Carlsberg

Reference: page 56

Carlsberg manages ESG through a governance model anchoring its Together Towards ZERO and Beyond (TTZAB) programme. The Supervisory Board oversees ESG, discusses impacts, risks and opportunities at least twice a year, and reviews overall performance and strategic approach annually as set out in its Rules of Procedure. Board committees assist with oversight: the Audit Committee covers ESG reporting and risk management, the Remuneration Committee covers ESG-linked incentives, and the People & Culture Committee covers diversity, equity and inclusion. The Executive Committee (ExCom) is accountable for effective ESG management, approving strategy, policies, targets and resource allocation. The ESG Steering Committee monitors progress and met five times in 2024. The Board concluded that both bodies possess sufficient ESG skills and experience aligned with material IROs.

Reference: page 56

The Supervisory Board and its committees addressed a range of impacts, risks and opportunities during 2024. These included carbon emissions in operations and the value chain, carbon pricing on own operations and purchased goods, collective bargaining and work-related human rights, purchasing of raw ingredients, biodiversity impacts from raw material sourcing, development of recycling and deposit return schemes, post-consumer waste from packaging, and the purchasing of packaging material. Group Sustainability & ESG develops the ESG programme and Group Sustainable Finance collates ESG data; both report to the ESG Steering Committee at least quarterly and work with internal audit and compliance. ESG risks identified through the double materiality assessment are funnelled into the broader risk management landscape. Information on how frequently bodies are informed about material IROs is provided under GOV-1.

Reference: page 14

Disclosures on the integration of sustainability-related performance into incentive schemes are incorporated by reference to the Remuneration Report. The ESRS index identifies GOV-3 Integration of sustainability-related performance in incentive schemes as addressed in the Remuneration Report section (REM, page 14), rather than in the body of the sustainability statement. The governance model notes that the Remuneration Committee is the ESG-relevant board committee responsible for ESG-linked incentives. ESG-linked executive remuneration is also identified as one of Carlsberg's material impacts, risks and opportunities under the G1 Business conduct topical standard. Readers are directed to the Remuneration Report for the full description of how ESG performance is reflected in incentive arrangements.

Reference: page 61

Carlsberg provides a table mapping where information on its due diligence process appears across the sustainability statement, with corresponding labels placed throughout the report. The mapping follows the core elements of due diligence. Embedding due diligence in governance, strategy and business model is covered by cross-topic disclosures ESRS 2 GOV-2, GOV-3 and SBM-3. Engaging with affected stakeholders maps to SBM-2 and IRO-1, plus social disclosures S1-2, S2-2 and S4-2. Identifying and assessing adverse impacts maps to IRO-1 and the environmental, social and governance IRO-1 disclosures. Taking actions to address adverse impacts and tracking and communicating effectiveness are mapped to the relevant environmental, social and governance action, target and metric disclosures across the topical standards.

Reference: page 61

Carlsberg's Internal Control Framework for Sustainability Reporting is designed to reduce and mitigate sustainability reporting-related risks. It defines roles and responsibilities, sets procedures for data collection, validation and reporting, and provides assurance that key reporting risks are covered by control activities. The framework is monitored through a biannual Group-level self-assessment and currently contains Group-level controls across markets and regions. Group Internal Audit and Group Risk & Internal Controls prepare a quarterly report to the Audit Committee on control activities and their operating effectiveness. Analysis of audit observations and prior assurance identified three main risk categories: misstatements, compliance breaches and fraud. This led to 12 initial internal controls covering reporting stages from data collection to programme management. A 2025 risk assessment will focus on the ESG data collection process.

Reference: page 55

Carlsberg's ESG programme, Together Towards ZERO and Beyond (TTZAB), is an integral part of its corporate strategy to create value for shareholders and society, with targets across the 11 focus areas most material to the business and stakeholders. The Group produces and markets beer and other beverages, with focus on premium beer, alcohol-free brews, Beyond Beer and soft drinks, operating mainly across Europe and Asia. To brew its products, Carlsberg relies on inputs including agricultural products such as barley and hops, water and energy, equipment and packaging, a skilled workforce of 32,591 employees, and intellectual assets. These inputs are transformed into outputs including products, environmental impacts, economic and social impacts, intellectual contributions and brand presence. The business model focuses on optimising the supply chain, prioritising leading markets and serving a range of customers and consumers.

Reference: page 62

Carlsberg requires input and consultation from suppliers, employees, consumers and other stakeholders to run its business. The disclosure sets out key stakeholder groups, their interests, how Carlsberg engages with them, and the impact on operations, business model and strategy. Groups include consumers, on- and off-trade customers, employees and contractors, industry organisations, investors and analysts, suppliers, sustainability experts and NGOs, and policymakers and regulators. Engagement methods range from consumer research, customer satisfaction surveys and supplier audits to employee surveys, industry memberships, investor reports and bilateral meetings with regulators. This continuous dialogue, including engagement that formed part of the double materiality assessment, informs the ESG programme, projects and processes. Feedback is shared on an ongoing basis with the ESG Steering Committee, Executive Committee and Supervisory Board.

