A.P. Møller - Mærsk

The role of the administrative, management and supervisory bodies

Reference: pages 43-44; page 52; index page 111 (Corporate governance p.46, ESG governance model p.52).

Board composition (page 43): 10 non-executive and 0 executive members, 2 of them employed by the company; 70% independent; 30% women, 70% men. "Currently, the Board consists of three women and seven men, none of whom are members of the registered management of the company. The current 30/70 split is not considered to be equal gender representation on the Board, and the Board has set a target for reaching this."

Board-level sustainability oversight (page 52): three committees carry ESG duties under their charters. The Energy Transition Committee, which "replaced the previous ESG Committee in 2025", supports strategic direction on energy transition including the net-zero ambition; the Audit Committee "oversees Maersk's double materiality assessment, external ESG reporting, data quality and internal controls"; the Remuneration Committee reviews sustainability-linked targets in the long-term incentive programme.

Executive level (page 52): "dedicated sponsors are allocated to Maersk's material sustainability categories", named per category, accountable to the full Executive Leadership Team and the Board. The Risk and Compliance Committee is "the main executive governance forum for sustainability and ESG".

Board competences named include ESG (page 43).

Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

Reference: page 44; page 52; page 53.

Cadence (page 52): "To facilitate oversight and support decision making for strategic dilemmas and risks through the year, progress updates are compiled quarterly for strategic and prioritised targets and KPIs. These updates, as well as deep dives into individual categories are overseen at the quarterly meetings of the RCC and subsequently, if relevant, discussed with the full ELT."

Matters managed in 2025 (page 44). Audit Committee, 7 meetings: "Monitor CSRD reporting including double materiality assessment", "Review of tax report", "Oversee the company's Enterprise Risk Management framework and review key enterprise risks and related mitigation plans". Energy Transition Committee, 3 meetings: "Review implications of the IMO negotiations and outcome hereof for Maersk", "Review fleet considerations for the future", "Review LNG market and other current and future fuel types", "Review decarbonisation ambitions". The Board met 10 times; attendance ran from 95.2% to 100% across members.

The revalidated double materiality assessment "was approved by Executives in our Risk and Compliance Committee and the Audit Committee" (page 53).

Integration of sustainability-related performance in incentive schemes

Reference: page 45; page 44; page 52. The index incorporates GOV-3 and E1.GOV-3 by reference to the separate Remuneration Report (pages 111, 113).

In 2025 "the core elements of the Executive Board's remuneration remained consistent, with variable components fully linked to business results, ensuring alignment between executive remuneration and shareholders' interest, over the short- and the long-term incentive plan also included ESG targets within the overall performance scorecard" (page 45).

The Remuneration Committee "reviews sustainability-linked targets as part of the long-term incentive programme for the Executive Leadership Team" (page 52), and in 2025 acted to "Review, monitor and present proposal to the Board for the 2025 and 2026 scorecards (including KPIs and targets)" (page 44).

Aggregate Executive Board remuneration awarded for 2025 was USD 15m: USD 3m fixed pay, USD 3m short-term cash incentives, USD 6m long-term share-based incentives and USD 3m in connection with redundancy, resignations and release from duty to work. Board fees totalled USD 2m (page 45).

Gap: the Annual Report gives no percentage of variable remuneration linked to sustainability or climate. The datapoint "Information on sustainability-linked remuneration" (GOV-3 paragraphs 27, 29a-e; E1.GOV-3 paragraph 13) is incorporated by reference to the Remuneration Report, outside this document (page 113).

Statement on due diligence

Reference: page 55; index pages 111 and 114 (GOV-4 paragraph 30, SFDR).

"Due diligence is a cornerstone of our approach to responsible business: It enables us to identify, mitigate and monitor potential adverse environmental and social impacts linked to business activities in our operations and value chain." Commitments follow the UN Guiding Principles on Business & Human Rights, the OECD Guidelines for Multinational Enterprises and the UN Global Compact, reflected in a public human rights policy statement, the Code of Conduct and the Supplier Code of Conduct.

The risk-based approach "combines standalone human rights assessments plus integrating human rights into existing due diligence processes", naming Commit, upstream supplier and third-party labour risk assessments, integrity screening of high-risk suppliers, low-emissions fuel sourcing due diligence, internal audit, and downstream customer screening, cargo due diligence, responsible ship recycling and M&A reviews.

Five prioritised salient risks are tabulated with the group at highest risk and a page reference: working conditions including wages, benefits, hours and accommodation (p.93); health and safety (p.91); violence and harassment at work (p.103); access to remedy (p.102); and just transition for communities and workers connected to decarbonisation (p.66). In 2025 Maersk "began work to refresh our corporate human rights saliency assessment", to be finalised in early 2026.

Risk management and internal controls over sustainability reporting

Reference: page 44, where the text carries explicit GOV-5 paragraph 36a-e markers; page 53; page 59.

Control environment (36a, 36b): the Board, Audit Committee and Executive Board "regularly assess material risks and internal controls associated with the company's integrated reporting process. This includes sustainability reporting, where work to mature our ESG KPIs was undertaken during 2024 and 2025 with a focus on improving and implementing controls to support completeness and accuracy of reported ESG data."

Risk assessment (36c): the annual enterprise risk exercise "also includes sustainability reporting risks, including addressing risks of incompleteness and inaccuracy of reported ESG data by ensuring that clear definitions and procedures are in place and that process maps, risk assessments and internal controls have been implemented."

Control activities (36d): controls are "defined and implemented for each business segment, including internal controls that are performed by relevant functions in relation to ESG KPIs." Monitoring (36e): "Material weaknesses, omissions and violations are reported to the Executive Board." Group Internal Audit "acts independently of the Executive Board", its Head reporting to the Chair of the Board and the Audit Committee.

Five key estimates are tabulated with their impact on reported data (page 59).

Strategy, business model and value chain

Reference: pages 10-11; page 58; page 72. The index routes SBM-1 to Business model (p.10), Sustainability strategy (p.51), note 2.1 (p.130) and Social performance data (pp.94-98).

Business model (page 10). Three segments: Ocean, Logistics & Services, Terminals. Ocean deployed 721 container vessels and moved 12.9m FFE serving over 500 ports; Logistics & Services held more than 9,300k sqm of warehousing across 500+ sites and managed 7.0m FFE of First Mile volumes; Terminals recorded 14.3m moves and 13,780+ vessel calls across 53 operating facilities in 29 countries.

Dependencies are stated directly: "Our business relies on natural resources such as steel for our assets and fossil fuels and biomass for conventional and e- and bio-methanol fuels", and "Maersk is a significant emitter of greenhouse gases, and we target realising net-zero emissions by 2040."

Value chain scope (page 58): the assessment "covered both upstream partners, such as shipyards, fuel suppliers, equipment manufacturers and manning agencies, and downstream stakeholders, including retailers, manufacturers, freight forwarders, customs authorities and port operators."

EU Taxonomy (page 72): aligned revenue rose to 9% from 5%, aligned CAPEX was 19%, aligned OPEX 11%. Of aligned revenue, 5% (USD 2.4bn) is Ocean, 4% (USD 2.2bn) Terminals and USD 17m Logistics & Services.

Interests and views of stakeholders

Reference: pages 56-57. Listed in the index against Stakeholder engagement and carried under the E2, E4, E5, S1, S2 and S3 topic-level entries (pages 111-113).

"Our stakeholder landscape spans seven key stakeholder groups consisting of both affected groups and users of our published information and including vulnerable populations such as indigenous communities and underrepresented groups in our workforce" (page 56). The seven are 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.

Responsibility is allocated by topic: "workforce engagement is anchored in the People function and Safety & Resilience, or in Sustainable procurement, depending on the topic" (page 56).

2025 examples: Maersk "hosted its first Sustainable Procurement Awareness Week"; at Pier 400 in Los Angeles "local outreach prompted APM Terminals to intensify engagement around workforce development, environmental stewardship and emergency preparedness" (page 56). Customers opting for ECO Delivery Ocean "increased to 460 during 2025, a 34% year-on-year increase" (page 57).

"Insights gathered through such engagements inform our strategy refresh" (page 57). No distinct channel for the Board to receive stakeholder views is described.

Material impacts, risks and opportunities and their interaction with strategy and business model

Reference: page 53; pages 61-62, 87-88, 100-101.

"Maersk reports on 29 IROs representing the areas where Maersk has material impact on people and the planet or faces material financial risks and opportunities... this list does not provide an exhaustive overview of all IROs relevant to Maersk" (page 53).

The 29 split into 14 environment, 9 social and 6 governance IROs (pp.61, 87, 100). Each entry states where the IRO sits, its time horizon and, for social topics, the affected group. Three value chain maps place each numbered IRO where it arises.

Financial materiality (page 53): "While most topics are material from an impact perspective, remediation costs, reputational risks and the ability to attract and retain critical talent are also financially material."

2025 amendments: the invasive species impact was expanded "to also include land and air transportation"; ecosystem degradation from construction was narrowed to "construction and expansion activities"; the diversity IRO was amended "to focus on equal rights and equal treatment" (pages 53, 61, 87).

"None of the identified material risks are expected to cause material adjustments to carrying amounts of liabilities reported in the financial statements in the next annual reporting period" (page 53). Climate risk identification is also under E1-2 and resilience under E1-3 (2025 ESRS numbering).

Description of the processes to identify and assess material impacts, risks and opportunities

Reference: page 53; page 58.

