Danica Pension

The role of the administrative, management and supervisory bodies

Danica's Board of Directors and Executive Board consider questions on sustainability. Board members complete the statutory board leadership course, and the Rules of Procedure for the Board of Directors stipulate that, based on the Danish FSA's requirements as to the knowledge and experience of board members in life insurance companies, the Board of Directors must once a year discuss and assess whether the relevant skills and expertise are represented on the Board. ESG is included as a parameter in this assessment. In addition, Danica is strengthening its sustainability expertise across the organisation to better integrate sustainability throughout the business.

Danica's top management consists of the Executive Board and the Board of Directors. At 31 December 2024, the Board of Directors had nine members: five elected at the annual general meeting, three elected by the employees and one external member appointed by the Danish Minister for Finance. The board members elected at the annual general meeting are up for election every year, and board members elected by the employees are elected for a period of four years, as prescribed by the applicable legislation. One of the five board members elected at the annual general meeting (20%) is independent, i.e. is not employed by the Danske Bank Group, and 20% of the members of the Board of Directors, i.e. one out of the total of five members elected at the annual general meeting, is a woman.

Danica has established a CSRD working group, which is responsible for Danica's CSRD project and the preparation of the double materiality assessment, which are approved by the CSRD steering committee, headed by the CFO. The CSRD project manager reports to the steering committee on the progress of the CSRD project. On this basis, new initiatives are considered to ensure the project's progress, and it is also discussed whether the necessary skills and expertise are represented in the organisation. Danica's Board of Directors is also involved when needed through presentations to the Audit Committee and the Board of Directors, both on the CSRD project and Danica's overall sustainability efforts.

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

Danica has prepared a Process for revision of and reporting on the sustainability strategy and a Process for reporting on carbon sector targets towards 2025 and temperature targets towards 2030 in Danica.

The process description for revision of and reporting on the sustainability strategy comprises an internal and an external track. The internal track covers reporting via a quarterly KPI dashboard, which is distributed to internal stakeholders in Danica. The external reporting includes reporting on the sustainability strategy, which is incorporated in Danica's annual report (CSRD) and interim report. It also includes an annual status report on selected areas of Danica's sustainability strategy in Danske Bank's annual report (CSRD). Both are distributed to external financial stakeholders, but a number of internal stakeholders are also involved.

The sustainability topics that Danica's Executive Board and Board of Directors considered in 2024 included: • Status of the sustainability strategy towards 2025 • Review of Danica's material sustainability risks • Introduction to and presentation of the CSRD project • Inspection of sustainable investments with the Danish FSA • Taxonomy reporting • Responsible Investment Policy, Active Ownership Policy and Sustainability Policy • Climate target status for investments

To support corporate governance, responsible investment decisions, including on climate and environmental risks, are anchored in Danske Bank Asset Management's Responsible Investment Committee, on which Danica is represented by two members, the Chief Investment Officer (CIO) and the Head of Sustainability. The Responsible Investment Committee's work is agreed with Danske Bank's Business Integrity Committee and supported by the work of Danske Bank's ESG Integration Council, which includes representatives of Danica's investment and sustainability team. Day-to-day ESG decisions are anchored in Danica's Investment Committee and Product Committee. Moreover, Danica has set up a knowledge-sharing forum in order to ensure a strong approach to compliance with statutory requirements and to facilitate the implementation of the sustainability strategy across the organisation.

Integration of sustainability-related performance in incentive schemes

Sustainability-related KPIs, including climate-related KPIs, are integrated into the Danske Bank Group's, and consequently Danica's, performance management framework to ensure that remuneration programmes reflect the Group's sustainability ambitions. The KPIs for remuneration programmes are approved by the Board of Directors after being reviewed by the Board of Directors' Remuneration Committee. The incentive schemes do not apply to members of the Board, as they do not receive variable remuneration.

For Danica's Executive Board, KPI agreements are prepared by the CEO, and the KPI agreement applying to the CEO is made with the chairman of Danica's Board of Directors. In 2024, ESG aspects made up 10% of the Executive Board's incentive programme.

Remuneration: The Executive Board members participate in a bonus programme in which sustainability KPIs have a weighting of 10% of the total bonus programme.

Statement on due diligence

As part of the Danske Bank Group, Danica supports a number of international sustainability initiatives and standards. These include: • the 2030 Agenda and the UN Sustainable Development Goals • the UN Global Compact • the OECD Guidelines for Multinational Enterprises • the UN Guiding Principles on Business and Human Rights • the UN-supported Principles for Responsible Investment • the UN Environment Programme Finance Initiatives • the ILO Declaration on Fundamental Principles and Rights at Work • the Universal Declaration of Human Rights • the Paris Pledge for Action • the Poseidon Principles • the Responsible Ship Recycling Standards • the UN Principles for Responsible Banking • the Net-Zero Asset Owner Alliance • the Finance for Biodiversity Pledge • FAIRR

Danica regularly performs sustainability due diligence processes, for example in relation to responsible investments, employee engagement, human rights, etc.

The table below describes where in the Sustainability Statement relevant information about due diligence processes is found:

Risk management and internal controls over sustainability reporting

As part of Danica's sustainability reporting process, governance structures and processes have been established to ensure that risk management and controls are implemented.

Danica has established a working group and a steering committee to manage day-to-day decisions related to sustainability reporting. Danica's Audit Committee receives regular project status updates, and the project is also closely monitored by the internal and external auditors and Compliance. Danica's Board of Directors is responsible for approving sustainability reporting before its publication.

In relation to quantitative data, an audit tool has been developed that provides an overview of datapoints, data sources, data quality, data use, calculations, documentation, a description of risk and control environments, etc. Mitigating data controls include spot checks and four-eyes controls.

Danica will work continually to improve risk management and controls in order to improve data quality over time. In the coming years, Danica will invest in and improve existing controls, for example by implementing a higher degree of automation.

Strategy, business model and value chain

Business model

Danica is owned by Danske Bank and is one of the largest life insurance and pension providers in Denmark. The Board of Directors holds overall responsibility for decisions about Danica's business model to balance the interests of customers and owners. Danica's business model applies to Danica Livsforsikringsaktieselskab.

Pension savings products: Danica offers pension savings products and various risk products, including life and disability insurance. Danica focuses particularly on investments that reflect environmental, social and governance (ESG) factors.

Risk products: Customers have a choice of various risk products including cover for loss of earning capacity, waiver of contribution, covers on death and spousal covers. The insurance rules are intended to provide a balance between the desired return and the related risk. Danica also offers risk products through Forenede Gruppeliv as well as health insurance and health packages. Danica has not identified any particular products or services in relation to material impacts, risks or opportunities.

Customer segments and sales channels: Danica writes pension schemes for customers, mainly in Denmark, within these two categories:

1. Personal customers with individual agreements
2. Personal customers with an agreement under a framework agreement with Danica, e.g. PFS (Pension for Selvstændige) or employees of an undertaking that has entered into a company pension agreement setting out the terms of the pension schemes and insurance covers of its employees

Sales are made according to a multi-channel distribution strategy via Danica's own sales force, brokers, partners and in collaboration with Danske Bank. Danica has not identified any particular customer groups in relation to material impacts, risks or opportunities.

Investment and financial risk management: Danica focuses on generating competitive investment returns for its customers. Consequently, the objective of its investment strategy is to achieve systematically high net returns. The investment strategy is based on calculated required rates of return and on analyses and simulations to ensure the security, quality, liquidity and profitability of the portfolio.

Investment limits are determined so as to ensure that Danica does not assume concentration and liquidity risks on individual products that jeopardise the customers' interests. In addition to the investment limits, the Board of Directors adopts separate risk management frameworks. The purpose of these limits and frameworks is to accurately reflect Danica's actual risk in a Solvency II scenario as well in a more commonly occurring market scenario.

Value chain

Danica's own operations and value chain activities: Danica has upstream value chain activities involving the use of services from suppliers, own operations comprising administrative activities, and downstream value chain activities in the form of investments and management of products and services for customers.

Danica's own operations are defined as activities related to the Executive Board, the Board of Directors, employees and building operations.

Included under own operations are employees' working terms and conditions, such as working hours, remuneration, diversity and employment security. Another component is the management structure of the business, including corporate culture, degree of political engagement and prevention of corruption and bribery. Included in building operations are Danica's carbon emissions and energy consumption from office buildings, resource consumption and waste management.

Danica's upstream activities mainly comprise services provided by suppliers. Central services include the supply of data, energy and heating, IT equipment, canteen and services and healthcare providers' services.

Danica's downstream activities comprise the management of pension and insurance products (Danica's services and products), investment activities and business relationships with external stakeholders such as NGOs, industry associations, media houses, professional bodies and politicians.

Interests and views of stakeholders

Stakeholder engagement in double materiality assessment

Danica has interviewed several stakeholders to gain a better insight into the stakeholders' view of Danica's sustainability efforts, to validate the double materiality assessment and to exchange experience. The interviewees were an employee, a key customer, an NGO and an industry association.

The stakeholders' feedback confirmed that the outcome of the double materiality assessment largely met the stakeholders' expectations. Moreover, Danica received inputs for its future work on the sustainability strategy, including inspiration for new employee initiatives, the green transition, trends in real estate investment and on maintaining focus on returns and financial security.

The stakeholders' inputs will be taken up at steering committee meetings and in other relevant forums and will also be a natural part of Danica's regular reviews of the sustainability strategy. In addition, inputs will also be included in work on the revised sustainability strategy to be developed during 2025. Danica expects to revisit the double materiality assessment during 2025.

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

Sustainability-related risks

Sustainability risks are environmental, social and governance (ESG) events or circumstances that, if they occur, may have a material negative impact (including financial and/or non-financial), on society, the environment or people or on Danica's assets and performance. Risks arise, for example, through Danica's strategic obligations and activities in investee companies.

