Copenhagen Airport

Reference: page 41

CPH's commitment to sustainability is anchored at the highest level of governance. The Executive Management has overall responsibility for preparing and presenting the sustainability statement as part of the consolidated annual report, and is accountable for overseeing sustainability and climate-related impacts, risks and opportunities, including approving targets and implementing policies and actions to mitigate negative impacts.

The Sustainability department, led by the Chief Sustainability Officer (CSO), is the central coordinating body and comprises four teams: Energy Management, Environmental Management & Compliance, Sustainability Development, and Strategic Partnerships & Innovation. The CSO reports to Executive Management. Reporting escalates from the CSO to Executive Management and, "when warranted by the subject matter," to the Audit and Risk Management Committee (ARMC) and the Board of Directors.

The governance structure for the double materiality assessment (DMA) is described under IRO-1 (page 45). Gender distribution and targets for the Board and Executive Management are described on page 92 of the report.

Reference: page 41

Material sustainability matters are reported regularly to Executive Management and subsequently to the ARMC and the Board of Directors, supplemented by quarterly reports on key performance indicators and initiatives. In 2025, Executive Management and the Board focused on strengthening the governance and internal control environment for sustainability reporting, including refining the DMA methodology. "Biodiversity and nature emerged as new priority topics following the publication of our first ESRS-aligned sustainability statement in 2024, and these topics received increased attention from management throughout 2025."

All material IROs disclosed were approved by Executive Management, the ARMC and the Board of Directors; the full list of IROs is provided on page 48. Strategic sustainability updates go to the Corporate Leadership Team (CLT) every four months in a dedicated session.

Reference: page 42

The Executive Management's incentive schemes include environmental objectives (scope 1 and 2 emission reduction targets and waste management-related targets), together with fostering "an equitable and inclusive organisational culture" and a "zero-fatality workplace safety record."

The proportion of total expensed remuneration to Executive Management linked to climate-related performance targets for 2025 was 2.6% for STI and LTI combined. The proportion of total expensed variable remuneration (STI and LTI) linked to performance against all ESG-related targets for 2025 was 8.5%. The Remuneration Committee reviews and approves these incentive schemes annually. Further detail is in the Remuneration Report.

Reference: pages 42, 110-111

A table mapping how CPH applies the core elements of due diligence for people and the environment, and where each is presented in the sustainability statement, appears on pages 110-111. The core elements covered are: (a) embedding due diligence in governance, strategy and business model (ESRS 2 GOV-2, GOV-3, SBM-3, IRO-1); (b) engaging with affected stakeholders (GOV-2, SBM-2, IRO-1, and the topical policy DRs E1-2, E2-1, E4-2, E5-1, S1-1, S2-1, S3-1, S4-1, G1-1); (c) identifying and assessing adverse impacts (IRO-1, SBM-3, and the topical action DRs E1-3, E2-2, E4-3, E5-2, S1-4, S2-4, S3-4, S4-4, E1-1, E4-1, G1-1); and (d) tracking effectiveness (E1-4, E1-5, E1-6, E2-4, E4-4, E4-5, E5-5, S1-5, S1-6, S1-9, S1-14, S1-16, S2-5, S3-4, S4-5, G1-4).

Reference: page 42

CPH has established internal control systems to manage sustainability reporting risk, built around defined targets, policies and controls and subject to continuous improvement through an annual risk assessment informed by the double materiality methodology and the enterprise risk management framework.

Accounting manuals, reviewed annually, now define three levels of responsibility, with the most senior accountable data sponsor sitting on the Corporate Leadership Team (CLT). "To enhance the integrity of reported data, a four-eye principle has been implemented for the review of both accounting manuals and sustainability data, ensuring critical disclosures are subject to dual verification." Oversight runs through the ARMC in line with the ESRS requirements for sustainability information.

Reference: pages 14, 43

CPH's business spans infrastructure and air traffic services at its Greater Copenhagen locations, including rental and concession income from property and parking leasing and cargo/passenger air transportation; the business model is detailed on page 14 of the Management's review. The value chain is illustrated on page 48.

The sustainability strategy is structured around four programmes: Pollution (air pollution, noise, soil and water protection), Circularity (resource and waste targets), Decarbonisation (net zero own operations by 2030, a 90% reduction versus 2019, detailed under E1-1), and Nature (understanding dependencies on nature, both directly and through the value chain).

Reference: pages 43-44

Stakeholder engagement occurs as an integrated part of CPH's role as critical infrastructure. The Board of Directors and Executive Management are regularly informed of stakeholder views through survey findings and dialogue with customers, passengers, employees, affected communities and regulatory bodies, alongside the annual DMA.

The stakeholder table (page 44) sets out engagement channels, purpose and outcome for: passengers/business partners/customers (surveys, strategic meetings), employees (surveys, training), suppliers (Supplier Code of Conduct, contract negotiation), government/regulators (continuous policy dialogue), industry bodies (DI and DE trade organisation boards, public consultations), owners (Annual General Meeting, board meetings) and local communities (public meetings, social media, consultations).

