DFDS A/S

The role of the administrative, management and supervisory bodies

Reference: pages 45, 48.

DFDS' governing bodies are the Annual General Meeting, the Board of Directors and its committees (Audit Committee, Remuneration Committee, Nomination Committee), and the executive management bodies (Executive Board and Executive Management Team, EMT).

Board composition (page 45): six shareholder-elected directors plus three employee-elected directors. In 2025 three of the six shareholder-elected directors were assessed independent; three of nine directors are women and two have non-Danish nationality.

Sustainability allocation of responsibility (page 48): "The Board of Directors approve the ESG strategy as part of the group strategy and is actively involved in approving long-term targets." The Audit Committee "includes responsibility for sustainability reporting" in its charter; the Remuneration Committee "oversees the Executive Board's ESG-related incentives." The EMT "has ownership of the ESG agenda." The Board is updated on strategic ESG topics and progress at least twice a year, including approval of the annual DMA review, and the material IRO list (pages 72-74) "has been reviewed and approved by the EMT and the Board of Directors."

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

Reference: page 48.

The Board reviews strategic ESG topics and progress "at least twice a year, including the approval of the annual DMA (Double Materiality Assessment) review." The Board's rules of procedure specify compliance and risk management among its tasks, and the Audit Committee charter includes responsibility for sustainability reporting.

The EMT and the Board "meet regularly with in-house experts including the VP of Decarbonisation, the Director of Sustainability, and the Head of CSRD Reporting, which enables them to assess the level of expertise in these functions." As part of its strategy review, the Board "reviewed DFDS' climate strategy as well as the climate plans for the Ferry Division and Logistics Division providing for the deployment of increasingly emission-friendly propulsion technologies." Key sustainability expertise identified as relevant includes decarbonisation, health & safety, own-workforce matters, responsible procurement, biodiversity and sustainability reporting.

Integration of sustainability-related performance in incentive schemes

Reference: page 52.

"DFDS integrates sustainability-related performance into the STI scheme for the Executive Board through an ESG performance basket representing 20% of total STI weighting." The ESG basket combines three indicators: CO2 emissions reduction, female representation, and safety performance measured by Lost Time Injury Frequency (LTIF).

"Each ESG indicator has a high-level internal performance goal that guides assessment; the Remuneration Committee may apply discretion in the final payout determination." Remuneration overall is aligned with DFDS' Remuneration Policy and Section 139b of the Danish Companies Act, and includes short-term incentives (STI) based on annual performance and long-term incentives (LTI) for sustained value creation.

Statement on due diligence

Reference: page 75 (core-elements table), cross-referencing pages 48, 52, 66-74, 82, 91, 93-94, 101, 104, 109-114.

DFDS maps the UNGP/OECD core elements of due diligence to sections of the statement (page 75):

Due diligence is guided by the UN Guiding Principles on Business and Human Rights and OECD Guidelines for Multinational Enterprises.

Risk management and internal controls over sustainability reporting

Reference: page 75.

"To effectively mitigate risks and ensure robust controls in sustainability reporting in compliance with the Corporate Sustainability Reporting Directive (CSRD), DFDS has a dedicated CSRD Reporting Team within the Group Finance department."

Three key risks and mitigations are named: (1) Data completeness and quality - controls implemented by the CSRD Reporting Team, strengthened through training and data-owner engagement; (2) Discrepancies between land and sea data - tailored data-collection methodologies specific to each; (3) Manual reporting processes - an integrated sustainability reporting software was introduced in 2025 as part of a phased implementation, though "certain manual processes will persist in the medium term." The acquired Türkiye & Europe South (TES) unit is being integrated into health & safety, compliance and environmental data processes and is excluded from selected metrics during the transition. The Audit Committee and Board oversee sustainability-reporting risks and receive regular updates.

Strategy, business model and value chain

Reference: page 65.

"DFDS operates an integrated transport and logistics model combining ferry, road and rail transport with logistics services such as warehousing, packaging and cross-docking." Operations span pre-carriage to port, port handling, sea voyage and onward transport.