Taking a risk-based approach, Danica prioritises its efforts by managing sustainability risks where the adverse impact is deemed to be high on the basis of the double materiality assessment.

The principal financial risks related to sustainability are linked to the investments as they may affect Danica's responsibility to comply with the prudent person principle. This principle implies that the investment strategy and the actual investments must support long-term financial and sustainability objectives, including ensuring the best possible return for the customers.

Danica considers sustainability risk to extend to all aspects of the business, and sustainability risk is thus integrated in all other risk factors via the risk management framework. Danica therefore has access to external data providing insights into material environmental, social and governance (ESG) issues in investee companies. For example, Danica has access to ESG data on investee companies' working conditions, how they handle the green transition, fight corruption, and whether management possesses the right skills.

Danica has company exclusions within coal, tar sand, controversial weapons, norms and tobacco. Countries are also excluded if they appear on sanction lists and on the basis of a number of sustainability criteria. At 31 December 2024, Danica furthermore implemented exclusions in the fossil fuel area.

Most material sustainability risks

Climate risk is the most pressing ESG-related investment risk, and risk analyses are evolving in line with growing requirements from regulators, public authorities and developments in the pension sector in general.

Danica Risk Management does not currently monitor and report on climate-related risks. Today, ongoing risk monitoring is only able to detect indirect effects of climate-related risks through financial markets fluctuations.

Climate risks are described in detail in section E1 Climate and environment in this statement.

Follow-up on goals

Danica reports on the sustainability strategy on a quarterly basis via an internal KPI dashboard. The KPI dashboard data describes environmental, governance and social issues that are relevant in order to assess progress on the implementation of the sustainability strategy.

Sustainability information provided to the Board of Directors and the Executive Board

Danica has identified three sustainability topics on which to focus: Climate and environment, Financial security and A healthier lifestyle. These three topics are all material to varying degrees in terms of impact, risk and opportunities. The Executive Board and the Board of Directors are notified of the status of each of the three topics as part of the regular strategy follow up. The Board of Directors and the Executive Board are also informed of the outcome of Danica's double materiality assessment.

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

Double materiality assessment methodology

In 2024, Danica performed a double materiality assessment on the basis of the following steps:

1. Preparation of the materiality assessment a. Identification of internal stakeholders b. Workshops (scoring of topics) c. Establishment of impacts, risks and opportunities (IROs) d. Financial materiality assessment e. Impact assessment of downstream activities f. Preparation of template

2. Review of materiality assessment a. Presentation of assessment to Executive Board and others b. Adjustment of assessment c. Interviews with external stakeholders d. Documentation of the outcome and preparation of methodology memo

Preparation of the materiality assessment 1.a.: Danica identified employees and top management members from various departments and the Executive Board as significant internal stakeholders because they possess knowledge about Danica's business and organisation that is useful for the assessment.

1.b. & c.: These internal stakeholders participated in workshops where impacts, risks and opportunities (IROs) on own operations and customer-facing processes were identified based on specific information about Danica's business. These IROs were recorded and categorised within the relevant ESRSs, and the internal stakeholders assessed each sub-topic, scored them and argued their relevance.

1.d.: For the financial materiality analysis of own operations, a materiality level of DKK 100 million was applied to assess whether a topic was material. Whenever possible, financial reporting data was obtained to support the financial impact of the topic in question.

1.e.: Similarly, a downstream impact assessment was conducted to assess the societal impact of Danica's investments. The analysis was prepared by the Sustainability Team and the CFO.

1.f.: Subsequently, a template was prepared for the overall double materiality assessment, in which the IROs were listed at sub-topic level. In the financial materiality assessment, likelihood and a scale of the financial impact were also added.

Review of materiality assessment 2.a.: The results of the scoring and assessment were then collated by the Sustainability Team and reviewed by the Executive Board, the Responsible Investment team at Danske Bank and Danica Ejendomme. Finally, the Board of Directors was presented with the outcomes.

2.b.: On the basis of the review of the assessment with the Executive Board, Responsible Investment at Danske Bank and Danica Ejendomme, the assessment was adjusted to arrive at the final outcome.

2.c.: Interviews with relevant external stakeholders were then conducted to validate the assessment.

2.d.: Finally, Danica prepared a methodology memo describing the double materiality assessment process.

Identification of IROs

The double materiality assessment sets out IROs for environmental, social and governance matters. The IROs were the result of the workshops with internal stakeholders and the material from the preparation of the financial assessment and the downstream assessment. Policies, business procedures, employee satisfaction surveys, job satisfaction survey, reporting on the Disclosure Regulation (SFDR) and own estimates were also employed in the identification of IROs.

To each IRO is attached an evaluation, a rationale and documentation of Danica's material impacts, risks and opportunities.

Impact materiality

Danica's assessment considered both positive and negative impacts, distinguishing between actual and potential impacts. Entity-specific information is shown under S4.

Impact materiality was assessed according to four parameters: Scale, Scope, Irremediable character and Likelihood. Scale is an assessment of the intensity of an impact, Scope is an assessment of how many people or how widespread an area is impacted, Irremediable character is an assessment of how easy/difficult it would be to mitigate an impact, and Likelihood is an assessment of how likely an impact is to occur.

All four parameters were scored on a scale of 0-5. An impact with an overall average score of three or more across all parameters is considered material to Danica.

Financial materiality

Financial materiality was assessed according to two parameters: likelihood of occurrence and scope of financial impact.

The likelihood of occurrence was assessed on the basis of previous occurrences and whether measures have been taken to reduce the likelihood of occurrence. The scope of the financial impact and the likelihood of its occurrence were assessed using a scale of 0-5, zero representing no financial impact and no likelihood and five representing high impact on risks and opportunities and high likelihood. The scores were assessed on the basis of estimates of the scope of financial impact.

The financial materiality was calculated as the sum of the assessed likelihood of occurrence and the scope of the financial impact, divided by two. An underlying sub-topic is considered material when the average score of IROs within the sub-topic in question equals or exceeds three.

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

Danica's Sustainability Statement was prepared on the basis of the double materiality assessment and the material ESRSs and sub-topics mentioned below. Danica has chosen to include material IROs in this Sustainability Statement. A comprehensive list of disclosure requirements complied with are shown in the Appendix.

The following topics have been assessed to be material according to Danica's double materiality assessment:

Where possible, Danica uses the phase-in provisions in ESRS 1, Appendix C. Voluntary datapoints have been omitted when Danica assesses that such omission will not alter the quality of reporting in terms of fairly representing material topics.

Transition plan for climate change mitigation

Danica does not yet have a transition plan that fully complies with the ESRS disclosure requirements in relation to transition plans. During 2025, Danica expects to collaborate with the Group on developing a group-wide transition plan that is in compliance with the ESRS's disclosure requirements in relation to transition plans. The transition plan will include Danica and be based on the climate targets and actions in the Climate Action Plan, which forms part of the overall business strategy.

The Group's Climate Action Plan covers Danica's climate targets and measures for equity and bond investments in relation to decarbonisation targets for five sectors and Science Based Target initiative SBTi temperature targets, green transition investment targets for the entire investment portfolio and decarbonisation targets for the real estate portfolio.

Danica's target of having a net-zero investment portfolio by 2050 or earlier is anchored with and part of the Danske Bank Group's Climate Action Plan, which was launched in 2023 as a transition plan toward Net Zero for the Danske Bank Group in line with the Paris Agreement. The plan describes primary interim targets and actions to deliver on the 2050 target. The plan is in accordance with Danica's business strategy and constitutes the first step toward a transition plan for Danica. Alongside the work of developing a transition plan, Danica focuses on managing potential risks related to the achievement of a net-zero investment portfolio and adjusts actions to address these.

Policies related to climate change mitigation and adaptation

Danica's sustainability strategy consists of a number of climate actions and targets, which are a central element in the overall business strategy, Tryghedsrådgiverstrategien (Financial security provider strategy), effective until the end of 2024. As from 2025, this strategy will be replaced by the new business strategy, Forward 28 – Danica. In the new strategy, sustainability, including the climate targets, is one of four strategic focus areas, and the current climate targets are maintained.

Danica's subsidiary Danica Ejendomme has adopted its own ESG strategy, which builds on Danica's sustainability strategy and defines climate targets and related actions specifically for the real estate portfolio.

In combination with the business strategy, as described under ESRS 2, the sustainability strategy and associated climate targets (described in this section under Climate targets) present a roadmap for Danica's climate change mitigation efforts through green transition investments, CO2e reduction targets and integration of climate-related risks and opportunities in the investment process.

Danica's sustainability strategy, responsible investments and climate targets are operationalised through a number of policies, business procedures and guidelines. These support Danica's systematic efforts to mitigate climate change and manage risks and opportunities in relation to climate aspects, which contributes to Danica's obligation under the prudent person principle to generate the best possible risk-adjusted returns and the ambition to support society's net-zero transition.

At the same time, Danica applies a double materiality perspective in the investment process, taking into account both the potential financial impact of climate-related aspects and the potential negative impact of investments on the sustainability of society and climate change. This is defined, among other things, through the following:

Responsible Investment Policy

Outlines the overarching principles of responsible investment practices supporting the goal of protecting customers' investment portfolios. It describes processes for managing climate aspects through the inclusion of ESG in selection of investments, active ownership, screening and investment restrictions. This is done from a double materiality perspective of protecting the financial value of investments while also minimising the negative impacts of the investments.

Investment Policy

Establishes the overall framework for the allocation of customers' pension savings across Danica's investment portfolios. The investment strategy generally considers and integrates climate and ESG factors.

Active Ownership Policy

Outlines Danica's guidelines and approach to active ownership in portfolio companies in relation to financial and ESG aspects, including climate-related aspects. Active ownership is pursued through direct engagement, voting at general meetings and collaboration with other investors. Active ownership is applied to protect the investment in portfolio companies and contribute to their positive development and management of climate-related risks and opportunities.

