Copenhagen Airport

CPH's commitment to sustainability is anchored with the Board of Directors and integrated throughout the organisation. The Executive Management is responsible for preparing and presenting the annual sustainability statement as part of the Annual Report, and holds ultimate responsibility for sustainability and climate-related risks and opportunities, including approving targets and overseeing policies and actions to mitigate negative impacts. Multiple functions across the organisation set goals, targets and action plans for social and governance matters. Reporting and internal controls for sustainability follow the same internal governance structure as other reporting, reporting first to Executive Management and, when the subject merits, to the ARMC and the Board of Directors. In 2024 the Board of Directors consisted of six shareholder-elected members, of whom two (33%) were considered independent. Both bodies have extensive knowledge of airport operations and the aviation industry. Gender distribution and targets for the Board and Executive Management are described on page 94, and further detail on roles, composition and experience is on page 30.

On a regular basis, material IROs and developments therein are reported to the Executive Management, and subsequently to the ARMC and the Board of Directors. In 2024, the Board of Directors considered all material IROs as part of the review of the materiality assessment. An overview of material IROs is included in the sustainability statement in the IRO-1 section on page 48. Both the Board of Directors and the Executive Management have thorough and extensive knowledge of the operation of an airport, positioning them to evaluate the effects of the IROs identified as part of the double materiality assessment. Given their knowledge of the aviation industry and experience from other listed companies, the Board is well-positioned to evaluate sustainability matters relating to CPH's products and services.

The remuneration policy for the Executive Management is designed to align compensation with organisational objectives, with a primary focus on long-term sustainable business development and creating lasting value for shareholders. CPH's compensation framework integrates sustainability performance metrics to drive strategic alignment. The Executive Management's incentive schemes encompass both environmental and social objectives, including the development of a renewable energy plan to facilitate the 2030 net zero goal in own operations, fostering an equitable and inclusive culture, and maintaining a zero-fatality workplace safety record. Total remuneration of the Executive Management in 2024 was DKK 18.6 million. The proportion linked to climate-related performance goals was DKK 0.8 million, or 4.2%. Total variable remuneration was DKK 7.9 million, and the proportion of variable remuneration linked to all sustainability-related performance goals was DKK 1 million, or 13%. The Remuneration Committee provides governance by annually reviewing and approving these incentive schemes. Further detail is in the Remuneration Report.

A table outlining CPH's application of due diligence for people and environment, together with the location of the related information within the sustainability statement, is included on page 120. CPH is currently establishing a structure for the reporting of due diligence and the effectiveness of sustainability-related impacts, risks and opportunities similar to the set-up it has for enterprise risk management issues.

To mitigate the inherent risk of material misstatements arising from potential human error or data incompleteness, CPH has established internal control systems to manage sustainability reporting risks through clear targets, policies and controls. Going forward these will be monitored and improved through an annual risk assessment to identify potential errors based on materiality, complexity and likelihood of mistakes. Reporting on controls will be carried out periodically in accordance with the internal controls set-up for financial reporting. The control framework includes evaluating key sustainability reporting areas, reviewing existing controls and adding new ones where needed. CPH has implemented a structured sustainability governance process, including ARMC oversight, and has established accounting methodologies in line with ESRS requirements. Controls are continuously tested, and an ongoing evaluation of material aspects of sustainability reporting has been established, including regular reassessment of existing controls and identification of additional measures at least once per year.

CPH's value chain is illustrated on page 42, based on information gathered across multiple functions that contributed knowledge to the materiality assessment. CPH's business spans both infrastructure and services relating to air traffic in its locations in the Greater Copenhagen area, including rental and concession income from leasing properties, passenger and employee parking, and cargo and passenger air traffic. As of 31 December 2024, the total number of employees came to 2,835 (headcount) and total net revenue to DKK 5,070 million. CPH operates within two sectors as classified by EFRAG: Other transportation (operation of the airport and parking) and Real Estate (other concession activities and services). Reducing environmental and related social impacts is a strategic priority. The sustainability strategy contains three programmes centred on operations in Copenhagen and Roskilde: Circularity, Environmental Impacts and Decarbonisation. CPH is committed to net zero emissions from own operations by 2030, with a long-term target of net zero across the value chain by 2050.

Stakeholder engagement is an essential part of CPH's day-to-day business and provides understanding of material matters, forming the basis for developing solutions and initiatives. Interaction with stakeholders is an organic process allowing continuous calibration of the strategy. Engagement with employees and their representatives plays a key role in shaping the human resources strategy, and the strategy is determined by the Board of Directors with input from the entire organisation. Regarding sustainability impacts, the Board and Executive Management are informed about the views and interests of affected stakeholders through the presentation of the double materiality assessment, regular surveys and dialogue sessions with key stakeholder groups such as employees, local communities, customers, suppliers and regulatory bodies. So far CPH has not identified any need to adjust the strategy or business model as a result of stakeholder engagement. A stakeholder engagement table describes engagement with passengers and business partners, employees, suppliers, government and regulators, industry bodies, owners, and local communities, along with the purpose and outcomes of each engagement.

The results from CPH's double materiality assessment helped identify material impacts on the environment and society (impact materiality) alongside material risks and opportunities (financial materiality). The outcome is presented at an aggregated level by ESRS topic. The ESRS topics triggered by the materiality assessment are E1, E2, E4, E5, S1, S2, S3, S4 and G1, of which only S3 is double material. E3 was not considered material for CPH. In the double materiality matrix, G1 is shown as financially material and S3 as double material. The identified environmental impacts are closely linked to the strategic efforts of the sustainability strategy described further on page 61, and some environmental impacts are also reflected in the identified social and governance impacts. The material IROs are presented on the following pages, including their location in the value chain (own operations, upstream, downstream) and time horizon (short, medium and long term), and briefly at the beginning of each ESRS topic section. CPH has not estimated the anticipated financial impacts of the listed IROs.

