Alm Brand

Alm. Brand describes the governance of sustainability across the Board of Directors, audit committee, Executive Management and an ESG steering committee. Three of the nine members of the Board of Directors of Alm. Brand A/S are elected by employees, and staff are represented by three staff associations under collective agreements. The Board has 50% independent members and an equal gender distribution as measured against statutory requirements. Management members must be fit and proper and approved by the Danish Financial Supervisory Authority. The Board sets the strategy and overall risk appetite for sustainability through the policy and guidelines on corporate social responsibility and the investment policy, and mandates Executive Management to execute within that framework. The audit committee monitors financial and sustainability reporting processes. The ESG steering committee monitors, manages and oversees impacts, risks and opportunities and reports to Executive Management. Sustainability experts have been employed to support the required skills.

Alm. Brand explains how sustainability information reaches its governance bodies. All members of the Board of Directors of Alm. Brand A/S receive sustainability reporting from the Executive Management and the audit committee, and the Board monitors compliance with the corporate social responsibility policy and the investment policy. During the reporting period the Board considered impacts, risks and opportunities including prevention of claims, sustainability topics set out in governance documents, the results of the double materiality assessment, the group's GHG emissions and emission targets, and targets for employee satisfaction and the under-represented gender at senior management level. The audit committee considered the baseline for GHG reduction targets and the double materiality assessment results, and meets at least four times a year. The ESG steering committee, which meets at least every two months, considered the double materiality assessment results, GHG emissions and targets, energy efficiency improvements, and the strategy and risks related to governance documents.

Alm. Brand states that the Board of Directors and the Executive Management are remunerated under the group's remuneration policy, which is adopted by shareholders in general meeting. The policy is intended to promote sound and efficient risk management aligned with the company's strategy, objectives and values, and sustainability risks are integrated into remuneration in the same way as other types of risk. However, the remuneration policy is not intended to address material impacts, risks or opportunities related to sustainability topics. The policy is reviewed annually and monitored through a first, second and third line of defence in line with financial regulation. Board members receive a fixed annual remuneration and no variable remuneration. The Executive Management's package comprises fixed remuneration plus fixed remuneration in the form of shares, pension contributions, a company car, a company-paid telephone, insurance schemes and other usual components. No sustainability-linked incentive scheme is disclosed.

Alm. Brand describes the purpose of its sustainable due diligence process as identifying and addressing negative impacts on the environment and human beings, mitigating those impacts and addressing any derivative risks. A table maps the core elements of due diligence to the disclosure requirements where they are reflected, in ESRS 2 and in the material topical standards, together with page references and whether each relates to people, the environment or both. The core elements are: embedding due diligence in governance, strategy and business model (linked to GOV-2 and SBM-3 disclosures); engaging with affected stakeholders in all key steps (SBM-2, S1-2 and S2-2); identifying and assessing adverse impacts (IRO-1); taking actions to address adverse impacts (E1-3, E5-2, S1-4 and S2-4); and tracking the effectiveness of these efforts and communicating (E1-4, E5-3, S1-1 and S2-4).

Alm. Brand states that the sustainability statement is anchored in the Board of Directors and senior management, with transparency and measurability as cornerstones. The group is working to increase the maturity of data quality and the internal control environment for the non-financial part of the reporting. Non-financial transactions were not included in the periodic reporting to management in 2024, and no periodic reporting of emissions or of the effectiveness of the internal control environment for the non-financial part is carried out, although some emission results form part of the financially controlled environment. The insurance exposure to climate-related risks is reviewed once annually through the double materiality assessment process, and the approved risk assessment provides the framework, updated in the group's compliance system. Data tasks follow a two-party approval principle. The most significant reporting risks are assessed as incomplete or inaccurate records, manual interaction, and the use of estimates or proxies. The group aims to place non-financial reporting on an equal footing with financial reporting as data quality improves.

Alm. Brand describes itself as one of the largest non-life insurance companies in Denmark, with more than 800,000 customers and a market share of about 17%. It acquired the Danish business of Codan Forsikring in 2022, roughly doubling the group's size, and announced the planned divestment of its energy and marine business in 2024. Integration of the original companies is to be completed in 2025, realising synergies of DKK 600 million. The group had 2,142 FTEs at 31 December 2024 (about 2,150 employees) working at the head office in Copenhagen and local offices. Alm. Brand was founded in 1792 and Codan in 1916; the largest shareholder, Alm. Brand af 1792 fmba, holds 47.8%. The business model spans resources (employees, suppliers, financial capacity), management and value creation, serving customers west and east of the Great Belt including through a bancassurance partnership. Under the phase-in option, the paragraph 40(b) breakdown of total revenue by ESRS sector is omitted, as the sector-specific standards are not expected to be finalised until 2026.