Reference: pages 46-48

"In 2025, several changes in materiality were observed. Climate change (E1) is now double material, with climate change adaptation becoming financially material, noise pollution was added as a new entity-specific material subtopic of Pollution (E2), and local community impacts replaces the previous entity-specific topic of noise pollution in Affected communities (S3). The subtopic direct drivers of biodiversity loss is material, adding a new subtopic to Biodiversity and ecosystems (E4). The subtopic Personal safety of consumers (S4) is now double material, Political engagement and lobbying (G1) was reassessed as immaterial, and Corruption and bribery remains impact material only."

"Based on our assessment of material IROs, we have not identified any current or future financial effects that present a significant risk of material adjustment to CPH's financial position or the carrying amount of assets within the next reporting period." CPH states it "has not estimated the anticipated financial impacts of the listed IROs, but strategic implications are described where relevant," and that no action plan currently requires OPEX/CAPEX in excess of normal operating budgets. The full value chain overview and material IRO list (E1 through G1) is presented on page 48.

Reference: pages 45-46

CPH's 2024 DMA was reviewed and refined in 2025 through an eight-step process: ESRS alignment, methodology review, value chain review, desktop research, calibration, SME sessions, re-scoring, and confirmation/approval by the CSO and CFO. The 2024 assessment was "informed by SASB standards and ESRS 1 AR 16 topics, and validated against EFRAG guidance," using SME interviews and stakeholder proxies; "no scenario analysis was performed for the purpose of the DMA," and physical/transition risks were evaluated using SME expertise and GHG Protocol principles.

Per-topic process notes: for E1, "we have not conducted a scenario-based resilience analysis for the IRO identification process"; for E2/E3/E4/E5, site-specific screening covered Copenhagen and Roskilde Airports and "we have not conducted a biodiversity-related resilience analysis"; "as a result of the DMA process in 2024 and the review in 2025, E3 was not considered material." For G1, the process focused on bribery, corruption and human rights risk areas across own operations and the value chain.

Reference: pages 112-114 (index), 115-121 (EU-legislation datapoints)

The ESRS content index lists material disclosure requirements by topic with page references: ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1); E1 (E1-1 to E1-7); E2 (E2-1 to E2-4, with E2-6 marked N/A as a phased-in requirement); E4 (E4-1 to E4-5); E5 (E5-1, E5-2, E5-3, E5-5); S1 (S1-1 to S1-6, S1-9, S1-14, S1-16, S1-17); S2 (S2-1 to S2-5); S3 (S3-1 to S3-4); S4 (S4-1 to S4-5); and G1 (G1-1, G1-3, G1-4). E3 does not appear, consistent with the DMA finding that water and marine resources are not material. A further table (pages 115-121) lists datapoints deriving from SFDR, the Benchmark Regulation, Pillar 3 and the EU Climate Law, flagging each as material or not material with its own page reference.

Reference: pages 51-53

CPH's transition plan targets net zero emissions from own operations by 2030 (90% reduction in scope 1 and 2 versus 2019) and is built on three levers: "leveraging low-carbon technologies," "resource optimisation," and "stakeholder engagement." The near-term scope 1/2 target is aligned with the Paris Agreement and was set using the SBTi Corporate Net-Zero Standard methodology, though "have not been submitted for validation." The plan is "not yet fully compliant with ESRS requirements for scope 3, pending reassessment" of the scope 3 target: a 2025 scope 3 decarbonisation roadmap concluded that full value-chain net zero by 2050 is "highly uncertain under current technological and regulatory conditions."

CPH has "not yet fully quantified the total OPEX and CAPEX required to execute the entire transition plan," applying instead a dynamic annual allocation process, and states that "alignment with the EU Taxonomy criteria remains difficult." Potentially locked-in GHG emissions (vehicle fleet, heating, refrigerants, de-icing substances) are assessed as short/medium-term and as not materially affecting the 2030 net zero balance. Since 2019, scope 1 and 2 (market-based) emissions have fallen 89.9%, driven by a renewable electricity PPA, HVO100 biodiesel and reduced district-heating intensity. The plan was approved by Executive Management and the Board of Directors; CPH is not excluded from Paris-aligned benchmarks.

Reference: pages 45-46 (ESRS 2 IRO-1)

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 45-46). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

CPH's 2024 DMA "evaluated GHG emissions and their effects on climate change, with a particular focus on direct emissions from our own operations and our value chain," and considered "climate-related physical risks... by assessing CPH's risk exposure on operations and assets, both upstream and downstream," alongside "climate-related transition risks and opportunities." This was revisited in 2025 "to reflect updated data and stakeholder input."

CPH states plainly: "We have not conducted a scenario-based resilience analysis for the IRO identification process." Physical and transition risks were instead assessed "using SME expertise and GHG Protocol principles" rather than a named climate scenario (e.g. no SSP or IEA NZE scenario is cited). The methodology element of paragraph 16 is therefore present; the scenario-analysis element of paragraph 17 is not applicable, since no scenario analysis was performed.