The double materiality assessment is "aligned with the European Sustainability Reporting Standards (ESRS)" and "reviewed annually". 2025 was a revalidation: "Since the previous assessment in 2024, our internal context has remained largely unchanged, while external developments prompted a revalidation" (page 53).

Impact materiality (page 58): "Maersk uses an internally developed scoring methodology for each of the 10 ESRS topical standards... Severity (scale, scope and irremediable character) and likelihood are scored from 1 to 5 and weighted 50/50 for most topics. For human rights-related topics, severity carries a higher weight (75%). A threshold score of 3 ensures inclusion of significant or critical impacts in external reporting."

Risks and opportunities (page 58): assessment "aligns with our ERM framework... In 2025, we advanced scenario-based modelling to quantify ESG risks, including inherent and residual risk scores."

Nature: "Environmental impacts are informed by Maersk's 2025 LEAP assessment" (page 58), but "IROs for pollution, water use and the circular economy were assessed through a desktop study at group level, not at location level" (page 53). Time horizons follow ESRS 1 (page 58). Climate-specific scenario analysis is also presented under E1-2 (2025 ESRS numbering).

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: pages 111-115.

Maersk prints a genuine ESRS content index, "Disclosure requirements in ESRS covered by Maersk's Annual Report 2025" (pages 111-112), listing each covered DR with section and page. It covers ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2), the topic-level entries (E1.GOV-3, E1.SBM-3, E1.IRO-1, E2/E4/E5.IRO-1, E4.SBM-3, S1/S2/S3.SBM-2 and SBM-3, G1.GOV-1, G1.IRO-1) and the topical standards E1, E2, E4, E5, S1, S2, S3 and G1. ESRS E3 and ESRS S4 do not appear.

Absent from the topical listings: E1-7; E2-5; E4-6; E5-6; S1-7, S1-8, S1-11 to S1-13, S1-15; and S3-5.

An "Incorporation by reference" table (page 113) routes GOV-3 and the S1-16 CEO pay ratio to the separate Remuneration Report, GOV-1/GOV-2/GOV-5 to Corporate governance, and revenue by sector to note 2.1.

A third table (pages 114-115) lists datapoints deriving from other EU legislation with a Material / Not material key. Marked not applicable: E1-7 GHG removals; E1-5 nuclear, coal and crude oil fuels; E3-1 and E3-4 "All disclosures"; E5-5 non-recycled and radioactive waste; and S4-1 and S4-4 "All disclosures". Marked "Phased in": E1-9 paragraphs 67(c) and 69.

Phase-in: "In 2025, we have continued to apply the phase-provisions as per the EU regulation" (page 58). Entity-specific topics: Data and AI ethics (p.106) and Responsible tax (p.107).

Transition plan for climate change mitigation

Reference: pages 64-65; index page 111.

The plan runs to SBTi-validated 2030 and 2040 targets on a 2022 baseline and rests on "two fundamental decarbonisation drivers - efficiency measures and energy shifts", across five levers: network efficiency, asset efficiency, electrification of owned assets, energy shifts of business partners, and fuel shifts.

Approval and ownership (page 65): "Our transition plan is approved by the Executive Leadership Team and the Board of Directors." "The Chief Operating Officer owns the transition plan and execution."

Scenarios and gaps (pages 64-65): the plan "includes three possible scenarios for the IMO Net-Zero Framework, optimistic, base case and pessimistic". After the October 2025 postponement of the IMO vote, "we see a possible move from a base-case fuel shift scenario towards a more pessimistic fuel shift scenario". The chart shows gaps to target of 4.8 and 1.4m tonnes CO2e at 2030 and 6.2m tonnes of residual emissions at 2040, to be "neutralised in accordance with the net-zero criteria of the Science Based Targets initiative".

Financing (page 65): 2025 expenditure by lever - asset efficiency approx. USD 1,700m, electrification of own assets approx. USD 200m, fuel shifts approx. USD 200m; two levers N/A. The Green Finance Framework "aligns with EU Taxonomy criteria", and since 2021 an internal shadow carbon price of USD 75 per tonne has applied to investment decisions.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate content (pages 53, 65, 71). This DR did not exist under the 2023 ESRS the report was prepared against.

Classification (page 53): "two main climate-related risks identified: transition risks, which have for a long time been part of our enterprise risk landscape, and physical risks".

Physical risk methodology (page 71): the 2025 assessment "covered more than 1,400 own and third-party assets, including terminals, warehouses, offices, and data centres, to identify exposure to hazards such as flooding, storm surge, windstorms, heatwaves and water stress", "in partnership with Swiss Re using its Risk Data Services platform", with Annual Expected Loss projected to 2050 and 2100.

Scenarios and stated warming (page 71): "SSP1-2.6 representing a sustainability trajectory with 1-2°C warming, SSP2-4.5 as a middle-of-the-road scenario with 2-3°C warming, and SSP5-8.5 reflecting fossil-fuelled development with 3-5°C warming. The primary modelling was based on SSP2-4.5." A high-emission scenario is therefore used for physical risk.

Timing (page 59): the Swiss Re platform replaced "a Cambridge Centre for Risk Studies assessment from 2022", so prior-year numbers are not comparable.

Gap: transition risk uses three IMO Net-Zero Framework scenarios (page 65), not a named 1.5°C-aligned scenario.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 climate content (pages 63, 65, 71). This DR did not exist under the 2023 ESRS the report was prepared against.

Maersk performs no resilience analysis as defined by the ESRS. What it discloses:

Physical resilience (page 71): "Maersk is developing resilience strategies, site-specific assessments and mandatory climate risk reviews for new projects. On-site assessments at three APM Terminals, including Lázaro, Mobile and Pipavav, led to a focus for future actions such as topographical surveys, infrastructure reviews, evaluation of off-site dependencies, enhanced maintenance and emergency response plans." And: "While we do not have a specific target for physical climate risks... we have contingency plans in place for hubs and assets across our operations."

Transition resilience (page 65): the three IMO scenarios each carry "different implications for lower-GHG-emission fuels scaling and demand and therefore a corresponding need to adapt our transition plan".

Uncertainty (pages 63, 65): "we are aware that we have gaps, and we depend on certain external factors for successfully reaching our near-term 2030 climate targets."

Capacity to adapt: the Green Finance Framework funds emission-reduction projects across vessels, warehouses, terminals and electrified equipment (page 65). No financial flexibility analysis is given.

Policies related to climate change mitigation and adaptation

Reference: index page 111, which maps E1-2 to Climate change, pages 63-71; page 53.

The climate chapter carries no single policies block.

Overarching: the Employee Code of Conduct "serves as the overarching policy document for many sustainability topics, including climate, with an objective to minimise harm to the environment through a scope focused on decarbonisation in alignment with the SBTi" (p.53).

Fuel sustainability (page 68): "Maersk's requirements for lower-GHG-emission fuels" sets three rules - third-party certification with "a proof of sustainability"; "all fuels must meet the minimum reductions of the EU Renewable Energy Directive which is 65% for biofuels and 70% for e-fuels"; and "Maersk's preference is for second-generation feedstocks such as wastes and residues." Lifecycle analysis "is governed by two policies, which are available online": the methanol and biofuel sustainability requirements. In 2025 Maersk "initiated a targeted review of our fuel sustainability policies to assess the potential role of selected first-generation, crop-based fuels such as ethanol".

Financing policy (page 65): the Green Finance Framework and the USD 75 per tonne internal shadow carbon price applied in all investment committee decisions.

A public recalculation policy governs restatement of inventories and targets (p.76). No standalone climate adaptation policy is disclosed.

Actions and resources in relation to climate change policies

Reference: pages 66-71.

Network efficiency (page 66): Gemini "became fully operational in collaboration with our partner Hapag-Lloyd", with "29 mainliner services"; "Our Gemini services nearly halve port calls per service compared to traditional networks". "APM Terminals hubs have boosted productivity by 14% over two years, cutting time of port stays by 15-20%."

Asset efficiency (page 67): Maersk "completed more than 425 fuel saving initiatives on 230 of its owned vessels" and "approximately 215 retrofit initiatives on 150 TC vessels"; 10 dual-fuel methanol vessels were delivered, taking the dual-fuel fleet to 19, with 94 in total.

Fuel shifts (pages 68-69): first e-methanol bunkering of Laura Mærsk at the Kassø plant; trials with "e-methanol fuel blends mixed with 10% and 50% ethanol"; a framework supply agreement with Avenir Marine for liquefied biomethane from 2027; first volumes from the Goldwind offtake (500,000 tonnes annually) due in 2026.

Electrification (page 69): an agreement with SANY Marine "to replace some 500 diesel-powered terminal tractors with battery-electric models by 2030"; the Rijeka Gateway terminal "fully powered by renewable electricity"; APM Terminals electricity 62% renewable, up from 46%; "a reduction of more than 16% in absolute scope 1 and 2 emissions in our Terminals in 2025 compared to our 2022 baseline". Expenditure by lever is given under E1-1 (page 65).

Targets related to climate change mitigation and adaptation

Reference: page 64; page 60; pages 75-76.

2030 targets against a 2022 base year (pages 60, 64): absolute scope 1 emissions −35%; renewable electricity sourcing 100%; absolute scope 3 emissions −22%. 2040: total scope 1 and 2 −96% and scope 3 −90%.