Risk Management Policy

Describes the processes of Danica's general risk management approach, where climate aspects are an element in the overall risk assessment of the investment portfolio's robustness. Danica's risk management practices are organised in line with the principles of the three-lines-of-defence model, under which the potential impact of the risks is identified, monitored and mitigated in the risk management process across all risk types.

Non-financial Risk Policy

A separate policy setting out the processes and responsibilities for identifying, assessing and mitigating non-financial risks as part of managing and protecting the customers' pension investments. This includes political developments, changes in legislation, technological advances, changes in customer preferences and ESG developments. It includes non-financial risks related to climate change (particularly transition risks).

Voting Guidelines

Describe how Danica expects portfolio companies to address financial aspects and ESG in general, including climate aspects. This indicates how Danica is expected to vote on proposals at general meetings on specific climate-related aspects.

These policies and guidelines are integrated into the practical business operations by means of business procedures for the internal Danica departments involved. Danica has an annual cycle comprising all policies. Using a risk-based approach, controls are performed to check how the policies function and are implemented in the business, including the preparation of gap analyses to support compliance with legislation. Policies are approved by the Board of Directors annually, and Internal Audit monitors compliance with the policies using a risk-based approach. As a general rule, information on compliance with the policies is also regularly reported to the Board of Directors. The policies were prepared according to the prudent person principle, the purpose of which is to safeguard customers' financial interests. The policies support various international initiatives and standards.

Governance

Policies and business procedures on responsible investments, climate targets and management of climate-related risks, opportunities and impacts are laid down by Danica's Board of Directors. The Board of Directors regularly monitors these and is involved when significant aspects and possible adjustments are discussed. The Board also assesses climate-related risks in connection with Danica's annual own risk and solvency assessment (ORSA). Material sustainability risks, including climate risks, are reported annually to the Board of Directors' Risk Committee.

Operational responsibility for the implementation of the climate targets lies with Danica's Executive Board, which is also responsible for monitoring developments in collaboration with relevant departments and adjusting actions in order to deliver on climate targets. The Board of Directors of Danica's subsidiary Danica Ejendomme has a separate responsibility for compliance with the ESG strategy, including climate targets regarding the real estate portfolio, and for its approval.

Actions and resources in relation to climate change policies

Climate stress testing of the investment portfolio

In the short and long term, climate change could expose the investment portfolio to a number of risks, which Danica's business and risk management system must gradually adapt to in order to mitigate climate change. The impact of climate change will vary in nature and strength, depending on the geographical region, and will affect global socio-economic and financial development, which will influence the investment portfolio. This will be reflected in economic growth, world trade, employment, inflation, interest rates and equity prices.

In January 2024, Danica performed a climate stress test of equities and credit bonds in the investment portfolio on the basis of scenario values from the end of 2022. The climate stress test indicated that assets in the Danica Balance pension product were to some extent exposed to climate risk. It is estimated that investments in companies with high CO2e emissions in particular could be financially affected in the future. Quantifying the risk is difficult, however, among other things due to poor data quality. The climate stress test also suggested a number of value reductions on commercial and residential real estate. There is a risk that carbon-intensive companies covered by Danica's sector reduction targets will not transition fast enough and that parts of the targets will therefore not be met.

Climate scenarios from the Central Banks and Supervisors' Network for Greening the Financial System (NGFS) have been used to identify the potential financial impact on parts of the investment portfolio based on specific temperature scenarios. It must be determined whether the NGFS is to be used in the future, or whether other models are necessary or more relevant to reporting on Danica's climate risks and temperature scenarios.

Investment process

ESG and climate aspects are included in the investment process from a double materiality perspective. This supports Danica in: • managing and mitigating physical risks and transition risks related to climate aspects that could have a negative impact on the return potential of the investments • reallocating investments on an ongoing basis to companies and other assets that support the green transition and have a positive return potential • reducing the negative impact of the investment portfolio on societal sustainability and climate change

Aspects such as renewable energy production, decarbonisation, climate governance and compliance with the EU Taxonomy are taken into account in the investment process. Any material negative impacts of the investment portfolio on societal sustainability and climate change are also taken into account by using Principal Adverse Indicators (PAI).

Active ownership

Danica exercises active ownership with the aim of influencing and supporting portfolio companies to continuously improve their climate plans and address business-relevant climate risks and opportunities, including PAI. It does so through direct engagement, voting at general meetings and participation in various climate-focused investor associations.

In 2024, climate aspects such as energy transition, CO2e emissions and climate neutrality were once again among the topics most often discussed with portfolio companies. In 2024, Danica continued the approach of supporting climate proposals at general meetings that are ambitious and practicable and that promote value creation for the company and the wider society.

Investment restrictions

Danica applies investment restrictions that contribute to: • minimising the climate-related risks of the investment portfolio and thereby optimising the portfolio's risk-adjusted return potential • minimising the investment portfolio's CO2e emissions and thus material negative impacts on PAI and societal sustainability

Excluding companies from the investment portfolio if it is assessed that there is no opportunity to use active ownership to influence their climate strategies if they do not show sufficient progress over time or if they are assessed not to manage climate-related risks and opportunities satisfactorily.

Danica currently has the following climate-related restrictions in place for equities and corporate bonds: • Companies are excluded if 5% or more of their revenue stems from certain thermal coal, peat or tar sand activities. Existing investments related to coal, peat and tar sand will be phased out by 2030 within the EU and the OECD and by 2040 for the rest of the world in line with the Paris Agreement phase-out plan.

• Companies may be exempted from the thermal coal exclusion if they have a credible plan to phase out thermal coal in alignment with the Paris Agreement. Such plans are assessed using the recognised Transition Pathway Initiative climate assessment tool • Companies are excluded if they are assessed to be involved in activities, services or products that have a material negative climate impact. This may also include companies that are deemed to have insufficient climate actions, policies and processes. Such exclusions are made on the basis of qualitative and quantitative data as well as qualitative judgements.

Additionally, Danica will start implementing the following restriction criteria for the fossil industry in 2025: • Companies focused on fossil fuels are excluded if they are deemed not to have credible plans in place to support the transition to more sustainable society. This applies to companies that derive 5% or more of their revenue from certain fossil fuel activities such as coal, oil, gas or tar sand. The companies' transition plans are assessed using a proprietary model developed in collaboration with Danske Bank Asset Management, which is primarily based on TPI methods and data.

At 31 December 2024, Danica had excluded 531 companies on the basis of the above climate restrictions.

Pension solution with a special sustainability focus

In 2020, Danica launched the investment solution Danica Balance Responsible Choice, which has a special focus on promoting sustainability aspects in investments. The investment solution consists of a minimum of 75% sustainable investments (pursuant to Article 2.17 of the EU Disclosure Regulation and its definition of sustainable investments) that aim in various ways to contribute to one or more of the UN Sustainable Development Goals, including the green transition.

For example, Danica invests in Paris-aligned and Climate Transition benchmarks, which have 50% and 30% lower carbon intensities, respectively, than the market in general and for which the intensity is to be reduced by 7% annually in alignment with the Paris Agreement phase-out plan. At 31 December 2024, the solution had total assets under management (AuM) of DKK 6.4 billion.

Targets related to climate change mitigation and adaptation

Danica has set climate targets to meet the climate change mitigation strategy and to address material impacts, risks and opportunities identified through the double materiality assessment. To ensure effective targets that are both scientifically based and operationally feasible, Danica has joined various initiatives under which all targets have been externally verified.

The expectation is that if companies manage their climate-related risks and opportunities, they will have a future-proof business with positive return potentials as a result. Therefore, Danica makes regular reallocations on the basis of climate and ESG analyses and employs active ownership and investment restrictions that support the execution of climate targets.

In 2020, Danica signed up to the international investor initiative the Net-Zero Asset Owner Alliance and thus committed to achieving a net-zero investment portfolio by 2050 in alignment with the Paris Agreement. In 2021, Danica set interim 2025 CO2e reduction targets for its equity and bond investments in five sectors based on the One Earth Model and the Transition Pathway Initiative, the methodologies of which are aligned with the Paris Agreement.

On the basis of this, Danica's objective is that the CO2e intensity of its equity and bond investments within the following industries is to be reduced by 2025 relative to 2019 levels as set out below: • Energy: 15% (covering scope 1, 2 and 3) • Utilities: 35% (covering scope 1) • Steel: 20% (covering scope 1 and 2) • Cement: 20% (covering scope 1) • Transportation:

• automotive: 30% (covering scope 1 and 3)
• shipping: 20% (covering scope 1 and 3)
• aviation: 15% (covering scope 1 and 3)

The reduction targets for each sector are defined according to various carbon scopes. The scopes for each sector were determined according to what the sector's main carbon emissions are and where sufficient valid carbon data is available.

CO2e reduction targets have also been set for the Danish real estate portfolio relative to 2019 levels: • The CO2e intensity is to be reduced by 37% by the end of 2025 and by 69% by the end of 2030.

Together with the Danske Bank Group, Danica in 2023 committed to the UN-supported Science Based Targets initiative (SBTi). On the basis of the existing standards at the time, Danica submitted temperature rating targets for its equity and credit bond investments and decarbonisation targets for the real estate portfolio to the SBTi, which are validated by independent experts. The targets were set according to SBTi methods and data models and aligned with the Paris Agreement. The submitted targets have yet to be approved by the SBTi.

Presently, Danica has defined and submitted the following targets in accordance with the SBTi standards: • Equity and corporate bond investments must have a temperature rating of 2.0°C by 2030 (covering scope 1 and 2) relative to a baseline of 2.5°C in 2020. • Equity and corporate bond investments must have a temperature rating of 2.2°C by 2030 (covering scope 1, 2 and 3) relative to a baseline of 2.8°C in 2020. • The carbon intensity in the Danish real estate portfolio is to be reduced by 69% by 2030 (scope 1, 2 and 3) relative to 2019 levels.

