ESG solution and integrating ESG more deeply into its end-to-end supplier lifecycle.

(Section ESRS S3-1, Approach to human rights pp 112-113; Grievance and remedy pp 73-74; Environment and ecosystems pp 101-106; Climate change pp 78-88; Business ethics p 129) Maersk explains that impacts on affected communities are not called out as standalone IROs in its double materiality assessment because impacts on people in local communities can occur across its operations and activities; they are integrated across environmental, social and governance topics. Its overarching commitment is Maersk's Human Rights Policy Statement, founded on the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Responsible Business Conduct, committing to respect human rights in own operations and the entire value chain. Human rights are anchored in Corporate Sustainability under the Chief Corporate Affairs Officer. Community-relevant policies include the Environment and Ecosystems Policy Architecture and the Environmental and Social Impact Assessment (ESIA) procedure; responsible ship recycling standards to prevent adverse impacts on human health and the environment; business ethics Commit Rules on anti-corruption, sanctions and competition; a speak-up culture with a zero-tolerance, non-retaliation policy; and climate policy outreach conducted in line with the Paris Agreement, including calls for a just and equitable transition benefiting developing nations.

(Section ESRS S3-2, Stakeholder engagement pp 70-74) Maersk lists local communities and nature as one of seven prioritised stakeholder groups, whose material issue is responsibility and accountability towards areas of highest impact. Engagement channels include Environmental and Social Impact Assessments and Corporate Social Responsibility initiatives, engagement with community representatives and employees, collective action alliances and partnerships, and scientific studies. Maersk states its operations can impact people in local communities and their natural surroundings, highlighting a responsibility to proactively engage with communities or their representatives; this engagement is described as crucial as a licence to operate and to understand local needs and conditions, informing decisions to invest and make meaningful contributions. As part of new infrastructure and landside projects, the ESIA screening process reviews environmental and social sensitivities against ten environmental criteria using global and regional data. Going forward, Maersk plans to integrate a more structured approach to consult with affected communities as part of environment and social screenings. It also engages civil society organisations and, during 2024, worked to strengthen the direct collection of external stakeholder perspectives into the double materiality process.

(Section ESRS S3-3, Grievance and remedy pp 73-74) Maersk's whistleblower programme, anchored in the Commit framework and enshrined in the Code of Conduct with a zero-tolerance, non-retaliation policy, is open to everyone, including external affected stakeholders. Reporting is independently managed on a third-party platform with complete confidentiality and an anonymous reporting option, accessible in all countries where Maersk operates with phone lines in 75 languages and publicly available on Maersk.com. Maersk actively monitors cases raised across stakeholder groups, including from affected communities, as an indication of awareness and trust in the channel. Maersk is committed to providing remedy in cases where it has caused or contributed to an adverse negative impact, and it continues working towards strengthening processes for providing remedy to affected stakeholders, including affected communities. It collaborates with both judicial and non-judicial mechanisms to provide access to remedy where allegations are reported externally, and commits to using its leverage to provide remedy where directly linked to impacts through business relationships. Issues raised are addressed, documented and fed back to key stakeholders. The report notes potential barriers to access, such as language, fear of retaliation, or psychological or physical barriers.

(Section ESRS S3-4, Environment and ecosystems pp 101-106; Climate change pp 78-88; Approach to human rights pp 112-113; Grievance and remedy pp 73-74; Business ethics p 129) Because community impacts occur across operations rather than as standalone IROs, Maersk's actions are embedded in topical work. Environmental and social impact assessments are performed for all new Logistics & Services and APM Terminals projects to identify environmental and social impacts and assess community impacts, with plans to integrate a more structured approach to consult affected communities. Landside environmental actions across 220+ warehouse sites include spill kits, waste and water infrastructure improvements and environmental site assessments, and Maersk engages communities through its annual Go Green campaign on waste. Responsible ship recycling standards aim to prevent adverse impacts on human health and the environment; in the Alang, India area, CSR projects and a mobile health unit provided complementary health care, with 15,000 out-patient department services in 2024, and Maersk monitors the impact of its recycling activities. On climate, Maersk advocates a just and equitable transition, including that IMO revenue collection benefits developing nations. Its salient human rights issues, addressed across topical sections, include impacts of climate change and decarbonisation (just transition) and access to remedy.

(Section ESRS G1-1, Responsible business conduct pp 128-132; Grievance and remedy pp 73-74) Maersk's business conduct is governed by its Commit framework, built around three core elements: guiding Core Values, a Code of Conduct, and 21 rules of business ethics, governance and authority covering high-risk areas. The Code of Conduct sets global standards for engaging with colleagues, customers, suppliers, communities and authorities, is aligned with the Universal Declaration of Human Rights and the UN Global Compact, and is publicly available on Maersk.com in 17 languages. Commit rules cover anti-corruption, sanctions and export controls, competition law and data privacy, each with a designated owner responsible for compliance. Employees complete Code of Conduct training at onboarding and through yearly refreshers, supported by campaigns tied to events such as Business Ethics Day and Anti-Corruption Day. Maersk fosters a speak-up culture backed by a zero-tolerance, non-retaliation policy. Its whistleblower programme, anchored in Commit, is independently managed on a third-party platform, allows anonymous reporting, is accessible in all countries with phone lines in 75 languages, and is open to employees, suppliers and external stakeholders. An internal Ombuds function offers a further confidential channel.