Value chain (page 65): upstream covers inbound transport and sourcing of fuel, vessels, equipment, port and terminal services, with primary emphasis on first-tier suppliers; downstream covers outbound transport, waste handling and recycling. Deeper-tier resource extraction, vessel/truck manufacturing and end-of-life activities were screened and excluded due to "limited leverage and risk proximity being significantly lower than first-tier upstream activities."

2025 key figures: total revenue DKK 30,947m (Ferry Division DKK 15,294m; Logistics Division DKK 15,618m); total headcount 16,471, largest by UK (3,810), Türkiye (2,998), Denmark (2,012).

Interests and views of stakeholders

Reference: page 66.

DFDS identifies key stakeholder groups and engagement channels in a table (page 66): customers (account management, day-to-day interaction, to understand demand for green transport); employees (development activities, surveys); investors and ESG analysts (AGM, interim reporting); regulators (consultation on regulatory matters); NGOs (ad hoc meetings); ESG rating agencies (annual reporting); and peers and market (network activities, desk research).

"The interests and views of all our stakeholders provide key inputs in our strategy processes, which in turn impacts our business model." The Executive Management Team takes an active role in stakeholder engagement and the Board is informed about stakeholder views as part of general strategy and risk-management processes.

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

Reference: pages 71-75 (materiality matrix and IRO overview).

The 2025 DMA places E1, S1, S2 and G1 as double material (both financially and impact material); E2 and E4 as impact material; and E3, E5, S3 and S4 as non-material.

Changes versus 2024 (page 71): water pollution was added as a material IRO alongside air pollution, "reflecting growing stakeholder concern and regulatory focus on marine discharges and port-related water contamination." S1-8 (collective bargaining) and S1-10 (adequate wages) "were reported in 2024 though they were not linked to an IRO... the disclosures have been discontinued." Passengers "are no longer considered material end-users," primarily due to the Strait of Gibraltar route adjustment and the sale of the Copenhagen-Oslo route; remaining passenger activity does not present material S4 impacts or risks.

The full per-topic IRO tables with location, time horizon and operation (Ferry/Logistics) tagging are on pages 72-75.

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

Reference: pages 67-70.

The DMA follows four steps: (1) preparation and scoping - reviewing the business model, value chain, boundaries and thresholds; (2) mapping impacts, risks and opportunities via workshops and stakeholder/expert engagement; (3) assessing materiality using scale, scope, irremediability and likelihood, with severity taking precedence for human-rights topics; (4) validation and reporting.

Deeper-tier stages (resource extraction, vessel/truck/equipment manufacturing, end-user use, end-of-life activities) "were assessed as not material at our point of influence due to low leverage, indirect linkage, lower relative severity and insufficient data quality for assured reporting," and remain under monitoring.

Climate scenario analysis and resilience (pages 68-70) are addressed within IRO-1 as dedicated sub-sections rather than as separate ESRS 2023 disclosure requirements; see E1-2-ScenarioAnalysis and E1-3-Resilience below for the back-filled content and provenance.

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

Reference: pages 77-78 (IRO-2 Index of material disclosures and incorporation by reference).

DFDS publishes a two-page ESRS content index listing, for each covered disclosure requirement, the section (Management Review "MR" or Sustainability Statement "SS"), any incorporation by reference, and the page number. It covers ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2) and the material topical standards E1, E2, E4, S1, S2 and G1.

E3, E5, S3 and S4 do not appear in the index at all, consistent with the materiality matrix marking them non-material (page 71). Some 2023-ESRS codes that exist in the standard (E1-7, E1-8, E1-9, E2-5, E2-6, E4-1, E4-5, E4-6, S1-7, S1-8, S1-10 to S1-13, S1-15, S1-16, S1-17, S2-3, G1-5) are likewise absent from the index; see the individual disclosure entries below for the company's own explanation of each (phase-in, not-linked-to-an-IRO, or the ESRS 1 paragraph 17 summarised-disclosure relief for E4 and S2).

Transition plan for climate change mitigation

Reference: pages 81-83, 60.

The transition plan, "Moving to Green," has three pillars: decarbonisation at sea, decarbonisation on land, and "getting our house in order," all supporting net zero by 2050. Core techniques follow a hierarchy: efficiency, electrification, alternative fuels and, for residual emissions, "last-resort" carbon capture or offsetting.