Reference: page 59

The 2024 double materiality assessment identified 24 material impacts, risks and opportunities across eight topical standards (E1, E3, E4, E5, S1, S2, S4 and G1), all stemming from ESRS sub-topics and sub-sub-topics. Among the material topics, Carlsberg identified two financial risks and two financial opportunities, which are described in the relevant sections and are not currently impacting the business financially. The IROs are mapped across the value chain to show how they connect to strategy and business model, with the connection to Together Towards ZERO and Beyond (TTZAB) focus areas shown under SBM-3 for each topical standard. Carlsberg reports entity-specific disclosures for particular topics, namely ZERO Irresponsible Drinking targets and programmes under consumers and end-users, and ZERO Farming Footprint under regeneratively grown and sustainably sourced raw materials.

Reference: page 60

Carlsberg's double materiality assessment analysed the impacts, risks and opportunities of its own operations and upstream and downstream value chain, mapping IROs as identified to capture both direct and indirect impacts. The process used interviews with internal and external stakeholders and third-party research. Impacts were assessed on severity and likelihood, while risks and opportunities were assessed on financial magnitude and likelihood. Severity was scored 1-5 based on scale, scope and irremediability, with bespoke parameters per topic; risks and opportunities were scored on estimated impact on operating profit. In 2024, significant changes included an updated scoring methodology, consolidation of IROs to avoid double-counting and sharpened topical alignment, informed by EFRAG guidance. IROs were validated and approved by the ESG Steering Committee, Executive Committee and Supervisory Board. Carlsberg is working to align the DMA with its enterprise risk management framework.

Reference: page 53

Carlsberg provides an index listing all ESRS 2 disclosure requirements and those in the eight topical standards material to the Group (E1, E3, E4, E5, S1, S2, S4 and G1), which guided preparation of the sustainability statement. The index shows the section and page for each disclosure requirement and indicates where incorporation by reference has been used for items dealt with in the management review or Remuneration Report. To determine content, Carlsberg conducted interviews with key business stakeholders covering specific ESRS data points and company-specific targets, actions and roadmaps, followed by stakeholder consultation and verification. The DMA concluded that E2 Pollution and S3 Affected communities are non-material; relevant pollution aspects are addressed under E4 and E5, and affected communities aspects under E3. Data points deriving from other EU legislation are addressed on pages 106-107.

Reference: page 64

Carlsberg's transition plan sits within its Together Towards ZERO and Beyond (TTZAB) ESG programme. Targets: net ZERO emissions at breweries (Scope 1 and 2) by 2030, a 30% reduction in relative value chain emissions by 2030, and net ZERO across the entire value chain (Scope 1, 2 and 3) by 2040. Near-term and long-term targets are consistent with limiting warming to 1.5C, set using SBTi assumptions. Decarbonisation levers include energy efficiency, electrification, renewable energy and nature-based solutions. The plan was led by TTZAB target sponsors and the Group Sustainability and ESG function and approved under the Carlsberg governance model (GOV-1), with the plan embedded in business strategy and financial planning. Carlsberg expects locked-in GHG emissions below 10% that are hard to abate, to be covered through carbon removals. CapEx and OpEx detail appears under E1-3.

Reference: page 66

Two publicly available policies govern climate. The Environmental Policy summarises Carlsberg's approach to energy, climate change and resilience, water, waste, packaging, raw materials, agriculture, and investments and purchases. It is an overarching guiding document applying globally to all employees, contractors and visitors, and commits the Group to applicable laws, maintaining its ISO 14001-certified environmental management system, and continuous risk reduction toward ZERO environmental accidents. The EVP, Integrated Supply Chain is the most senior executive responsible, and the policy is reviewed every two years. The Supplier and Licensee Code of Conduct (SLCOC) includes an environmental section covering carbon emissions, water and waste, applying to all suppliers and setting minimum requirements, with suppliers expected to reduce their direct and indirect carbon footprint. The EVP, Integrated Supply Chain is also responsible for the SLCOC.

Reference: page 66

Actions span brewery and value chain decarbonisation. Brewery levers are energy efficiency (estimated 10-20% reduction), electrification and renewable energy (50-60%), technology innovation such as steam heat pumps and energy storage (10-20%), and nature-based solutions for residual emissions (around 10%). In 2024 Carlsberg began installing electric boilers, biogas recovery at two wastewater plants, and will add biomass boilers at five breweries in 2025. Value chain actions address agriculture, packaging, transportation and refrigeration, including replacing 28 diesel trucks with biogas vehicles in Western Europe and deploying electric trucks. Carlsberg invested DKK 120m in CapEx plus relevant OpEx in 2024, with DKK 130-180m in CapEx expected for 2025. Some investments overlap with EU Taxonomy activities (CCM 4.20, 7.3, 7.6).