Alm. Brand explains that engaging with the interests and views of internal and external stakeholders is an essential task, and that ongoing dialogue gives management insight that feeds into the overall strategy, business model and the double materiality assessment. A stakeholder analysis table sets out how the group engages with five stakeholder groups and the purpose and results of that engagement. Customers are engaged through day-to-day operations, hotlines, complaint and feedback procedures and satisfaction surveys. Employees are engaged through internal communication systems, appraisals, satisfaction surveys and PULSE surveys, with an employee satisfaction target of 80 or more. Suppliers are engaged through the Partner Code of Conduct, supplier screening and compliance, and direct interaction. Investors are engaged through board and investor meetings, roadshows, conference calls, general meetings and financial and sustainability reporting. Society, including authorities, regulatory bodies and staff associations, is engaged through inspections, meetings and regular dialogue to ensure regulatory compliance.

Alm. Brand states that the material impacts, risks and opportunities identified in its double materiality assessment are described in IRO-1, in the materiality matrix and in the IRO table. The material topical standards are E1 Climate change, E5 Resource use and circular economy, S1 Own workforce, S2 Workers in the value chain and G1 Business conduct. Disclosed items include GHG emissions from own operations, claims repairs and investments, the Principles for Responsible Investment, claims prevention, greater focus on climate in product development, and the risk of reduced profitability from more severe weather; recycling and repair and circular requirements for suppliers; diversity and being an attractive workplace; ESG screening of suppliers and human rights in the value chain; and good corporate culture, prevention of corruption and bribery and the UN Global Compact. Each is placed against the value chain (upstream, downstream, own operations) and time horizon. Under the phase-in option, the paragraph 48(e) anticipated financial effects are omitted, as current initiatives are not assessed to have significant financial effects and quantitative disclosures are currently impracticable.

Alm. Brand describes a double materiality assessment carried out on the basis of EFRAG's methodology and recommendations and relevant legislation. The process involves systematic screening and assessment of sustainability topics for their significance to the group's strategy, business model and value chain, with an initial assessment based on relation to strategy and to the business model and value chain. Impact materiality is scored using scale, scope, irremediable character and likelihood, while financial materiality considers potential scale and likelihood. Based on both, an overall score from 1 to 5 is calculated. Interviews were conducted with employees representing important stakeholders. The assessment took an overall view of the upstream and downstream value chain but did not specifically assess sectors, because a lack of standardised methodology and data limited the analysis, so the group focused primarily on its own operations. Dependency on natural resources, ecosystem services and biodiversity-sensitive areas was not included given the non-life insurance business model. As a result E2 Pollution, E3 Water and marine resources, E4 Biodiversity, S3 Affected communities and S4 Consumers and end-users were assessed as not material. The assessment is reviewed in depth annually.

Alm. Brand states that the disclosure requirements included in the statement were assessed as material based on the double materiality assessment and therefore form the basis of the sustainability statement. Alongside ESRS 2, the material topical standards are E1 Climate change, E5 Resource use and circular economy, S1 Own workforce, S2 Workers in the value chain and G1 Business conduct. The statement includes an ESRS 2 Appendix B concordance table listing the datapoints that derive from other EU legislation, cross-referenced to SFDR, Pillar 3, Benchmark Regulation and EU Climate Law references, with each datapoint marked as material or non-material and, where material, given a page number. Using the phase-in option for undertakings exceeding 750 FTEs, the group omits ESRS 2 SBM-1 paragraph 40(b), ESRS 2 SBM-3 paragraph 48(e), ESRS E1-9, ESRS E5-6, ESRS S1-11 on social protection and ESRS S1-13 on training and skills development, several as a result of first-time presentation.

