Board of Directors composition

DSB is an independent public institution owned by the Danish State. DSB is managed by a Board of Directors composed of representatives appointed by the Danish Ministry of Transport and representatives elected by the employees.

Management structure

DSB is managed by:

• A Board of Directors with representatives appointed by the Danish Ministry of Transport and representatives elected by employees
• Executive management led by CEO Flemming Jensen and CFO Pernille Damm Nielsen

Role in sustainability matters

The Board of Directors and management have oversight of DSB's sustainability strategy and implementation. DSB's purpose is 'A sustainable way forward with room for all of us', and sustainability is a central part of the strategy and day-to-day operations.

Strategic oversight

The Board and management oversee:

• Market-oriented DSB strategy with three main areas: attract more customers and improve customer satisfaction; deliver a competitive and sustainable DSB; develop employees and corporate culture
• Major investments in electric rolling stock and sustainable infrastructure
• Climate targets including reducing Scope 1 and 2 CO2e emissions by at least 8% by 2030
• Sustainability reporting and compliance with CSRD/ESRS requirements

Risk management and internal controls

DSB has established various risk management and internal control systems to support sustainability reporting and operations:

Data quality controls

We are making proactive efforts to enhance data quality in our calculations, including through quality control in our internal KPI processes and through audits performed by DSB's internal audit function. Enhanced data quality will not only improve the accuracy of our reporting, but also provide a better basis for making informed decisions on our environmental impacts.

Compliance function

DSB's Data Protection Officer (DPO) Compliance function is responsible for advising and following up on laws, rules and regulations of relevance to the company as a whole which do not fall under other specialist areas.

Emergency planning and crisis management

We continuously work to improve our emergency plans and risk management systems for rapid responses to any service disruption and crisis situation that may occur.

Climate risk assessment

To mitigate potential challenges from climate change, we have conducted an analysis of the risks associated with them. The analysis has been carried out using the Climate Atlas tool developed by the Danish Meteorological Institute (DMI), which incorporates the UN Intergovernmental Panel on Climate Change (IPCC) climate scenarios in a Danish context.

Review by external auditors

The sustainability report is covered by the review (limited assurance) performed by external auditors.

DSB's business model and value chain

Purpose and strategy Our purpose is 'A sustainable way forward with room for all of us.'

By saying 'with room for all of us', we mean: • Room for more customers - in all areas • Door-to-door travel must take place with a minimum of congestion • Attractive offers for everyone - at reasonable fares • Safe, secure and positive station experiences • Business partners and partnerships • Customers must be able to take travel safety for granted • A workplace committed to a high degree of wellbeing and cross-cutting collaboration

And by saying 'a sustainable way forward', we mean: • Mobility with minimal climate impact • Minimal environmental impact at all stages of operation • Waste must be recycled into new resources • A financially sustainable DSB

Our strategy is Market-oriented DSB. This implies that we must be 'As attractive to our customers and as competitive and sustainable as the best operators in Europe'. Our strategy unfolds in three areas: • Attract more customers and improve customer satisfaction • Deliver a competitive and sustainable DSB • Develop employees and corporate culture

Business model DSB's business model is built around the ambition to provide a seamless travel experience for customers.

Timetable The timetable has been prepared to support growth and deliver the best possible customer experience with the available railway infrastructure. This applies both to Long-distance & Regional Trains and to S-trains. We achieve this through timely planning and robust traffic management in collaboration with Banedanmark.

Operations management DSB has more than 3,800 operating staff to ensure that daily rail services keep to the timetable. They also ensure that our fleet of over 400 trains undergoes systematic maintenance and preparation. The workshops are spread across Denmark, which supports reliable and efficient operations.

Services Our services must support our objective of delivering more than 500,000 seamless travel experiences every day.

We invest in technological solutions to make it easier for our customers to travel on public transport in Denmark.

DSB's app combines national traffic information and ticket purchases, and its new Check-in feature allows customers to travel by swiping their mobile phones without having to worry about their departure point or destination.

We are making a dedicated effort to create opportunities for first and last-mile services through third-party partnerships.

DSB manages and develops almost 200 stations across Denmark. Customers should feel well guided at clean and secure stations. In the period to 2030, we are investing more than DKK 1 billion in station improvements.

DSB Service & Retail operates 61 7-Eleven stores at our stations. The stores play an active role in our customers' overall travel experience, especially their experience at the stations.