Reference: pages 46, 52, 54 (ESRS 2 IRO-1, E1-1, E1-3)

Back-filled from ESRS 2 IRO-1 and E1-1/E1-3, where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

CPH states it has "not conducted a scenario-based resilience analysis" as part of its IRO identification process. It does, however, disclose capacity-to-adapt information. On locked-in emissions (E1-1, page 52): the lock-in effects from the vehicle fleet, heating systems, refrigerants and de-icing substances "are assessed to be mainly short and medium term and collectively represent a minor share of our scope 1 and 2 emissions," which "do not materially affect our ability to achieve and maintain a net zero balance in scope 1 and 2."

On financial flexibility: "our approach to allocating OPEX and CAPEX to our transition plan is dynamic and responsive... By avoiding long-term fixed financial commitments, we remain agile in our investment approach." On physical adaptation (E1-3, page 54), CPH participated in a Ministry of Transport working group on storm-surge protection, which "concludes that CPH, as well as other major infrastructure owners, faces risks from future extreme storm surges," and CPH was separately developing an "adaptation plan for increased precipitation and cloudbursts" during 2025.

Reference: page 53

CPH's Environmental Policy "ensures that we operate our airports in an environmentally responsible manner, starting with full compliance with all relevant environmental, climate and energy regulations," and covers "resource management, climate change mitigation and adaptation, biodiversity and pollution," across own operations and the upstream/downstream value chain. The Energy Policy separately governs electricity, district heating and natural gas management, committing to "continuous optimisation of energy consumption, and a gradual increase in the share of renewable energy," aligned with CPH's ISO 50001 certification.

Both policies are overseen by the Chief Sustainability Officer and are accessible to all employees and lessees of CPH real estate. New sustainability-related policies are "in the process of" being developed for implementation in 2026.

Reference: pages 53-54

Actions are grouped under three levers. Leveraging low-carbon technologies: CPH is reassessing the timing of its natural gas phase-out after a reduction in district-heating GHG intensity made it possible to hold net zero in scope 1/2 "without a complete natural gas phase-out"; no gas boilers were replaced in 2025. HVO100 biodiesel was introduced in Q2 2025 for all compatible diesel vehicles/equipment. Since January 2025, a PPA with Vattenfall has matched CPH's and tenants' electricity consumption with offshore wind generation (101 GWh procured in 2025).

Resource optimisation: material hotspots with high embodied emissions (steel, concrete, asphalt, glass, brick) were identified, and lifecycle assessments and sustainability screenings are now integrated into project planning, though "no comprehensive actions or resource allocations have yet been implemented" for circular construction. Stakeholder engagement: EV charging points reached 561 (up 99 since 2024), and CPH continued work with airlines and the air traffic provider on fuel-efficient protocols, though "we cannot report on specific outcomes in 2025" for that dialogue-based work. On adaptation, CPH co-financed four reports on storm-surge protection with the Ministry of Transport and was developing a cloudburst/precipitation adaptation plan.

Reference: page 55

CPH targets net zero GHG emissions from own operations by 2030 via a 90% reduction in scope 1 and 2 (market-based) emissions against the 2019 baseline (27,179 tCO2eq), compensating residual emissions with verified carbon removal credits. The roadmap shows emissions falling from 24,984 tCO2eq (2024) toward a 2030 target of 2,718 tCO2eq, via natural gas phase-down, renewable electricity (PPA), district heating decarbonisation, and energy efficiency, assuming a 24% increase in 2030 electricity consumption from building expansion and electrification.

The target "has been established using the cross-sectoral, absolute contraction target-setting methodology described in SBTi's Corporate Net-Zero Standard," but "has not been validated by SBTi and was set without external stakeholder involvement." CPH is "currently revisiting our long-term scope 3 emission reduction target" based on the 2025 decarbonisation roadmap. Progress is tracked by the Sustainability team with regular reporting to the CSO, CLT and Board.

Reference: page 56

Table 1 (Energy consumption and mix) discloses 2025 and 2024 fuel consumption by source (coal, fuel oil, diesel/gasoline, natural gas, biomass/biofuels), purchased electricity, heat, steam and cooling, and total energy consumption from fossil versus renewable sources, split between own operations and, where applicable, non-renewable fuel consumption in high climate impact sectors. Accounting policy: "total energy consumption related to own operations is calculated by aggregating and converting all forms of energy consumption to MWh using standard conversion factors," sourced from supplier invoices and meter readings; for a limited number of building units consumption is "estimated using an area-based allocation key rather than unit-specific metering," introducing minor uncertainty.

Reference: pages 57-59

Table 3 discloses gross scope 1, 2 (location- and market-based) and scope 3 emissions (categories 1-2, 3, 4, 5, 6, 7, 9, 11, 13) for 2019, 2024 and 2025, plus total GHG emissions and % change. Scope 1 and 2 (market-based) emissions fell 89% in 2025, "driven by renewable electricity procurement, the mid-year roll-out of HVO100 biodiesel, and a substantial reduction in the GHG intensity of district heating," reaching 89.9% below 2019. Scope 3 emissions rose 3%, "driven by passenger growth and increased investments in physical infrastructure." Total market-based emissions fell 2%; the carbon footprint split is aircraft LTO (scope 3) 61%, own operations (scope 1-2) 8%, supply chain (scope 3) 28%, ground transportation beyond own operations 2%, other scope 3 sources 1%.