Reference: page 66

Carlsberg has four climate change targets under ZERO Carbon Footprint. Target 1: net ZERO carbon emissions at breweries by 2030 (Scope 1 and 2), allowing up to 10% of hard-to-abate emissions to be offset with carbon credits, so 90% must be reduced from the 2015 baseline; the target covers 92% of baseline Scope 1 and 2 emissions and was set using SBTi criteria aligned with 1.5C. Target 2: 100% of brewery electricity from operational or contracted renewable sources by 2030. Target 3: 30% reduction in relative value chain emissions by 2030, covering all Scope 1 and 2 and most Scope 3, aligned with 1.5C. Target 4: net ZERO across the entire value chain by 2040 (Scope 1, 2 and 3). Following the Britvic acquisition, baselines and Scope 3 SBTi targets will be updated in 2025.

Reference: page 71

Total energy consumption related to own operations was 2,477 GWh in 2024. Total fossil energy consumption was 1,500 GWh (61% of the total), comprising fuel from coal and coal products (under 1 GWh), crude oil and petroleum products (296 GWh), natural gas (1,017 GWh), other fossil sources (1 GWh) and purchased electricity, heat, steam and cooling from fossil sources (186 GWh). Consumption from nuclear sources was 0 GWh (0%). Total renewable energy consumption was 977 GWh (39%), comprising renewable fuel including biomass (196 GWh), purchased renewable electricity, heat, steam and cooling (771 GWh) and self-generated non-fuel renewable energy from solar (10 GWh). Energy intensity from high climate impact sectors was 33 MWh per DKK million, on total consumption of 2,477 GWh.

Reference: page 72

Gross Scope 1 GHG emissions were 331 kt CO2e in 2024, with 11% from regulated emissions trading schemes. Gross location-based Scope 2 was 300 kt CO2e and gross market-based Scope 2 was 57 kt CO2e. Total gross indirect Scope 3 emissions were 7,832 kt CO2e, with the largest categories being Category 1 purchased goods and services (5,020 kt CO2e), Category 4 upstream transportation and distribution (736 kt CO2e), Category 14 franchises (570 kt CO2e), Category 9 downstream transportation and distribution (495 kt CO2e) and Category 15 investments (282 kt CO2e). Categories 8, 10 and 13 are not reported as not applicable or significant. Total GHG emissions were 8,463 kt CO2e location-based and 8,220 kt CO2e market-based. 2024 is Carlsberg's baseline year for CSRD reporting.

Reference: page 70

Carlsberg applies internal carbon pricing through shadow pricing during CapEx project approvals. For certain CapEx projects exceeding an investment of EUR 1.5m that relate to utilities and packaging, a shadow price is applied to assess climate impacts and potential climate-related financial impacts during decision-making. The current internal carbon price for Europe is fixed based on the 2022 average price of the EU Emissions Trading Scheme (ETS), while a different price applies to all other markets based on an estimate informed by the World Bank's Carbon Pricing Dashboard. An evolutionary pricing approach reflects forecasted carbon price increases. The shadow prices applied are: Europe DKK 574/t CO2e in 2024 rising to DKK 671/t CO2e in 2030, and Rest of the world DKK 440/t CO2e in 2024 rising to DKK 671/t CO2e in 2030. Shadow prices cover future emissions only on eligible CapEx projects.

Reference: page 78

Carlsberg's Environmental Policy sets the foundation for using water with maximum efficiency and engaging local communities in water management, particularly in high water risk areas. The policy underpins the ZERO Water Waste ambition and the voluntary TTZAB water targets, committing to sustainable water use and ensuring long-term water availability in water-scarce regions. High-risk areas are first identified using WWF's Water Risk Filter, then refined by operational risk, growth and size. The policy objectives address managing impacts of water consumption, including water scarcity, potential reduced availability for local communities, and biodiversity and ecosystem health. Targets are based on stakeholder views and internal subject matter expertise on technological feasibility.

Reference: page 79

Global actions focus on structuring, standardising and rolling out a best practice programme for more efficient water use in beverage production, with strong focus on the 17 breweries in high-risk areas. Key 2024 actions included updates to the global operations manual, development of a water diagnostic tool giving a detailed overview of brewery water consumption, and launch of a manual to optimise water used in cleaning. For replenishment, Carlsberg established new projects at four high-risk locations (three in China, one in Laos) and expanded or continued projects at four locations (one in Cambodia, three in India). In 2024 the company invested DKK 30m in CapEx and DKK 5m in OpEx, with DKK 50-70m CapEx expected in 2025.