Alm. Brand Group has established the framework for a climate change transition plan that supports the Paris Agreement. The plan concretises the framework for achieving a 42% reduction in CO2 emissions by 2030 for Scopes 1 and 2 relative to the 2024 base year. The group is working on a plan that also includes targets for Scope 3 and long-term targets for 2050 in line with the Paris Agreement. At present, no specific operating expenditures (OpEx) or capital expenditures (CapEx) have been determined for the transition plan, and the actions are not dependent on the availability or significant allocation of resources. No locked-in GHG emissions that could obstruct the targets have been identified. The plan does not currently include targets for adapting the investment portfolio and insurance products covered by the EU Taxonomy. Because 2024 is the base year, no progress statement can yet be provided. The plan has been approved by the Executive Management and the Board of Directors.

Alm. Brand Group has a policy and guidelines for corporate social responsibility, approved by the Board of Directors, covering climate change mitigation and adaptation, energy efficiency, resource use and circular economy, and applying to all group activities. The climate change section sets out the objective of committing to the Paris Agreement for Scopes 1 and 2 by optimising leased premises and monitoring energy consumption, and addresses Scope 3 efforts including claims prevention and mitigation. The policy was updated and approved by the Board at the end of 2024, with the climate section amended and non-material areas deleted. A separate policy and guidelines for the investment area, also updated at the end of 2024 and covering the group's value chain for the investment portfolio, integrates responsible investment considerations, applies exclusion criteria (including UN Global Compact breaches, controversial weapons, coal, Arctic oil and gas, and IEA Net Zero contraventions) and commits the group to the UN Principles for Responsible Investment. Policies are monitored through three lines of defence.

To support its targets under the transition plan and corporate social responsibility policy, Alm. Brand Group has implemented two decarbonisation levers: optimising its locations and gradually transitioning its lease fleet to electric cars. The group works to connect all locations to district heating where possible, reducing use of fossil fuels for heating and thereby supporting the Scope 1 target. It also explores optimising its use of locations to reduce electricity consumption in support of the Scope 2 target, with the ambition that these efforts alone will enable meeting the 42% reduction in Scope 2 by 2030. The group notes it does not want to optimise locations if this affects operations, and other measures may be necessary if optimisation cannot be carried out as planned. In addition, the group focuses on optimising resource use in claims repairs, prioritising repair over replacement, using sustainable materials and recycling.

Alm. Brand Group has set two separate targets to reduce Scope 1 and Scope 2 emissions by 42% by 2030, using 2024 as the base year. The targets are in line with the Paris Agreement and use a science-based approach to setting climate targets. In preparing the targets, the group applied relevant accounting principles including the GHG Protocol and used the Absolute Contraction Approach (ACA Method), which ascribes a linear development in emission reductions from the perspective of a 42% target. Future emissions were estimated using historical data and expected projections from the Danish Energy Agency to assess which measures are needed to reach the 2030 target. There has been no external validation of the estimation in the transition plan. The group has not set specific CO2 targets for Scope 3, despite Scope 3 being its primary reported emissions, because of data reliability and its current inability to monitor decarbonisation effectiveness; it is working to improve the data basis to set Scope 3 targets in future.

Alm. Brand Group's energy consumption consists mainly of fuel consumption for the car fleet, together with district heating and electricity. For 2024, total energy consumption was 9,657 MWh. Total fossil energy consumption was 7,438 MWh, representing a 77% share. Consumption from nuclear sources was 448 MWh (4.6%). Total renewable energy consumption was 1,771 MWh (18.3%), comprising 672 MWh of fuel consumption from renewable sources including biomass, 1,099 MWh of purchased or acquired renewable electricity, heat, steam and cooling, and 0 MWh of self-generated non-fuel renewable energy. Lines 1 to 5 of the energy table are not disclosed because the group operates in NACE sector K (financial and insurance), a sector categorised as having low climate impact. Reporting for the energy mix follows the same delimitation as the financial statements, assuming indirect sources such as electricity and district heating match the original sources for the rest of the country.

As a Denmark-based non-life insurance company, Alm. Brand Group's Scope 1 and 2 emissions are limited, with its main impact from Scope 3, which represents 99% of the total reported statement. The statement is presented in tCO2eq using 2024 as base year. Gross Scope 1 emissions were 599 tCO2eq. Gross location-based Scope 2 emissions were 255 tCO2eq and market-based Scope 2 emissions were 1,591 tCO2eq. Significant Scope 3 emissions totalled 258,504 tCO2eq, comprising Category 1 (purchased goods and services) 37,787 tCO2eq, Category 11 (use of sold products) 99,208 tCO2eq, and Category 15 (investments) 121,509 tCO2eq. Total GHG emissions were 259,358 tCO2eq (location-based) and 260,694 tCO2eq (market-based). GHG intensity per net revenue (insurance revenue of DKKm 11,083) was 23.40 and 23.52 tCO2eq/DKKm respectively. Emissions from primary supplier data amount to 0%. The 2030 targets are 347 tCO2eq for Scope 1 and 923 tCO2eq for market-based Scope 2 (42% reductions). No biogenic emissions were included as they were assessed not material.