In October 2025 DFDS "committed to set both near-term and net-zero targets via the Science Based Targets initiative (SBTi)," due by October 2027; existing targets stand in the meantime. "Our pathway to 2050 includes 1.5°C and well below 2°C strategies. However, we do not currently have targets or a transition plan which is explicitly aligned with limiting to 1.5°C," though DFDS is "not currently excluded from the EU Paris-aligned benchmarks."

Investments: the investment needs for vessel decarbonisation "are currently under review... Revised estimates will be disclosed once the review is finalised" - no capex figure is committed for 2025. Locked-in emissions are concentrated in vessels (indicative 35-year lifetime); land-asset locked-in emissions are assessed as low. A Decarbonisation Board (CEO plus key stakeholders) prioritises investment via a standardised KPI framework.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report as dedicated "E1 Climate risk scenario analysis" and "E1 Resilience analysis" sub-sections (pages 68-70). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

DFDS applied two IPCC scenarios: SSP2-4.5 (moderate-emissions trajectory, used to assess physical hazard exposure - storms, heat stress, sea-level rise) and SSP1-2.6 (a below-2°C, closer-to-1.5°C pathway, used to assess transition risks from stricter emissions regulation, fossil-fuel phase-out and low-carbon technology adoption). Neither is a high-emission scenario (e.g. SSP5-8.5/RCP8.5) - the physical-risk scenario used is moderate, not high-emission, a gap worth flagging against the ESRS ¶17(a)(i) expectation.

Physical and transition risks are tabulated by short/medium/long-term horizon and by Ferry/Logistics operation (page 69-70), covering chronic hazards (air-temperature change, sea-level rise, heat stress), acute hazards (storms and flash weather), and transition risks (technology, policy & legal, market & reputation, financial, energy demand). No explicit temperature-projection rationale per scenario or date of analysis is given.

Resilience in relation to climate change

Back-filled from ESRS 2 IRO-1's "E1 Resilience analysis" sub-section (page 68). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"Our strategy and business model are designed to adapt to climate change over the short-, medium-, and long-term, due to our inherent operational flexibility and ongoing risk management... Our network's flexibility, through adjustable shipping routes, modal shifts, and operational optimisation based on evolving conditions, enables us to effectively address anticipated challenges while maintaining resilience and continuity for our customers."

"Our resilience analysis in 2025 demonstrated progress towards our targets. Our vessels represent the largest area of uncertainty, particularly regarding the technological developments and investments needed for the green transition." Based on residual risk after mitigation, "the risk severity assessment has returned low to medium scores for the sustainability-related risk items in the ERM process," which DFDS reads as reflecting "a high resilience of the business overall."

Policies related to climate change mitigation and adaptation

Reference: page 82.

"DFDS has a Climate Policy supporting our commitment to net-zero emissions by 2050. It addresses climate change mitigation, climate change adaptation, energy efficiency, and renewable energy deployment."

The policy "reflects our support of the UN Global Compact's environmental principles." It is cross-referenced from E2 (pollution) and E4 (biodiversity) as the common framework pending more topic-specific policy development.

Actions and resources in relation to climate change policies

Reference: pages 84-87.

"In 2025, DFDS advanced its decarbonisation strategy through targeted actions across key levers": energy efficiency (Every Minute Counts schedule optimisation and slow steaming programme), renewable electricity procurement, electrification of assets and charging/port-electrification infrastructure, and expanded use of transition fuels (biofuels, HVO).

Vessels: shore power conversion continuing at an average of five vessels per year to 2030; a battery-electric vessel project on Dover-Calais and Dover-Dunkerque continues in collaboration with the three ports; ammonia vessels have been dropped from the 2030 plan due to limited technology maturity and fuel availability.

Road: e-truck fleet expansion across multiple European markets; HVO as a near-term drop-in fuel; reduced role for hydrogen in the 2030 pathway versus last year.

Terminals: a 2025 HVO trial achieved 4 kg CO2e/unit against a 12 kg CO2e/unit (restated) baseline, "well below" the interim trajectory, described as a "temporary testing phase."

Targets related to climate change mitigation and adaptation

Reference: page 83.