Table 4 shows GHG intensity per net revenue: market-based intensity fell 10% to 83.5 tCO2eq/'000 DKK, "reflecting both the aforementioned fall in absolute emissions and a 3% reduction in the per-passenger GHG intensity of our aircraft operations," attributed primarily to fleet renewal and the 2% SAF blending mandate under ReFuelEU Aviation.

Reference: page 59

CPH invests in third-party-verified carbon removal credits to compensate scope 1, scope 2 (market-based) and business-travel (scope 3 category 6) emissions, aligned with the Airport Carbon Accreditation programme. For 2025 emissions (scope 1: 2,406 tCO2e; scope 2: 335 tCO2e; business travel: 169 tCO2e), CPH retired 2,911 carbon removal credits: "87% of the retired credits are verified by Plan Vivo and 13% are verified by Puro.earth," all from biogenic sinks (87% reforestation, 13% industrial biochar). "None of the credits are issued from projects in the EU, and the credits do not qualify as corresponding adjustments under Article 6 of the Paris Agreement." CPH plans to retire approximately 8,400 tCO2e of credits for 2026-2030.

Reference: page 64

CPH's pollution management "is governed by comprehensive external regulations, including those from local municipalities and the Danish Environmental Protection Agency, which steer our mitigating measures." The Environmental Policy "does not therefore specifically address the area of pollution; rather, our efforts are guided by regulation, operational controls and procedures," reducing the need for a standalone pollution policy while CPH focuses resources on material impacts.

Reference: pages 64-66

Actions are organised by pollution type. Air: a local air-quality programme with airlines and handlers, a planned ultrafine-particle sensor network, HVO100 biodiesel for CPH's own vehicles, an expanding EV charging network, a partnership with Schiphol Airport, the concluded five-year EU Horizon ALIGHT project, and 40 AI-enabled thermal cameras (39 deployed) to monitor auxiliary power unit (APU) use at the busiest aircraft stands, covering "up to 70% of total aircraft traffic." Water and soil: a new surface-water treatment facility at the fire training area, a planned water retention tank, and continued treatment and monitoring of historic PFAS contamination at Kastrup and Roskilde, with a dedicated PFAS treatment plant and collective mitigation strategy under development for 2026; monitoring data from the treatment plants was made publicly available in 2025. Noise: ongoing monitoring via two fixed and two voluntary mobile monitoring stations, with data published on cph.dk.

Reference: page 66

Since 2019, CPH has held two noise targets tied to the Day-Evening-Night Level (LDEN, 55 dB threshold, 2018 baseline): by 2030, the absolute number of affected households in Kastrup should not exceed 2018 levels "irrespective of growth in air traffic"; by 2050, the relative number of exposed households should fall 50% versus 2018. Roskilde's target is simple regulatory compliance. LDEN is recalculated every three years; the Total Day-Evening-Night Level (TDENL, 2018 baseline of 145.3 dB) is monitored annually as a proxy between LDEN assessments.

On PFAS, CPH "has formalised an ambition towards 2030 and beyond: to limit the dispersal of PFAS through continuous containment and mapping," but "has not set quantitative targets for mitigation of PFAS due to imprecise data for mass measurements." "Internal targets are not formalised for other areas of pollution"; CPH instead relies on regulatory compliance for air, water and soil pollutants, "including substances of concern and very high concern."

Reference: pages 66-70

Air: emissions are measured in the landing-and-take-off cycle using the US AEDT model and reported "in indexed form and not the actual quantities"; the share of new, lower-emission aircraft types operating at CPH rose from 5% (2019) to 39% (2025). Water: monthly sampling of surface water discharged to Øresund and wastewater discharged to Dragør/Tårnby tests for heavy metals and PFAS. Soil: 267 soil samples were taken across 28 construction works in 2025 (up from 277 samples/25 works in 2024), reported to Tårnby Municipality; contaminated soil is treated on-site or sent to external facilities. Noise: Table 6 shows TDENL of 144.4 dB in 2025 versus 144.7 dB in 2024 (index 81.28 versus 87.90, adjusted from 99.4 for a calculation error); 2025 data confirm "we have again operated within the permitted limit values" for air quality, and the two LDEN-based noise targets were met, with the latest (2024) three-yearly assessment showing "a 34% reduction in the number of households" exposed.

Reference: page 72

"The continued development of the Nature Programme was a focus throughout 2025 to ensure we account for our impacts on nature both on site and throughout our value chain." 2025 work focused on "scoping our own areas and the possibilities within them," given that CPH acknowledges "we take up a large amount of physical space and the way we utilise that space is not compatible with diverse nature." CPH will "initiate an assessment of the impact of our activities beyond our own areas" to deepen understanding of nature-related impacts and risks.

Reference: page 72

Biodiversity is addressed as a whole within CPH's Environmental Policy (see E1-2) and supported by pollution-mitigating actions (see E2-2). Wildlife dispersal activities are managed by CPH's Wildlife Control team, and the Wildlife Hazard Management Programme is run by the Safety Services Office, both guided by a Wildlife Risk Assessment Matrix. "The Nature Programme is still under development, and we expect to revisit our policy framework for biodiversity in parallel." The policy is overseen by the Chief Sustainability Officer and accessible to all employees.