2025 progress and gaps (page 75): scope 1 −1% versus 2022, a 34 point gap to 2030; renewable electricity sourcing 38% (2024: 29%), a 62 point gap; scope 3 +7% versus 2022, a 29 point gap. Sub-targets: own container shipping scope 1 and 3 well-to-wake −1% against −35%; subcontracted shipping −10% against −17%; other operations scope 1 −11% against −42%; use of sold products covering distributed fossil fuels +62% against −42%, a 104 point gap.

Validation and coverage (page 76): "Maersk has validated near-term and net-zero climate targets by Science Based Targets initiative (SBTi)". The near-term target "covers >95% of scope 1 and 2 and >66% of scope 3; the net-zero coverage is >95% and >90% respectively." "The emissions reduction targets are gross targets, meaning that GHG removals, carbon credits or avoided emissions are not currently considered as means of achieving the GHG emission reductions."

"Maersk maintains its 2030 climate targets, fully aware of the difficulty and scale of the work ahead" (page 63). No adaptation target exists: "we do not have a specific target for physical climate risks" (page 71).

Energy consumption and mix

Reference: page 78; index page 111.

2025 (2024 in brackets), GWh: total energy consumption 120,161 (121,008), down 1%. Fossil energy 118,197 (117,664), of which fuel oils 116,654 (116,789), gas fuels 135 (101), other fuels 681 (14) and electricity and heating from fossil sources 727 (760). Renewable energy 1,964 (3,344), of which renewable electricity 415 (303), fuels from renewable sources 1,524 (3,034) and self-generated non-fuel renewable energy 25 (7).

Intensity and mix: energy intensity 2.23 GWh per USDm (2.18); share of renewable energy 2% (3%); share of fossil fuel sources 98% (97%). "All of Maersk's energy consumption is considered as related to high climate impact sectors."

Maersk explains the fall in renewables plainly: "In 2025, changes in our fuel mix resulted in a significant decrease in consumption of fuels from renewable sources and a corresponding increase in consumption of gas fuels and other fuels, including grey methanol." Self-generated renewable energy rose "by more than three times compared to 2024, primarily due to the increased usage of solar power in Bahrain", and renewable energy production reached 30 GWh (9).

Appendix B marks the E1-5 datapoints for nuclear energy and for coal and crude oil fuel consumption as not applicable, and routes the fossil and renewable, natural gas, purchased electricity and high-climate-impact intensity datapoints to page 78 (page 114).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 73-77; index page 111.

1,000 tonnes CO2e, 2022 base / 2024 / 2025: gross scope 1 34,416 / 33,939 / 33,953 (0%), of which 15% sits under the EU ETS (2024: 16%). Gross location-based scope 2 441 / 431 / 470 (+9%); gross market-based scope 2 421 / 356 / 313 (−12%). Total scope 3 47,980 / 49,232 / 51,183 (+4%). Total GHG emissions 82,817 / 83,527 / 85,449 market-based (+2%), and 85,605 location-based.

Scope 3 categories, 2025: purchased goods and services 4,667 (−13%); capital goods 3,658 (+45%); fuel and energy-related 5,893; upstream transportation and distribution 22,103 (−7%); waste 3; business travel 120; employee commuting 24; upstream leased assets 242 (−61%); use of sold products 13,424 (+38%); end-of-life treatment 548 (+84%); downstream leased assets 166; investments 334 (−42%). "Of the 15 scope 3 categories in the GHG Protocol, 12 categories are currently determined as applicable", with 9, 10 and 14 excluded (page 74).

Maersk attributes the increase to categories 2, 11 and 12, "related to Maersk taking delivery of an increased number of vessels, and increased volumes of traded maritime fuels, and containers sold" (page 73).

Intensity and biogenic (pages 76-77): GHG intensity 1.59 location-based and 1.58 market-based kt CO2e per USDm (2024: 1.51); biogenic emissions outside scope 1 fell 50% to 417. 30.44% of scope 3 is modelled with EcoTransIT World (page 74).

Internal carbon pricing

Reference: page 65, which the index lists as "Financing our transition plan" (page 111).

"Since 2021, Maersk has applied an internal shadow carbon price of USD 75 per tonne of GHG in investment decisions. This price, based on abatement costs and future carbon tax expectations, is used for projections - not actual emissions - to ensure regulatory and carbon cost considerations in all investment committee decisions."

The disclosure sits inside the transition plan financing block alongside the Green Finance Framework, which "enables funding for emission-reduction projects through various instruments" and "aligns with EU Taxonomy criteria and covers areas such as newbuild and retrofitted vessels, warehouses, terminals and electrified equipment" (page 65). Governance of the scheme is stated in the same block: "The Chief Operating Officer owns the transition plan and execution, and the ELT and Board regularly discuss key market trends, progress against science-based targets, and the implications of IMO regulation to integrate the energy transition into business planning."

Gaps: the type of scheme is identified as a shadow price and the price level and year of introduction are given, but Maersk does not disclose the share of gross GHG emissions covered by the price, nor which scopes or business segments fall within its scope beyond "all investment committee decisions". No price trajectory to 2030 or 2040 is disclosed.

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

Reference: page 71; index pages 111 and 114.

Physical risk is quantified asset by asset. The 2025 Swiss Re assessment calculated Annual Expected Loss (AEL) for material damage and revenue loss, with 2050 projections under three SSP scenarios. Top five assets by 2025 AEL (page 71): APM Terminals Lázaro Cárdenas, Mexico USD 19.8m, rising to 21.4/22.5/23.6 by 2050 under SSP1/SSP2/SSP5, flood 25% and cyclone 75%; Brasil Terminal Portuário USD 12.6m (13.6/14.3/15.0), flood 100%; South China Oceangate, Guangzhou USD 10.8m (11.7/12.3/12.9), flood 100%; Port of Tanjung Pelepas USD 10.8m (11.7/12.3/12.9), flood 15% and cyclone 85%; South Florida Container Terminal USD 10.4m (11.3/11.9/12.5), cyclone 100%.

Phase-in (page 114): Appendix B marks paragraph 67(c) (real estate by energy efficiency class) and paragraph 69 (financial opportunities from climate change actions) as "Phased in"; paragraph 66, assets at material financial risk, is routed to page 71.

Gaps: no anticipated financial effect is quantified for transition risk, and the physical assessment covers land-based assets only, excluding vessels. At group level, "None of the identified material risks are expected to cause material adjustments to carrying amounts of liabilities reported in the financial statements in the next annual reporting period" (page 53).

Policies related to pollution

Reference: page 81; index page 111.

"Maersk's Environment & Ecosystems Policy Architecture provides a unified framework that guides employees in minimising material environmental impacts. It sets out principles aligned with our environmental management systems and global policies, covering key areas such as pollution prevention, ecosystem health and biodiversity protection, and responsible waste management."

"Maersk actively mitigates pollution risks by following a comprehensive management framework and strict guidelines for prevention and response across all land and sea operations. These measures include air quality management, chemical handling protocols, spill prevention standards and detailed emergency response procedures."

"In Maersk's Ocean business, pollution is regulated through the International Convention for the Prevention of Pollution from Ships (MARPOL) and International Maritime Organization (IMO) regulations." Ocean also holds "ISO 14001 targets in place for waste and pollution", and Maersk expects the revised ISO 14001:2026 standard, which "introduces explicit consideration of biodiversity and climate resilience" (page 79).

The policy text covers air, water and soil pollution prevention. It does not address substances of concern or microplastics, consistent with the absence of those sub-topics from the double materiality assessment (pages 54, 61).

Actions and resources related to pollution

Reference: page 81; page 80; index page 111.

Spills (page 81): "In 2025, APM Terminals improved their incident management process for spills, combining previously separate incident reporting and incident management standards for increased transparency and response consistency. Updates were also made to the spill prevention and management standard for landside businesses in Maersk, ensuring risk-based prevention measures and updated training for facility personnel."

Containers lost at sea (page 81): "in 2025, Maersk rolled out a parametric roll risk management solution that enables crews to optimise route planning by incorporating real-time weather forecasts, along with an alert system thereby avoiding adverse seas that could cause dangerous rolling conditions. In addition, advanced technology lashing systems, equipment and software... were developed and installed onboard." Maersk participated in the TopTier Joint Industry Project, "successfully concluded at end-2024", whose final report reached the IMO in 2025.

Anti-fouling and biocides (page 80): "all vessels are coated with anti-fouling paint and regular inspections are performed in line with vessel's Biofouling Management Plan. In addition, to improve environmental friendliness of anti-fouling paints, a switch to ultralow biocide antifouling systems has been initiated for the fleet."

No monetary amounts are allocated to pollution actions.

Targets related to pollution

Reference: page 81; page 60; index page 111.

Maersk discloses one quantified pollution target, an annual one: "No major uncontained hydrocarbon spills and releases to the environment. In 2025, Maersk did not record any major spills (above 10 m3) to the environment" (page 81). The environmental target summary shows the annual target as "No major uncontained hydrocarbon spills and releases (>10 m3) to the environment", with a target of 0 and a 2025 result of 0 (page 60).

On waste, the company states the limit of its target setting: "While we do have Ocean-related ISO 14001 targets in place for waste and pollution, we do not have any long-term waste targets at Maersk, we work with continuous improvement of our waste management practices across all our business segments" (page 81).

Gaps to note. No target is set for the two other material pollution impacts. Air pollutants from vessels and landside or air transportation carry no reduction target, although SOx, NOx, NMVOCs, CO, PM10, PM2.5 and black carbon are all measured and reported (page 84). Discharged wastewater to the sea, including scrubber, bilge, sewage and grey water, carries neither a target nor a reported volume, although it is one of the three material E2 impacts (page 61).