Value chain partnerships DSB collaborates with various stakeholders, including our customers and local communities (for instance in the form of meetings with commuter clubs and an annual commuter rally), NGOs, disability organisations, suppliers, business partners (for instance Banedanmark as regards the common traffic information) and other public transport market players.

DSB operates train services on infrastructure that is owned and managed by Banedanmark and Sund & Bælt, among others.

Stakeholder engagement

In pursuing our business activities, DSB collaborates with various stakeholders, including our customers and local communities (for instance in the form of meetings with commuter clubs and an annual commuter rally), NGOs, disability organisations, suppliers, business partners (for instance Banedanmark as regards the common traffic information) and other public transport market players.

Customer engagement DSB engages with customers through:

• Commuter clubs and annual commuter rally
• DSB's app with more than 1.8 million unique users
• DSB Plus loyalty programme with more than 1.8 million customer profiles
• Customer service and feedback mechanisms
• Regular customer satisfaction monitoring

Community partnerships DSB seeks out and enters into partnerships with organisations that support our purpose while demonstrating a strong commitment to social responsibility:

• We collaborate with the 'Natteravnene', a project that contributes to the sense of safety at the stations
• Partnership with 'Livslinien' on focused efforts to prevent suicide on the railway
• Strategic partnership with the Danish Red Cross to develop activities aimed at supporting vulnerable people in both Denmark and the world's hot spots
• Collaboration with 'VELKOMMEN HJEM', an association supporting veterans in making a balanced and realistic transition from the military to the civilian labour market
• Corporate member supporting InterForce, making it possible for our employees to be allowed time off to serve as reservists in the Danish Armed Forces and the Danish Home Guard

Local community involvement We involve local communities in and around the station improvements.

In connection with our major civil engineering and construction projects, we minimise the risks of nature and biodiversity impacts through engagement of local communities in the form of public meetings and collaboration with the authorities on EIA processes and local development plans.

Supplier engagement We demand high standards from all our suppliers and business partners. Not only in relation to the goods and services they provide, but also in relation to how they demonstrate social responsibility and treat their employees. Our suppliers must respect fundamental human rights, including the prohibition on the use of child labour and of forced labour or the exploitation of involuntary labour.

Ethical guidelines have been incorporated into our supplier contracts, which demand that suppliers meet occupational health and safety standards, maintain proper pay and working conditions and respect fundamental human rights.

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

Climate change impacts and strategy interaction Due to direct and indirect emissions from our energy consumption for traction and non-traction operations, we have a material climate impact. Most of our overall climate impact comes from our value chain (Scope 3), while primary cause our direct emissions is the use of our diesel-powered trains.

The core effort is the investment in modern, electric trains. But the effort applies to our entire business: We develop more sustainable workshops. We are switching to renewable energy sources. We demands ambitious climate reduction targets from suppliers. We reduce energy and resource waste and aim to recycle everything from rolling stock to uniforms and surplus products in DSB 7-Eleven stores.

DSB has been given a political mandate to purchase new electric rolling stock in replacement of the ageing diesel-powered train fleet. This is the biggest investment in DSB's history.

Climate adaptation and resilience Climate change presents DSB with the greatest challenges when it affects the use of traffic infrastructure. The more severe weather conditions caused by climate change are also expected to increasingly cause disruption to train operations. The greatest risks to DSB's business are related to storms and strong winds, which can tear down overhead lines and cause trees to fall, and to flooding of low-lying areas by storm surges and cloudbursts as well as landslides along railway lines.

Based on DSB's experience of service disruption incidents due to climate conditions, it is estimated that the consequences will most often be relatively short-lived (half to two days), and the disruptions will often be restricted to reduced speed, reduced service frequency or briefly suspended train operations.

Banedanmark has drawn up contingency plans in collaboration with the railway companies in Denmark. The traffic consequences are thus known, and contingency plans can be implemented quickly with as little disruption as possible.

Air pollution impacts Air pollution has an impact on the surrounding environment that derives from our train operations across the country. The direct impact is local and consists primarily of ultrafine and fine particulate matter connected with the burning of diesel for traction operations. Running our electric trains contributes indirectly to air pollution, where electricity generation results in local air pollution to a varying extent depending on the method of generation.