Net-zero by 2050 across all scopes, with "no more than 10% of our total emissions... reduced by indirect means, such as offsetting." Three 2030 intensity pathway targets, each with a distinct baseline year:

Target coverage: an estimated 89% of Scope 1 and 71% of total 2025 emissions. Targets follow a range between 1.5°C and well-below-2°C pathways and do not rely on GHG removals, carbon credits or avoided emissions. The Decarbonisation and Energy Security Team leads target-setting; the Decarbonisation Board, EMT and Board of Directors review and approve.

Energy consumption and mix

Reference: page 88.

All DFDS activities are classified as high climate impact sectors under NACE Section H (freight rail, road freight, sea passenger and freight water transport, warehousing). Renewable energy is recognised on a market-based approach using Renewable Energy Certificates/Guarantees of Origin. The renewable share more than doubled year on year, driven by increased biofuel use and on-site solar generation.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: page 89.

Scope 3 is reported for categories 1 (purchased goods/services), 2 (capital goods), 3 (fuel/energy-related), 4 (upstream transportation/distribution), 6 (business travel) and 8 (upstream leased assets, new in 2025); categories 5, 7, 9-15 are excluded as "not applicable or significant." Own-fleet GHG intensity fell to 13.98 gCO2e/GT-mile (from 14.40, restated). Several prior-year figures were restated for emission-factor updates (TTW to WTW) and category-3 methodology changes; see BP-2, page 76.

Policies related to pollution

Reference: page 91.

DFDS has no pollution-specific policy: "we consider our current Climate Policy to provide a common framework for addressing pollution impacts, while acknowledging the need for further policy development to more explicitly address pollution-specific risks." The IRO table (page 91) records "Climate Policy (reducing GHG, no specific policy for pollutants)" against both the pollution-of-air and pollution-of-water IROs.

The rationale given is that CO2e-reduction actions - "enhancing fuel efficiency, and optimising operations" - simultaneously reduce non-GHG pollutant releases, so DFDS "consider[s] our current Climate Policy" sufficient for now while planning further pollution-specific policy work.

Actions and resources related to pollution

Reference: page 91.

Air pollution actions: use of exhaust-gas scrubbers on the majority of the vessel fleet to reduce sulphur oxide (SOx) emissions, compliance with SECA (Sulphur Emission Control Area) requirements, and Euro IV/V-and-above truck emission standards.

Water pollution actions: "emissions from scrubber wash water are managed under international conventions, specifically MARPOL and the IMO Ballast Water Management Convention. Compliance is ensured through on-board treatment and monitoring systems installed on vessels."

"DFDS does not measure or track pollutants emitted to water beyond regulatory compliance," and "data availability for reporting remains limited... DFDS is assessing options to improve systematic data collection... We are not in a position to provide a timeline for when full reporting on pollution metrics will be implemented."

Targets related to pollution

Reference: page 91.

"DFDS has not set measurable outcome-oriented targets related to pollution. We will continue to monitor the effectiveness of decarbonisation as a driver for pollution reduction."

The IRO table (page 91) records the tracking mechanism as "GHG emissions tracking," on the basis that "reducing GHG emissions will lower pollutants" - i.e. pollution reduction is tracked only indirectly, through the E1 climate targets, rather than via a dedicated pollution target or KPI.

Pollution of air, water and soil

Reference: pages 91-92.

Split by land and sea (page 92), with the sea leg dominating each pollutant (e.g. 51,468.0 of 53,359.7 tonnes NOx). "Air pollutant emissions in 2025 decreased in line with the overall reduction in fuel consumption" reflecting the same operational drivers as GHG emissions - lower sailed distance, route adjustments, and increased biofuel/renewable-electricity use. Methodology follows the Climate & Clean Air Coalition Black Carbon Methodology for the Logistics Sector.

Policies related to biodiversity and ecosystems

Reference: page 93.

"DFDS' Biodiversity Policy forms the foundation for our long-term work to reduce our environmental footprint and enhance biodiversity." Ambitions: minimise underwater noise and support marine life through innovation and vessel design; integrate biodiversity considerations into operational decision-making; and support research and conservation initiatives.

DFDS established a Biodiversity Strategy in 2024. Given the nature of operations, "the most material biodiversity impacts are associated with vessel activities at sea," so mitigation of underwater noise is prioritised over fixed-site impacts.