Pollution of air, water and soil

Reference: page 84; index pages 111 and 114 (E2-4 paragraph 28(a), SFDR).

Air pollutants, 1,000 tonnes, 2025 (2024): SOx 94 (97); NOx 699 (704); NMVOCs 18 (16); CO 125 (80); PM10 55 (58); PM2.5 43 (40); black carbon 3 (3). "For 2025, Maersk's air pollutant emissions followed the trend in the energy mix and consumption. SOx and NOx emissions decreased as a result of lower bunker consumption. The significant increase in CO emissions is a result of increased air freight activity and related kerosene consumption."

Environmental incidents: hydrocarbon spills greater than 10 m3, 0 (2024: 0); containers lost at sea, 0 (2024: 5). "For the fourth consecutive year, we had no significant oil spills from our operations during 2025. We also did not have any container loss at sea."

Methodology: pollutants are "prepared and stated based on the first version of the Stockholm Environment Institute's (SEI) reporting guide, except for BC and PM10 reporting from the fleet of Maersk, which is based on the methods outlined by IMO in MEPC 75/7/15". Where scrubbers are used, "SOx output is assumed to be maximum for the operating area in which the vessel spends 80% of time".

Gap: emissions to water and to soil are not quantified, and no volume is given for discharged wastewater to the sea even though that discharge is a material impact (page 61).

Anticipated financial effects from pollution-related impacts, risks and opportunities

Reference: the ESRS content index lists E2-6 against "Environment and ecosystems", page 84 (index page 111).

The cross-reference does not resolve to an E2-6 disclosure. Page 84 carries the environmental incidents table (hydrocarbon spills over 10 m3 and containers lost at sea) and the air pollutant table with their accounting policies. No anticipated financial effect from pollution appears on that page.

What the statement does say on the subject, elsewhere:

• The hydrocarbon spill impact description names a cost consequence: adverse impacts "from the loss of containers at sea, resulting in the release of pollutants into the ocean and accompanying costs for Maersk to clean up polluting materials" (page 61).
• At group level, "None of the identified material risks are expected to cause material adjustments to carrying amounts of liabilities reported in the financial statements in the next annual reporting period" (page 53).
• A related KPI was dropped as immaterial: the "operating expenditures (OPEX) in conjunction with major incidents and deposits" KPI was discontinued for 2025 "due to the immaterial amounts of operational expenditures Maersk has in relation to such activities" (page 59).

Recorded as reported because the company's own index lists the requirement with a page reference, but the referenced page contains no financial effect figures.

Transition plan on biodiversity and ecosystems

Reference: pages 79-80; index page 112.

Maersk discloses no biodiversity transition plan as such. What the index points to is the maturing of its TNFD LEAP assessment.

"In 2024, Maersk initiated an assessment using the Taskforce on Nature-related Financial Disclosure's LEAP (Locate, Evaluate, Assess, Prepare) framework to identify and evaluate key nature-related issues... In 2025, we advanced this approach by integrating LEAP findings more deeply into our environment management frameworks" (page 79).

"Maersk's business segments vary significantly in their nature-related risks and in the maturity of their LEAP implementation. APM Terminals is currently the most advanced, as its fixed locations make it easier to identify risks... Logistics & Services faces ecosystem and biodiversity risks primarily linked to land expansion at existing and greenfield sites. In 2025, we focused on laying the groundwork to mature the LEAP approach across all segments. This foundation will enable expanded efforts in 2026, as Maersk aims to embed LEAP as a strategic tool and value driver for the business" (page 80).

Forthcoming requirements named are "the UN High Seas Treaty, and the revised ISO 14001:2026 Environmental Management Standard" (page 79). No timeline, milestones or resources are attached.

Policies related to biodiversity and ecosystems

Reference: page 80; index pages 112 and 114 (E4-2 paragraph 24(b)(c)(d), SFDR, routed to pages 79-80).

The "Environment & Ecosystems Policy Architecture provides a unified framework that guides employees in minimising material environmental impacts... covering key areas such as pollution prevention, ecosystem health and biodiversity protection, and responsible waste management."

Specific prohibitions and controls (page 80):

• "Maersk enforces a strict zero-tolerance policy against the transportation of illegal wildlife and timber, as outlined on Maersk.com. We also prohibit the carriage of any products derived from sharks or whales."
• "we maintain rigorous internal controls to prevent misdeclaration and unauthorised transboundary movement of hazardous waste, including plastic scrap, battery waste, and industrial waste."
• "Maersk complies with international conventions to perform pest control, ensuring vessels adhere to the Company Pest Control Plan."
• Biofouling is managed under each vessel's Biofouling Management Plan, with "a switch to ultralow biocide antifouling systems" initiated for the fleet.

Underwater Radiated Noise management is developed "in line with IMO guidelines" (page 80). No deforestation or sustainable-land policy commitment is quoted beyond the illegal timber prohibition.

Actions and resources related to biodiversity and ecosystems

Reference: page 80; index page 112.

Locating exposure: "To evaluate our presence in ecologically sensitive areas, we utilised data from the World Database on Protected and Conserved Areas, the World Database of Key Biodiversity Areas as well as the IUCN Red List of Threatened Species. Initial findings based on the geolocations of our sites per 1 October 2025, indicate that 61 (of 62) terminals, 888 (of 919) inland logistics facilities, and 407 (of 420) offices are in or near ecologically sensitive locations. Our key biodiversity impacts from locations come from greenfield construction and expansion projects of existing sites. In 2025, we had 22 of such projects, where environmental assessments were performed in accordance with local regulatory requirements."

Ocean actions (page 80): "In 2025, our Ocean segment contributed to the TNFD's new guidance for assessing material nature-related risks in the maritime sector. Trials using the new guidelines are underway and will continue into 2026." StarConnect capabilities were improved "to monitor our presence in marine protected areas and particularly sensitive sea areas, integrating new updates to the World Shipping Council's Whale Chart". At the 2025 UN Ocean Conference "Maersk committed its entire operated fleet to the 10,000 Ships for the Ocean initiative". No monetary resources are attached to these actions.

Targets related to biodiversity and ecosystems

Reference: page 80; index page 112.

Maersk states the position plainly: "Currently, Maersk does not have group-wide targets specifically addressing ecosystem health and biodiversity. However, we continuously monitor performance across both landside and ocean operations to better understand our impacts" (page 80).

In the absence of targets, effectiveness is tracked through the LEAP roll-out and the site-exposure screening described under E4-3: annual geolocation screening of terminals, inland logistics facilities and offices against the World Database on Protected and Conserved Areas, the World Database of Key Biodiversity Areas and the IUCN Red List, and environmental assessments for each of the 22 greenfield construction and expansion projects undertaken in 2025 (page 80).

The closest quantified commitments sit under other standards and address emissions rather than biodiversity: the SteelZero commitment "to use 50% lower-emission steel by 2030 on a pathway to using 100% net-zero emission steel by 2040" (page 83), and the statement that "We do not currently have targets to address the wider environmental impacts from the steel and fuel value chains aside from our GHG emissions targets" (page 83).

No biodiversity offsets are used or referenced, and no ecosystem restoration target is set.

Impact metrics related to biodiversity and ecosystems change

Reference: page 80; index pages 112 and 114.

The metrics disclosed are site-exposure counts rather than biodiversity condition measures. Per the geolocations of sites at 1 October 2025, "61 (of 62) terminals, 888 (of 919) inland logistics facilities, and 407 (of 420) offices are in or near ecologically sensitive locations", assessed against the World Database on Protected and Conserved Areas, the World Database of Key Biodiversity Areas and the IUCN Red List of Threatened Species. Maersk reports "22 of such projects" of greenfield construction and expansion in 2025, "where environmental assessments were performed in accordance with local regulatory requirements" (page 80).

Appendix B lists the E4.SBM-3 paragraph 16(a)(b)(c) datapoint, "Activities in biodiversity-sensitive areas, impacts related to land degradation, desertification and soil sealing, and operations affecting threatened species", as material and routes it to page 61 (page 114).

Gaps: no land-use change figure (land use, sealed area, nature-oriented area), no species population or extinction-risk metric, and no ecosystem extent or condition metric is reported. Underwater radiated noise and invasive species, both material impacts, are managed through plans and engagement rather than measured (page 80).

Policies related to resource use and circular economy

Reference: pages 81-83; index page 112.

Waste: the "Environment & Ecosystems Policy Architecture provides a unified framework that guides employees in minimising material environmental impacts", covering "pollution prevention, ecosystem health and biodiversity protection, and responsible waste management" (page 81). In Logistics & Services Maersk "rolled out an updated Waste Management standard, Waste Management Plans, and training modules for operational personnel through the new Waste Coordinator program" (page 81).

Ship recycling (page 82): "Maersk's Responsible Ship Recycling Standard (Maersk's RSRS) establishes comprehensive requirements to ensure that all ship recycling activities are carried out in a safe, ethical and environmentally sound manner... Maersk's RSRS meets the different global regulatory sets of requirements, including those in and outside of EU." The standard is publicly available.

Critical resources (page 83): "Maersk's approach to sourcing steel and lower-GHG-emissions fuels is governed by our Environment & Ecosystems Policy Architecture, which outlines our sustainability requirements for lower-GHG-emissions fuels and our efforts to understand and mitigate negative impacts across fuel and steel value chains."

No policy on resource inflow reduction, product design for circularity or secondary material content is disclosed.