The SBTi and the ambition of a net-zero investment portfolio complement each other as management tools in relation to the target of investing in alignment with the Paris Agreement. The SBTi is a forward-looking metric showing the portfolio's future temperature rating targets, whereas the net-zero ambition is based on the portfolio's actual emissions.

Climate targets have been set on the basis of scientific methodologies. The setting and execution of climate targets do not incorporate or account for potential changes to political goals or regulatory changes that might accelerate the green transition. Nor do they take into account potential major technological advances in climate solutions or changed consumption patterns of green products or the like. Danica has established an in-house working group that continuously monitors progress on the targets based on data from external data providers such as ISS ESG and TPI.

As Danica is a financial institution and not a production company, transitioning the business will not require capital-intensive CapEx or OpEx investments. Accordingly, disclosure requirements related to CapEx and OpEx investments and exposures to specific activities are not considered material. Also, as Danica and Danica Ejendomme are not publicly traded, disclosure requirements regarding inclusion/exclusion from Paris-aligned benchmarks are not considered material.

Energy consumption and mix

Own operations energy consumption

Danica reports energy consumption from its own operations in Denmark at locations where it has operational control. The reporting period for 2024 runs from Q4 2023 to Q3 2024.

Total energy consumption (2024): 2,405 MWh (own operations in Denmark)

Scope and methodology:

• Energy consumption covers heating, cooling and electricity supplied by external suppliers at Danica's Danish operations.
• Renewable energy share is calculated based on total energy consumption and the amount of renewable electricity certified by guarantees of origin and renewable energy certificates.
• Natural gas consumption covered by biogas certificates of origin is not considered renewable energy for this KPI.
• Fuel consumption from company cars is not included (only one company car in use).
• The renewable energy share decreased from 41% (2023) to 35% (2024), partially driven by a lower renewable energy share in the energy grid.
• The increase in fossil energy consumption was mainly driven by Danica's move to a new, LEED Gold certified and more energy-efficient head office in 2024.

Energy intensity

Energy intensity per revenue is not reported. Danica does not belong to the NACE High climate impact sectors classification and therefore does not report on E1-5/10-14 or E1-5/18-21.

Multi-year energy data

Broader climate reporting on own operations (scope 1, 2, 3):

Gross Scopes 1, 2, 3 and Total GHG emissions

Own operations (Scope 1, 2, 3)

Danica reports emissions from own operations separately from investment portfolio emissions.

Scope 3 breakdown by category (own operations)

Methodology notes (own operations):

• Scope 1: Emissions from company cars calculated using mileage and DEFRA emission factors. Biogas certificate purchases exclude gas consumption from Scope 1; biogenic emissions reported separately.
• Scope 2 market-based: Electricity emissions omitted due to purchase of guarantees of origin. District heating/cooling calculated using specific emission factors (Copenhagen area: CTR/VEKS/HOFOR; elsewhere: Danish Energy Agency).
• Scope 3.6: Air travel calculated by American Express using mileage data and DEFRA emission factors (updated methodology in 2024). Road travel based on mileage from Nordania/HR and DEFRA fuel-specific factors.
• Scope 3.7: Homeworking emissions calculated using office occupancy data, working hours, FTEs per quarter, and DEFRA emission factor for office equipment electricity.
• Reporting period: Q4 2023 to Q3 2024.

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Investment portfolio emissions (Scope 3, Category 15)

Danica calculates investment portfolio emissions separately. The investment portfolio accounts for 99.9% of total emissions. Only PCAF data quality scores 1 and 2 (reported company data with limited estimation) are included for Scope 3.

Equities

Credit bonds

Equities and credit bonds combined

Real estate portfolio

Methodology notes (investments):

• Data source: ISS ESG for equities and credit bonds. PCAF data quality scores 1 or 2 only for Scope 3 (reported company data). Companies without data or with PCAF scores 3-5 excluded from Scope 3 totals to reduce volatility from third-party estimation models.
• Coverage: 95% of positions covered for Scope 1 and 2; 56% covered for Scope 3 (Category 15) at 31 December 2024.
• Asset classes included: Equities, corporate bonds, mortgage bonds. Excludes sovereign debt, unlisted companies, other alternatives, derivatives, cash.
• Products included: Danica Balance, Danica Traditionel, Danica Link, Tidspension. Excludes Danica Select (customer-managed).
• Real estate: Danica Ejendomme portfolio calculated using GHG Protocol and Real ESG Framework. Area measured by BBR area (heated floorspace in prior years; historical figures restated). Increasing use of digital meters vs. EPC calculations increases reported intensity.
• Comparative figures: 2023 and prior years restated due to methodology changes (Scope 3 data quality restriction; air travel emission factor update; real estate area calculation change).

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Comprehensive overview: Own operations + Investments

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GHG intensity per net revenue

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Regulated emissions and biogenic CO2

• Regulated emissions (e.g. EU ETS): Not separately disclosed.
• Biogenic CO2 emissions (reported separately from Scope 1): 4.34 tCO2e (2024), 6.22 tCO2e (2023) from biogas use in own operations.

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General notes:

1. 2030 targets: Own operations Scope 1, 2 (market-based) and 3: reduce by 50% vs. 2019 baseline (622 tCO2e). 2024 status: 590 tCO2e (-5.2% reduction vs. baseline).
2. Investment portfolio 2019 baseline and 2024 status not disclosed in emissions tables; only sector-specific and real estate intensity targets referenced.
3. Scope 3 Category 15 (Investments): Comprises 99.9% of total emissions. Only PCAF quality scores 1-2 included due to estimation uncertainty in third-party models.
4. Comparative figures restated: Scope 3 data quality restriction, air travel methodology update, real estate area calculation change applied retroactively.
5. Energy consumption: Total 2,405 MWh (2024) vs. 2,390 MWh (2023). Renewable share 35% (2024) vs. 41% (2023).

GHG removals and GHG mitigation projects financed through carbon credits

Danica has not invested in any GHG removal activities or financed any GHG mitigation projects through carbon credits in 2024. The reason is that such activities are not deemed cost-effective relative to other climate change mitigation activities such as investing directly in companies with credible decarbonisation plans or supporting the development of renewable energy capacity.

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

Phase-in exemption applied

Danica has opted to omit Disclosure Requirement E1-9 on anticipated financial effects from material physical and transition risks and potential climate-related opportunities in this statement.

Materiality assessment of related datapoints

The following datapoints associated with E1-9 have been assessed as not material in the double materiality assessment:

• Datapoint 66: Exposure of the benchmark portfolio to climate-related physical risks (Delegated Regulation (EU) 2020/1818, Annex II and Delegated Regulation (EU) 2020/1816 Annex II) - assessed as not material

• Datapoint 66 (a); 66 (c): Disaggregation of monetary amounts by acute and chronic physical risk; Location of significant assets at material physical risk (Article 449a of Regulation (EU) No 575/2013, Commission Implementing Regulation (EU) 2022/2453 paragraphs 46 and 47: Template 5: Banking book - Climate change physical risk: Exposures subject to physical risk) - assessed as not material

• Datapoint 67 (c): Breakdown of the carrying value of its real estate assets by energy-efficiency classes (Article 449a of Regulation (EU) No 575/2013, Commission Implementing Regulation (EU) 2022/2453 paragraph 34 Template 2: Banking book - Climate Change transition risk: Loans collateralised by immovable property - Energy efficiency of the collateral) - assessed as not material

• Datapoint 69: Degree of exposure of the portfolio to climate-related opportunities (Delegated Regulation (EU) 2020/1818 Annex II) - assessed as not material

Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Danica has not developed a transition plan for biodiversity and ecosystems that is fully compliant with the ESRS disclosure requirements. However, biodiversity considerations are integrated into Danica's business strategy and investment approach through specific targets and actions.

Danica recognizes that biodiversity is under pressure, and the restoration of biodiversity and ecosystems is crucial in terms of aligning with the Paris Agreement and safeguarding the foundation of the companies Danica invests in.

Biodiversity considerations are incorporated into the investment process as part of Danica's ESG integration and active ownership approach. The investment strategy takes into account biodiversity-related risks and opportunities when making investment decisions.

Danica has established specific biodiversity targets:

1. Active ownership target: Danica is to have conducted 30 engagements with 30 portfolio companies by the end of 2025
2. Nature-enhancing projects: Danica is to launch three to five nature-enhancing projects per year

These targets are integrated into Danica's overall sustainability strategy and are monitored as part of the quarterly sustainability reporting to management and the Board of Directors.

The biodiversity strategy also extends to Danica's real estate portfolio through Danica Ejendomme, where biodiversity considerations are integrated into property development and management practices.

Policies related to biodiversity and ecosystems

Danica's approach to biodiversity and ecosystems is integrated into the overall sustainability strategy and responsible investment framework. Biodiversity considerations are embedded in the following policies:

Responsible Investment Policy: Outlines principles for responsible investment practices that include consideration of biodiversity and ecosystem impacts. The policy describes processes for managing biodiversity aspects through ESG integration in investment selection, active ownership activities, and screening processes.

Active Ownership Policy: Defines Danica's approach to engaging with portfolio companies on biodiversity and ecosystem-related issues. This includes direct engagement with companies, voting on biodiversity-related proposals at general meetings, and collaboration with other investors on biodiversity initiatives.

ESG Strategy (Danica Ejendomme): The real estate subsidiary has adopted specific ESG considerations that include biodiversity aspects in property development and management. This strategy builds on Danica's overall sustainability approach and defines specific actions for the real estate portfolio.