Biodiversity impacts DSB impacts biodiversity and ecosystems directly as well as indirectly. Our direct impacts arise from the fact that we carry on our activities in areas with a share of potentially valuable nature, which impacts local flora and fauna.

The indirect impacts arise through the purchase of goods and services in our value chain. Our indirect impacts on biodiversity have been initially mapped. As biodiversity is a new area and calculation methodologies and reporting standards are still subject to significant uncertainty, the indirect impacts are currently not reported.

No assessment has been made as to whether our operations impact threatened species, as their vulnerability varies greatly, and therefore it cannot be concluded at present whether their presence on or near DSB's areas of land entails a risk of impact.

Social impacts and workforce strategy The ability to attract and retain employees is essential to the realisation of our targets. We want to create a culture that makes our employees feel valued, recognised for their efforts, feel that they are being listened to and feel committed, which is essential to achieving a high level of employee loyalty.

The consequences of failure to succeed in this area are higher employee turnover and, as a result, increased loss of productivity.

With a good physical and psychological working environment, we join forces to make DSB an attractive workplace with low absence due to illness and few workplace accidents.

Process to identify and assess material impacts, risks and opportunities

The sustainability reporting is based on our double materiality assessment (DMA) assessed for our own operations and DSB's value chain (see page 40).

All topics dealt with in the environment, social and governance sections have been assessed as material in our double materiality assessment.

A comprehensive double materiality assessment process was conducted to identify material sustainability topics. This assessment considered both impact materiality (DSB's impacts on people and the environment) and financial materiality (sustainability matters that could affect DSB's financial performance).

For a comprehensive overview of DSB's impacts, risks and opportunities, see the section on DSB's double materiality assessment on page 40.

Approach to data collection and reporting

We generally take an activities-based approach to the collection and reporting of environmental data, and we apply keys and emission factors from representative, recognised official sources such as the Environmental Protection Agency (EPA) and the Department for Environment, Food & Rural Affairs (DEFRA) to support our calculations.

A large part of our current reporting is based on our own records and primary data, and we are working to increase the scope thereof rather than relying on estimates or third-party information.

We are continually working to improve our sustainability reporting and to provide a true and fair view of our material direct and indirect impacts.

Quality control measures

We are making proactive efforts to enhance data quality in our calculations, including through quality control in our internal KPI processes and through audits performed by DSB's internal audit function. Enhanced data quality will not only improve the accuracy of our reporting, but also provide a better basis for making informed decisions on our environmental impacts.

Disclosure requirements covered by DSB's sustainability statement

Based on our double materiality assessment, DSB has identified the following material topics and corresponding ESRS disclosure requirements:

Material topics identified:

• ESRS 2 - General Disclosures
• E1 - Climate Change
• E2 - Pollution
• E4 - Biodiversity and Ecosystems
• E5 - Resource Use and Circular Economy
• S1 - Own Workforce
• S2 - Workers in the Value Chain
• S3 - Affected Communities
• S4 - Consumers and End-Users
• G1 - Business Conduct

The data points presented for material topics have been selected in accordance with the disclosure requirements (including the application requirements) related to the specific sustainability matters in the corresponding topical ESRS.

The quantitative reporting covers DSB's own operations, however, as regards the calculation of Scope 3 CO2 emissions also upstream and downstream activities.

Topics not assessed as material

Based on our double materiality assessment, the following ESRS topics were not assessed as material for DSB:

• E3 - Water and Marine Resources

This assessment was based on DSB's business model, operations, and value chain analysis which determined that these topics do not represent significant impacts or financial risks/opportunities for the organization.

Disclosures incorporated by reference

In connection with the preparation of the sustainability report, the following disclosures have been incorporated by reference: • ESRS 2 SBM-1, ESRS 2 SBM-2 and ESRS 2 SBM-3 • ESRS E1 SBM-3 • ESRS E4 SBM-3 • ESRS S2 SBM-2 and ESRS S2 SBM-3 • ESRS S4 SBM-2 and ESRS S4 SBM-3

The above disclosures are incorporated in the section 'Strategy, business model and value chain' on page 11.

Transition plan for climate change mitigation

Overall strategy and targets DSB has a target of supplying all our rail journeys and all other operations with renewable energy by 2030. Moreover, we want to reduce the climate impact of our suppliers to ensure that emissions from all our activities reach net zero by 2050.