CPH conducted its first double materiality assessment in compliance with ESRS requirements, subsequently enhanced through a strategic review in 2024. To ensure methodological rigour and objectivity, CPH engaged an external consultancy to establish standardised criteria and thresholds prior to scoring IROs. Targeted interviews with internal subject matter experts across the organisation identified actual and potential IROs throughout the value chain, with experts in some cases acting as proxies for suppliers, investors and employees. Findings were validated against SASB industry standards and cross-referenced with EFRAG's implementation guidance to identify applicable disclosure requirements. Time horizons follow the CSRD: short term up to one year, medium term one to five years, and long term more than five years. No climate-related scenario analysis was conducted; physical and transition risks were assessed using in-house expertise and GHG Protocol principles. Impact materiality scoring was based on an average of severity and likelihood, while financial materiality scoring multiplied the magnitude of the potential financial effect by its likelihood. A matter was material if at least one IRO scored above threshold, and double material where relevant IROs exceeded thresholds for both. The DMA is reviewed annually, and results are signed off by the Executive Management and the ARMC and Board of Directors. As a result of the process, E3 was not considered material.

A table outlining the material disclosure requirements covered by the sustainability statement can be found on page 122. A separate table outlining datapoints from cross-cutting and topical standards that derive from other EU legislation can be found on page 125. The underlying material IROs identified during the materiality assessment are all covered by ESRS disclosure requirements and are presented in the following pages, including an explanation of where the IROs are located in the value chain (own operations, upstream, downstream) and their time horizon (short, medium and long term).

CPH commits to aligning its strategy and business model with the transition to a net zero global aviation sector by 2050. It reaffirms its near-term commitment to net zero emissions from its own operations by 2030 and its long-term target of net zero across the value chain by 2050, both aligned with limiting warming to 1.5 degrees C. The near-term scope 1 and 2 target is Paris-aligned, though CPH has not yet set a science-based near-term scope 3 reduction target. The plan is built around leveraging low-carbon technologies, resource optimisation and stakeholder engagement. GHG-intensive assets will be replaced with lower-carbon alternatives or decarbonised using renewable biofuels. The transition plan was approved by the relevant administrative and management bodies and is embedded in business strategy and financial planning. CPH has not fully quantified the OPEX and CAPEX needed to execute the plan and notes EU Taxonomy alignment remains difficult. Since 2019, combined scope 1 and 2 market-based emissions have fallen 7.5%.

CPH has implemented policies to identify, assess and manage material environmental impacts, risks and opportunities. Its Environmental Policy covers resource management, climate change mitigation and adaptation, biodiversity and pollution across operations and the upstream and downstream value chain. The policy starts with full compliance with all relevant environmental, climate and energy regulations and commits CPH to implementing concrete actions to continuously improve environmental performance, focusing on preventing and reducing negative impacts including greenhouse gas emissions and discharges to air, water and soil. It is overseen by the Chief Sustainability Officer and is accessible to all employees and lessees of CPH real estate. CPH's Energy Policy focuses on managing electricity, district heating and natural gas across facilities, committing to compliance with energy regulations, continuous optimisation of energy consumption, and a gradual increase in the renewable energy share, aligned with its ISO 50001 energy management certification. Environmental targets are reviewed and updated annually. The Sustainability department is responsible for updating the policies, which are approved by the Board of Directors.

CPH outlines actions to achieve its Environmental and Energy Policy objectives through three levers: leveraging low-carbon technologies, resource optimisation and stakeholder engagement. Resource availability is assessed and funds allocated through CPH's annual strategic and financial planning cycle. Under low-carbon technologies, CPH is electrifying operations, replacing natural gas boilers with electric heat pumps and district heating, and increasing the share of battery-electric vehicles and equipment. It is implementing energy efficiency building retrofits and pursuing on-site renewable generation plus market-based renewable procurement. In 2024 CPH signed a power purchase agreement with Vattenfall to source 100% of its electricity from two wind farms off Jutland, effective 1 January 2025, expected to cut scope 2 emissions to 94% below the 2019 baseline and scope 3 downstream leased asset emissions to 91% below the 2024 baseline. Resource optimisation focuses on supplier engagement, circular resource management, procuring lower lifecycle emission goods, and construction practices like prefabrication and material reuse. Stakeholder engagement involves collaboration with airlines, the air traffic service provider, ground handling companies, employees and passengers to reduce aircraft and ground transportation emissions, including expanding EV charging and cycling facilities.

CPH has established targets to mitigate negative climate impacts, aligned with limiting warming to 1.5 degrees C. Its first target is to achieve net zero emissions from own operations by 2030, requiring a 90% reduction in scope 1 and 2 (market-based) emissions by 2030 against a 2019 baseline, with residual emissions compensated through high-quality third-party-verified carbon removal credits. The target was set using the cross-sectoral absolute contraction target-setting methodology from SBTi's Corporate Net Zero Standard, though it has not been validated by SBTi. The 90% reduction is to be achieved by electrifying the vehicle and equipment fleet, phasing out natural gas boilers via district heating and electric heat pumps, and procuring renewable electricity via a PPA. The roadmap assumes a 24% increase in electricity consumption in 2030 relative to 2024. CPH's second target is net zero across the value chain by 2050, reducing combined scope 1, scope 2 (market-based) and scope 3 emissions by 90% by 2050 against a 2024 baseline. Scope 3 levers have not yet been formally evaluated or adopted. The 2030 and 2050 targets were set without external stakeholder involvement.