Actions and resources related to biodiversity and ecosystems

Reference: page 94.

Three named actions in 2025: (1) "Mapped all DFDS terminals against Natura 2000 areas to identify proximity to biodiversity-sensitive locations... Five of our terminals under operational control are located within a 5 km radius of such sites"; (2) "Adjusted shipping routes and reduced sailing speed in selected Mediterranean areas to protect endangered marine species, including sperm whales"; (3) "Monitored marine wildlife in partnership with ORCA on selected routes, including Amsterdam-Newcastle, to increase insight into species presence and behaviour."

DFDS states its current focus is "monitoring marine ecosystems, strengthening knowledge through partnerships, and reducing pressures on biodiversity where direct impacts from our operations are identified."

Targets related to biodiversity and ecosystems

Reference: page 94.

"DFDS has not set measurable outcome-oriented targets related to biodiversity."

The IRO overview (page 73) instead records qualitative ambitions against the two named biodiversity IROs: "Ambition to minimise impact on marine life" for GHG-driven ecosystem effects, and "Ambition to minimise underwater noise impact" for vessel underwater noise, with no dedicated tracking metric shown ("-") for either.

Policies related to own workforce

Reference: page 101, policy table page 103.

Named policies: Code of Conduct (CoC, linked to the UN Global Compact's ten principles); Labour Code of Conduct (LCoC, "minimum standard for critical working conditions"); Human Rights Policy (aligned to the UN Guiding Principles on Business and Human Rights and OECD Guidelines); Diversity, Equity & Inclusion (DEI) Policy; Health & Safety Policy (targets "zero accidents, no harm to people"); and the Whistleblower Policy governing the Compliance Line.

"We perform human rights impact assessments (HRIA), which is performed as part of the double materiality assessment, and serves as the foundation for our continued work with human rights." Coordination of human-rights efforts sits with the Director of Sustainability. DFDS also maintains a UK Modern Slavery Act statement, published annually.

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

Reference: page 102.

Primary channels: an annual engagement survey (MyVoice, covering Engagement, Diversity & Inclusion, and Health & Wellbeing) and an annual performance-appraisal process for all employees, plus ongoing manager-employee interaction.

"In 2025, the survey achieved a response rate of 73%, with an aggregated engagement score of 7.5" (down from 80% response / 7.6 score in 2024). The decline "is likely impacted by the integration of the Türkiye & Europe South business unit," which increased the share of non-office employees who "often face practical challenges in participating in surveys." Employee/workforce representative involvement in the DMA itself is limited: "our own workforce or workforce representatives have not been directly involved" in DEI target-setting (page 106), though the material-IRO list was presented to workers for the 2024 DMA.

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

Reference: page 104.

"DFDS has established a formal channel for employees to anonymously report any concerns regarding breaches of acceptable behaviour... through a Whistleblower System, which is hosted by an independent third party." Employees may also raise concerns directly with local managers, HR, or an EMT member.

"DFDS strictly prohibits and does not tolerate any form of retaliation... against individuals who submit reports in good faith or participate in investigations." "The Board of Directors receives regular updates regarding reports and findings derived from the Whistleblower System." Trust in the mechanism is tracked annually through MyVoice questions specific to the whistleblower system.

Taking action on material impacts on own workforce

Reference: page 104.

DFDS applies "a structured due-diligence approach" including preventive policies, risk assessments, safe-work procedures, training and tracking, informed by the engagement survey, whistleblower system, H&S system reports and manager insight. Resources allocated include HR and H&S tracking systems, dedicated teams and targeted campaigns.

"Should tensions arise between preventing negative impacts and business pressures, DFDS prioritises employee well-being and compliance with our Code of Conduct." No numeric effectiveness metric is given at this general level; effectiveness is tracked through the topic-specific KPIs under S1-5/S1-9/S1-14 (diversity, health & safety, engagement).

Targets related to own workforce

Reference: page 104.

"DFDS has defined ambitions and targets to address key areas such as health and safety, diversity and inclusion, and employee engagement." The individual quantified targets sit under the relevant topic disclosures: a zero-accident ambition tracked via Lost-Time Injury Frequency (S1-14); gender-diversity targets of 30% for the underrepresented gender across management levels by 2030 (S1-9); and MyVoice-tracked engagement/work-life-balance indicators, for which "we have not set any measurable targets" but track "relevant indicators."