Reference: page 79

There are two ZERO Water Waste targets. Target 1 aims for water usage efficiency of 2.0 hl/hl globally and 1.7 hl/hl at breweries in high-risk areas by 2030, applying to all breweries from a 2015 baseline of 3.6 and 4.0 hl/hl. Target 2 aims for 100% replenishment by 2030 of the water consumed at breweries in high-risk areas through off-site projects, following the Volumetric Water Benefit Accounting method developed by the World Resources Institute. A 2020 assessment using WWF's Water Risk Filter identified 17 high-risk breweries across India, Cambodia, Laos and China. The replenishment baseline of 0% was established in 2021. There were no changes to the targets in 2024.

Reference: page 80

In 2024, total water withdrawals were 27 million m3, total water consumption was 12 million m3, total water discharges were 15 million m3, and total water recycled and reused was 1 million m3. Water consumption in areas at water risk, including areas of high water stress, was 3 million m3. The water intensity ratio was 162 m3 per DKK million of net revenue. Water consumption is calculated as withdrawal at breweries minus discharged and sold water. Areas at water risk include breweries in high water stress areas identified through a detailed WWF Water Risk Filter assessment covering physical, regulatory and reputational risks, last conducted in 2020. Water intake is metered on site, with discharges roughly 80% metered and the remainder estimated.

Reference: page 82

Carlsberg has not yet conducted a full resilience analysis on nature, but its DMA addresses financial risks from biodiversity and ecosystems at a high level using stakeholder input and desktop research. The DMA, together with the nature-related assessment, identified material impacts related to nature, while financial risks related to biodiversity and ecosystems were assessed as immaterial. The company believes its TTZAB ambitions contribute to mitigating or reducing nature-related impacts and enhance resilience to changes in biodiversity and ecosystems. The biggest driver of biodiversity impacts is land use change, including agriculture, and Carlsberg is committed to reducing these impacts across its value chain through the ZERO Farming Footprint approach.

Reference: page 82

Through its TTZAB targets, partnerships and advocacy work, Carlsberg encourages farmers and suppliers to adopt regenerative agriculture practices that enhance conditions for biodiversity. Its stance on regenerative agriculture, set out in the Environmental Policy, directly addresses material value chain impacts including pollution of waterways, groundwater and soil, harm to ecosystems and biodiversity linked to raw material sourcing, and land use changes. The policy also addresses dependence on nature, including water supply, through a commitment to use water sustainably. Suppliers are contractually obligated to provide documentation of their regenerative claims, ensuring traceability. The policy includes a commitment to no deforestation across the primary deforestation-linked raw materials purchased.

Reference: page 82

Foundational actions include formalising principles of regenerative agriculture, mapping supply areas and partners, engaging suppliers, and integrating regenerative requirements into automated procurement. Carlsberg is piloting approaches across Europe at three levels: engaging, advancing and leading. In the UK it works with farmers to brew Carlsberg Danish Pilsner with 100% regenerative barley by 2027; Finland's KOFF Christmas Beer uses some regenerative principles; France's Kronenbourg 1664 Blonde uses 50% such barley; and Denmark signed an agreement for up to 500 tonnes of regeneratively grown malting barley. In Laos, a project reducing chemical fertiliser expanded from 100 to 340 hectares. In 2024 the company spent DKK 4m OpEx on pilots, with DKK 10-15m COGS expected in 2025.

Reference: page 82

The ZERO Farming Footprint approach has two targets. Target 1 requires 30% of raw materials purchased, measured as total weight, to be regeneratively grown by 2030 and 100% by 2040, covering all malt, barley, wheat, rice, sugar, corn and hops globally. Target 2 requires 30% of raw materials to be sustainably sourced by 2030 and 100% by 2040, using the Sustainable Agriculture Initiative's Farm Sustainability Assessment tool. Baselines of 0% for each were established in 2021. In 2024, less than 1% of raw materials were grown to leading regenerative principles and 0% were sustainably sourced, results described as expected during the ramp-up phase. No ecological threshold or impact allocation has been applied as definitions are still developing.

Reference: page 85

Through the ZERO Packaging Waste focus area of TTZAB, Carlsberg works to source more reusable, recycled or recyclable packaging and to drive circularity. The underpinning Environmental Policy details requirements for reducing packaging impact, minimising all waste and utilising by-products. It commits the group to using life cycle assessments or similar environmental assessments for all new packaging types and to working with partners to reduce packaging material consumption while promoting a more circular approach. The policy addresses sustainable sourcing and the use of renewable materials from both packaging and raw material perspectives. Details of the policy are summarised under E1-2 on page 66.

Reference: page 85

Actions focus on increasing recyclable, reusable or renewable packaging and expanding from primary to secondary packaging. In 2024 Carlsberg developed a roadmap of specific actions and improved data collection. The group promotes industry-driven non-profit deposit return schemes (DRSs) to raise collection rates and maintain mono-material value in closed recycling loops. It has long developed recycling and DRSs across the Nordic and Baltic countries and is exploring expansion in Asia and Central and Eastern Europe. In 2024 it finalised a position paper advocating DRSs and hosted a workshop in Latvia. For purchasing recycled packaging materials, primarily recycled PET, it invested DKK 120m in OpEx in 2024, with DKK 130-170m expected in 2025.