As part of the Danske Bank Group, Danica also supports international biodiversity initiatives, including: • The Finance for Biodiversity Pledge • UN Sustainable Development Goals, including those related to biodiversity conservation • The UN Global Compact principles related to environmental stewardship

The policies are operationalized through business procedures and guidelines that integrate biodiversity considerations into investment decision-making processes. These policies are approved by the Board of Directors and are subject to regular review and monitoring to ensure effective implementation.

Actions and resources related to biodiversity and ecosystems

Active ownership and engagement

Danica exercises active ownership with portfolio companies to address biodiversity and ecosystem-related risks and opportunities. This includes: • Direct engagement with portfolio companies on biodiversity-related issues • Voting on biodiversity-related proposals at general meetings • Participation in investor collaborations focused on biodiversity conservation • Supporting companies in developing and implementing biodiversity strategies

In 2024, biodiversity and ecosystem considerations were integrated into Danica's active ownership activities, with specific focus on companies with significant biodiversity impacts or dependencies.

Investment process integration

Biodiversity and ecosystem considerations are integrated into Danica's investment process through: • ESG analysis that includes biodiversity risk assessments • Screening for companies with significant negative biodiversity impacts • Consideration of biodiversity-related opportunities in investment decisions • Use of biodiversity-related data and metrics in investment analysis

Real estate portfolio actions

Through Danica Ejendomme, specific actions are taken to support biodiversity and ecosystems: • Implementation of biodiversity considerations in property development projects • Integration of green building standards that promote biodiversity • Development of nature-enhancing features in real estate projects • Assessment of biodiversity impacts in property management decisions

Collaboration and initiatives

Danica participates in industry initiatives and collaborations focused on biodiversity: • Member of the Finance for Biodiversity Pledge • Participation in investor networks focused on biodiversity conservation • Collaboration with other financial institutions on biodiversity-related issues • Support for research and development in biodiversity measurement and management

Resources allocated

Danica has allocated resources to support biodiversity-related activities: • Dedicated sustainability team members with biodiversity expertise • Investment in biodiversity-related data and analysis tools • Allocation of time and resources for active ownership activities related to biodiversity • Training and capacity building for investment teams on biodiversity issues

Targets related to biodiversity and ecosystems

Danica has established specific targets related to biodiversity and ecosystems to address material impacts identified through the double materiality assessment.

Active ownership target

Target: Danica is to have conducted 30 engagements with 30 portfolio companies by the end of 2025

Status: This target has been achieved in 2024. Danica has successfully conducted engagements with portfolio companies on biodiversity-related topics as part of its active ownership program.

Methodology: The target focuses on engaging with portfolio companies that have significant biodiversity impacts or dependencies. Engagements cover topics such as: • Biodiversity risk management • Ecosystem conservation efforts • Sustainable land use practices • Biodiversity-related disclosure and reporting • Development of biodiversity strategies and action plans

Nature-enhancing projects target

Target: Danica is to launch three to five nature-enhancing projects per year

Status: This target has been achieved in 2024. Danica has successfully launched nature-enhancing projects, primarily through its real estate portfolio managed by Danica Ejendomme.

Project types: Nature-enhancing projects include: • Green roof installations and biodiversity-friendly landscaping • Creation of habitat areas in real estate developments • Implementation of sustainable water management systems • Integration of native plant species in property developments • Collaboration with local environmental organizations on conservation projects

Target monitoring and reporting

Progress on both biodiversity targets is monitored through: • Quarterly sustainability KPI dashboard reporting • Regular reporting to the Executive Board and Board of Directors • Integration into the overall sustainability strategy follow-up • Documentation and tracking of engagement activities and project outcomes

These targets contribute to Danica's broader sustainability objectives and support the company's commitment to contributing to biodiversity conservation and ecosystem restoration. The targets are aligned with international frameworks and contribute to relevant UN Sustainable Development Goals related to biodiversity and ecosystem conservation.

Impact metrics related to biodiversity and ecosystems change

Danica reports on biodiversity and ecosystem impacts primarily through its active ownership activities and nature-enhancing projects. The following metrics are tracked:

Active ownership engagement metrics

• Number of biodiversity-related engagements: 30 engagements conducted with 30 portfolio companies in 2024 • Engagement topics: Focus areas include biodiversity risk management, ecosystem conservation, sustainable land use practices, and biodiversity-related disclosure • Portfolio company coverage: Engagements target companies with significant biodiversity impacts or dependencies across various sectors

Nature-enhancing project metrics

• Number of nature-enhancing projects launched: 3-5 projects per year target achieved in 2024 • Project types: Green infrastructure, habitat creation, native species integration, and sustainable water management systems • Real estate portfolio integration: Projects primarily implemented through Danica Ejendomme's property development and management activities

Investment portfolio considerations

Biodiversity considerations are integrated into investment decisions through: • ESG analysis including biodiversity risk assessments • Screening for companies with significant negative biodiversity impacts • Active ownership engagement on biodiversity-related issues • Support for companies developing biodiversity strategies

Danica recognizes that comprehensive biodiversity impact measurement is an evolving area, and the company continues to develop its approach to biodiversity metrics and reporting in line with emerging standards and best practices in the financial sector.

Policies related to own workforce

Danica has established comprehensive policies to manage workforce-related impacts, risks, and opportunities. These policies are integrated into the overall business strategy and governance framework.

Human Rights and Labor Standards

As part of the Danske Bank Group, Danica supports fundamental international labor standards and human rights principles: • The UN Universal Declaration of Human Rights • ILO Declaration on Fundamental Principles and Rights at Work • UN Global Compact principles related to labor rights • OECD Guidelines for Multinational Enterprises

Danica has due diligence policies addressing issues covered by the fundamental International Labor Organisation Conventions 1 to 8, including: • Freedom of association and collective bargaining • Elimination of forced and compulsory labor • Abolition of child labor • Elimination of discrimination in employment and occupation

Workplace Safety and Health

Danica has implemented workplace accident prevention policies and management systems, including: • Health and safety protocols for office environments • Risk assessment procedures for workplace hazards • Employee wellness programs and health support services • Emergency response procedures • Regular monitoring and reporting of workplace safety metrics

Anti-Trafficking and Modern Slavery

Danica has established processes and measures for preventing trafficking in human beings, including: • Supply chain due diligence procedures • Vendor screening and assessment processes • Training and awareness programs for employees • Reporting mechanisms for suspected violations

Equal Opportunity and Non-Discrimination

Policies address equal treatment and non-discrimination in: • Recruitment and hiring practices • Career development and promotion opportunities • Compensation and benefits • Training and skills development • Work environment and culture

Grievance and Complaints Handling

Danica has established grievance and complaints handling mechanisms that provide: • Clear procedures for raising concerns • Multiple channels for reporting issues • Protection for whistleblowers • Fair and timely investigation processes • Appropriate remediation measures

Policy Implementation and Governance

These workforce policies are: • Approved by the Board of Directors annually • Monitored through regular compliance assessments • Integrated into performance management systems • Subject to internal audit review • Supported by training and awareness programs

The policies are designed to ensure compliance with applicable labor laws and regulations while promoting a positive and inclusive work environment that supports employee engagement, development, and well-being.

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

Danica has established systematic processes for engaging with its workforce and workers' representatives to address impacts, risks, and opportunities related to working conditions and employment practices.

Employee Engagement Surveys

Danica conducts regular employee engagement surveys to: • Assess employee satisfaction and motivation levels • Identify areas for improvement in working conditions • Gather feedback on workplace policies and practices • Monitor progress on employee-related initiatives • Benchmark performance against industry standards

The employee engagement survey includes assessment of satisfaction and motivation, with Danica meeting the target of an employee score of at least 80 out of 100 on satisfaction and motivation.

Collective Bargaining and Social Dialogue

Danica maintains constructive relationships with employee representatives through: • Recognition of employees' rights to collective bargaining • Regular dialogue with worker representatives • Participation in industry-wide negotiations where applicable • Consultation on significant workplace changes • Collaborative approach to resolving workplace issues

Management-Employee Communication

Regular communication channels include: • Town hall meetings and management updates • Department-level meetings and discussions • One-on-one performance review conversations • Open-door policies with management • Employee suggestion and feedback systems

Specific Consultation Processes

Danica engages employees on specific topics such as: • Health and safety matters • Workplace policies and procedures • Training and development programs • Diversity and inclusion initiatives • Environmental and sustainability topics

Worker Representative Involvement

Employee representatives are involved in: • Board of Directors representation (3 employee-elected members) • Health and safety committees • Policy development and review processes • Workplace change management • Resolution of collective employment issues

Feedback Integration

Employee input is systematically integrated into: • Policy development and revision • Workplace improvement initiatives • Training program design • Performance management system updates • Strategic planning processes

These engagement processes ensure that employee voices are heard and considered in decision-making that affects their working conditions, career development, and overall employment experience.

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

Danica has established comprehensive processes to address negative impacts on its workforce and provide multiple channels for employees to raise concerns safely and effectively.