Alm. Brand Group has established a policy and guidelines for corporate social responsibility, approved by the Board of Directors, which include a section on promoting the circular economy. The section does not set specific targets but defines a general objective of a circular economy focus on claims repairs, directed primarily at the two strategic areas of recycling and repair, which account for the group's most material impact on sustainability in relation to circular economy. The material impact relates to resource use in connection with products and services, where the group can influence the amount of recycled material used through suppliers in the value chain during claims repairs. The group has defined selection requirements for business partners and suppliers to ensure damaged items are repaired and, for selected suppliers, to increase the use of recycled materials where this does not impair safety or quality. The policy scope covers the group's claims repair activities and value chain, and is further described in section E1-1.

Alm. Brand Group has initiated a number of actions and allocated resources to promote sustainable resource use and support the transition to a circular economy, including initiatives to optimise the use of materials and promote recycling through partnerships with suppliers to develop and use sustainable materials and technologies. In 2024, the group entered into a partnership with Bygma to promote a more sustainable use of materials. From November 2024, Alm. Brand's network craftsmen use Bygma when insurance customers require claims repair services, making it possible to take climate footprint and environmental impact into account when choosing materials, as Bygma in some cases offers materials with a lower environmental and climate impact than others in its range. Bygma also provides documentation of the climate impact of materials, enhancing Alm. Brand's data infrastructure. The group's partnership with Glad Teknik, which specialises in repairing computers, is a further initiative supporting its environmental commitments and the circular economy.

Alm. Brand Group has not set any specific targets but wants to promote the circular economy. As a non-life insurance company, its greatest opportunity is to promote the circular economy through claims repairs, and its efforts are summarised in two strategic focus areas: repair and recycling. Under repair, the group works to a greater extent to repair damaged items or parts rather than replace them with virgin products, in order to reduce the use of virgin materials and ensure longer product life. Under recycling, the group has defined selection requirements for business partners and suppliers of specific services, including increased focus on claims repair, delivery of used items in similar condition and increased use of recycled materials for selected suppliers, as long as safety, quality or regulatory compliance is not compromised. In the long term, the group wants to develop specific targets to track the effectiveness of its policies and procedures, but at present is unable to set a specific timeframe for establishing targets due to a lack of data.

Alm. Brand Group complies with the UN Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work, and incorporates the UN Global Compact principles into group policies. It has a corporate social responsibility policy and guidelines, with a section on own employees covering equality, diversity, unintended bias and good working conditions, applied to the group's own employees in Denmark. The policy sets targets on diversity among employees, diversity on boards of directors, and taking social responsibility for employees. It is revised at least annually. In addition, a staff policy prohibits differential treatment and a recruitment policy prohibits all forms of differential treatment, including on grounds of gender, age, ethnicity, sexual orientation, disability, political conviction, religious beliefs and national, social or ethnic origin. A staff handbook applies to all employees. The Head of HR and Property is responsible. The group enforces zero tolerance to human rights violations.

Alm. Brand Group has a consultation committee on which its three employee associations are represented by employee-elected representatives covering insurance employees, tied agents, and managers and specialists under their respective collective agreements. Representatives are notified about significant changes or decisions of importance to employees before implementation. This duty of notification, triggered by redundancies or significant changes affecting at least two employees, is set by Danish law and collective agreements. The consultation committee meets quarterly, with extraordinary meetings for significant changes, and ongoing dialogue with the employee associations is maintained on staff grievances and workforce changes. The group also runs satisfaction surveys, including an annual employee engagement survey and a PULSE survey four times a year, and in 2023 launched a dialogue format called 'The Blue Hour', held quarterly with the CEO, Deputy CEO and other Group Executive Management members, allowing employees to set the agenda.