Reference: page 85

Carlsberg set four packaging targets, inspired by Ellen MacArthur Foundation definitions. Target 1: 100% recyclable, reusable or renewable primary packaging by 2030; in 2024, 94% qualified (baseline year). Target 2: 90% collection and recycling rate for bottles, cans and kegs by 2030; in 2024 markets achieved an average 76%, up 4 percentage points from the 2019 baseline of 72%. Target 3: 50% recycled content in bottles and cans by 2030; in 2024 recycled materials made up 43% of primary packaging content, up 14 percentage points from the 2019 baseline of 29%. Target 4: 50% reduction in virgin fossil-based plastic by 2030 versus 2019. Targets were unchanged in 2024.

Reference: page 87

Resource inflows are measured directly through procurement reports covering all material inflow related to beverage production. In 2024 the total weight of products and biological materials used was 3,616 kt. The total weight of recycled or reused materials was 774 kt, giving a share of recycled or reused materials of 21%. The share of biological materials that are sustainably sourced was 0%. Total weight of products and biological materials includes agricultural ingredients (adjuncts such as barley and rice; other ingredients such as hops and sugar; process materials such as brewing additives and yeast) and packaging materials (primary aluminium, glass and plastic; secondary and tertiary such as corrugated and hi-cone). A consistent cut-off period and standardised classification are applied across all regions.

Reference: page 87

In 2024 the recyclable content in packaging was 96%. Products in scope include the primary packaging categories of glass bottles, aluminium cans, PET bottles and plastic kegs (DraughtMaster). Share of recyclable content in packaging is calculated as the weight of recyclable packaging materials divided by the total weight of packaging materials across primary, secondary and tertiary. To be considered recyclable, a material must be technically designed to fit a recycling stream proven to work in practice and at scale in a representative market, following the principles of the Ellen MacArthur Foundation's global approach. For PET, a component-specific assessment of colour and barrier is conducted. A higher degree of measurement uncertainty is present in the input data.

Reference: page 87

In 2024 the recyclable content in packaging was 96%. Products in scope include the primary packaging categories of glass bottles, aluminium cans, PET bottles and plastic kegs (DraughtMaster). Share of recyclable content in packaging is calculated as the weight of recyclable packaging materials divided by the total weight of packaging materials across primary, secondary and tertiary. To be considered recyclable, a material must be technically designed to fit a recycling stream proven to work in practice and at scale in a representative market, following the principles of the Ellen MacArthur Foundation's global approach. For PET, a component-specific assessment of colour and barrier is conducted. A higher degree of measurement uncertainty is present in the input data.

Reference: page 89

Carlsberg's management of own-workforce IROs is underpinned by several policies, all available on the intranet and all but the Human Resources Policy published online. The Human Resources Policy covers recruitment, working conditions, career development, wellbeing and employee relations, and is owned by the Chief Human Resources Officer. The Health and Safety Policy, aligned with ISO 45001 and ILO standards, applies to employees and on-site contractors; a chemical management standard was added in 2024. The Diversity, Equity and Inclusion Policy targets unequal gender representation in senior management with zero tolerance for harassment. The Human Rights Policy, enhanced in 2024 with BSR, articulates due diligence and grievance channels.

Reference: page 90

Employee engagement is part of Carlsberg's people strategy, with the Chief Human Resources Officer responsible for global processes. Engagement channels include the annual My Voice survey covering topics such as work-life balance, harassment and gender representation; quarterly global townhall meetings with the Group CEO and CFO; senior management market visits; two Employee Resource Groups; the Organisational Health Index; the European Works Council; and onboarding and exit surveys piloted in 11 markets. The 2024 European Works Council met in June with 27 representatives from 15 markets, the 24th year it has convened. My Voice wellbeing questions scored 76 out of 100, 6 points above the external benchmark. Effectiveness is monitored via survey metrics, ERG participation and turnover.

Reference: page 89

Carlsberg's Human Rights Policy outlines continuous human rights due diligence and rightsholder engagement, including the provision of grievance channels, and describes how the Group provides and cooperates to remedy where appropriate. Carlsberg is committed to providing or cooperating in the remediation of any adverse human rights impact on individuals, including its own workforce, that it has caused or contributed to, and will collaborate with judicial or non-judicial mechanisms to provide access to remedy. Where actual or potential discrimination is identified through in-country human rights impact assessments, a remedial action plan is established with clear deadlines and a procedure if corrective actions are not closed within the agreed timeframe. The SpeakUp Line is the channel for raising concerns. Further detail is incorporated by reference to the management review and ESRS index.