CPH reports total energy consumption of 96,140 MWh in 2024, up from 94,914 MWh in 2023. Total fossil energy consumption was 54,577 MWh (57% share), comprising 7,049 MWh from crude oil and petroleum products, 3,333 MWh from natural gas, and 44,195 MWh of purchased electricity, heat, steam and cooling from fossil sources. Consumption from nuclear sources was 4,351 MWh (5% share). Total renewable energy consumption was 37,213 MWh (39% share), made up of 1,828 MWh of renewable fuel including biomass, 33,195 MWh of purchased renewable electricity, heat, steam and cooling, and 2,191 MWh of self-generated non-fuel renewable energy. CPH states its entire energy consumption is from a high climate impact sector (transportation and storage). Energy intensity per net revenue from high climate impact activities was 19.0 MWh per monetary unit in 2024, down 18.9% from 23.4 in 2023. Self-generated non-fuel renewable energy comes from 13 photovoltaic systems, five owned by CPH.

CPH reports GHG emissions prepared under the GHG Protocol using the operational control approach. For 2024, gross scope 1 emissions were 2,761 tCO2eq (up 1% from 2,725 in 2023; 2,870 in 2019). Gross scope 2 emissions were 6,581 tCO2eq location-based and 21,868 tCO2eq market-based (down 1% from 22,046 in 2023; 23,748 in 2019). Gross scope 3 emissions were 455,436 tCO2eq location-based and 471,520 tCO2eq market-based, with 2024 established as the scope 3 baseline year and 77% calculated using primary data. Major scope 3 categories include use of sold products (aircraft LTO cycle) at 266,300 tCO2eq, downstream transportation and distribution 61,679, capital goods 72,050, purchased goods and services 32,971, and downstream leased assets 22,758 (market-based). Total GHG emissions were 464,778 tCO2eq location-based and 496,149 tCO2eq market-based. GHG intensity per net revenue was 91.7 (location-based) and 97.9 (market-based) tCO2eq per 000' DKK.

In 2024, CPH entered a contractual agreement with Klimate ApS to procure carbon removal credits from agroforestry projects in India and Nepal amounting to 23,000 tCO2. In Q1 2025 these removals will be verified against Verra's Verified Carbon Standard (VCS) and delivered to CPH. In January 2025, CPH will enter a second agreement with Klimate ApS for an additional 7,300 tonnes of carbon removal, comprising 6,738 agroforestry credits, 533 industrial biochar credits and 29 direct air capture credits, verified against Plan Vivo, Puro Earth or VCS. The two orders total 30,300 tCO2. In Q1 2025, CPH will retire a total of 24,972 carbon removal credits equal to its 2024 GHG emissions from scope 1, scope 2 (market-based) and business travel (scope 3 category 6). To achieve net zero from own operations by 2030, carbon removal credits will compensate for residual emissions equal to a maximum of 10% of scope 1 and 2 (market-based) emissions from the 2019 baseline year. CPH does not attach any claims of GHG neutrality to its carbon offsetting practice.

CPH states it is guided by comprehensive external regulations, including those from local municipalities and the Danish Environmental Protection Agency. These regulatory frameworks provide clear and detailed guidance, reducing the need for additional internal policies and enabling CPH to focus resources on mitigating material impacts while ensuring compliance with applicable standards. Its Environmental Policy does not specifically address each pollution impact; instead efforts are guided by management and operational controls and procedures. CPH continuously measures air quality at and around the boundaries of its airports in accordance with its environmental permit, reports data to relevant authorities and publishes it on cph.dk. The 2024 results confirm operation within permitted limit values.

In 2024 CPH complied with regulations to mitigate pollution impacts, structuring actions by pollution type. For air, it ran a local air quality programme involving airlines and handlers, signed a new agreement with SAS, Copenhagen Infrastructure Partners and Aalborg Airport to initiate sustainable aviation fuel (SAF) production in Denmark, participated in the EU Horizon project ALIGHT to reduce auxiliary power unit (APU) use, ran information campaigns and training, approved investment to deploy AI-enabled thermal cameras at the 40 busiest aircraft stands in 2025, installed particle filters, electrified ground handling equipment, and is converting a fleet of roughly 650 vehicles. For water, it improved run-off management, sending de-icing fluids with glycol above 5% to external treatment, established a surface water treatment plant, and expanded PFAS treatment to four active plants in Copenhagen and Roskilde. For soil, contaminated soil is treated on-site or sent externally.

CPH adheres to relevant legislation to mitigate air, water and soil pollution. It states internal targets are not formalised but that air pollutants, emissions to water, pollutants to soil and substances of concern and very high concern are prevented and controlled in line with regulations. The targets are not required by any legislation and are not measured using specific loads. To track effectiveness of actions to prevent and mitigate air pollution, CPH aims to ensure that 90% of all local equipment and vehicles are low-carbon emission by 2030. This definition covers vehicles powered by electricity, hybrid technology (plug-in hybrid), diesel with a closed particle filter approved by the Danish Road Traffic Authority, or new technology documenting a clean exhaust such as fuel cells or gas. Targets on low-carbon-emission vehicle numbers were reported in previous annual reports and were not changed during the reporting year.

Air quality and emissions are monitored by accredited provider FORCE Technology, with emission inventories prepared annually using the AEDT model developed by the US Federal Aviation Administration, covering aircraft activities below 1,000 feet and indexed to 2019. In 2024 air pollution included CO 749 tonnes, NOx 1,243 tonnes, SOx 109 tonnes, THC 89 tonnes, PM2.5 11 tonnes, and ultrafine particles 8,298 (number in 10 to the 22). Operations totalled 239,760. Surface water discharged to Oresund included Total-N 64.90 mg/l, Total-P 0.40 mg/l, mineral oils 5,270 ug/l, plus PFOS 0.084 kg/year, sum 4 PFAS 0.141 kg/year and sum 22 PFAS 0.267 kg/year. Wastewater was discharged to Dragor and Kastrup. For soil, 277 samples across 25 construction works were taken in 2024, with no pollution exceeding Annex 2 of EU Regulation 166/2006.

CPH reports that in 2024, leveraging internal expertise, progress was made on developing a nature-focused programme within its sustainability strategy. As part of the new Nature programme, a resilience assessment will be carried out and the transition plan will be further developed. The company frames this within its priority on flight safety, which requires managing nature and biodiversity within secure airport areas, alongside continued efforts to contain and reduce pollution to minimise effects on ecosystems.