Alm. Brand Group encourages employees to raise concerns and needs with their immediate superiors or HR. For those who prefer not to raise concerns internally, it offers a whistleblower scheme managed by an external legal adviser, allowing anonymous reporting of a wide range of concerns including financial crime, personal data breaches and severe environmental harm. Reports are treated confidentially and the whistleblower is protected against retaliation under Danish law. The group has a defined business procedure and process description for handling whistleblower reports, involving the external legal adviser and trusted Compliance and HR employees as required, and records and reports the number of concerns submitted. It also provides a psychological working environment channel allowing reports without risk of retaliation. HR follows up on and monitors reported concerns, and the group proactively makes employees aware of these mechanisms through internal communication. Further structures are described under G1-1.

To promote employee satisfaction and good working conditions, Alm. Brand Group has implemented a range of actions, with effectiveness monitored through satisfaction surveys, employee interviews and PULSE surveys. Measures include employer-paid pension, comprehensive health insurance extendable to household members, pay during illness absence, freedom from work in urgent family circumstances, and flexible or part-time working with full pension contributions. The group runs employee sports associations and fitness facilities, and holds an annual Working Environment Camp at the end of May with employee and management representatives, where topics such as returning to the office, good office conduct, local safety, mental health and threats were addressed and working groups established. On 1 December 2024, the staff handbook was updated with new guidelines on employee relations and conflicts of interest. To prevent violence and harassment, clear guidelines and support processes are in place, with investigations, support for affected employees and preventive measures. Terminations are treated as a last resort where redeployment is not possible, and exit interviews and surveys are conducted.

Alm. Brand Group has set a target for the underrepresented gender of 40% by 2030 at senior management levels, in line with regulatory requirements for equal gender composition. Senior management is defined as the Board of Directors (excluding employee-elected members), the Executive Management and Group Executive Management. The group reports meeting both its own target and the statutory target for Alm. Brand A/S at the balance sheet date. It has also set a target for employee satisfaction of a score of 80 or more on a scale of 0 to 100, based on a banking and insurance benchmark of 78, with a supplier assumption that 75 or more reflects high job satisfaction. All employees working more than eight hours per week (99.6% of employees) are invited to the survey, carried out with supplier Ennova. In 2024 the employee satisfaction score was 75 at a response rate of 91%, which the group intends to improve through the measures described under S1-4.

Employee figures are presented on a headcount basis using a one-for-one factor for all employee groups. At the end of the reporting period Alm. Brand Group had 2,356 employees (headcount), comprising 1,493 male and 863 female employees, with 'other' and 'not reported' recorded as N/A. By contract type there were 2,179 permanent employees (1,406 male, 773 female), 48 temporary fixed-term employees on monthly payment (27 male, 21 female) and 129 non-guaranteed hours employees paid by the hour (60 male, 69 female). There were 2,055 full-time employees (1,353 male, 702 female) and 301 part-time employees (140 male, 161 female). By age, 481 employees were under 30 (20%), 1,193 were between 30 and 50 (51%) and 682 were over 50 (29%). The rolling 12-month employee turnover totalled 490 employees at a rate of 20.3%, split into 298 voluntary departures (12.3%) and 192 involuntary departures (8.0%).

96% of Alm. Brand Group's employees are employed under prevailing collective agreements made between the Danish Employers' Association for the Financial Sector (now Forsikring og Pension / Insurance and Pension Denmark) and relevant trade unions, as well as between the group and its local staff associations of employee representatives. Likewise, 96% of employees are represented by employee representatives through their employment under current collective agreements, covering the staff association for insurance employees, Assurandorforeningen for tied agents, and ABC-foreningen for managers and specialists. Employees under a collective agreement are covered by an employer-paid pension plan providing for retirement savings and various insurance schemes, with additional schemes beyond the statutory ones including group life, dental and health insurance. Employees covered by the agreements may be represented by employee representatives in individual cases, depending on membership of the relevant associations.

Alm. Brand Group reports gender diversity across management bodies. The supreme governing body (Board of Directors excluding employee-elected members) had 3 male and 3 female members, 6 in total, a 50% share of the underrepresented gender. Executive Management had 1 male and 1 female member, 2 in total (50%). Group Executive Management (non-executive board members) had 2 male and 1 female member, 3 in total (33%). Total other management levels had 3 male and 2 female members, 5 in total (40%). Across the whole workforce, of 2,356 employees, 1,493 were male and 863 were female, with 'other' and 'not reported' recorded as N/A.