Target: Reduce Scope 1 and 2 CO2e emissions by at least 8% by 2030

Key investments and initiatives With investments in excess of DKK 45 billion over the next years, DSB is well on its way to offering customers solutions that are even more sustainable when they choose to take the train.

Electric rolling stock transition The core effort is the investment in modern, electric trains. DSB has been given a political mandate to purchase new electric rolling stock in replacement of the ageing diesel-powered train fleet. This is the biggest investment in DSB's history.

• Production of seven IC5 electric train sets has been completed
• It has been agreed that the supplier Alstom will deliver a minimum of 100 electric train sets
• The first electric train sets will be put into passenger service at the beginning of 2027
• DSB purchases 16 new rakes of coaches from the Spanish supplier Talgo to be pulled by EB electric locomotives
• DSB is preparing to convert the current S-train line from a traditional urban railway to a fully automated, driverless transport system, 'S-trains of the Future'

Renewable energy transition In 2024, DSB invested in yet another Power Purchase Agreement (PPA) and entered into an agreement to purchase large amounts of power from a solar park on Lolland. From November 2025, DSB will receive renewable energy equivalent to half of the consumption for S-trains.

For a number of years, DSB has had solar cells on the roofs of Nørreport, Albertslund, Sjælør and Avedøre stations. In 2024, solar cells were installed at Høje Taastrup station.

Sustainable infrastructure New, comprehensive maintenance facilities are needed for the new electric rolling stock. DSB is therefore in the process of building three new workshops: one in Copenhagen, one in Aarhus and one in Næstved. There is a strong focus on sustainability in the builds, and the new workshops are to be certified according to at least DGNB Gold standard.

Green financing In August, DSB completed its first issuance of green bonds. Bonds in a nominal amount of EUR 500 million were issued with a fixed coupon of 3.125 percent and a maturity of 10 years. The bonds were issued under DSB's EMTN (European Medium Term Note) programme. The related Green Bond Framework describes DSB's investments that can be financed with green bonds. The proceeds of the bond issue will be used to purchase new electric rolling stock and construct new workshops.

Carbon offsetting initiatives DSB has entered into a partnership with the Danish Climate Forest Foundation. For each registered business journey, DSB provides a contribution to the Danish Climate Forest Foundation. The contribution is used for afforestation to increase absorption of CO2. Since 2023, DSB has furthermore provided a climate contribution equivalent to the emissions from its own business travels by air.

In 2024, DSB's contribution is expected to finance 6,850 tonnes/CO2e, corresponding to approximately 220,000 m2 of forest, distributed on 6,500 tonnes of CO2 from registered business journeys and 350 tonnes of CO2 from business travels by air.

Policies related to climate change mitigation and adaptation

DSB has disclosed one policy governing its work on climate change mitigation and adaptation.

Environmental Policy

Purpose and application

DSB's Environmental Policy sets the framework for the company's efforts to minimise overall environmental impacts and ensure compliance with applicable legislation across all activities. The policy is based on DSB's environmental impacts, binding commitments and stakeholders' expectations for the company's work to prevent and minimise environmental impacts.

The Environmental Policy applies to all employees of DSB and all people working for DSB.

Climate change mitigation and adaptation coverage

DSB's climate change mitigation efforts are covered by the Environmental Policy. Through ambitious climate reduction targets, climate change adaptation and a high level of energy efficiency, DSB works to mitigate climate change from its operations. This also applies to the company's work in support of renewable energy deployment.

The policy governs DSB's environmental work and sets the framework for a structured approach to preventing, managing and minimising direct and indirect environmental impacts. Backed by the Environmental Policy, DSB has an ambition to offer travel with a low environmental impact to customers – including climate impact.

Governance and oversight

The Executive Team is responsible for implementing the Environmental Policy at DSB. The policy is updated as required and reviewed at least once annually to ensure continued relevance and effectiveness. The Executive Team approves the revised environmental policy on an annual basis.

Public availability

The policy is publicly available on DSB's website.

Material impacts covered

The Environmental Policy addresses the following material areas in relation to climate change:

1. Climate impact
2. Energy consumption
3. Climate adaptation

Targets related to climate change mitigation and adaptation

Climate mitigation target

• Reduce Scope 1 and 2 CO2e emissions by at least 8% by 2030 (baseline not specified in the available text)

Renewable energy target

• Supply all rail journeys and all other operations with renewable energy by 2030

Net zero target

• Reach net zero emissions from all activities by 2050

Progress in 2024 In 2024, DSB further reduced its overall climate impact by 5 percent. For Scopes 1 and 2, the reduction was 7 percent, primarily driven by the increased use of green power. For Scope 3, the reduction was 4 percent in 2024.