CPH states its Environmental Policy, described under E1-2, addresses biodiversity as a whole, supported by pollution-mitigating actions referenced in E2-2. Additionally, activities related to wildlife impacts are managed by its safety management system. This system comprises the habitat plan described in the Strategy section, a wildlife hazard management programme, a Wildlife Hazard Risk Assessment Policy, and several procedures for mapping wildlife activity and patterns at CPH sites. These initiatives support current impact understanding and mitigation. As the Nature programme is further developed in coming years, CPH expects to revisit its policy framework for biodiversity, with key actions to be developed and completed in coming years covering on-site, off-site and value chain impacts. The policy is overseen by the Chief Sustainability Officer and is accessible to all CPH employees.

CPH notes some drivers of its material biodiversity impacts stem from E1 Climate change and E2 Pollution, and references actions outlined in E1-3 and E2-2. It states these actions also contribute to mitigating negative impacts on the extent and condition of ecosystems, with pollution-management measures for air, water and soil playing a dual role by simultaneously addressing pollution and ecosystem degradation. Reference is also made to the E4 Strategy section describing efforts to mitigate impacts on species. CPH states local knowledge and nature-based solutions have not been included in its biodiversity actions, and it does not use biodiversity offsets in current or future action plans. Strategy actions include a habitat plan to make airside areas unattractive to wildlife, scare tactics and bird control, and in 2024 establishing a first area dedicated to more diverse nature spanning 2,400 m2 with wildflowers to attract pollinators.

CPH states its main goal is to minimise its impact through the mitigating actions mentioned in the Strategy section. Because CPH's impact depends on the behaviours of wildlife and the successful execution of its habitat plan, it has not set targets related to this impact. It notes that measurable outcome-oriented targets in relation to pollution of air, water and soil are found in E2-3, and that these are by-proxy targets related to the IRO management of CPH's potential effects on ecosystems. CPH also states it does not yet track the effectiveness of its policies and actions and does not currently have a defined level of ambition for evaluating progress on E4 IROs.

CPH states that metrics in relation to pollution of air, water and soil are found in E2-4, and that these metrics are used to evaluate the effectiveness of its actions to manage material pollution IROs. As pollution impacts are the key drivers of its potential effects on ecosystems, it refers to the metrics in E2-4 for this material impact. In relation to the material impact on wildlife management, under EU Commission Regulation no. 139/2014 CPH has obligations pursuant to article 10 on wildlife hazard management. It identifies and describes each regulated species and produces an annual report of the amount per species per month and total individuals regulated, submitted to the Danish Civil Aviation and Railway Authority and the Danish Environmental Protection Agency. Ring-marked species are reported to the University of Copenhagen. Given established reporting mechanisms to Danish authorities, CPH has not identified additional metrics for this statement.

CPH has adopted policies to ensure identification, assessment and management of its material resource use-related impacts, risks and opportunities. Its Environmental Policy (described under E1-2) underpins the commitment to lower impact, including reduction of waste, increased recycling and reuse of materials. The policy sets out a commitment to establish quantified and time-bound goals supported by comprehensive plans. CPH states its policies do not currently specifically address transitioning away from the use of virgin resources, nor do they directly address the sustainable sourcing and use of renewable resources. The policy is overseen by the Chief Sustainability Officer and is accessible to all CPH employees. These disclosures relate to the waste management and construction workstreams of the circularity strategy launched in 2023.

CPH identified two key material impacts related to resource use: resource inflows and waste, and structured actions to address each. In 2024 the main focus was mitigating waste impacts. It initiated upgrades to waste collection systems across priority airport areas to enable source separation for passengers, staff and tenants, introducing waste sorting in the central shopping centre and Pier B for three waste types with 186 new bins, fitting 12 new bins in outdoor areas, upgrading 50 bins in internal auto and repair workshops, and in November 2024 expanding sorting in Pier A with smart bins using sensors and IoT technology. Actions were supported by staff training and procurement of advanced recycling equipment. Pilot projects tested a CO2-reduced concrete mixture cutting concrete production carbon footprint by 15%. Actions result in OPEX and CAPEX not considered financially material. Planned 2025 measures include a commercial partnership with industry leaders and waste sorting bins in all passenger-facing and staff areas, projected to increase the recycling rate by 5% by end of 2025.

CPH's target for the material impact of waste management is to reach a recycling rate of 60% by 2030, using the 2023 rate as a baseline. This is an ongoing relative target, part of the waste management programme covering all waste generated across operations throughout the value chain at Copenhagen Airport and Roskilde Airport, and is directly related to the Environmental Policy objective of reducing environmental impact. Progress is monitored through waste audits. For 2024, with more passengers and operations than 2023, the recycling rate was 33%, consistent with 2023 levels. The construction workstream has targets to avoid unnecessary new construction and components, reduce use of virgin materials and enable reuse to build more efficiently and design for longevity, adaptability and disassembly. However, CPH has not yet developed time-bound outcome-oriented targets for the construction and operation of infrastructure impact. There are no direct targets for other layers of the waste hierarchy, though reuse initiatives have been launched.

CPH has exercised the provision to omit metric information for E5-4. It states this is because its material impact related to the subtopic Resource inflows, including resource use, is located exclusively in its upstream value chain for the construction of new buildings. No resource inflow tonnage figures are disclosed.

CPH reports resource outflows focused on waste, stating it continues to manage a substantial volume of waste annually given the complex nature of organising waste as an international airport, with food and goods sourced globally and passengers arriving with diverse waste management practices. In 2024 it enhanced sorting facilities and continued stakeholder collaboration, including awareness campaigns targeting airport staff, to ensure a significant portion of waste generated is effectively recycled. Because CPH does not engage in any production processes and does not produce key products or materials derived from production activities, it states it is not applicable to disclose information related to product durability, reparability or rates of recyclable content.