Reference: pages 72-73

Actions draw on E1 and E2: "some of the drivers of our material impacts related to biodiversity stem from impacts related to E1 Climate change and E2 Pollution," so pollution-mitigating initiatives under E1-3/E2-2 play a dual role in reducing ecosystem degradation. Species-level mitigation runs through the Wildlife Hazard Management Programme, which aims to make airside areas "as homogeneous as possible" to reduce visiting bird species, using scare tactics and, where risk assessment shows a direct threat to aircraft, lethal shots as a last resort. "Local knowledge and nature-based solutions have not been included in our biodiversity actions, nor do we use biodiversity offsets as part of our current action plans."

Reference: page 73

"CPH has not set targets related to this impact" for wildlife-driven biodiversity effects, since outcomes "are dependent on wildlife behaviour and the successful execution of our Wildlife Hazard Management Programme." For the pollution-driven biodiversity impacts, CPH refers to its E2-3 air, water, soil and noise targets (page 66). "We do not yet track the effectiveness of our policies and actions, nor do we have defined targets relating to nature-related impacts," and CPH currently has no defined ambition levels for evaluating progress on E4 IROs.

Reference: page 73

CPH cross-references its pollution metrics (E2-4, pages 66-69) as the basis for evaluating ecosystem effects, "as pollution impacts are the key drivers of our potential impacts on ecosystems." For wildlife management, CPH operates under EU Commission Regulation No. 139/2014 Article 10: it identifies and describes each regulated species and produces an annual report on the number of species and individuals regulated per month, submitted to the Danish Civil Aviation and Railway Authority and the Danish Environmental Protection Agency (and to the University of Copenhagen where a species is of research interest). "Given the established mechanisms for reporting to relevant Danish authorities, CPH has not identified additional metrics for the purposes of this sustainability statement."

Reference: page 75

CPH's Environmental Policy "is the foundation of our commitment to minimising environmental impact, including reducing waste and increasing the recycling and reuse of materials," and "outlines a clear commitment to setting quantified, time-bound targets supported by robust implementation plans." However, "the policy does not explicitly encompass the transition away from the use of virgin resources, nor does it directly address the sustainable sourcing and utilisation of renewable resources." The policy is overseen by the Chief Sustainability Officer and accessible to all employees.

Reference: pages 75-76

CPH structures resource actions around two material impacts: resource inflows and waste generation. Waste: a 2025 roll-out added 171 smart bins and 54 sorting stations for tenants, backed by a new partnership with an external waste handler that also took over waste-volume and treatment-method data collection, "resulting in improved data quality and more comprehensive waste reporting," expected to be fully implemented by early 2026. Resource inflows: a circular-construction framework is being defined, but "no comprehensive actions or resource allocations have yet been implemented"; pilot projects reused ceiling panels and façade elements in Terminal 3 and recycled crushed concrete from old runways at Roskilde Airport, and work continued on testing low-carbon concrete.

Reference: page 76

CPH has a "voluntary 2030 recycling target of 60%" of total operational waste diverted from residual waste (excluding construction/demolition and in-flight waste); energy recovery from residual waste is tracked separately and does not count toward the rate. The 2025 recycling rate reached 32.9%, "which should be seen in the context of overall passenger growth." A 2025 target to raise the recycling rate by 5% was not achieved: "projects required more time for implementation and additional processes are needed to ensure correct material handling by all stakeholders," though "early results from the end of the year show an upwards trajectory." "No specific targets have been established for the other levels of the waste hierarchy," and time-bound, outcome-oriented targets for the construction circularity workstream "have not yet been established."

Reference: pages 76-77

"Due to the complex nature of our organisation, managing the substantial volume of waste represents a significant challenge, including the adaptation of waste solutions to the various waste fractions and operational areas across the airport." Recycled fractions include electronic waste, glass, plastics, biowaste, paper, cardboard, metal, street sweepings and beverage packaging; a significant share of remaining waste is residual mixed material sent for energy recovery, with a smaller share going to specific solutions including hazardous-waste handling. CPH states that because it "does not carry out any production activities and does not manufacture products or materials, the disclosure requirements related to product durability, reparability and proportion of recyclable content are not applicable to our operations."

Reference: page 77 (Table 1); accounting policies, page 77

Table 1 (Resource outflows - waste) reports, for 2025 versus 2024: total waste generated 5,078,885 kg (2024: 4,982,967 kg, restated); diverted from disposal 5,042,825 kg, split hazardous 48,602 kg and non-hazardous 4,994,223 kg; waste directed to disposal 36,060 kg (2024: 154,666 kg, restated), split incineration 3,710 kg and landfill/other disposal 32,350 kg; 1% of total waste was non-recycled (2024: 3%, restated). Zero radioactive waste in both years. CPH categorises waste into 18 "fractions" per the EU Waste Framework Directive (2008/98/EC), reported from invoices or collector data; construction and demolition waste handled directly by external contractors is excluded, so "the total amount of waste generated can be tracked, but the distribution of waste collected from different areas within the airport is not documented." 2024 figures were restated "due to incorrect population of table," including reclassifying sand-drain waste streams as hazardous following the prior year's PFAS facility shutdown.