Actions and resources related to resource use and circular economy

Reference: pages 81-83; index page 112.

Waste data and governance (page 81): "In 2025, for the first time, all Maersk-operated vessels had available garbage e-logbooks to capture actual waste generated from vessels... Further actions are ongoing with shore side waste reception facilities to improve line of sight of eventual waste handling and treatment." APM Terminals "focused on setting up a global waste management governance framework and conducting gap analyses at their respective sites". A "zero-waste framework in Pier 400 in Los Angeles" was established.

Circularity pilots (page 81): "we have set clear goals to minimise plastic waste across our fleet. In 2025, we successfully piloted circular economy-based projects with focus on plastic/polymer and electronic waste."

Ship recycling (page 82): the Hong Kong Convention "entered into force" in 2025 and Maersk supports it as the global legal standard; the company is "collaborating with partners to develop commercially viable solutions for the scaling of ship recycling facilities capable of handling post-Panamax vessels, including Memorandums of Understanding and Letters of Intent at locations including Bahrain and Egypt in 2025".

Steel (page 83): "Again in 2025, we reported our yearly steel consumption to the SteelZero Coalition." No monetary resources are disclosed.

Targets related to resource use and circular economy

Reference: pages 81-83; index page 112.

Waste (page 81): no target. "While we do have Ocean-related ISO 14001 targets in place for waste and pollution, we do not have any long-term waste targets at Maersk, we work with continuous improvement of our waste management practices across all our business segments." A directional goal is stated for one stream: "we have set clear goals to minimise plastic waste across our fleet", without a figure or date.

Ship recycling (page 82): a qualitative target, "Increase the global capacity for the responsible and financially viable recycling of post-Panamax vessels", reported against as: "In 2025, we continued our advocacy work and efforts to increasing global capacity for responsible ship recycling. We welcome the Hong Kong Convention as the global baseline for responsible ship recycling." No metric or target year is attached.

Steel (page 83): the one dated, quantified commitment - "As members of Climate Group's SteelZero coalition, we have made a commitment to use 50% lower-emission steel by 2030 on a pathway to using 100% net-zero emission steel by 2040." Maersk adds: "We do not currently have targets to address the wider environmental impacts from the steel and fuel value chains aside from our GHG emissions targets."

No target is set for resource inflows, secondary material content or waste diversion.

Resource inflows

Reference: page 85; index page 112.

Maersk reports a single resource inflow metric: total weight of steel consumed, 102,525 tonnes in 2025 against 73,118 tonnes in 2024 as restated (originally 73,394).

The rise is a mix of volume and method: "In 2025, we have updated the methodology... We now report the weight of steel procured during the year. In prior years, we prepared the KPI by combining bill of material data and number of containers produced. In 2025, we have increased the number of containers produced; consequently, the weight of steel sourced has increased from 73,118 tonnes in 2024 to 102,525 tonnes in 2025."

Scope is stated and narrow: "Total weight of steel consumed is the weight of steel used for producing containers. The weight is based on the procured amounts of steel during the year and is collected directly from Maersk's procurement systems. The scope is limited to steel we directly source and does not include steel from our value chain."

Gaps: no total mass of products and technical or biological materials used, no weight of materials by category, and no share of secondary reused or recycled components, materials or intermediary products. The statement acknowledges the wider exposure it does not quantify: "much of the equipment we use across our operations and broader value chain, including vessels, terminal cranes, warehouses and trucks, also contains significant amounts of steel" (page 83).

Resource outflows

Reference: page 85; index page 112.

Maersk's E5-5 disclosure consists of waste figures only. Waste generated totalled 535,000 tonnes in 2025 against 556,000 in 2024, split hazardous 368,000 (2024: 236,000) and non-hazardous 167,000 (2024: 320,000), tagged with EFRAG IDs E5-5_07, E5-5_10 and E5-5_15.

"In 2025, Maersk recorded a 5% decrease in waste generated compared to last year. This is primarily driven by the improved data quality from vessels (actual waste data from 320+ vessels extrapolated to our total fleet), which has had a significant impact on the overall waste. The increase in hazardous waste primarily derives from the sludge reported from vessels, and the subsequent reduction in non-hazardous waste a direct outcome of better reporting and estimation practices for our Ocean segment and Logistics & Services sites. Due to the improved methodology applied this year, the waste reported is not directly comparable to 2024."

Appendix B marks the E5-5 datapoints for non-recycled waste and radioactive waste as not applicable and routes hazardous waste to page 85 (page 114).

Gaps: no information is given on products and materials outflows - expected durability, reusability, repairability, recyclability or recycled content - and no recyclable-content rate for packaging. Waste is reported in total and by hazard class only, with no diversion-from-disposal or disposal-route breakdown. See also E5-5-Waste.

Waste

Reference: page 85; pages 59, 81.

1,000 tonnes: total waste 535 in 2025 (2024: 556; 2023: 517; 2022: 553), of which hazardous 368 (236; 218; 229) and non-hazardous 167 (320; 299; 324).

Method change, not restated (page 59): "We enhanced waste reporting from vessels by using actual amounts recorded in electronic logs for all Maersk Line vessels (320+)... We also updated conversion factors from m3 to tonnes for all MARPOL Annex V categories and improved hazardous/non-hazardous waste classification. Waste data reported in prior years have not been restated as we did not have electronic logs for all Maersk Line vessels at that time."

Composition and estimates (page 85): "Non-hazardous waste primarily consists of municipal and industrial waste, such as food waste, pallets, cardboard, general trash and metal and wood scrap." For land-based operations data comes "from billing and accounting systems or from the procurement/supply management department", while "For some offices and minor sites, where it is challenging to obtain actual waste data, estimates based on FTE counts and Facility-wise sqm are used". Waste estimates are flagged in the uncertainties table (page 59).

Scope 3 category 5, waste generated in operations, was 3,000 tonnes CO2e (page 73).

Gap: no recycling, reuse, recovery or disposal-route split is reported, and the non-recycled waste datapoint is marked not applicable (page 114).

Policies related to own workforce

Reference: pages 89-93; pages 102-103; index pages 112 and 115.

People and culture (page 90): "Our approach is anchored in our Anti-Discrimination, Harassment, Bullying and Violence Policy, designed to proactively foster a culture of respect, as well as mitigating potential harm. The policy is available on Maersk.com... reinforced by our Commit governance rules, Code of Conduct and aligned with international frameworks and standards such as the UN Global Compact and the UN Guiding Principles on Business and Human Rights."

Health and safety (page 92): the HSSE Policy "applies globally across all Maersk's entities, employees and anyone working under Maersk's supervision, including non-employee workers (contracted workers)", and is expanded in the HSSE Commit Rule and HSSE Management Framework.

Employee relations (page 93): two main policies - "The Commit Rule applies to our own employees and describes the fundamental rights of employees", and "Maersk Global Standards on Third-Party Labour applies to contract/third-party labour". Both are "aligned with international standards, such as the UN International Labour Organisation core conventions and the UN Global Compact and cover all fundamental labour rights, including guidelines on forced and child labour, adequate housing and sanitation, wages and working hours."

Appendix B routes the S1-1 paragraph 20-23 datapoints to pages 89-93 and 102-103 (page 115).

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

Reference: pages 56-57; page 90; page 93; index page 112.

Channels (page 56): "Daily manager/colleague interactions; Engagement and inclusion surveys; Grievance mechanisms; Engagement with unions and interest groups; Supplier audits." Engagement "is anchored in the People function and Safety & Resilience, or in Sustainable procurement, depending on the topic."

Survey (page 90): "In 2025, we introduced a new survey approach, the PeoplePulse, designed to better reflect and measure the lived experience of our diverse workforce... In 2025, we had a high participation rate of 89% and achieved a score of 83." The change answered a stated shortcoming: "while engagement levels remain high, only 4 in 10 employees felt sufficient progress after past surveys. Leaders have received survey results and are accountable for acting with their teams, while we track progress through the twice-yearly survey cadence."

Unions (page 93): "We met with the International Transport Workers Federation (ITF) regularly to discuss a variety of topics, including migrant labour considerations within our Malaysia Logistics and Services operations, labour topics in multiple countries in Latin America, facilitation of a successful new collective bargaining agreement in Liberia." Maersk "was actively involved in negotiating the new six-year Master Contract for ports on the US East and Caribbean Coasts".

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

Reference: pages 102-103; index pages 112 and 115.

"Maersk promotes a 'speak-up' culture where everyone is encouraged to voice and share concerns and feels safe doing so... supported by a strict zero-tolerance and non-retaliation policy" (page 102).

Whistleblower programme (pages 102-103): "anchored in the Maersk Commit framework... independently managed on a third-party platform and complete confidentiality is maintained, including the option of anonymous reporting." Reach is quantified: "the mechanism is available in 73 languages via phone hotlines and in 20 languages through the online reporting portal", and is "integral to both our Code of Conduct and Supplier Code of Conduct". Reports "are supported by effective investigations led by independent and impartial investigators, with follow-up actions taken to address violations and implement controls that prevent recurrence."

2025 change: "we implemented a new whistleblower system with enhanced case management capabilities, simplified intake, built-in artificial intelligence, machine translation... To support the rollout, we launched the Speak Up campaign across all our locations, targeting both direct and indirect workers."

Other channels: "direct management or leaders, our Compliance, People or Ombuds functions, and our employee assistance programme".

Taking action on material impacts on own workforce

Reference: pages 89-93; index page 112.