Alm. Brand Group has a working environment manager, a committee and a related working environment organisation tasked with creating a physically and psychologically safe and healthy working environment. Employees are mainly office workers, so work-related injuries are rare. In 2024 there were no deaths among own employees due to work-related injuries or work-related ill health, and the group recorded 11 incidents of work-related accidents. To ensure employees can report work-related injuries, an electronic reporting channel is accessible via the intranet, and employees may also contact their immediate superiors or HR.

Although work-life balance is not listed in the report's disclosure-requirement index, the source discloses metrics for it. Alm. Brand Group states it complies with Danish statutory requirements and collective agreements giving all employees the right to family-related leave, including maternity leave, parental leave, carers' leave and paternity leave. In 2024, 9.1% of employees chose to take family-related leave, of whom 9.5% were men and 8.5% were women. The group notes this gender balance shows that both men and women use the opportunity to take leave in connection with family responsibilities, and states it will continue to work to create an inclusive environment where all employees feel welcome regardless of their need for family-related leave.

Alm. Brand Group reports on equal pay and remuneration. Pay statistics have been compiled for a number of years using payroll data provided to Statistics Denmark via DISCO codes, and the group has started working with a job architecture for the entire group to improve the quality, validity and transparency of pay setting and assess appropriate pay levels regardless of gender. In 2024, the gender pay gap, defined as the pay gap between female and male employees, was 16.7%. The annual total remuneration ratio for the highest paid individual relative to the median of the total annual remuneration for all employees was 17.4. The group notes that these figures include the group's Executive Management. It states it will continue to work proactively to achieve full equal pay and to identify and address any inequalities.

Alm. Brand Group discloses incidents of discrimination, which include allegations based on age, disability or pregnancy. Discrimination concerns may arise before, during or after the employment relationship and may be reported through structured channels, including the whistleblower scheme, an internal reporting channel for poor psychological working environment, and a channel made available by collective agreement, as well as through unstructured channels such as enquiries from employee representatives, for example in connection with termination of employment. In 2024, the total number of alleged discriminatory treatment received through the various structured and unstructured channels was 11. During the financial reporting period, the group did not pay any fines, penalties or similar as a result of discriminatory treatment.

Alm. Brand Group has adopted a policy and guidelines on corporate social responsibility and a code of conduct for suppliers (Partner Code of Conduct) to address material impacts, risks and opportunities related to workers in the value chain. The policy commits the group to promote and support the UN Sustainable Development Goals and to comply with the UN's Universal Declaration of Human Rights in the value chain, making demands on suppliers and business partners to avoid human rights violations. The Partner Code of Conduct is based on international standards including the UN's Universal Declaration of Human Rights, the UN Global Compact and the fundamental ILO Conventions, and sets requirements on working conditions, human rights and environmental responsibility, including prohibitions on child labour and forced labour. It covers working time, adequate wages, health and safety, gender equality and equal pay, diversity, and adequate housing. In 2024 the code did not specifically prohibit trafficking in human beings, though it prohibited complicity in human rights violations generally. In early 2025 the group updated the code to explicitly prohibit human trafficking. The code is available to affected stakeholders on the group's website. The group has not fully implemented the UN Guiding Principles on Business and Human Rights or the OECD Guidelines for Multinational Enterprises.

In 2024, Alm. Brand Group had no direct engagement with value chain workers or their representatives about impacts. Section S2-4 describes the group's intention to implement an ESG screening process aimed at mapping and addressing ESG risks and opportunities in the value chain, which will help assess how workers' perspectives and experiences may contribute to the group's risk management and decision-making. Based on the screening, the group intends to identify, differentiate and prioritise areas where engagement with workers may be relevant. Any engagements will be handled through a situation-adapted approach, which may include reporting via the whistleblower scheme or other publicly available schemes. No timing, types or frequencies of such engagements have been determined. The Head of Procurement is responsible for facilitating engagement when deemed relevant. The group has not entered into global framework agreements, but all its activities in Denmark are subject to the Danish labour market model, which supports a high level of labour rights.