Reference: page 91

Carlsberg's Health and Safety programme aims to prevent physical harm and mitigate the risk of severe accidents across all global markets and sites, also covering work outside sites such as driving and deliveries, plus contractors and visitors. The programme prioritises prevention; when incidents occur, an incident review panel investigates root causes and learnings are shared via a weekly health and safety update. Key actions include regular health and safety days, quarterly townhalls, safety walks, espresso shot micro-training sessions on the five Life Saving Rules, leadership coaching training, and campaigns on common injuries such as slips, trips and falls, chemical hazards and driving risks. Effectiveness is measured through action trackers, monthly reporting, site visits, self-assessments, audits and an annual incident heat map.

Reference: page 91

Carlsberg's Health and Safety Policy is founded on the belief that all accidents are preventable, with a target of achieving ZERO accidents. Two health and safety targets apply to all own employees: a year-on-year reduction in the accident rate, and ZERO lost-time accidents by 2030. The KPIs are the number of lost-time accidents and the lost-time accident rate (LTAR). Employees are engaged on performance during safety week and through regular campaigns, and incident review panels are convened after lost-time accidents and near-misses to share learnings. The targets were set based on extensive stakeholder engagement under the Together Towards ZERO and Beyond programme. A separate DE&I target of 40% women in senior leadership roles by 2030 is described under S1-9.

Reference: page 94

Carlsberg reported 32,591 total employees (headcount at period end), comprising 8,819 female, 23,771 male and 1 other. By contract type there were 30,347 permanent employees, 2,111 temporary employees and 133 non-guaranteed hours employees; 32,098 were full-time and 493 part-time. By gender breakdown, male totalled 23,771, female 8,819, other 1 and none not reported. China was the only country with at least 50 employees representing at least 10% of the total, at 6,843. By age, 6,204 employees (19%) were under 30, 19,466 (60%) between 30 and 50, and 6,921 (21%) over 50. In 2024, 5,077 employees left Carlsberg, giving an employee turnover rate of 16%.

Reference: page 94

Carlsberg welcomes collective bargaining and does not discriminate against participants. It has no global target or baseline, focusing instead on sound processes and management support, but tracks coverage annually in every market. Its stance is set out in the global Human Rights Policy, with agreements negotiated locally in good faith and relevant employee representatives consulted on potential changes to working conditions. In 2024, 61% of the global workforce was covered by collective bargaining agreements. Coverage by region was 49% in Western Europe (excl. EEA), 65% in CEEI (excl. EEA) and 60% in Asia. The percentage of employees covered by workers' representatives was 72%, a figure that includes an agreement signed with the European Works Council.

Reference: page 93

Carlsberg's DE&I approach promotes gender equity, supported by a Women's Sponsorship Programme (13 participants in 2024) and pay equity and transparency work. The target is 40% women in senior leadership roles by 2030, with interim targets of 30% by 2024 and 35% by 2027, applying to all senior leaders globally (Director level and above). Against a 2020 baseline of 28%, representation reached 30% in 2024, meeting the interim target; women in ExCom rose to 33% from 0% in 2020. Gender split in senior leadership was 246 female (30%) and 562 male (70%), with 0 other and 0 not reported. A DE&I Council of senior executives oversees alignment, and ExCom receives quarterly gender balance data. Further headcount diversity data is reported under S1-6.

Reference: page 94

Adequate wages have not historically been managed centrally, and Carlsberg has no global target or baseline, as current performance indicates no cases of employees paid below the minimum or living wage. The Group offers competitive salaries and regularly reviews local payment practices against criteria aligned with the ESRS framework, reflecting its Global Pay Principles. In 2024, Carlsberg reviewed all markets to gather the lowest wage paid, benchmarking against national minimum wages where available and an external living wage benchmark otherwise. Findings confirmed all employees are paid at or above the minimum or living wage. Data collection continues annually, with concerns reported to the Chief Human Resources Officer. A My Voice survey question on fair compensation, added in 2023, scored 7 percentage points above the Glint Global Benchmark.

Reference: page 92

In 2024 Carlsberg experienced 94 lost-time accidents among own employees, a 69% decrease from its 2015 baseline of 302, and a lost-time accident rate of 1.6, down 63% from the 2015 baseline of 4.4 and a year-on-year improvement. Lost-time accidents among contractors numbered 37. The Group recorded ZERO severe injuries and fatalities from work-related injuries. Health and safety metrics: 100% of employees were covered by Carlsberg's health and safety management system; fatalities from work-related injuries and ill health were 0; recordable work-related incidents totalled 190 at a rate of 3.3. The number of contractor fatalities on Carlsberg sites from work-related injuries or ill health was 0. The accident rate is calculated per one million hours worked, using FTEs multiplied by 1,746 hours.