Reference: page 87

Three workforce policies apply to all employees via the learning management system: the Employee Code of Conduct (approved by the Corporate Leadership Team, aligned with the UN Guiding Principles, OECD Guidelines, ILO conventions, UN Global Compact and the Universal Declaration of Human Rights; prohibits "any form of human trafficking, forced labour or child labour"); the Working Environment Policy (covers all employees and temporary workers but "excludes non-employees within CPH's workforce," overseen by the People Health and Safety (PHS) department); and the Diversity and Inclusion Policy (approved by the Board of Directors, implementation led by the Chief People Officer, covering gender balance, age and educational background).

Reference: pages 87-88

Employee perspectives feed into decisions through health and safety representatives on the General Occupational Health and Safety Committee (HAMU), and through the annual occupational workplace assessment (APV) - historically two surveys, one on physical working environment and one on psychological safety and inclusivity. APV results are published on the intranet, and "managers are instructed to discuss the APV findings with their teams, ensuring employee feedback drives meaningful improvements." The APV includes "a dedicated question on whether employees feel comfortable talking to their manager." The Director of Health and Safety holds operational responsibility for the APV.

Reference: page 88

Employees are encouraged to raise concerns first with their manager or the People department, or with their trade union or elected health and safety representative; severe incidents trigger root-cause analysis and reporting to Executive Management. "As a final measure, members of our workforce may anonymously report violations of the Code of Conduct or other behavioural issues through our whistleblower mechanism," described further under G1-1. The PHS department reports regularly to Executive Management and the ARMC, including voluntary additional safety data from construction sites.

Reference: pages 88-90

2025 progress was shaped by "a year marked by transition within the People organisation"; some previously planned actions "were not carried out and will not be taken forward" as the department reset its strategic direction, so disclosed progress is more limited than in 2024. Ongoing actions include annual health and safety conference training for HAMU representatives, weekly incident monitoring by managers in higher-risk roles, and mandatory training (including security and disability-awareness training repeated every other year). New actions in 2025 included a new governance model to accelerate gender-balanced leadership, a near-miss reporting app, four mobile ultrafine-particle instruments for the PHS department, an updated senior-employee scheme (60+), and preparation of a 2026 employee engagement survey and new leadership assessments tied to the 2025 Leadership Commitments. Effectiveness is tracked via diversity targets, gender-split monitoring, key safety metrics (15% weighting in the employee bonus programme) and APV participation rates.

Reference: pages 90-91

Two safety-related targets are set for 2025: rate of absence due to illness of 6.2% for operational roles and 3.5% for corporate roles (versus an overall 4.5% target in 2024), benchmarked against industry averages - actual 2025 performance was 5.4%; and a relative work-related accident target of no more than 10 occupational injuries with over 1 day's absence per million working hours (LTIF) - CPH recorded 10.3 in 2025, "which brings us very close to our target." Both targets are "ongoing," with no baseline year or value set. Performance is monitored monthly by the PHS department and the Corporate Leadership Team, with HAMU engaged on monitoring and the Working Environment Committee (AMO) briefed semi-annually; "stakeholders, including members of CPH's workforce, were not directly involved in target setting."

Reference: page 93

2025 headcount: 1,090 women and 1,964 men (total 3,054), versus 1,019 women and 1,816 men (total 2,835) in 2024. All employees are located in Denmark (Copenhagen and Roskilde). CPH "defines gender based on social security numbers, hence the data exclusively distinguishes between female and male"; "Other" and "Not disclosed" categories are not reported "due to GDPR restrictions on data collection." Employee turnover rate for 2025 was 10.9% (2024: 11.8%, restated for a completeness error).

Reference: page 93

Board gender diversity: 3 of 7 non-employee Board members (43%) are women, achieved in 2025 when the new Board was established, meeting CPH's 40% underrepresented-gender goal set for 30 June 2026 ahead of schedule. Women in senior leadership positions: 10 of 32 (31.3%) in 2025, versus 16 of 46 (34.8%) in 2024. CPH's broader workforce target is 40/60 gender distribution by 2030 in both the overall employee base and management; in 2025 "women represented 36% of our total workforce, in line with the gender distribution reported in 2024." "CPH has not set targets relating to other diversity-related metrics."

Reference: page 91

2025 versus 2024: zero fatalities (own employees and value-chain workers on own sites, both years); 100% of the workforce covered by a health and safety management system (both years); rate of absence due to illness 5.4% overall (2024: 5.8%), split 6.7% operational / 2.1% corporate (2024: 6.6%/2.2%, restated); 158 recordable work-related accidents (2024: 133, restated), of which 111 involved less than 1 day's absence and 47 involved more; occupational injuries per million working hours (LTIF) 34.5 overall, 10.3 for accidents with more than 1 day's absence (2024: 32.4 and 12.6, restated). "CPH has 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)."