Grievance and Complaints Handling Mechanisms

Danica operates formal grievance and complaints handling mechanisms that provide: • Clear, accessible procedures for raising workplace concerns • Multiple reporting channels to accommodate different preferences and situations • Confidential reporting options to protect employee privacy • Anonymous reporting capabilities where appropriate • Timely acknowledgment and response to all reports

Reporting Channels

Employees can raise concerns through various channels: • Direct supervisor or line management • Human Resources department • Internal compliance and ethics hotlines • Employee representatives and works councils • Anonymous tip systems • External ombudsman services where available

Whistleblower Protection

Danica has implemented protection of whistleblowers through: • Clear policies prohibiting retaliation against employees who report concerns • Confidentiality protections for those making reports • Independent investigation processes • Support and counseling services for affected employees • Regular monitoring to ensure no retaliatory actions occur

Investigation Processes

When concerns are raised, Danica follows structured investigation procedures: • Prompt and fair investigation of all reported issues • Independence of investigation teams from implicated parties • Documentation of investigation processes and outcomes • Regular communication with reporting parties about progress • Implementation of appropriate corrective actions

Remediation Measures

Danica implements various remediation measures when negative impacts are identified: • Direct compensation for financial losses • Policy changes to prevent recurrence • Additional training and awareness programs • Disciplinary actions against responsible parties • Workplace environment improvements • Career development support for affected employees

Prevention and Continuous Improvement

Danica focuses on preventing negative impacts through: • Regular risk assessments of workplace conditions • Proactive policy updates based on emerging issues • Training programs for managers and employees • Monitoring of industry best practices • Integration of lessons learned into standard procedures

Monitoring and Effectiveness

The effectiveness of these processes is monitored through: • Regular tracking of complaint volumes and resolution times • Employee feedback on the accessibility and fairness of processes • Third-party assessments of grievance mechanisms • Benchmarking against industry standards • Continuous improvement based on stakeholder feedback

These comprehensive processes ensure that employees have accessible, fair, and effective means to raise concerns and that Danica can promptly address and remediate any negative impacts on its workforce.

Characteristics of the undertaking's employees

Total headcount and FTE

2024:

• Total number of employees (head count): 984
• All employees are in Denmark
• Average number of full-time-equivalent employees during the year: 917
• Number of full-time-equivalent employees, end of year: 940

2023:

• Average number of full-time-equivalent employees during the year: 902
• Number of full-time-equivalent employees, end of year: 912

Headcount by gender

Headcount by country/region

All Danica employees are located in Denmark.

Headcount by employment contract type and gender

Note: Temporary employees are defined as employees on a fixed-term employment contract.

Headcount by employment type (full-time/part-time) and gender

Employee turnover

2024:

• Number of employees who left Danica: 36
• Employee turnover rate: 3.87%

Methodology: Employee turnover is calculated as the number of permanent employees leaving the undertaking over the 12-month reporting period, divided by the average number of permanent employees (head count) over the same period.

Historical comparison (2022-2024)

Note: Number of employees is based on head count, and historical figures comprise employees in Denmark only.

New hires

No specific data on new hires (number or rate) is disclosed in the excerpts provided.

Health and safety metrics

Work-related injuries and fatalities

Coverage and scope

All employees are covered by working environment regulations and legislation. As a result of the business model, Danica's employees are not widely exposed to dangerous situations or situations that typically lead to employment injuries. In 2024, Danica recorded one employment injury. Employment injuries are reported in the EASY system at virk.dk.

Danica is prohibited from registering work-related ill health pursuant to the GDPR. Accordingly, no statistics are available on this.

Methodology

Employment injuries are calculated as the number of injuries divided by the number of hours worked by Danica's own workforce and multiplied by 1,000,000. Hours worked by Danica's own workforce are stated as the employees' standard hours of work.

Compensation metrics (ESRS S1-16)

Pay gap

Danica strives to ensure equal pay. A Danica employee's remuneration is determined on the basis of factors such as the person's role, position, experience, seniority, education, responsibility, job complexity, local market situation, department performance, what business unit the person is employed in, and individual performance. Danica has the following measures in place to ensure equal pay regardless of gender, ethnicity, etc.

Danica has a pay gap, with men being paid 26.2% more than women on average. This is a deterioration compared with a gender pay gap of 25.9% in 2023.

Data has been collected for all Danica employees broken down by gender. Men are generally employed in higher-paid job functions at Danica compared with the job functions women are employed in. As all Danica employees are employed in Denmark, there are no geographical or collective agreement factors that may affect pay formation.

Danica does not currently have a specific pay gap target, other than that Danica always strives to remunerate its employees according to experience and skills in order to minimise the pay gap as much as possible. Preparation is underway for the implementation of new guidelines in relation to the EU Pay Transparency Programme 2025/26.

Remuneration ratio

Remuneration reflects the ratio between the remuneration of the highest-paid individual and the median remuneration for Danica employees. This ratio was 11.1 in 2024.

Methodology

Pay gap: The gender pay gap is calculated as the ratio of the average gross hourly pay level of permanent male employees less the average gross hourly pay level of permanent female employees to the average gross hourly pay level of permanent male employees. The gross hourly pay level comprises base pay, bonuses and individual allowances (S1-16).

Remuneration ratio: The annual total remuneration ratio is calculated as the ratio of annual total remuneration of the highest paid person to the median annual total remuneration of all employees (S1-16).

Adequate wages

Benchmark used

Danica does not disclose the use of a living wage benchmark. The company relies on:

• Collective agreements covering the majority of employees for a period of two to three years (concluded with Forsikringsforbundet for most employees, and Assurandørforeningen for sales staff and insurance agents)
• Industry-specific minimum wage (or higher) for employees not covered by collective agreements (excluding employees on individual contracts), particularly those with weekly working hours of less than eight hours or in temporary employment not exceeding one month

Coverage

The disclosure states that "the majority of employees are covered by collective agreements." Those not covered are mainly management employees with individual contracts, especially top management team members who often have additional individual bonus agreements.

For employees not covered by collective agreements, Danica states it "ensures adequate pay" through industry-specific minimum wage or higher hourly rates.

Methodology

No living wage calculation methodology is disclosed. The company describes its pay determination approach based on factors including:

• Role, position, experience, seniority, education
• Responsibility and job complexity
• Local market situation
• Department performance and business unit
• Individual performance

The company notes that "for most employees, the total remuneration package of salary and pension does not include pension contributions paid by the employees themselves."

Geographic scope

All employees are located in Denmark (referenced in the pay gap disclosure: "As all Danica employees are employed in Denmark, there are no geographical or collective agreement factors that may affect pay formation").

Targets and commitments

No forward-looking targets or commitments related to adequate wages or living wage implementation are disclosed.

Taking action on material impacts on own workforce

Danica has numerous measures in place to reinforce a good corporate culture and a responsible workplace that addresses opportunities and risks related to Danica's employees.

Effectiveness indicators:

• Employee satisfaction with working at Danica: 80 out of 100 (half-yearly survey, second half of 2024)
• Employee satisfaction with workload: 79 out of 100 (same survey)
• Employee satisfaction with flexible workplace: 86 out of 100 (same survey)
• Note: Employees expressed dissatisfaction with working environment at previous Lyngby location; satisfaction expected to improve following move to new Postbyen location in Copenhagen

Actions implemented

Danica offers measures covering the following areas:

Offers for employees with children

• Maternity leave for both mothers and co-parents
• Option to work reduced hours while maintaining pension contributions
• These options exceed EU requirements in the area

Offer of help with stress management

• Employees can contact Danica Health Insurance if they need help to manage stress
• Opportunity to participate in networks for employees affected by stress, in complete confidentiality, in groups of eight to ten employees
• Guidelines for managers on how best to handle employees who are absent due to stress

Offer of addiction treatment

• As part of Danske Bank, Danica offers treatment for alcohol, drug and/or medicine and gambling addictions
• Treatment is confidential
• Managers can contact HR Legal's specialists who will guide the process
• Guidelines for managers in this area

Volunteering opportunities

• Employees have the opportunity to spend three paid workdays doing volunteer work for the benefit of society
• Examples of volunteer work in 2024: Pride, Ren Natur, World Cleanup Day, and the Child Accident Prevention Foundation

Offer of a flexible workplace

• Employees work from home and from the office on agreed days
• Danica encourages employees to be present at the office at least three to four days a week to reinforce corporate culture

Optimisation of physical working environment

• As part of Danske Bank, Danica has a Working Environment Management System (WEMS) to manage the working environment
• WEMS ensures transparency and documentation of progress
• WEMS provides overview of action plans on working environment and safety as well as documentation of actions and progress on a healthy working environment
• Health and safety representatives regularly receive overviews to keep track of working environment developments
• Individual managers responsible for ensuring optimal working environment
• Managers can contact health and safety group, which may escalate matters in WEMS if issues cannot be readily resolved

Narrowing of gender pay gap

• The Danske Bank Group, including Danica, constantly strives to promote equality within the Group with respect to employment, career development, promotions, equal pay, etc.
• With a view to closing the gender pay gap, Danske Bank [text cut off in excerpt]

Targets related to own workforce

Danica has defined targets for the following topics:

Employee satisfaction

Target metric: Overall employee engagement score based on employees' replies to questions about satisfaction and motivation

Target value: At least 80 out of 100

Target year: 2028

Baseline year: Not disclosed

Scope: Own workforce

Type: Absolute

Progress: Not disclosed for 2024

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eLearning completion

Target metric: Percentage of employees completing annual mandatory eLearning courses

Target value: 95%

Target year: Ongoing/annual

Baseline year: Not disclosed

Scope: Own workforce (all employees)

Type: Absolute

Progress (2024): 99.5% of employees completed their eLearning courses

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Gender distribution among managers

Target metric: Percentage of female managers

Target value: 45%

Target year: 2028

Baseline year: Not disclosed

Scope: Management level

Type: Absolute

Progress (2024): 52% of Danica's managers were female

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Gender distribution on Executive Board

Target metric: Percentage of female members on Executive Board

Target value: 40%

Target year: 2028

Baseline year: Not disclosed

Scope: Executive Board

Type: Absolute

Progress (2024): 25% of members of the Executive Board were female

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Gender distribution on Board of Directors

Target metric: Percentage of female members on Board of Directors (elected at annual general meeting)

Target value: 40%

Target year: 2028

Baseline year: Not disclosed

Scope: Board of Directors (members elected at AGM)

Type: Absolute

Progress (2024): 20% of board members elected at the annual general meeting were female

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Pay gap

Future targets: Danica does not currently have a specific pay gap target, other than that Danica always strives to remunerate its employees according to experience and skills in order to minimise the pay gap as much as possible. Preparation is underway for the implementation of new guidelines in relation to the EU Pay Transparency Programme 2025/26.