Reference: page 93

Carlsberg reported a gender pay gap of 0% for 2024, describing its global gender pay gap as negligible while noting the figure can be heavily influenced by the geographic and functional composition of the workforce, so it continues to monitor at a granular level in each market. CEO pay (S1-16) is disclosed in the Remuneration Report. The gender pay gap is calculated as the difference between the average gross annual pay of all male and female employees divided by the average gross annual pay of all male employees, with gross pay covering all fixed and variable compensation components. Carlsberg is satisfied it operates according to equal pay for equal work and has developed an internal Pay Transparency dashboard, initially for Western European markets and being rolled out further globally.

Reference: page 95

Carlsberg reported the following grievance mechanism figures for 2024: 39 incidents of discrimination including harassment; 17 complaints filed through channels for people in own workforce to raise concerns; 0 complaints to National Contact Points for OECD Multinational Enterprises; and DKK 0 in fines, penalties and compensation for damages from these incidents and complaints. Confirmed severe human rights incidents connected to own workforce were 0, including 0 cases of non-respect of the UN Guiding Principles and OECD Guidelines, with DKK 0 in related fines. Incidents of discrimination and harassment include substantiated SpeakUp Line cases of bullying, harassment, sexual harassment, discrimination and retaliation. No confirmed severe human rights incidents occurred within the FY2024 reporting year.

Reference: page 96

The Supplier and Licensee Code of Conduct (SLCOC) addresses forced labour, human trafficking and child labour, and requires suppliers to notify Carlsberg of any breaches. Its principles are aligned with the UN Guiding Principles and the ILO Fundamental Principles and Rights at Work. The policy follows a risk-based approach: the SLCOC is part of every supplier contract, with monitoring based on a risk assessment aiming to cover all high-risk suppliers by the end of 2026. The EVP, Integrated Supply Chain is the most senior executive responsible for implementation. The SLCOC was revised in 2024 to reflect SMETA requirements across labour conditions, human rights, environmental management and business ethics. It is available internally and publicly online. The Human Rights Policy is also relevant and is described in S1-2.

Reference: page 97

Carlsberg monitors compliance with its Human Rights Policy through three methods: country- or region-specific human rights impact assessments (HRIAs), third-party SMETA audits of high-risk suppliers via Sedex, and internal human rights audits of its own operations. Upstream suppliers are screened using four tools, starting with a Sedex Self Assessment Questionnaire, with high-risk suppliers required to undergo a SMETA audit. HRIAs include direct inputs from workers, and Sedex auditors must speak confidentially with workers. Downstream, confidential face-to-face interviews are conducted with rightsholders. Brand promoters and outsourced drivers are identified as at-risk groups. Effectiveness is monitored through audit performance results, improvement curves over time, action plan progress and reports to the SpeakUp grievance line.

Reference: page 98

Where Carlsberg finds it is directly linked to adverse human rights impacts, it uses its leverage to bring positive change. The Sedex escalation process ensures best-practice procedure is followed and follow-up actions are monitored in a timely manner. If gaps that might lead to a severe violation of ESG criteria are not closed, an escalation and remediation process is applied, and if this fails Carlsberg will consider terminating the business relationship. For specific material negative impacts, it undertakes supplier training with external providers, hosts supplier days and collaborates with industry peers. Carlsberg communicates its Whistleblower Policy and how workers in its value chain can raise an issue if a breach of the SLCOC is suspected. Further detail is incorporated by reference to the management review.

Reference: page 98

In 2024 Carlsberg fully implemented its enhanced Responsible Sourcing Framework, sharpening focus on salient human rights risks and integrating compliance into procurement processes. The Framework uses the Sedex Risk Assessment tool for country and industry risk, and for higher-risk raw materials requires transparency on origin, including the Responsible Minerals Assurance Process for cobalt and an internal tool for sugar. Within the first year, more than 200 suppliers joined the Sedex platform, all completing the SAQ, with high-risk suppliers required to complete a SMETA audit. Carlsberg is a member of AIM Progress and addresses working conditions in the informal waste sector. In 2024 it provided six training sessions for procurement teams and suppliers across three regions.

Reference: page 98

Carlsberg does not currently have an official target for responsible sourcing, as it is focused on building a strong foundation through policies and processes. Its responsible sourcing commitments include a target of achieving 100% compliance with the Supplier and Licensee Code of Conduct, tracked through continuous monitoring via SMETA audits. Onboarding of suppliers to Sedex began in 2023, and in the coming years Carlsberg aims for all suppliers in scope to be onboarded to the Sedex platform and for the majority of those in scope to be audited or certified. For suppliers receiving a high risk score, it expects to see progress and improvement after their first audit. Information on allocation of financial resources is provided on page 102.

Reference: page 100

Carlsberg's approach to managing its material impacts, risks and opportunities relating to consumers and end-users is underpinned by its Marketing and Communication Policy, which sets out its approach to communicating with consumers and the general public. The policy has eight key focus areas: transparency and integrity, adult appeal, enjoyment in moderation, alcohol-free, safe and sensible behaviours, effects, health and performance, socially inclusive and environmentally conscious. It was updated in 2024 with clearer commitments and new sections on sponsorships, influencers, digital marketing and gaming. The CMO and VP, Corporate Affairs govern the policy, which covers all alcohol brands and their alcohol-free line extensions. Carlsberg is a signatory to the Responsible Marketing Pact of the World Federation of Advertisers. The policy is available internally and publicly online.