Reference: page 93

Gender pay gap (average gross hourly pay, male versus female): 17.7% in 2025, versus 17.4% in 2024 (restated from 20.2% for a completeness error). Annual total remuneration ratio (highest-paid individual versus median employee, excluding the highest-paid individual): calculated on fixed salary, pension, other benefits and bonus; restatements to 2024 comparatives were made "to correct for completeness error" (cross-referenced on page 84 of the report).

Reference: page 91

2025 versus 2024: 2 incidents of discrimination and harassment (both years); 1 complaint filed through grievance/complaints mechanisms (2024: 0); 0 complaints to National Contact Points for OECD multinational enterprises (both years); 0 severe human rights incidents connected to the workforce, 0 cases of non-respect of UNGPs/OECD guidelines, and 0 DKK paid in fines, penalties or compensation (all zero in both years). CPH notes that "at present, the Group's formal processes are not designed to fully capture ESRS-required metrics pertaining to S1-17," and discrimination/harassment is defined to include "threats, physical violence and unintended sexual attention as well as discrimination related to sex, gender, religion, disability, etc."

Reference: pages 96-97

Responsibility for value chain workers' health and safety "rests with their employers, in accordance with Danish law," though CPH "has a legal responsibility to coordinate health and safety at construction sites when more than one employer is present." CPH's Supplier Code of Conduct, aligned with the UN Global Compact and ILO Fundamental Principles, covers environment, health and safety, human rights, and bribery and corruption, and "explicitly prohibits any form of forced labour" and child labour; it is provided to every supplier on a standard contract. 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 on Business and Human Rights, the ILO Fundamental Principles and Rights at Work or the OECD Guidelines for Multinational Enterprises involving value chain workers."

Reference: page 97

The PHS department coordinates monthly meetings with value chain operators in areas such as baggage handling and flight-related activities, including employee health and safety representatives from the majority of third parties, "to ensure alignment on safety procedures." The Senior Director of CPH's Projects department holds ultimate accountability for this engagement.

Reference: page 97

Value chain workers raise health and safety concerns through their own employer's reporting routes and health and safety representatives; CPH supports contracted parties' own investigations following a safety incident. For construction workers specifically, CPH holds safety meetings every 14 days on major projects, including representatives from all involved companies and an employee health and safety representative per company. Workers may also use CPH's third-party whistleblower platform for health and safety allegations. The PHS department follows up on and monitors concerns raised.

Reference: page 97

Actions are identified through the monthly contractor engagement described under S2-2 and resourced from the PHS department's operating budget, integrated into ongoing operational cycles rather than multi-year plans; "no actions required significant OPEX/CAPEX expenditure during the year." Construction workers must complete a mandatory safety induction before entering sites, and CPH holds quarterly meetings with turnkey contractors beyond statutory requirements "to proactively predict risks and implement preventive measures." "CPH did not take specific action during the year to remedy impacts on value chain workers because responsibility for their working conditions lies with their employers," and "no cases of severe human rights issues and incidents were reported involving workers in CPH's upstream and downstream value chain."

Reference: page 98

CPH's 2025 LTIF target for contractors (more than 1 day's absence) was adjusted to "no more than 17 occupational injuries per one million working hours"; actual 2025 performance was 13.9, "well within our target" (2024: 20.8, restated). Total recordable work-related accidents among contractors: 17 in 2025 (2024: 29, restated), split 10 with less than 1 day's absence and 7 with more. "Stakeholders, including value chain workers, were not involved in target setting," though value chain representatives are indirectly engaged through quarterly construction health and safety meetings and annual ERFA meetings.

Reference: page 100

PFAS-related measures follow Danish Environmental Protection Agency guidelines and Tårnby Municipality requirements, detailed under E2 Pollution (pages 62-70); the policy is overseen by the Chief Sustainability Officer. For general airport-operation impacts, CPH "has not adopted additional policies beyond" its environmental permits and regulatory compliance framework (see E2-1). On the social dimension of community impact, CPH states: "we do not currently have a dedicated policy addressing the social dimension of these impacts; this aspect is managed through an ongoing and adaptive process" drawing on the Employee Code of Conduct and UN Global Compact commitments (see S1-1).

Reference: pages 101-102

The Local Dialogue Forum, meeting three times a year, brings together local ambassadors, spokespersons and representatives, with minutes and written answers published on CPH's website. CPH also engages via social media, school tours and homeowner association meetings. The Chief Sustainability Officer and the Public Affairs department hold joint operational responsibility. Effectiveness is tracked through a local population survey, "which we aim to conduct annually; the next survey will be conducted in 2026." CPH states it has "not identified materially distinct impact profiles across specific vulnerable groups that would require differentiated engagement processes," so its engagement model "applies uniformly to all community members."

Reference: page 102

Communities can raise concerns via a designated neighbour email, the "Dear Neighbour of Copenhagen Airport" Facebook group, requested meetings, or directly with Danish environmental authorities (handled via the Environmental Management and Compliance department). "During the year, there were no reported cases of human rights violations involving affected communities." Channels are advertised on CPH's website, in external communications and at Forum meetings; trust in these channels is assessed through the population survey referenced under S3-2.