Total waste generated in 2024 was 4,982,967 kg (2023: 4,734,386 kg). Recovery operations totalled 4,828,301 kg, of which recycling was 1,661,911 kg and other recovery 3,166,390 kg; preparation for reuse was reported as N/A. Waste directed to disposal was 3,283,466 kg, comprising incineration 3,154,450 kg, landfill 13,980 kg and other disposal 115,036 kg. Within disposal, hazardous waste was 65,688 kg and non-hazardous waste 3,217,778 kg. Total non-recycled waste was 3,321,056 kg, representing 67% of waste (unchanged from 2023). Total hazardous waste was 72,331 kg (2023: 81,918 kg) and radioactive waste was 0. CPH categorises waste per the EU Waste Framework Directive (2008/98/EC) using 18 waste groups (fractions). Total waste covers waste entering CPH's containers regardless of source; project waste handled by external contractors is excluded.

CPH reports several policies. The Employee Code of Conduct sets behavioural standards for all workforce members, is approved by Executive Management, and is aligned with the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, ILO conventions on workers' rights, the UN Global Compact and the Universal Declaration of Human Rights. It affirms a zero tolerance approach to discrimination and harassment and prohibits human trafficking, forced labour and child labour. In 2024 CPH introduced a new Diversity and Inclusion Policy, approved by the Board of Directors, applying to all employees and setting five dimensions of diversity, behavioural principles and gender diversity targets; the Chief HR Officer is accountable for implementation. CPH also has a Working Environment Policy covering safety, health and wellbeing, applying to all employees and temporary workers but excluding non-employees. CPH has no formalised training policy but has structures to ensure mandatory training completion.

CPH's primary employee engagement is an annual occupational workplace assessment (APV), two anonymous surveys offered to all workforce members covering physical and psychological working environment and wellbeing. The APV is prepared by the People Health and Safety department together with the Safety Organisation and HAMU; the Director of Health and Safety holds operational responsibility. Employee perspectives feed into workplace decisions through health and safety representatives on the General Occupational Health and Safety Committee (HAMU). CPH considers a participation rate above 75% successful; the 2023 assessment achieved 81%. Additional engagement on diversity and inclusion occurs through a voluntary DEI Sounding Board of employees from diverse backgrounds that meets every two months, plus regular training and workshops. General feedback and resulting changes are shared with employees by email and on the intranet, and a reading and writing programme supports dyslexic employees.

CPH encourages employees to raise concerns first with their immediate manager or the HR department, including complaints about salary conditions or interpersonal issues, and concerns can also be raised with a trade union or health and safety representative. Many concerns are resolved through open dialogue; cases resolved informally are not registered or monitored. Cases requiring action, such as reprimands, warnings, termination or dismissal, are registered with HR, which follows a structured follow-up approach. The Code of Conduct requires managers to ensure an environment free of retaliation. As a final measure, workforce members may anonymously report violations through the whistleblower mechanism described in G1-1. For health and safety, each department has an elected health and safety representative who receives specialised training and can receive anonymous reports and escalate them; severe incidents are reported to Executive Management with root cause analysis, and support is provided via health insurance and a dedicated counsellor. CPH does not yet formally assess workforce trust in these processes.

CPH describes actions across two areas. For diversity and inclusion, actions are governed by the MIT CPH strategic framework covering five diversity dimensions, with responsibilities defined by Diversity and Inclusion Leads and a dedicated annual budget. Actions in 2024 included a mandatory two-year Leadership Development Programme with an inclusive leadership module, 20 diversity and inclusion workshops held with departments that requested them, two LGBTQ+ workshops with LGBT+ Denmark, an e-learning programme on inclusive behaviour, gender diversity targets, bias mitigation in recruitment, and the First Professionals initiative for talent under 35 (59 enrolled in 2024). For health and safety, based on APV findings the PHS department identifies improvement areas while local managers coordinate daily work. Actions included weekly incident monitoring in higher-risk air- and landside roles, a stress prevention strategy, training and networks, and four workshops to prevent electrocution during aircraft docking. No actions in 2024 required significant operational or capital expenditure.

In 2024 CPH introduced new gender diversity targets of a 40/40/20 gender distribution (at least 40% men, 40% women, with a 20% margin for the remaining binary distribution and to include non-binary representation) for all employees by 2030, applying separately to Executive Management and lower management levels. This is an absolute target assessed against the goal rather than a baseline year. In 2024 the proportion of females in the workforce was 36%, a slight increase on 2023. The Board of Directors aims for at least 40% representation of the underrepresented gender by 30 June 2026 (a relative target with no baseline). CPH set no targets for other diversity impacts due to legal data-collection restrictions and no training targets due to data unavailability. For health and safety, CPH set a target of 7.5 occupational injuries per one million working hours (LTIF) and a 4.5% rate of absence due to illness. Stakeholders including the workforce were not directly involved in target setting.

CPH reports employee headcount at year-end. In 2024 total headcount was 2,835 (2,681 in 2023), comprising 1,019 female (956 in 2023) and 1,816 male (1,725 in 2023); Other and Not reported were N/A. CPH defines gender based on social security numbers, so data distinguishes only female and male. The number of FTEs was 2,577 in 2024 (2,452 in 2023), split into 932 permanent FTEs, 12 temporary FTEs and 1,633 non-guaranteed hours FTEs. Temporary employees are defined as apprentices, substitutes and office students, and non-guaranteed hours employees as those on contracts without specified working hours. Employee turnover rate was 11.8% in 2024 (13.6% in 2023), with 325 employees leaving (345 in 2023). All employees are located in Denmark at Copenhagen and Roskilde.

CPH reports that 100% of employees in Denmark were covered by collective bargaining agreements in both 2024 and 2023. This reflects a 1999 labour law judgement directing that all jobs at CPH must be covered by a collective agreement. The coverage calculation includes all employees, full-time and part-time, but excludes the Executive Management. Employee perspectives are also incorporated through health and safety representatives who sit on the General Occupational Health and Safety Committee (HAMU).