Persons with disabilities

Disclosure Requirement S1-12 (Persons with disabilities) is marked as Omitted in Danica Pension's sustainability statement.

No metrics, methodology, or other disclosures related to the percentage of employees with disabilities are provided.

Incidents, complaints and severe human rights impacts

Bullying and harassment

In the employee satisfaction survey, 99% of employees responded that they have not been bullied or harassed. This means that one per cent of employees have experienced bullying or harassment and stated so in the employee satisfaction survey. Although these are good statistics, Danica seeks to minimise all bullying and harassment, for example through the Code of Conduct. At present, the Danica's formal processes are not designed to capture ESRS-required metrics pertaining to S1-17.

Danica pursues a management culture where employees who experience bullying can go to their manager. Employees complete mandatory eLearning courses on e.g. the Code of Conduct, which covers how to treat each other properly. The eLearning course describes good behaviour and how to take any issues further.

Reporting principles

The number of incidents of discrimination

The number of incidents of discrimination include substantiated incidents within the Group's own workforce related to discrimination, bullying, sexual harassment and other types of harassment that can occur at the workplace. Cases are reported to the HR department through leaders, union or employee representatives or through the Whistleblower hotline. At present, the Danica's formal processes are not designed to capture ESRS-required metrics pertaining to S1-17.

Characteristics of non-employees in the undertaking's own workforce

Not disclosed.

Danica has opted to omit ESRS S1-7 (Characteristics of non-employee workers in own workforce) as indicated in the index table on page 7/156 and explicitly confirmed on page 49/156 where the company states: "Danica has either found the following disclosure requirements not material in the double materiality assessment or has opted to omit them in this statement: Disclosure Requirement S1-7 Characteristics of non-employee workers in own workforce."

Collective bargaining coverage and social dialogue

Coverage of collective agreements and social dialogue

As Danica only has employees in Denmark, it is not considered relevant to break this down by country and region.

81% of Danica's employees are covered by collective agreements and social dialogue.

Methodology note: All employees are generally entitled to a union representative through their membership of a trade union. All members of a professional organisation (Forsikringsforbundet i Danica or Assurandørforeningen i Danica) have direct access to advice and guidance from a union representative.

The percentage regarding social dialogue is calculated as the share of employees covered by collective agreements, as Danica does not have access to information about whether employees are members of a trade union, trade union membership information being specially protected data under the GDPR.

European Works Council

Danica is part of Danske Bank's work on the European Working Council. Additional information is available on Danske Bank's website: Employee well-being and diversity | Danske Bank.

Collective agreements structure

The majority of employees are covered by collective agreements. Those not covered are mainly management employees, as they have individual contracts. This is especially true for members of the top management team, which often have additional individual bonus agreements.

At Danica, collective agreements are typically concluded for a period of two to three years for employees with Forsikringsforbundet.

Employees who are not covered by a collective agreement (excluding employees on individual contracts), i.e. employees with weekly working hours of less than eight hours or in temporary employment not exceeding one month, are usually paid on an hourly basis according to an industry-specific minimum wage (or higher).

Diversity metrics

Number of employees by gender and age

Danica had 984 employees in 2024: 506 women, 478 men and 0 other and not reported.

Employee composition by gender and contract type

Note: Temporary employees are defined as employees on a fixed-term employment contract.

Number of employees by age

Gender distribution at top management level

Danica's top management is the Executive Board. The top management in 2024 consisted of three male members in the positions of CEO, CFO and COO and one female member in the position of CCO.

Multi-year diversity metrics

****Number of employees is based on head count, and historical figures comprise employees in Denmark only.

*****Includes board members elected at the annual general meeting.

Gender diversity targets

Danica has defined a target of having 45% female managers by 2028. In 2024, 52% of Danica's managers were female. On the Executive Board, the target is 40% by 2028, whereas in 2024, 25% of members of the Executive Board were female. Finally, the goal is for the Board of Directors to have 40% female members by 2028, whereas 20% of board members elected at the annual general meeting were female in 2024.

Reporting principles

Datapoints regarding employee characteristics are disclosed by number of employees at the end of the 2024 reporting period. Under characteristics of the undertaking's employees, the number of employees is stated as the head count at the end of the reporting period.

Policies related to consumers and end-users

Danica focuses on social inclusion by being particularly mindful of avoiding discrimination and treating all customers equally. This is reflected in the way Danica conducts its business through advisory and other services, making digital solutions available to customers. In addition, Danica promotes a healthier society by focusing on prevention and healthcare solutions.

The policies below apply to all customers. Danica complies with minimum disclosure requirements for policies (MDR-P) by reviewing all policies and, using a risk-based approach, controlling the effectiveness of the policies and their implementation in the business, including preparing gap analyses to support compliance with legislation. The policies support various international initiatives and standards (see the list in the ESRS 2 section Statement on due diligence).

Code of Conduct

Key content:

• Danica strives to do its best for its customers and meet their needs
• Committed to respecting human rights
• Ensures equal opportunities and equal treatment for all customers
• Does not accept any form of discrimination, disrespectful behaviour, bullying or harassment of customers, business partners or other persons associated with Danica
• Does not accept human trafficking, child labour or any form of forced labour
• States that Danica must treat customers fairly and safeguard customers' interests

Scope: All customers

Monitoring:

• Mandatory for Danica employees to complete eLearning courses related to the Code of Conduct, which includes human rights

Treating Customers Fairly

Key content:

• Objective is to support Danica in complying with applicable laws and regulations while providing appropriate consumer and investor protection
• Addresses the importance of ensuring non-discriminatory practices in the Group's engagements with customers
• Promotes equality and non-discriminatory behaviour
• Part of the Group's focus on respecting people and workforce rights as stated in the Group's Code of Conduct

Scope: All customers

The IDD and conduct of business

Key content: Policy addressing conduct of business requirements (no further details disclosed)

Risk management and the prudent person principle

Key content: Policy on risk management and the prudent person principle (no further details disclosed)

Development of new products and monitoring of existing ones

Key content: Policy on development of new products and monitoring of existing ones (no further details disclosed)

Policy on Insurance

Key content: Policy on Insurance (no further details disclosed)

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Additional policy implementation details:

Particularly vulnerable customers: A vulnerable customer may be a customer whose personal situation, for instance due to illness, implies a heightened risk of having a negative impact due to the way Danica develops and distributes its products. Danica therefore strives to sell products and services that meet its customers' needs and are suitable to the customers' requirements and characteristics.

Advisory services and contact with customers: Danica is in regular contact with customers through various channels, including in-person or online customer meetings with customer advisers, via self-service solutions or by telephone. Danica provides clear recommendations for customers on their pension schemes. The CCO business unit has the operational responsibility for organising the customer-facing advisory services.

Complaints process: Customers may express any dissatisfaction by contacting Danica by phone, by filing a complaint via Danica's website or by using the whistleblowing system. Customers can also give feedback after a customer consultation and give it a score (Net Promoter Score - NPS), for which a target has been set and sales managers follow up on progress.

Taking action on material impacts on consumers

Danica has taken a number of actions to address material potential impacts on customers, manage material risks and pursue material opportunities and ensure the effectiveness of these measures. The following policies have been implemented to ensure that all customers are treated equally and with equal opportunities.

Actions and initiatives

Extended and improved self-service and digital advisory services

Danica has extended and improved its customers' self-service and digitally supported advisory services options, e.g. by making it easier to switch products and change investment profiles. Also, Danica's products and offerings have been incorporated in Danske Bank's platforms to give Danske Bank customers an even more comprehensive overview of their pension scheme, insurance and healthcare covers.

Effectiveness monitoring: Danica follows up on customer satisfaction on a monthly basis through a Net Promotor Score. The score is also presented to the Executive Board on a monthly basis.

Marketing/Treating Customers Fairly

Marketing communication, including financial promotions, must be clearly identifiable and must comply with applicable laws and regulations. Accordingly, Danica must make necessary and appropriate information available to customers. Such information may be necessary to adapt to the customers' circumstances and the type of information being communicated.

Data security guidelines

Danica adheres to the data security guidelines of Insurance and Pension Denmark (F&P), which is based on the three guidelines: Transparency, Personalisation and Prevention. Danica also takes a proactive approach to data ethics and actively collaborates with F&P in the efforts to systematise data ethics across F&P.

Changed health requirements without 30-day rule

Danica has relaxed its health requirements so that customers are no longer asked if they have been ill for 30 days within the past year and, if so, have their health assessed on this basis. Danica has implemented this change to ensure that more customers have insurance covers.

Exclusion clause regarding mental conditions

Danica has implemented an exclusion clause regarding mental conditions. This means that customers may get an exclusion clause regarding mental conditions but be fully covered for other illnesses and conditions such as cancers and musculoskeletal disorders. Before this provision was implemented, customers suffering from mental conditions were turned down and thus left without any cover. This solution benefits customers and Danica, as customers get improved cover, and Danica is able to offer more customers insurance covers.

Prevention services - family wellbeing

When Danica launches new prevention services, the focus is on family wellbeing, offering tips and advice to parents on how to spot signs of poor mental wellbeing in their children and how best to support them. Danica reports on this several times a year to the provider of these services, including on customers' use and assessment of the service.

Forebyggelsesalliancen (Prevention Alliance)

Danica and 25 other organisations have together launched a prevention alliance – Forebyggelsesalliancen – which in 2024 focused on setting a number of specific targets aiming to strengthen prevention towards 2035. The alliance has also compiled a full catalogue of ideas for delivering on the binding targets.

Partnership structure: 26 organisations in total

Time horizon: Targets set towards 2035

Effectiveness measurement

Net Promoter Score (NPS): The Net Promoter Score (NPS) calculates customer feedback and generates a score indicating customer satisfaction and loyalty based on an index ranging from 0 to 10. Customers are classified as detractors (0-6), passives (7-8) or promoters (9-10). The NPS is calculated as: percentage of promoters minus percentage of detractors = NPS.