Alm. Brand Group has prepared a Partner Code of Conduct setting out expectations of business partners to minimise negative impacts on value chain workers. This is primarily based on the existence of whistleblower schemes described in section G1-1, through which workers in the value chain may raise concerns anonymously. In 2024 the group had no direct engagement with value chain workers or their representatives about impacts. To date there are no reports of known severe human rights issues or incidents in the group's value chain, including incidents of non-alignment with internationally recognised instruments. Should such incidents occur, the company will take a situation-adapted approach to address and remediate the issue as quickly as possible. The Head of Procurement is responsible for assessing and implementing necessary actions and follow-up procedures in cases concerning material impacts on value chain workers. The whistleblower scheme is described as an important step in detecting and addressing potential violations or negative impacts, though at present no further processes have been established to mitigate such negative impacts.

Through the policy and guidelines on corporate social responsibility and the Partner Code of Conduct, the group has established general accountability requirements, but no specific actions or processes have been implemented to prevent, mitigate or remediate material negative impacts on value chain workers. Concerns about working conditions and human rights can be reported via the whistleblower scheme described in section G1-1. In early 2025 the group updated its Partner Code of Conduct to strengthen transparency on safe working conditions, treating workers with dignity and respect, fair and ethical action, and environmentally responsible solutions, introducing new expectations for business partners in human rights, working environment, business ethics and climate. As a new initiative, the group introduced expectation criteria committing selected business partners to participate in an ESG screening process on request. This process aims to identify and address environmental, social and business conduct risks and opportunities and to integrate these into decision-making. The screening is currently in a data collection phase, and results will form the basis for future strategies and actions to manage sustainability-related risks and to determine where further action is required.

Alm. Brand Group has not set targets for workers in the value chain due to insufficient data. As part of the implementation of ESG screenings of suppliers, the group will consider developing targets in that respect. This process is scheduled for 2025 and depends on progress with implementation and development of the process. Although the group has not set targets, it intends to use the ESG screening process to monitor impacts, risks and opportunities in connection with supplier agreements on an ongoing basis.

Alm. Brand Group grounds its corporate culture in its purpose, "We secure today. So we can create tomorrow. Together.", defined by the Board of Directors and the Executive Management, and promoted through three values: being ambitious, showing confidence and exercising proper conduct. The values emerged from a culture-building process following the merger of Codan and Alm. Brand, drawing on two culture surveys, input from more than 1,200 colleagues and over 3,000 comments. The group maintains policies and instructions on business conduct, including the policy and guidelines on corporate social responsibility, the operational risk policy, general instructions on identifying and managing conflicts of interest, a gift policy and a whistleblower scheme. The corporate social responsibility policy sets the framework for anti-corruption and responsible investment and commits the group to the UN Principles for Responsible Investment (UN PRI). It was updated at the end of 2024 to describe the Partner Code of Conduct for suppliers and business partners. The whistleblower scheme operates under the Danish Act on the Protection of Whistleblowers, allows anonymous reporting through an external law firm's IT portal, and enforces zero tolerance to retaliation.

Alm. Brand Group has drafted a Partner Code of Conduct setting out how it expects business partners to comply with principles and rights covering environmental, social and general business conduct matters. The group has not implemented a structured process for assessing sustainability-related risks or for assessing and selecting suppliers based on sustainability metrics, but a process for ESG risk screening has been initiated with a view to including these criteria in future supplier assessments. For managing supplier relationships, the group has established a targeted process to prevent late payments to small and medium-sized enterprises (SMEs), though it does not have a policy on this. Payment processes are supported by an automated invoicing system that reduces the risk of manual errors and delays, and a video guide is provided to suppliers, including SMEs, to ensure correct invoicing and minimise the risk of late payments.

As a group of financial institutions, Alm. Brand Group operates a number of internal control functions capable of identifying and investigating unlawful conduct. At present, the group has not established specific anti-corruption systems or processes to prevent, detect, investigate and respond to allegations or incidents of corruption and bribery, and it has no related training programme. The group also states that it does not have a specific risk management process for bribery and anti-corruption, and therefore has no concrete overview of its risk exposure in relation to corruption and bribery, including the most vulnerable functions. In 2024, the internal audit department carried out an audit of business ethics and anti-corruption to examine and assess the group's business ethics, the anti-corruption framework and its practical implementation across the organisation. The internal audit department performs an audit of business ethics and anti-corruption every three years.

The control functions described under G1-1 did not identify any confirmed and documented incidents of corruption or bribery during the reporting period, including operational incidents related to corruption or bribery. There was a single situation in which incidents of breaches of business procedures led to appropriate and proportionate employment law consequences.