People and culture (page 90): talent is managed "through MPACT - our Performance Management System designed to maximise performance, alignment and career growth... we have identified critical positions across the business." "In 2025, turnover for this category is 4.9%." A Culture and Inclusion team was established in 2025.

Safety (pages 91-92): the multi-year "Protected By Maersk" standardisation programme continued, "while also conducting 146 warehouse and depots HSSE audits and closing over 1,850 improvement actions towards our standards. Maersk also launched a new digitally enabled HSSE platform for audits and inspections in 2025." "More than 15,000 safety and security Gemba walks were conducted by leaders", alongside the "Leading With Care" programme for frontline operational leaders. Business continuity planning reached "100 sites inducted in the system during 2025".

Labour rights (page 93): Maersk "further integrated the Global Standards on Third-Party Labour into APM Terminals' Project Execution department" and "rolled out a compliance tracking app across APM Terminals and Logistics & Services as a single source of truth for documenting due diligence compliance". On pay, "We have advanced our pay transparency and pay equity readiness, with a multidisciplinary project team to prepare for upcoming EU requirements." No monetary resources are allocated.

Targets related to own workforce

Reference: page 86; page 90; page 91; page 59; index page 112.

Two targets with results (page 86): an engagement score target of 84 by 2026, against a 2025 result of 83; and an annual target of 100% of learning teams completed following a high potential incident, achieved at 100% in 2025 (2024: 99%).

"In 2025, we successfully completed 100% Learning Teams to understand and learn from the high potential incidents that were recorded across Maersk's operations. Completion of Learning Teams and acting on the learnings helps us applying a contextual and systemic understanding of what caused the incident to happen and bring the risks under control before someone gets injured" (page 91).

Diversity targets ended in 2025 (page 59): "By the end of 2025, our KPIs and targets expired... Against our targets of having 40% women in management and 30% target nationalities in executive leadership by 2025, we landed at 36% and 19%, respectively." No replacement target is set.

No targets for labour rights (page 93): "While we do not have separate targets for employee relations and labour rights, these topics are part of Maersk's Code of Conduct, which all Maersk's office-based employees are trained in annually."

No lost time incident frequency reduction target is disclosed, although LTIf rose from 1.53 to 1.67 (page 98).

Characteristics of the undertaking's employees

Reference: pages 94-95; index page 112.

Headcount (page 94): 107,638 employees at year end 2025 (2024: 108,160); average headcount 106,890 (106,626). By gender: male 69,662, female 37,261, other 1, not disclosed 714. By contract: permanent 87,153, temporary 20,485, non-guaranteed hours 0 - "Maersk does not employ any employees on non-guaranteed hours contracts, and the majority of Maersk's workforce is on permanent contracts."

By region (page 95): Asia Pacific 26,781; Europe 32,737; Indian subcontinent, Middle East and Africa 23,184; Latin America 11,286; North America 13,650, giving shares of 25%, 30% and 22% with Latin and North America together at 23%.

By country, where above 10% (page 95): India 15,388; Denmark 15,145; China 11,610; USA 10,552. "Denmark has been included in the list as Maersk's seafarer population is employed by a Danish legal entity and thus has been allocated to Denmark. The seafarer population totals more than 11,500 employees."

Turnover (page 96): 15,294 employees left in 2025 (2024: 11,835), a total turnover rate of 14% (11%).

Definitions exclude "employees on garden leave and unpaid leave, contractors and third-party workers" (page 94). Headcount is not broken down by gender and region together, and the FTE figure sits in note 2.2 of the financial statements rather than in the ESRS table.

Diversity metrics

Reference: page 96; page 43; index page 112.

Gender at top management (page 96): 5 women, a 36% share, against 4 and 31% in 2024. The definition is narrow and was restated: "Gender distribution at top management is the number and share of women at Board of Directors (BoD) minus 2 level, compared to the total headcount at the same levels. At Maersk, BoD minus 2 level is CEO and the direct reports to the CEO that are people leaders, excluding executive assistants and other administrative staff. 2024 numbers have been restated accordingly. Had we continued to report using prior-year definitions (JL6+) - the % of Women in leadership in 2025 would have been 29% (27% in 2024)."

Age distribution (page 96): under 30, 21,302 employees or 20% (2024: 23,909 / 22%); 30 to 50, 73,050 or 68% (71,946 / 67%); over 50, 13,286 or 12% (12,305 / 11%).

Board (page 43): 30% women and 70% men, which Maersk states "is not considered to be equal gender representation on the Board, and the Board has set a target for reaching this."

Context (page 59): the 2021-2025 diversity KPIs expired at the end of 2025. Against targets of 40% women in management and 30% target nationalities in executive leadership by 2025, Maersk "landed at 36% and 19%, respectively", and has restated "Gender distribution at top management level" to the Danish Financial Statements Act definition.

Adequate wages

Reference: page 97; page 93; index page 112.

"For 2025, our assessment shows that we have no employees in any country that are paid below the applicable adequate wage benchmark" - 0%, unchanged from 2024 (page 97).

Benchmark methodology (page 97). Inside the EEA, Maersk applies "The minimum wage set in accordance with Directive (EU) 2022/2041... on adequate minimum wages in the European Union", and where none applies, "an adequate wage benchmark from a neighbouring country with a similar socio-economic status or not lower than a commonly referenced international norm such as 60% of the country's median wage and 50% of the gross average wage". Outside the EEA a three-step hierarchy applies, ending in the "Living Wage benchmark (typical family law) as provided by Wage Indicator". "In countries with multiple minimum wage benchmarks, varying by region or industry, the highest minimum wage is initially used to identify employees earning below this threshold."

Excluded from the calculation are "learners, interns, graduates, students, cadets, long-term assignees and inactive employees on unpaid or garden leave" (page 97).

The narrative adds a qualification the metric does not show: "Our 2025 assessment, based on CSRD guidance and benchmarks, confirmed no employees are below adequate wage levels. However, some high-risk locations exist, and we are developing customised solutions for these" (page 93). Adequate wages for contracted labour fall under S2.

Health and safety metrics

Reference: page 98; page 91; index page 112.

2025 (2024): fatalities 0 (1); lost time incidents 552 (493), of which own employees 353 (377) and contractors or non-employees 199 (116); lost time incident frequency 1.67 (1.53), of which own employees 1.29 (1.39) and contractors 3.49 (2.28); learning teams completed following a high potential incident 100% (99%). The five-year LTIf series reads 0.93, 0.93, 1.14, 1.53, 1.67.

LTIf rose "due to a higher number of reported Lost Time Incidents in certain business areas. In Logistics & Services, the increase primarily reflects improvements in safety reporting practices" (page 98). Breakdowns for own employees and contractors were added "to comply with ESRS", with 2024 restated (page 59).

Value chain fatalities, outside the metric (page 91): "four fatal incident involving value chain workers that were not working under Maersk's supervision or responsibility were recorded within Maersk's operations. On 18 March, at a Maersk warehouse in Santa Fe Springs, California, a forklift mechanic with an external supplier suffered a fatal incident... On 7 November, an explosion occurred on the Kyparissia, a time-chartered vessel... at the Port of Tanjung Pelepas (PTP), Malaysia, resulting in 3 fatalities."

Exposure hours are partly estimated; no percentage of the workforce covered by a health and safety management system is given (page 98).

Compensation metrics (pay gap and total compensation)

Reference: page 97; index pages 112, 113 and 115.

2025 (2024): gender pay gap 4% (5%); annual total remuneration ratio 215 (205).

Maersk qualifies the pay gap itself: "This unadjusted gender pay gap does not measure a difference in compensation between men and women at the same job level or in the same countries, but it is a broad average across our business. We work constantly to ensure fairness for all our colleagues." On the ratio: "The annual total remuneration ratio result for 2025 landed at 215. In the coming years, we will continue to refine our approach, which may also impact the outcome of the KPIs."

Method (page 97): both metrics use a "fully loaded cost index... calculated per job level and country", estimating "benefits, guaranteed allowances, employer liabilities, on-target short-term incentives, on-target long-term incentives and recognition costs for 2025". The ratio compares "the annual total remuneration of the highest paid employee in Maersk with the annual median total remuneration of the rest of the own employees". For comparability "The calculation is based on 2,103 hours per year for all employees." Both are prepared in USD, and "These currency conversions may affect the annual results and comparability over time."

The CEO pay ratio datapoint (paragraph 97(b)) is incorporated by reference to the Remuneration Report (page 113).

Incidents, complaints and severe human rights impacts

Reference: pages 102-103; page 108; index pages 112 and 115.

"In 2025, 1,174 whistleblower reports in scope of the programme were received, up 24% compared to 2024... During 2025, we had 3 cases on discrimination in the workforce. We had no severe human rights incidents during the 2025 reporting year" (page 103).

Case outcomes (page 108): of 1,174 in-scope cases, 357 were substantiated, 258 unsubstantiated, 153 closed for insufficient information and 406 remained open. "Substantiated cases primarily involved people conduct and workplace behaviour, along with ethical concerns, conflicts of interest, and misuse of company resources. Three cases of discrimination on protected grounds were confirmed, resulting in dismissals and written warnings. No incidents related to human rights violations such as forced labour, human trafficking or child labour were reported."

The prior year was restated from 1,387 to 947 because cases "now exclude 'out-of-scope' cases" (pages 59, 108).

External case closed (page 103): "In August 2025, NCP Denmark... made their final statement on the case against Maersk regarding the joint venture of Douala International Terminal in Cameroon. NCP Denmark concluded that Maersk has satisfactorily implemented the recommendations provided by the NCP." No amount of fines, penalties or compensation for damages is reported.