Targets related to consumers

Danica's Executive Board has set the following targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities:

1. Financial security through advisory services

• Target metric: Number of persons and undertakings helped to achieve a healthier lifestyle
• Target value: Not quantified
• Target year: 2025
• Baseline year: 2019
• Baseline value: Not disclosed
• Scope: Danica customers
• Progress to date (2024): 400,081 persons and undertakings helped with treatment or financial compensation (including health insurance, cover for loss of earning capacity, cover for critical illness and the health package)

Note: Danica acknowledges that this target does not measure the effect of customers' use of Danica's products. This will be taken into consideration going forward. The company notes that a single customer may be counted multiple times in the figures over the period.

2. Net Promoter Score (NPS)

• Target metric: Net Promoter Score for employees of business customers
• Target value: 45 or above
• Target year: 2024
• Baseline year: Not disclosed
• Baseline value: Not disclosed
• Scope: Employees of business customers
• Progress to date (2024): Average score of 78

3. Healthier society

• Target metric: Not specified
• Target value: Not quantified
• Target year: Not disclosed
• Details: Focus on prevention and healthcare solutions, referenced as a strategic target but without specific quantified metrics

Incidents of corruption or bribery

Metrics disclosure

Danica Pension has disclosed the following metrics related to corruption or bribery for the reporting period (2024):

The company noted in the S1 (Own workforce) section that "At present, Danica's formal processes are not designed to capture ESRS-required metrics pertaining to S1-17."

Materiality statement

Under the UN Convention against Corruption indicator (SDG 10(b)), Danica referenced "Indicator no. 15 Table #3 of Annex 1" as disclosed in the Sustainability statement.

Under "Fines for violation of anti-corruption and anti-bribery laws" (indicator 24(a), Delegated Regulation (EU) 2020/1816, Annex II, Indicator no. 17 Table #3 of Annex 1), Danica stated: Not material.

Under "Standards of anti-corruption and anti-bribery" (indicator 24(b), Indicator no. 16 Table #3 of Annex 1), Danica stated: Not material.

Investigation and speak-up procedures

Danica has implemented a comprehensive whistleblowing system:

• Employees and stakeholders can report concerns via an independent, external website operated by a third party
• Reports can be made anonymously
• Whistleblowers are protected from all forms of retaliation under law and internal standards
• Reports are initially processed by Group Compliance at Danske Bank, with Danica-specific cases handled by Danica Compliance
• The Whistleblowing Policy complies with EU data protection requirements and financial supervisory authority requirements

Training and awareness

Danica has a target of 95% of employees completing annual mandatory eLearning courses. In 2024, 99.5% of employees completed their eLearning courses, which cover topics including bribery and corruption, money laundering, the Code of Conduct, and corporate culture.

Business conduct policies and corporate culture

Danica has established several policies related to business conduct and corporate culture, covering anti-corruption, ethical business practices, employee treatment, and supplier requirements.

Code of Conduct

Scope: All employees and business practices

Governance: The policy is reviewed and approved annually by the Board of Directors. Implementation is monitored through mandatory annual eLearning courses that all employees must complete.

Key content:

• Alignment of business practices with sound corporate culture and responsible behaviour
• Integration of ESG risk considerations into business practices and decision-making
• Zero tolerance to financial crime
• Ethical handling and protection of personal data to ensure privacy and security
• Promotion and respect for human and labour rights, including prevention of discrimination, harassment, forced labour and child labour
• Fair treatment of customers
• Promotion of respect, diversity and sound performance in the workplace
• Appropriate compensation structures that do not reward unethical behaviour
• Strong risk management

International standards: The Code of Conduct supports international human rights, including all human rights stated in the International Bill of Human Rights and the International Labour Organization's (ILO) Declaration on Fundamental Principles and Rights at Work. Zero tolerance for human trafficking, child labour, or forced labour.

Monitoring: Mandatory annual eLearning courses for all employees. In 2024, 99.5% of employees completed their eLearning courses, exceeding the target of 95%. Non-compliance may have serious consequences including fines, criminal liability, regulatory requirements, employment law consequences and reputational damage.

Supplier Code of Conduct

Scope: All suppliers and their sub-suppliers throughout the supply chain

Governance: Part of the Danske Bank Group Supplier Code of Conduct; integrated into individual supplier contracts

Key content:

• Basic environmental, social and ethical standards that suppliers must comply with
• Minimum requirements for suppliers to be considered for contracts
• ESG requirements, including climate and environmental aspects
• Respect for workers' rights and cultures
• Compliance with national laws and international labour and human rights standards
• Healthy and safe working environment
• Treatment of employees with dignity and respect; workplace free from harassment, abuse and violence
• ESG due diligence of existing and potential suppliers
• Environmental management systems for suppliers to record environmental impacts
• Specific environmental and climate requirements for specific products and services (e.g. hardware and office supplies)

International standards: Compliance with international standards established by the International Labour Organization (ILO)

Monitoring: Suppliers must cooperate with Danica on due diligence assessments, risk/impact assessments, inspections, monitoring, reporting, and audits. Danica reserves the right to terminate contracts if suppliers fail to comply with requirements by intention or repeated negligence, continually refuse to engage in due diligence activities, or lack commitment to make progress on identified issues. The Supplier Code of Conduct is an end-to-end supply chain initiative, with suppliers responsible for setting comparable standards for sub-suppliers.

Whistleblowing Policy

Scope: All employees and customers

Governance: Part of the DoRight framework; reports processed by the Whistleblowing Operations Team under Group Compliance at Danske Bank, or Group Internal Audit if the report concerns Group Compliance. Cases involving Danica are processed by Danica Compliance.

Key content:

• Independent and external reporting system allowing anonymous reports
• Protection from all forms of retaliation for whistleblowers under law and internal rules
• Confidential conversations available with the Whistleblowing Operations Team before deciding to report
• EU data protection requirements compliance
• Compliance with requirements of all relevant financial supervisory authorities

Public availability: Accessible through Danica's website for customers and employees

Monitoring: Mandatory annual eLearning courses for employees on the Code of Conduct Policy and how to share concerns, including the whistleblowing system. Non-compliance may result in disciplinary action.

Diversity and Inclusion Policy

Scope: All employees

Governance: Reviewed and updated annually, involving various internal specialist functions and stakeholders. Board of Directors approves the policy.

Key content:

• Improving diversity across all characteristics
• Ensuring equal opportunities for all employees
• Practicing an inclusive culture and mindset by nurturing a sense of belonging
• Zero tolerance to discrimination, harassment or offensive workplace behaviour
• Compliance with Danish Financial Business Act and Danish Companies Act requirements relating to diversity in qualifications and skills

Monitoring: The policy is reviewed annually. Danica has set targets for gender diversity: 40% female members of the Executive Board by 2028 (25% in 2024) and 40% female Board of Directors members by 2028 (20% in 2024).

Human Rights Policy

Scope: All employees, customers, business partners and persons connected to the Group

Governance: Part of the Danske Bank Group framework

Key content:

• Commitment to respecting international human rights, including labour rights
• All human rights as stated in the International Bill of Human Rights
• ILO Declaration on Fundamental Principles and Rights at Work
• No discrimination, disrespectful behaviour, bullying or harassment
• No human trafficking, child labour or forced labour
• No discrimination based on: gender, marital status, sexual orientation, age, disability/health status, race, colour, nationality, social/ethnic origin, religion/belief, pregnancy/leave, part-time/temporary employment, union membership, employee representation, or whistleblowing

Public availability: Latest Human Rights Report available at danskebank.com

Monitoring: Mandatory eLearning courses related to the Code of Conduct, which includes human rights

DoRight Framework

Scope: All business conduct, products and services

Governance: DoRight Committee composed of members from top management, HR and employee representatives. Executive Board is represented on the Committee.

Key content:

• Portal collecting information about processes for addressing and escalating internal and external concerns
• Committee identifies and addresses issues related to products and service concepts
• Oversees handling of matters where past practices may conflict with legislation or where issues are inadequately disclosed to customers
• Liaises with various risk functions

Example of implementation: In 2023, the DoRight Committee discussed and managed an error regarding gradual reduction of risk on pension schemes of 6,000 customers.

Other relevant policies and business procedures

Business travel policy: Defines employee guidelines on choosing optimum mode of travel from a climate perspective

Company car policy: Only electric company cars offered going forward; manufacturers must endeavour to operate in accordance with international human rights, climate and environmental protection and anti-corruption guidelines

Collaboration agreement on working environment: Joint agreement between Danske Bank Group and trade unions; managers responsible for ensuring good physical and mental working environment; stipulates dialogue on workplace assessments (WPA) and formulation of action plans

Collective agreement for Danica employees: Negotiated with Forsikringsforbundet, covering rules on pay and working conditions; typically renegotiated every three years; available on Danica's intranet

Monitoring of corporate culture

Employee satisfaction surveys: Half-yearly surveys conducted giving employees opportunity to express views on employment conditions, job satisfaction, leadership, collaboration, diversity and inclusion. Results reviewed by individual department managers. In 2024, employees gave overall commitment a score of 80 out of 100, meeting the target.

Health and safety committees and groups: Meet quarterly to ensure collaboration on working environment; strengthen preventive health and safety measures

Joint consultation committee: Discusses major organisational initiatives; exchanges views on working conditions, wellbeing, stress management, finances, employment situation, outsourcing, new technology and employee skills development. Minutes available to all employees on the intranet.

Target: At least 80 out of 100 employee commitment score in 2024 and towards 2028 (achieved: 80 out of 100 in 2024). At least 95% of employees to complete annual mandatory eLearning courses (achieved: 99.5% in 2024).