(Section ESRS G1-2, Sustainable procurement pp 130-131) Maersk manages supplier relationships through its Sustainable Procurement programme, embedding ESG as a strategic priority across the supplier lifecycle and promoting supplier collaboration and co-development. Its 2024 Supplier Code of Conduct, aligned with the UN Guiding Principles and OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, is enforced through the Commit Sustainable Procurement Rule and sets expectations on ethics, human rights, working conditions and environmental standards, including that suppliers apply the Code or similar requirements to their sub-suppliers. It is available on Maersk.com in 12 languages. ESG due diligence is integral to supplier selection, prompted partly by the upcoming Corporate Sustainability Due Diligence Directive (CSDDD). Suppliers commit via a mandatory Sustainable Procurement Clause, with 87% having signed the Code in 2024. Maersk evaluates compliance across anti-corruption, health and safety, labour and human rights, and environmental practices through pre-screening, desktop assessments, on-site audits and improvement plans, focusing on high-risk categories such as terminals, outsourced labour, shipyards and drydocks. Suppliers must communicate the Whistleblower channel to their employees and subcontractors.

(Section ESRS G1-3, Business ethics p 129) Corruption, sanctions and export controls, competition law violations and data privacy are Maersk's most material business ethics risks. Commit Rules covering these areas set out measures to identify, mitigate and manage compliance risks, carried out through dedicated teams of more than 70 compliance professionals and a Business Compliance Ambassadors' network represented across regional offices and high-risk locations. Maersk is an active and founding member of the Maritime Anti-Corruption Network (MACN), and in 2024 partnered with MACN and USAID on a two-year Doing Business with Integrity project under USAID's Countering Transnational Corruption Grand Challenge for Development. A risk assessment on compliance and business ethics is performed at least every two years, most recently in 2023, targeting 100% of operations. Allegations of misconduct are investigated promptly, independently and objectively by internal or external investigators, with non-compliance cases reported to the Board of Directors and Executive Leadership Team via the Risk and Compliance Committee. In 2024 Maersk completed 87 compliance spot checks covering anti-corruption, sanctions, competition law and data privacy.

(Section ESRS G1-4, Governance performance data p 134) Maersk reports that it had zero confirmed incidents. The number of convictions for violation of anti-corruption and anti-bribery laws (G1-4_01) in 2024 was Nil, and the amount of fines for violation of anti-corruption and anti-bribery laws (G1-4_02) was Nil. The report states that Maersk has not been convicted for violation of anti-corruption or anti-bribery laws during 2024 and thus no fines have been paid in relation to such cases. The number of convictions covers all convictions resulting from legal proceedings against A.P. Møller - Mærsk A/S and/or any of its subsidiaries in the reporting year, and the amount of fines covers fines paid as a result of legal proceedings on these matters against the company or its subsidiaries in the reporting year.

(Section ESRS G1-5, Political engagement pp 71-72) Maersk is actively involved in shaping policy and regulatory discussions at global and regional levels to accelerate decarbonisation of the maritime and logistics industries, viewing supportive regulation as essential to achieving its targets. At EU level it has called for full implementation of the Fit for 55 package, including the EU Emissions Trading System and the FuelEU Maritime Regulation, pushed for inclusion of container terminals in the ETS, and advocated an end-date for fossil-fuel-only newbuild vessels. Maersk adheres to policies and procedures for responsible lobbying and is listed in the EU Transparency Register (registration number 680443918500-51). It performs risk-based management integrity screenings of third parties who interact with government officials on its behalf. In general Maersk does not provide financial or in-kind donations to politicians, regulators or political parties. In Denmark it is a member of trade associations such as Danish Shipping and Danish Industry, which may allocate political contributions. In the US, Maersk operates a Political Action Committee (PAC); in 2024 the amount donated through the PAC was USD 15k, and no other political donations were made.

(Section ESRS G1-6, Sustainable procurement pp 130-131; Governance performance data p 134) Maersk recognises that ensuring fair and timely compensation for suppliers is part of responsible supplier engagement. Its standard payment terms vary based on the service or spend category, and it strives to align payments with those terms while continuously monitoring payment practices to ensure compliance and improve suppliers' experience. Maersk is building visibility on supplier-related payment impacts, particularly late payments to small and medium-sized businesses, using internal processes and tools to minimise the impact of delayed payments by prioritising prompt and equitable payment processes aligned with local and national requirements, and is actively engaging with suppliers on arbitration of late-payment issues. The report does not state an average number of days to pay invoices. On outstanding legal proceedings, the number of legal proceedings outstanding for late payments (G1-6_04) was Nil in 2024, and the report confirms that no legal proceedings for late payments were outstanding at year-end 2024.