Policies related to value chain workers

Reference: page 105; pages 102-103; page 93; index pages 112 and 115.

Maersk "relies on a global network of approximately 40,000 suppliers" (page 105). Three policies anchor the approach:

Supplier Code of Conduct (page 105): it "outlines the minimum standards expected from suppliers... grounded in internationally recognised frameworks, including the UN Global Compact, ILO Conventions, UN Guiding Principles on Business and Human Rights and ISO standards on Health, Safety & Environment. Policy scope includes Health, Safety & Security; Labour Rights; Working with Integrity; Environmental Responsibility; Implementation & Accountability; Grievance and Remedy Mechanism." It is "publicly available on Maersk.com... translated into 12 languages".

Sustainable procurement commit rule (page 105): "applicable to all employees involved in supplier interactions... it provides employee guidance on how to select, engage and manage suppliers responsibly. The rule was updated in 2025."

Global vendor payment policy (page 105): safeguards "fair and timely payment practices, particularly for small and medium-sized enterprises".

The "Maersk Global Standards on Third-Party Labour applies to contract/third-party labour and further clarifies the labour expectations outlined in our Supplier Code of Conduct" (page 93). Appendix B routes the S2-1 paragraph 17 to 19 datapoints to pages 102-105 (page 115).

Processes for engaging with value chain workers about impacts

Reference: pages 56-57; page 105; page 93; index page 112.

Supplier channels (page 56): "Contract management; Supplier relationship management framework; Supplier surveys, workshops and capability-building programmes; Industry forums and associations." Input is used to "Enhance value chain visibility, including fair working conditions and supplier ethical business conduct." "In 2025, Maersk hosted its first Sustainable Procurement Awareness Week, engaging suppliers, customers and industry experts to share knowledge and strengthen ESG collaboration" (page 56).

On-site engagement (page 105): "To address supply chain risks and impacts, Maersk undertook audits, assessments and on-site 'Gemba' visits in 2025, with a focus on labour rights, occupational health and safety, and fair working conditions. Improvement plans and follow-ups are in place to ensure continuous supplier practice improvement for identified gaps."

Through unions (page 93): meetings with the International Transport Workers Federation covered "migrant labour considerations within our Malaysia Logistics and Services operations", and a joint workshop on "the future of work (automation/AI) and supply chain due diligence" is planned.

Engagement is largely with suppliers as enterprises; the clearest direct engagement with workers is the ITF relationship and the Alang health programme (page 82).

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

Reference: pages 102-103; page 105; index pages 112 and 115.

The whistleblower programme is designed "To make the whistleblower programme accessible to everyone, including employees and external stakeholders", and "the mechanism is available in 73 languages via phone hotlines and in 20 languages through the online reporting portal. The whistleblower channel is publicly available on Maersk.com and by telephone, and integral to both our Code of Conduct and Supplier Code of Conduct" (page 103). The 2025 Speak Up campaign ran "across all our locations, targeting both direct and indirect workers".

A "Grievance and Remedy Mechanism" is a named scope element of the Supplier Code of Conduct itself (page 105).

The material IRO behind this disclosure names the barriers candidly: "Potential barriers to access grievance mechanisms for our stakeholders (e.g., language, fear of retaliation, psychological or physical barriers) could result in violations of rights and lack of access to remedy. The risk is heightened in the value chain" (page 100).

External remedy (page 103): the NCP Denmark case on the Douala International Terminal joint venture in Cameroon closed in August 2025, with NCP Denmark concluding "that Maersk has satisfactorily implemented the recommendations provided by the NCP".

No count of grievances from value chain workers is reported separately.

Taking action on material impacts on value chain workers

Reference: page 105; page 109; page 82; page 66; index page 112.

Supplier risk platform (page 105): "In 2025, Maersk deployed a supplier risk assessments ESG Platform, expanding coverage across our supplier base. The platform assigns risk scores based on country and industry risks, business criticality and suppliers' performance across ESG topics, enabling prioritisation of high-risk suppliers."

Measured effect (page 109): suppliers committed to the Supplier Code of Conduct reached 100% (2024: 87%); tier 1 high-risk and strategic suppliers undergoing ESG assessments reached 86% (47%), "surpassing our 85% target"; improvement plans closed reached 83%, "exceeding our 80% target"; procurement staff trained 99%.

Ship recycling yards (page 82): "we were still active at the yards and continued to support facility workers with complementary health care access and health training. As part of our engagement, the Mobile Health Unit provided 13,000+ outpatient consultations... NGO-led preventive health initiatives trained 10,000+ workers on personal hygiene and ergonomics."

Just transition (page 66): the transition plan "includes addressing workforce impacts from electrification and mitigating risks to local communities from lower-GHG-emission fuel development. Maersk also retains audit rights under offtake agreements during methanol facility construction and production."

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 105; page 99; page 109; index page 112.

The one headline target, achieved (pages 99, 105): an annual target that 100% of in-scope suppliers commit to the Supplier Code of Conduct. "In 2025, we achieved our target of securing full commitment from all in-scope suppliers to Maersk Supplier Code of Conduct (SCoC), reinforced by a mandatory Sustainable Procurement clause. This was enabled by our strengthened source-to-contract process and supplier engagement, ensuring sustainability requirements are adhered to throughout the supplier lifecycle." Reported result: 100%, against 87% in 2024 (page 109).

Two further quantified targets, with results (page 109): ESG assessments of tier 1 high-risk category and strategic suppliers reached 86%, "surpassing our 85% target"; improvement plan closure reached 83%, "exceeding our 80% target".

Where no target exists, Maersk says so (page 105): "While we do not have specific targets for payment practices, we strive to treat all suppliers responsibly, also when it comes to payments."

Gap: the targets are process and coverage measures for suppliers as enterprises. No outcome-oriented target is set for the material impacts on value chain workers themselves - forced labour and debt bondage, excessive working hours, adequate wages, or adequate housing and sanitation (pages 54, 87).

Policies related to affected communities

Reference: page 55; page 104; pages 79-80; index pages 113 and 115.

Maersk discloses no standalone affected-communities policy. Its index routes S3-1 to Sustainability due diligence (page 55), Climate change (pages 63-71), Environment and ecosystems (pages 79-83) and Business ethics (page 104).

Human rights commitment (page 55): "We are committed to respecting human rights across our operations and value chain in line with the UN Guiding Principles on Business & Human Rights, the OECD Guidelines... and the UN Global Compact. These commitments are formally reflected in our public human rights policy statement, Code of Conduct and Supplier Code of Conduct."

Communities are named in the salient risk table: "Just transition for local communities and workers connected to our decarbonisation journey" affects "Communities connected to the land used in the sourcing of biofuels" (page 55).

Code of Conduct (page 104): it "sets global standards for how we engage with colleagues, customers, suppliers, communities, authorities and other stakeholders. Maersk takes active responsibility for the society and environment where we operate around the world."

Environmental safeguards (page 79): "global standards such as our Environmental and Social Impact Assessment process" govern community-facing construction. Appendix B routes S3-1 paragraphs 16 and 17 to pages 55-57 and the remedy datapoint to pages 102-103 (page 115).

Processes for engaging with affected communities about impacts

Reference: pages 56-57; page 80; index page 113.

"Local communities and nature" is one of Maersk's seven stakeholder groups, with channels listed as "Environmental and social impact assessments, corporate social responsibility initiatives; Engagement with community representatives and employees; Collective action alliances and partnerships; Scientific studies". "Local communities help us better understand the needs and constraints of nature where we operate, informing decisions to invest and procure resources" (page 56).

"For parts of our business that interact directly with local communities, for example our terminal operations, proactive engagement is vital to maintaining our license to operate... At Pier 400 in Los Angeles, local outreach prompted APM Terminals to intensify engagement around workforce development, environmental stewardship and emergency preparedness" (page 56).

Engagement is embedded in construction: in 2025 Maersk had 22 greenfield construction and expansion projects, "where environmental assessments were performed in accordance with local regulatory requirements" (page 80).

Citizenship activity in 2025 included the Los Angeles wildfire response, a school swimming pool in Cat Hai District, Vietnam, and the GIVO plastics partnership in Apapa Wharf and Onne Community, Nigeria (page 57).

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

Reference: pages 102-103; index pages 113 and 115.

The whistleblower programme is the channel Maersk offers communities, designed "To make the whistleblower programme accessible to everyone, including employees and external stakeholders", with "the mechanism available in 73 languages via phone hotlines and in 20 languages through the online reporting portal" and "publicly available on Maersk.com and by telephone" (page 103). Reports are investigated by "independent and impartial investigators, with follow-up actions taken to address violations" (page 102).

The material IRO that sits behind this disclosure names the barriers: "Potential barriers to access grievance mechanisms for our stakeholders (e.g., language, fear of retaliation, psychological or physical barriers) could result in violations of rights and lack of access to remedy. The risk is heightened in the value chain" (page 100).

A community case closed in 2025 (page 103): "In August 2025, NCP Denmark (the Danish Mediation and Complaints Handling Institution for Responsible Business Conduct) made their final statement on the case against Maersk regarding the joint venture of Douala International Terminal in Cameroon. NCP Denmark concluded that Maersk has satisfactorily implemented the recommendations provided by the NCP." No figure is given for grievances raised by communities.

Taking action on material impacts on affected communities

Reference: pages 102-103; page 55; page 66; page 80; index pages 113 and 115.