CPH reports diversity metrics for gender and age. Women in top management on the Board were 1 (16.7%) in both 2024 and 2023. Women in top management in senior leadership positions were 16 (34.8%) in 2024, up from 12 (30.8%) in 2023; CPH defines top management as employees reporting directly to the CEO or CxOs. Distribution of employees by age group in 2024 was 8.6% under 30 years old (9.8% in 2023), 44.6% aged 30 to 50 (48.2% in 2023) and 46.8% over 50 years old (42.0% in 2023). Age is determined at year-end, and gender is defined based on social security numbers, distinguishing only female and male.

CPH reports that 0% of employees were paid below the applicable wage benchmark in both 2024 and 2023. All members of the workforce, including third-party workers within the workforce, are paid an adequate wage in line with internal requirements and local collective bargaining agreements.

CPH reports that 100% of the workforce was covered by a health and safety management system in 2024 and 2023. There were zero fatalities among own employees and among value chain workers on own sites in both years. The rate of absence due to illness was 5.8% in 2024 (5.1% in 2023). The number of recordable work-related accidents was 54 in 2024, up from 33 in 2023. Occupational injuries per one million working hours (LTIF) were 12.6 in 2024, up from 8.2 in 2023, attributed to longer absence periods from individual accidents. Data is stored in the SafetyNet system, and CPH reports work-related injuries to the Danish Working Environment Authority. CPH exercised the phase-in provision to omit reporting on cases of work-related ill-health (88d) and days lost to work-related injuries, ill-health, accidents and fatalities (88e) for the first year of reporting.

CPH reports a gender pay gap of 9.7% in 2024, with no 2023 comparative shown. The gender pay gap is calculated as the difference between average gross hourly pay of male and female employees divided by the average gross hourly pay of male employees, covering all employees employed on 31 December. CPH also reports a remuneration ratio of the highest paid individual of 20.2 in 2024, with no 2023 comparative. This annual total remuneration ratio is the total remuneration of the highest paid individual divided by the median employee annual total remuneration excluding the highest paid individual, where total remuneration includes fixed salary, base salary, pension, other benefits and bonus. Data is drawn from the HR register and payroll system, with further detail in the Remuneration Report.

CPH reports on incidents and complaints. Incidents of discrimination and harassment numbered 2 in 2024, down from 4 in 2023; these comprise substantiated incidents defined as threats, physical violence, unintended sexual attention and discrimination related to sex, gender, religion, disability and similar, reported through leaders, union or employee representatives or the whistleblower mechanism. Complaints filed through grievance or complaints mechanisms were 0 in both years, as were complaints filed to National Contact Points for OECD multinational enterprises. Severe human rights incidents connected to the workforce were 0 in both years, of which cases of non-respect of UN Guiding Principles and OECD guidelines were 0. Total amount paid in fines, penalties and compensation for damages was 0 in both years. CPH notes that at present its formal processes are not designed to fully capture the ESRS-required metrics pertaining to S1-17.

CPH's overarching commitment is to a safe working environment where risks are proactively identified and addressed. Ultimately, responsibility for contractors' workers' health and safety rests with their employers under Danish law, and value chain workers at CPH sites are covered by their employers' policies. As a construction client, CPH has a legal responsibility to coordinate health and safety when more than one employer is present. As a UN Global Compact member, CPH is committed to internationally recognised human and labour rights. It has implemented a Supplier Code of Conduct aligned with the UN Global Compact and ILO Fundamental Principles, covering environment, health and safety, human rights, and bribery and corruption, and explicitly prohibiting forced and child labour. The Supplier Code applies to all suppliers unless contractually excluded and is available on CPH's website. The CFO is the most senior person responsible for its implementation. During the year there were no recorded cases of non-respect of the UN Guiding Principles, ILO Principles or OECD Guidelines involving value chain workers.

CPH supports a comprehensive approach to worker safety, providing safety instructions to all workers on site and initiatives for workers with diverse characteristics such as hearing impairments. Health and safety coordination is managed by the People Health and Safety (PHS) department, with the Senior Director of the Projects department holding ultimate accountability. For construction workers, CPH conducts safety meetings every 14 days for major projects, including CPH's working environment coordinator and contractor project managers, with an employee health and safety representative from each company attending to provide worker perspectives. CPH's project director ensures these meetings occur. For other value chain workers, the PHS department coordinates monthly meetings with operators in areas such as luggage handling and flight-related activities, including health and safety representatives from most third parties, though third parties in flight activities are occasionally not fully represented. CPH evaluates effectiveness by monitoring safety data reported to the Corporate Leadership Team. Due to Danish legal restrictions on collecting sensitive personal data, CPH has not identified whether certain value chain workers could be more vulnerable.

CPH has not established procedures for addressing and remediating health and safety impacts on value chain workers because responsibility for contractors' workers' health and safety rests with their employers under Danish law. In practice, a value chain worker wishing to raise a concern about their own health and safety must do so through their employer's reporting routes and by informing their own health and safety representatives. In the event of a safety incident at a CPH site, CPH would support the contracted party in performing its own internal investigations and root cause analyses. The PHS department is responsible for following up on and monitoring concerns raised and ensuring effective remediation. Value chain workers may also submit a report via CPH's third-party Whistleblower Platform for incidents relating to health and safety allegations. The Whistleblower Platform is available on CPH's website and described in detail in G1-1 Business conduct.