Reference: page 102

Pollution-related action plans are described under E2-2; the Sustainability department coordinates community-facing actions, financed through its operating budget for smaller initiatives and the CAPEX process for larger measures, informed by the Local Dialogue Forum, neighbour meetings and direct municipal engagement. "At present, CPH has not established community-specific targets beyond those set for pollution management, as described in E2 Pollution on page 66, and we are continuing to review whether additional indicators are appropriate as our understanding of community impacts evolves." For more people-centred impacts, CPH "relies on continuous dialogue" rather than a quantified target.

Reference: page 103

CPH has "a formalised overarching policy relating to the safety and security of passengers," overseen by the Security Services & Crisis Response department and approved by the Vice President, SEC, accessible to all employees. CPH complies with EU and Danish airport security regulation and, as a UN Global Compact member, embeds human rights into its security framework. "CPH has not received any reports relating to breaches" of the UN Guiding Principles, ILO Declaration or OECD Guidelines "involving passengers downstream in CPH's value chain."

Reference: page 103

CPH "closely monitors complaints data received directly from customers, airlines and handling companies to identify actions and adjust practices." Insights are distributed to relevant departments, and "all gender-related complaints are escalated immediately to director level, given the sensitivity of the topic and the potential vulnerability of passengers involved."

Reference: page 104

Passengers submit complaints in person or via CPH's website; those with complaints about the Central Security Checkpoint can speak to Security staff, who provide a contact card, and a Duty Manager may follow up directly. Passengers "receive an initial response to complaints within 24 hours." Customer Service tracks all complaints, with senior management from Security, Customer Service and Passenger Journey Experience meeting monthly and quarterly on trends. Business-conduct-specific concerns can also be raised through the whistleblower mechanism described under G1. "CPH does not assess whether passengers are aware of and trust these mechanisms for raising complaints."

Reference: page 104

CPH states its safety and security actions "are therefore shaped by sector-specific requirements rather than the ESRS approach to consumer and end-user impacts," but discloses them for transparency. Actions in 2025 included a repeated (every three years) security awareness e-learning course for all ID-badge holders, a two-yearly disability-awareness course for all staff, enhanced regulatory training for Security employees, targeted security campaigns, Corporate Crisis Management and Emergency Response planning, and visible security patrolling. Effectiveness is tracked through a quarterly customer satisfaction survey, monitoring of security waiting times against Danish legislation, and periodic audits of security processes. "No actions required significant OPEX/CAPEX expenditure during the year."

Reference: page 105

CPH states its metrics and targets here "are therefore defined by" regulatory and sector-specific aviation security standards "rather than by the ESRS framework," and that "existing targets are not designed to measure impacts on consumers and end-users as set out in the standard," though they are disclosed for transparency. Current quality-management measures include passenger screening within EU time limits, certified security personnel, EU-approved cargo security protocols, and background checks with "zero non-compliance cases reported." For 2026, CPH targets deployment of C3-standard CT scanners across all checkpoints by May 2026 and compliance with enhanced EU training requirements by January 2026.

Reference: page 107

CPH's whistleblower mechanism is "accessible to our employees, business partners and other stakeholders," hosted by an independent third party with encrypted, optionally anonymous reporting, and investigated independently by the Legal department; CPH states it does "not tolerate retaliation of any kind against whistleblowers, including discrimination, dismissal, disciplinary action and harassment," and whistleblowers "receive feedback on their report's conclusion within three months." The Employee Code of Conduct, approved by Executive Management, sets standards on anti-bribery, anti-money laundering, anti-fraud, fair competition, data protection and human rights, and is introduced to all employees during onboarding, who must read and acknowledge it.

Reference: page 108

CPH states it has "very limited direct business outside Denmark" and considers corruption and human rights risk "limited," with "no internal functions... identified as more at risk than others, therefore all functions are considered inherently at risk." CPH maintains "a strict zero-tolerance policy on corruption and bribery, including facilitation payments," prohibits accepting gifts, travel or hospitality beyond minimal value without prior approval, and requires managerial approval for company expenses. Suspected violations are investigated by Corporate Affairs & Legal independently of the management chain involved. "97% of current employees have completed the training" on the Employee Code of Conduct.

Reference: pages 107-108

Back-filled from the business conduct chapter, where business conduct targets are addressed through training coverage and incident monitoring rather than as a standalone numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS; under the 2023 ESRS, business conduct targets fell under MDR-T.

CPH discloses no quantified, outcome-oriented target for corruption and bribery prevention. Instead, it tracks effectiveness through training completion - "97% of current employees have completed the training" on the Employee Code of Conduct in the learning management system "CPH Quality" - and through ongoing monitoring of corruption and bribery incidents (see G1-4: zero convictions and zero fines in 2025). CPH maintains a "strict zero-tolerance policy," reviewed and enforced through its whistleblower mechanism and Corporate Affairs & Legal investigations, as the substitute for a formal numeric target.

Reference: page 108

"CPH was not convicted for violation of anti-corruption or anti-bribery laws during 2025, and therefore no fines were paid. Furthermore, no legal proceedings relating to these topics were brought against CPH, and no actual impacts or incidents were identified." Both the number of convictions and the fines paid (DKK) are reported as zero for 2025.