Reference: page 100

Carlsberg engages with consumers in an ethical and honest way, aiming to be proactive in self-regulation through the product development process and its marketing and communications activities, which provide transparent information to help prevent harmful use of its products. At a global level, the Marketing Insights team manages research into health and wellness trends that feed into brand planning, with insights indicating significant consumer interest in alcohol-free and low-alcohol products. Markets must report on local initiatives, campaigns and partnerships and on labelling compliance, and a survey is conducted among markets twice a year to monitor the impact of responsible drinking activities. Carlsberg is committed to protecting minors, mandating legal age-restriction symbols on packaging and applying a 70/30 rule for advertising channels.

Reference: page 101

Carlsberg does not have a global process for providing remedy in relation to the material impact, other than the processes described in the SpeakUp section within the management review. To ensure its practices do not contribute to negative impacts, it continuously monitors market developments to identify emerging issues and where it might need to update policies or develop initiatives to address and mitigate potential negative impacts. An example is the potential appeal of energy drinks to children, which it is monitoring and will address in its next policy update. For where more information can be found, the report refers readers to the ESRS index on page 50. Detail on grievance channels is incorporated by reference to the management review.

Reference: page 101

Carlsberg's primary focus under ZERO Irresponsible Drinking is investing in actions to minimise and mitigate potential negative impacts on consumers. It collects global and local inputs on consumer trends and monitors public and political interests in public health through engagements with industry organisations, health agencies and political engagements. It addresses its financial risk and opportunity in tandem by increasing the share and availability of low- and no-alcohol alternatives and engaging consumers through responsible drinking messaging and partnerships. Actions supporting its targets include promoting no- and low-alcohol products through marketing campaigns and partnerships, expanding the AFB portfolio, running partnerships with festivals, sporting events, retailers, authorities and NGOs, and continuously updating responsible drinking messaging on primary packaging across all markets.

Reference: page 101

Carlsberg has four ZERO Irresponsible Drinking targets to be achieved by 2030: 35% of brews globally to be low-alcohol or alcohol-free; 100% availability of alcohol-free brews across operating markets; 100% of markets running partnerships to support responsible consumption; and 100% responsible drinking messaging on primary packaging. In 2024, low-alcohol or alcohol-free beers represented 30% of total volume sold, up 3 percentage points from the 2021 baseline of 27%. AFBs were available in 90% of markets, up 32 points from 58%, and 86% of companies implemented responsible drinking partnerships, up 18 points from 68%. Performance is in line with expectations. Carlsberg does not engage consumers for the purpose of tracking performance against its targets.

Reference: page 103

Carlsberg's anti-bribery policy requires compliance with all applicable laws, including the U.S. FCPA, the UK Bribery Act 2010 and other national statutes, and commits to the UN Convention Against Corruption. It applies globally to all employees and contract workers, with the Group General Counsel and Chief Compliance Officer responsible for implementation. The Remuneration Policy, updated in 2024 to add long-term ESG targets to incentives, is reviewed by the Remuneration Committee and approved by the Supervisory Board and AGM. The SpeakUp Manual lets employees and external parties raise concerns confidentially, aligns with the EU Whistleblower Directive, and was updated in 2024 and translated into local languages.

Reference: page 104

Carlsberg operates a zero-tolerance approach to bribery and corruption supported by global policies and practices. Market managing directors sign an annual compliance attestation, and annual legal and compliance risk assessments, enhanced in 2024 with Group-level subject matter experts, are reported to ExCom and the Audit Committee. Breaches are identified through internal controls, internal audits and the SpeakUp whistleblower system. By end-2024 Carlsberg launched the Compass+ governance, risk and compliance programme, with full rollout from 2025. All employees with a corporate email address complete anti-bribery and Code of Ethics training at onboarding, with refreshers every three years and enhanced training for higher-risk roles. The share of functions at risk covered by training programmes was 100%. The policy is available in 27 languages.

Reference: page 104

Carlsberg reports its anti-bribery and corruption effectiveness partly through the number of convictions, acknowledging potential time lags. For 2024, the company reported zero convictions for violation of anti-corruption and anti-bribery laws and zero DKK in related fines. The metrics cover instances where a Carlsberg legal entity has been convicted of anti-bribery or corruption violations by a court of law, as well as any fines imposed in connection with enforcement actions brought against the company for such violations. Suspected cases are investigated and addressed through standard internal investigation processes. Carlsberg links executive remuneration to ESG performance through its Remuneration Policy, treating this as a material impact requiring robust governance rather than specific targets.