To facilitate a common approach to health and safety, CPH's PHS department has implemented several actions involving contractors' employees. Actions are identified through contractor engagement and resourced through the department's operating budget; no actions required significant OPEX or CAPEX during the year. All construction workers must complete a mandatory safety induction, refreshed annually, providing training on workplace safety and site-specific risks. CPH has hired additional resources to oversee construction site safety and adopted a more strategic and systematic approach to collaboration with turnkey construction contractors, holding quarterly meetings beyond statutory duties to predict risks and implement preventive measures. CPH facilitates an annual Experience Exchange (ERFA) meeting with contractors on smaller projects, though it does not track its effectiveness given the breadth of stakeholders. During the year CPH held targeted health and safety workshops attended by its own employees and airline handling company employees. CPH did not take specific action to remedy impacts because responsibility lies with employers. No cases of severe human rights issues involving value chain workers were reported.

CPH has set a relative annual target to achieve 12.5 occupational injuries per one million working hours (LTIF) for contractors at CPH. Performance against health and safety targets is monitored by the PHS department and overseen by the Corporate Leadership Team's Performance Board. The target applies to all construction contractors working at CPH sites subject to regulatory working environment coordination. As this is an ongoing target, CPH has not set a baseline year or baseline value. Stakeholders, including value chain workers, were not involved in target setting, and value chain workers are not engaged directly in monitoring performance. However, representatives of the value chain are indirectly involved in identifying lessons for improvement through the quarterly construction health and safety meetings and the annual ERFA meetings. In 2024, CPH achieved an LTIF of 21.0, down from 26.1 in 2023. The number of recordable work-related accidents was 10 in 2024 (8 in 2023), and there were zero fatalities for value chain workers on own sites in both years.

S3 Affected communities is CPH's material topic, focused on impacts related to noise and air pollution affecting residents near the Copenhagen and Roskilde airports, plus historic PFAS-related water pollution. For PFAS, the Danish Environmental Protection Agency has issued guidelines governing PFAS levels; CPH has adopted mitigating measures and ensures compliance with Danish legal requirements and requirements of Tarnby Municipality. The PFAS policy is overseen by the Chief Sustainability Officer and accessible to all CPH employees. For noise, CPH's environmental permit sets regulatory requirements governing airport noise; beyond complying, CPH has not adopted policies to manage noise-related impacts. Air pollution policies are described in E2-1. As a UN Global Compact member, CPH is committed to its Ten Principles including respect for human rights, set out in its Code of Conduct. Beyond this, CPH has not made explicit human rights policy commitments related to affected communities. During the year there were no cases of non-respect of the UN Guiding Principles, ILO Principles or OECD Guidelines involving affected communities.

CPH regularly engages with communities in Roskilde and Copenhagen directly through neighbour meetings on issues related to living close to airports, including noise, disturbances, air quality, actions to address pollution and local sponsorships. These meetings take place periodically, including annual townhall meetings. CPH also attends local homeowner association meetings and engages via social media. Indirect engagement includes annual meetings with city councils and engagement with media and local politicians. CPH has not taken specific action to gain insight into the perspectives of particularly vulnerable communities. The Head of Sustainability and the Head of Public Affairs have joint operational responsibility for all community engagement. In 2025, CPH will launch a local Dialogue Council providing a regular forum for local residents, businesses and stakeholders, establishing a more formalised access point for community feedback. CPH tracks effectiveness by regularly reviewing recorded issues and through a biannual local population survey sent to all affected residents, including questions on noise and pollution (including PFAS).

CPH has established multiple channels for affected communities to raise concerns directly. Individuals can contact CPH directly via email, join discussions in the Facebook group "Dear Neighbour of Copenhagen Airport", or request meetings with CPH. Affected individuals may also register complaints concerning noise or PFAS directly with the Danish environmental authorities; CPH's Environmental Management and Compliance department has ongoing dialogue with the authorities to address complaints. Every year CPH encourages people living around the airport to request a mobile noise monitoring unit placed in their garden, supplementing six permanent noise monitoring stations. All external stakeholders can report actual or suspected violations or unethical conduct via CPH's third-party Whistleblower Platform, described in G1-1. CPH ensures communities are aware of these mechanisms by advertising them on the website and providing contact information in external communications, social media posts, external emails, local advertisements and at engagement meetings. CPH assesses whether neighbours trust CPH to address concerns through dedicated questions in the biannual neighbour satisfaction survey. There are no explicit policies protecting communities against retaliation beyond those relating to whistleblowing, but such behaviour would violate the Code of Conduct.

The Sustainability department identifies actions to address PFAS- and noise-related impacts, in accordance with regulatory requirements and in dialogue with key stakeholders, funded through the department's budget with larger investments requested via the CAPEX funding process. For PFAS, CPH takes voluntary action to control the spread of contamination, including a water treatment plant at Roskilde Airport and a surface water treatment plant at Copenhagen Airport (see E2-2), and has established a PFAS action plan together with Dragor and Tarnby Municipalities to align with affected communities' priorities; the plan informs actions relating to Copenhagen rather than Roskilde Airport. CPH has not established ways to assess the effectiveness of PFAS-related actions. For noise, CPH performs ongoing noise monitoring via a dedicated platform collecting data from six permanent stations under its environmental approval, six additional permanent stations and two voluntary mobile units in residents' gardens; it works closely with Naviair and the airlines to reduce noise exposure. CPH assesses effectiveness by measuring the Total Day Evening Night Level (TDENL), a proxy for LDEN, and monitoring noise limit value violations. No specific action was taken during the year to remediate noise impacts due to the systemic nature of the issue. No severe human rights issues involving affected communities were reported.

CPH has not set targets to manage PFAS-related impacts due to data unavailability, as it cannot firmly conclude whether PFAS levels in the community result solely from CPH's historic activities; the environmental permit provides guidelines for PFAS levels in surface and groundwater but authorities have set no specific target levels. For noise, CPH has set two targets to curb noise-related impacts on neighbours relating to its Day Evening Night Level (LDEN) performance. By 2030, the number of households exposed to noise above the guideline limit value (LDEN: 55 dB) should not exceed 2018 levels, irrespective of air traffic growth; this is an absolute target. By 2050, the number of households exposed above the limit value should be reduced by 50% compared with 2018; this is a relative target. Both use 2018 as the baseline year, when TDENL was 145.3. The Copenhagen targets apply to affected neighbours, while the Roskilde target is to comply with regulatory limits. CPH did not engage directly with communities in setting targets, though stakeholders were indirectly involved through continuous communication with municipal authorities. In 2024, CPH achieved its noise pollution targets, with TDENL of 144.7 (144.2 in 2023) maintaining levels below the 2018 baseline.