"None of the social metrics have been validated by an external body."

Characteristics of the undertaking's employees

Reference: page 107.

Largest countries by headcount: UK (3,810), Türkiye (2,998), Denmark (2,012), Poland (1,358), France (1,239). "The most representative number in the financial statement is the average FTEs, which amounts to 16,138." The turnover increase "is primarily driven by the restructuring of the Türkiye & Europe South business unit... and the continuation of a route in the Strait of Gibraltar" (page 107).

Diversity metrics

Reference: page 106.

Gender targets (% women, 2030 target 30% except Board 33% "achieved"): Board of Directors 33% (2025) vs 33% (2024, target achieved); Executive Management Team 29% vs 29%; Group Leadership Team 24% vs 23% (restated); All Managers 20% vs 19%; All employees 23% vs 22% (office 42%, non-office 13%).

Gender distribution in management (2025): EMT 2 women/5 men (29%); Group Leadership Team 11 women/35 men (24%); All managers 473 women/1,867 men/2 not declared (20%). Age distribution 2025: under 30 = 19%, 30-50 = 51%, above 50 = 30%. A women's cadet programme, "Waves of Talent," and the Danish Shipping Charter support attraction of women to maritime and logistics roles.

Health and safety metrics

Reference: page 105.

"DFDS maintains a zero-accident ambition as part of our safety culture. DFDS has not adopted a measurable, time-bound outcome-oriented target, as defining a non-zero incident target is considered inconsistent with this ambition." Effectiveness is tracked via Lost-Time Injury Frequency (LTIF).

"The year was also marked by two tragic fatalities - one involving a member of our workforce and one involving a third-party worker." Türkiye & Europe South (approximately 15% of headcount) is excluded from the LTIF metric for 2024-2025 pending methodology alignment. Some S1-14 datapoints (§88(d-e)) are subject to phase-in - see the BP-2 note under S1-7.

Policies related to value chain workers

Reference: page 109 (Summary, per ESRS 1 paragraph 17).

"In line with the Omnibus 'quick fix' amendments and ESRS 2 paragraph 17, DFDS applies the temporary exemption and provides a summarised disclosure for Workers in the value chain."

Key policy: the Supplier Code of Conduct (SCoC), which "sets the standard for our supply chain to operate in accordance with business principles... applies to first-tier suppliers, parent, subsidiary, or affiliate entities... including suppliers, subcontractors, joint venture partners, and other third parties." SCoC "incorporates the IMPA ACT fundamentals and is based on the UN Global Compact and Guiding Principles on Environment, Labour Practices, Business Ethics and Human Rights," alongside the UK Modern Slavery Act statement. Own-workforce Human Rights Policy commitments "encompass workers in our value chain."

Processes for engaging with value chain workers about impacts

Reference: page 110 (Summary).

"During audits of suppliers (specifically third-party hauliers), we engage with business owners and their workers either directly or through a third-party performing the audit on our behalf." In-person and remote audits run "at intervals ranging from bi-annually to every two years depending on the analysed risk of the supplier," weighted by human-rights-violation risk and DFDS' annual spend with the supplier.

"Based on the Human Rights Index, we have an awareness on our operations in Türkiye and Morocco for forced and compulsory labour impacts in the value chain" (page 109). Feedback from audits and the whistleblower system "in turn inform our decisions and activities aimed at managing actual and potential impacts."

Taking action on material impacts on value chain workers

Reference: page 110 (Summary).

"Our action plans to manage material IROs related to value chain workers are centred around our SCoC, our supplier assessment processes, and the audits we perform directly or with the help of third parties," aimed at "unveiling non-conformance, enabling a dialogue to plan actions, and improve the working conditions in our value chain."

"In our supplier audits, any non-conformities are assessed for severity. DFDS will allow a certain time to rectify the matter depending on the severity of the finding and in particular, severe cases the supplier relationship may be discontinued." Group Procurement holds operational responsibility for engagement with value chain workers; the EMT ensures executive ownership of the ESG agenda.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 110 (Summary).

"DFDS has not set measurable outcome-oriented targets related to workers in the value chain."