Maersk's index routes S3-4 across five sections: Grievance and remedy (pages 102-103), Sustainability due diligence (page 55), Climate change (pages 63-71), Environment and ecosystems (pages 79-83) and Business ethics (page 104).

Just transition (page 66): "Maersk's transition plan is supported by strong policies and governance to manage the social implications of decarbonisation. This includes addressing workforce impacts from electrification and mitigating risks to local communities from lower-GHG-emission fuel development. Maersk also retains audit rights under offtake agreements during methanol facility construction and production."

Construction safeguards (pages 79-80): for the 22 greenfield construction and expansion projects in 2025 "environmental assessments were performed in accordance with local regulatory requirements", and "more emphasis has been put on the environmental and social impact assessments that we complete in connection with our construction and expansion activities compared to the previous report" (page 53).

Outcome reported (page 103): "We had no severe human rights incidents during the 2025 reporting year."

Appendix B lists the S3-4 paragraph 36 datapoint as material, routed to pages 55, 63-71, 79-83 and 102-104 (page 115). No community-specific remediation spend is disclosed.

Business conduct policies and corporate culture

Reference: pages 102-104; index pages 113 and 115.

Commit, the governance framework (page 102), has three core elements: the Core Values, "shaped and strengthened since our foundation in 1904"; the Code of Conduct, which "sets global standards for how we engage with colleagues, customers, suppliers, communities, authorities and other stakeholders"; and "21 rules of business ethics, governance and authority... covering high-risk areas. These are subject to internal controls and an annual internal assurance process."

Code of Conduct (page 104): "publicly available on Maersk.com, in 17 languages", with training "(onboarding and yearly refreshers)", guided by "the Universal Declaration of Human Rights, the principles of the UN Global Compact and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct".

Culture work (page 104): the #IOWNMYROLE campaign "to encourage each employee to take personal ownership of compliance and ethical behaviour", plus "Speak Up and No Retaliation campaigns, Sanctions and Export Controls awareness, Dawn Raid Preparedness and Data Privacy Due Diligence Check campaign". Delivery rests on "dedicated teams of 70+ Compliance professionals and a comprehensive Business Compliance Ambassadors' network of 70+ employees".

Appendix B marks the G1-1 paragraph 10(b)(d) datapoint as not applicable (page 115).

Management of relationships with suppliers

Reference: page 105; page 109; index page 113.

Maersk "relies on a global network of approximately 40,000 suppliers... Sustainable procurement is essential to managing supplier base risk, maintaining customer trust and ensuring that ESG is embedded in the entire supplier lifecycle" (page 105).

Lifecycle approach (page 105): "pre-qualification screening (based on environmental performance, labour practices and safety standards); inclusion of ESG clauses in supplier contracts, aligned with Maersk's Supplier Code of Conduct and sustainability policies; and maintaining continuous oversight and improvement once partnerships are in place."

2025 tooling (page 105): the ESG Platform "assigns risk scores based on country and industry risks, business criticality and suppliers' performance across ESG topics", with "A centralised ESG dashboard" for oversight.

Metrics, 2025 (2024) (page 109): suppliers committed to the Supplier Code of Conduct 100% (87%); tier 1 high-risk and strategic suppliers undergoing ESG assessments 86% (47%); improvement plans successfully closed 83% (87%); procurement staff trained 99% (99%).

Payments (page 105): the global vendor payment policy safeguards "fair and timely payment practices, particularly for small and medium-sized enterprises", with standard terms "in line with EU law". No disclosure is made of supplier concentration or of payment terms imposed on SMEs.

Prevention and detection of corruption and bribery

Reference: pages 104 and 108; index page 113.

"Corruption, sanctions and export controls, competition law violations and data privacy are Maersk's most material business ethics risks." The Commit Rules on those topics "set out the measures to identify, mitigate and manage compliance risks in jurisdictions where we operate" (page 104).

Detection activity in 2025 (page 104): "over 67 compliance spot checks were conducted in selected entities and processes, determined by location risk, annual risk assessment, legislative climate etc. These spot checks covered critical risks in anti-corruption, sanctions compliance, competition law and data privacy." Maersk also "continued rolling out and refining our 'Minerva' automated sanctions screening platform".

Risk assessment roll-out (page 104): "After a successful pilot with a joint venture entity, we conducted kick-off meetings with the first functional entity at the end of 2025, and will start the full risk assessment roll-out in January 2026."

Training (pages 104, 108): Code of Conduct completion was 92% (2024: 94%), but "The employees in scope of the Code of Conduct training cover 58% of the total employees in Maersk during 2025", being office-based staff. No separate anti-corruption training figure is given. "Cases of non-compliance are reported to the Board and to the Executive Leadership Team through the Risk and Compliance Committee."

Targets related to business conduct

Back-filled from the business conduct, sustainable procurement, data ethics and tax chapters, where targets sit under the MDR-T/GDR-T disclosures rather than a numbered DR. G1-3 became a standalone DR only in the 2025/2026 ESRS.

Two business conduct targets are stated (page 104): "Maersk has the strategic target of 100% of in-scope employees completing annual training on our Code of Conduct. In 2025, we achieved a rate of 92%... we have set the qualitative target of anchoring compliance risks ownership in our respective business functions." The summary shows the annual target as 100% against a 2025 result of 92% (page 99).

Sustainable procurement, achieved (pages 99, 105): an annual target that 100% of in-scope suppliers commit to the Supplier Code of Conduct. "In 2025, we achieved our target of securing full commitment from all in-scope suppliers."

Responsible tax (page 99): an "Ongoing ambition" to "Ensure full compliance with tax regulations in all countries where we operate".

Where there is no target, Maersk says so: "While we do not have specific targets for payment practices, we strive to treat all suppliers responsibly" (page 105); "While we do not have specific targets for Data and AI ethics, these are part of Maersk's Code of Conduct" (page 106); "We have not set measurable targets in regard to responsible tax. We aspire to act responsibly and with integrity in all tax matters" (page 107).

Incidents of corruption or bribery

Reference: page 108; index pages 113 and 115.

Nil returns, with the EFRAG identifiers shown (page 108): number of convictions for violation of anti-corruption and anti-bribery laws, Nil (2024: Nil); amount of fines for such violations, Nil (Nil). "Maersk has not been convicted for violation of anti-corruption or anti-bribery laws during 2025 and thus no fines have been paid in relation to such cases."

Convictions are defined as "all convictions as a result of legal proceedings against A.P. Møller - Mærsk A/S and/or any of its subsidiaries in the reporting year".

Whistleblower cases as the surrounding evidence (page 108): 1,174 in-scope cases received (2024 restated: 947), of which 357 substantiated, 258 unsubstantiated, 153 closed due to insufficient information and 406 open. "Cases in scope relate to alleged violations of laws, Maersk's Code of Conduct, or Maersk's Business Ethics Rules. This includes cases of fraud, corruption and bribery, conflicts of interest, discrimination and harassment on protected grounds etc."

Appendix B routes the G1-4 paragraph 24(a) datapoint to page 108 (page 115).

Gap: no count of confirmed corruption or bribery incidents is given separately from convictions, and no breakdown of actions taken against own workers or business partners is disclosed.

Political influence and lobbying activities

Reference: page 103; index page 113.

Contributions, quantified (page 103): "Maersk does not provide financial or in-kind donations to politicians, regulators or political parties. In Denmark, we are members of trade associations such as Danish Shipping and Danish Industry, which may allocate political contributions on behalf of their sectors; these decisions are made solely by the associations. In the US, Maersk operates a Political Action Committee (PAC)... In 2025, PAC donations totalled USD 16,500, and no other political contributions were made by Maersk."

Register and oversight: "Maersk adheres to policies and procedures to ensure responsible lobbying. The company is part of the EU Transparency Register (registration number 680443918500-51)." "The Executive Leadership Team is overseeing Maersk's political engagement and advocacy efforts."

Main topics (page 103): "A key focus for our political engagement efforts continues to be the decarbonisation of the maritime and logistics industries. Maersk's position is that shipping is global and therefore global regulations, such as the International Maritime Organization (IMO)'s Net-Zero Framework, are needed for shipping to reach its climate goals." In Europe the focus is "implementing the Fit for 55 framework". Maersk "actively participated in key global meetings during the year, including IMO MEPC (in April and October), New York Climate Week and COP30".

Payment practices

Reference: page 105; page 108; index page 113.

Policy and terms (page 105): "Our global vendor payment policy safeguards our efforts to ensure fair and timely payment practices, particularly for small and medium-sized enterprises... Unless otherwise agreed and subject to local and national legal requirements, Maersk's standard payment terms are in line with EU law. Internal tools provide visibility on payment practices, minimise late payments and improve supplier experience."

2025 activity (page 105): "We ensured fair and timely supplier compensation through active monitoring of payment timeliness. In 2025, our procure-to-pay compliance rate remained consistently high."

Metric (page 108): number of legal proceedings outstanding for late payments, Nil (2024: Nil), tagged G1-6_04. "no legal proceedings for late payments are outstanding per year-end 2025."

The material IRO is stated as an impact on suppliers: "Potential impact on suppliers' working capital and cash flow affecting their financial and operational stability. Especially with regard to late payments for small and medium-sized undertakings" (page 100).

Gaps: no average number of days to pay an invoice is disclosed, no percentage of payments aligned with standard terms, and the procure-to-pay compliance rate is described only qualitatively. No target is set for payment practices (page 105).