CPH has a formalised overarching policy relating to the safety and security of passengers, who are its consumers and end-users. In addition to ensuring safe and secure operation, CPH holds daily meetings with internal and external employees and stakeholders. As a highly regulated operation, CPH must comply with EU and Danish regulation on airport security and has established procedures to fulfil these obligations, taking a holistic approach to addressing risks to staff and passengers. CPH has an in-house Security department, allowing quick response to customer feedback when refining safety and security policies. As a UN Global Compact member, CPH is committed to upholding fundamental human rights within its operations and across its value chain, described in S1 and S2. Beyond this, CPH has not made explicit human rights commitments relating to passengers but does engage with and remedy impacts through its complaints mechanism. The policy is overseen by the Security Services & Crisis Response department, approved by the Vice President SEC, and accessible to all CPH employees. CPH has not received any reports relating to breaches of the UN Guiding Principles, ILO Declaration or OECD Guidelines involving passengers downstream.

CPH closely monitors complaints data received directly from customers, airlines and handling companies to identify actions and adjust practices. Insights from complaints are distributed to the relevant CPH departments, which identify and implement appropriate actions. All gender-related complaints are escalated immediately to senior director level, given the sensitivity of the topic and the potential vulnerability of passengers involved. This engagement occurs directly with passengers on a continuous basis.

Passengers who wish to raise concerns directly with CPH are encouraged to submit a complaint form in person or via CPH's website. Passengers submitting a complaint concerning their experience at the Central Security Checkpoint can inform a member of Security, who will provide a contact card to support the complaint, and a Duty Manager may enter into dialogue with the passenger if wished. Customer Service tracks and monitors all complaints, and senior management from CPH's Security, Customer Service and Passenger Experience departments meet monthly and quarterly to discuss trends and developments. Passengers receive an initial response within 24 hours. Most complaints are resolved through Customer Service and may involve remediation appropriate to the complaint. For a small number of unresolved, sensitive complaints, CPH may invite passengers to a telephone or face-to-face meeting to resolve it interpersonally. The customer complaints procedure includes protection against retaliation. For allegations relating to business conduct, stakeholders can raise concerns via the whistleblowing mechanism, described in G1. CPH ensures procedures are effective by monitoring the number of complaints received and through qualitative feedback from a quarterly customer satisfaction survey, but does not assess whether passengers are aware of and trust these mechanisms.

CPH implements extensive security training and procedures to ensure passengers are safe, in accordance with regulatory obligations and CPH's desired level of service. Actions to improve security procedures and mitigate safety-related impacts on passengers are identified by CPH's Security department based partly on complaints and concerns raised by customers, airlines and handling companies. The department works closely with the Customer Service and Passenger Journey Experience teams to integrate actions and procedural improvements into regular staff training. No actions required significant OPEX or CAPEX during the year. Actions taken during the year include: a mandatory security awareness e-learning course for all ID-badge holders repeated every third year; a disability awareness course every two years to protect disabled passengers; enhanced training for Security employees under EU and Danish regulations; targeted security campaigns under EU legislation; emergency response and crisis management procedures with e-learning on emergency procedures for all ID-card holders; and patrolling security units deterring unlawful activities. CPH ensures effectiveness through a quarterly customer satisfaction survey, reviewing complaints data, tracking security waiting times as required by Danish law, and periodic audits of security processes.

CPH has not set measurable targets relating to passenger safety and security, but it does track the effectiveness of its actions using qualitative and quantitative indicators required by Danish law. CPH has not defined a target level to be achieved and has therefore not set a baseline value.

CPH states that its business conduct rests on an Employee Code of Conduct, approved by the Executive Management, which sets standards on anti-bribery, anti-money laundering, anti-fraud, fair competition, protection of personal data and respect for human rights. A Supplier Code of Conduct extends the same expectations to suppliers, and violations of either code may lead to corrective actions including termination of contracts. All new hires must read and acknowledge the Employee Code of Conduct in the CPH Quality learning management system, and periodic refresher training is mandatory for managerial staff and above, with the most recent session conducted in 2023. CPH does not tolerate corruption and bribery, including facilitation payments. Given very limited direct business outside Denmark, it considers corruption and human rights risks limited and has not identified any internal functions as more at risk than others. A Whistleblower Platform, open to employees, business partners and stakeholders, allows good-faith reporting of misconduct with an anonymous option. Reports are encrypted, hosted by an independent third party, and investigated by the Legal department. Retaliation is prohibited, and whistleblowers receive feedback on the conclusion within three months. Whistleblowing is covered in mandatory Code of Conduct training, though no specific whistleblowing training is offered.

CPH reports that it has not made any direct financial or in-kind contribution to any political party or organisation. It does, however, actively participate in various political councils and forums covering topics such as transportation, mobility, tourism, business development and critical infrastructure. This participation includes representation on boards of business organisations, local municipal business councils, and public or state advisory boards and forums, where CPH contributes its expertise and insights. CPH is not registered in the EU Transparency Register or any similar registers. It defines its memberships in Dansk Erhverv (DE) and Dansk Industri (DI) as an indirect in-kind contribution to trade organisations, with membership fees paid to these organisations in 2024 amounting to DKK 4.7m. CPH does not have a formal policy governing its participation in these councils and forums and has not established board-level responsibility for oversight of these activities, though information on its involvement is publicly accessible on relevant websites. No members of the Board of Directors or the Executive Management held roles in public administration or regulatory bodies in the two years prior to the 2024 reporting period.