The IRO overview (page 74) instead records qualitative ambitions and tracking against each material S2 IRO (secure employment, work-life balance, health and safety, diversity, forced labour): "Increase SCoC commitment (G1)" as the shared ambition, tracked via "Assessments and audits track the effectiveness and adherence with our SCoC."

Business conduct policies and corporate culture

Reference: page 112.

"DFDS's corporate culture is fundamentally grounded in our CoC and in our corporate values." The Executive Management Team "is responsible for overseeing and approving communication initiatives and interactions that advance the corporate culture," operationally run by the People Division; the annual MyVoice survey is "utilised as a key instrument to assess and evaluate the state of the corporate culture."

"The CoC outlines how employees are expected to react if they should become aware of behaviour in contradiction of the CoC, including instructions on who to inform or to report via the whistleblower system." CoC training is mandatory for all employees and includes whistleblower-reporting training; the whistleblower system is open to internal and external stakeholders.

Management of relationships with suppliers

Reference: page 114.

Three-step supply-chain sustainability monitoring: (1) risk assessment "based on the three criteria: spend, supplier's country of origin and industry"; (2) target-group suppliers (annual spend >DKK 10m and/or flagged high-risk) are evaluated on ESG matters - environment, human & labour rights, ethics and sustainable procurement; (3) suppliers are engaged on improvements and corrective actions based on their score.

Suppliers who violate the SCoC or refuse remediation may have the relationship terminated. Standard payment terms are current month +63 days (minimum acceptable +30 days).

Prevention and detection of corruption and bribery

Reference: page 113.

"DFDS is firmly committed to the eradication of corruption and bribery... facilitation payments represent a persistent challenge within the ferry and logistics industries." Functions assessed as most at risk: Procurement, Customs and Border Control, Freight forwarding and shipping, Sales and marketing, and Finance and accounting (page 113).

Prevention runs through mandatory CoC training (anti-corruption/anti-bribery); "in 2025, the completion rate for the online CoC training was 81% for both land and sea." Detection relies primarily on the whistleblower system. Investigations of corruption/bribery allegations are conducted by the designated whistleblower officer in Legal - "the investigation function is not fully independent from the management structure responsible for implementing anti-corruption and bribery prevention measures," a limitation DFDS states directly.

Targets related to business conduct

This disclosure requirement is a 2025/2026-ESRS renumbering of the 2023 ESRS "MDR-T" targets minimum disclosure requirement for business-conduct topics; the report was prepared under the 2023 ESRS and has no standalone G1-3 "Targets" section, so this entry is back-filled from the G1 IRO overview's "Targets and ambitions" / "Tracking and effectiveness" columns (page 112).

DFDS has not set quantified, time-bound business-conduct targets, but ties each material G1 IRO to a stated ambition and an effectiveness-tracking mechanism: corporate culture - "Maintain strong culture aligned with DFDS values" and "Ensure 100% CoC training coverage," tracked via the MyVoice survey and learning-system training completion; whistleblower protection - "Maintain trust in the system" and "Ensure prompt, independent investigations," tracked via whistleblower-report volumes; supplier management - "Improve transparency and standardisation," tracked via supplier-risk and audit results; corruption and bribery - "Zero tolerance towards bribery and corruption," tracked via whistleblower reports and CoC training completion. This is effectiveness-tracking in the absence of a quantified target, the other MDR-T limb.

Incidents of corruption or bribery

Reference: page 114.

"DFDS has had no convictions for violation of anti-corruption or anti-bribery laws in the reporting year and consequently no fines for such violation."

This is disclosed as a direct, quantified nil return under the G1-4 accounting policy definitions given on page 114 (number of convictions; amount of fines paid), consistent with the whistleblower-based detection and Legal-department investigation process described under G1-3.

Payment practices

Reference: pages 114-115.

"DFDS has implemented a strategic initiative... which aims to optimise payment efficiency and reinforce our commitment to timely transactions and payments on time," using standardised payment terms across suppliers (current month +63 days, minimum +30 days), with case-by-case flexibility "especially for SMEs." "The resulting shift in the composition of payment terms has contributed to an increase in the average number of days to pay." "DFDS does not have any outstanding legal proceedings for late payments."