Energy consumption and mix

Total energy consumption

DSB's total energy consumption in 2024 was 814,000 MWh (803,000 MWh in 2023; 988,000 MWh in 2019 baseline). This represents an 18% reduction from the 2019 baseline.

Energy consumption by operation type:

Note: Diesel and petrol consumption are converted from litres to MWh. Consumption for heating (district heating, gas and heating oil) is calculated as gross energy consumption and not adjusted for degree days. Traction operations account for 91% of total energy consumption.

Energy consumption by fuel source

Methodology notes:

• Electricity: DSB does not purchase electricity certified by guarantees of origin and does not yet have electricity generation from PPAs on a significant scale. Market-based estimates are therefore used: 86% of consumption came from fossil sources in 2024.
• District heating: Fuel distribution is based on market-based declarations for 2023 from Kredsløb (Aarhus) for western Denmark and HOFOR for eastern Denmark using the 125% method.
• Biofuels: The share of biofuels in oil (diesel, heating oil, petrol) is based on B7 diesel with 7% biofuel content. The share of biogas in natural gas is based on monthly grid shares calculated by Energinet (average up to October 2024).
• Scope: All energy consumption is from activities in high climate impact sectors, as all sectors in which DSB operates are defined as such. DSB currently has no significant self-generation of energy.
• Electricity breakdown: The calculation uses Energinet's general electricity declaration for 2023 (most recent available), which is market-based and not broken down by DK1 (western Denmark) and DK2 (eastern Denmark).

Energy intensity

Energy intensity per net revenue: 0.00007 MWh per DKK in 2024 (0.00008 in 2023; 0.00009 in 2019), representing a 20% improvement from baseline.

Gross Scopes 1, 2, 3 and Total GHG emissions

Summary of GHG emissions (2024)

DSB's total GHG emissions in 2024 were 382.74 thousand tonnes CO2e (location-based) or 525.76 thousand tonnes CO2e (market-based).

• Scope 1: 116.68 thousand tonnes CO2e (primarily diesel traction operations: 114.41 kt; non-traction: 2.26 kt)
• Scope 2 (location-based): 18.83 thousand tonnes CO2e (traction: 14.63 kt; non-traction: 4.20 kt)
• Scope 2 (market-based): 161.86 thousand tonnes CO2e (traction: 139.04 kt; non-traction: 22.81 kt)
• Scope 3: 247.23 thousand tonnes CO2e

Table 8: Climate impact (full disclosure)

Notes:

1. Non-traction operations include emissions from energy consumption to buildings, trackside installations and cars as well as refrigerants for trains and buildings.

2. For purposes of consistency and error correction, the Scope 3 climate impact has been recalculated for 2023.

3. Biogenic emissions from Scope 3 have not been reported in 2024. DSB estimates emissions therefrom are probably not material compared to overall climate impact and expects to report in the annual report for 2025.

Scope 1 sub-breakdown

Traction operations: 114.41 thousand tonnes CO2e (primarily diesel combustion for train operations)
Non-traction operations: 2.26 thousand tonnes CO2e (energy consumption in buildings, trackside installations, leased cars; refrigerants in trains and buildings)

Methodology and scope notes

Consolidation approach: Operational control.

Scope 1: Based on DEFRA emission factors. Diesel combustion (mobile combustion) accounts for 95% of Scope 1+2 emissions. Zero emissions are covered by the EU ETS in 2024; ETS 2 (covering fuel operators) entered into force only on 1 January 2025.

Scope 2: Reported both location-based and market-based.

• Location-based: Uses Energinet environmental declaration for 2023 (125% method) broken down by DK1 (western Denmark) and DK2 (eastern Denmark). District heating uses Danish Energy Agency data for 2023. For market-based, electricity uses Energinet residual mix 2023; district heating uses 2023 declarations from Kredsløb (Aarhus, DK1) and HOFOR (Copenhagen, DK2) with the 125% method.
• DSB does not purchase electricity certified by guarantees of origin at significant scale; percentage of renewable energy instruments stated at 0%.

Scope 3: Covers 12 of 15 GHG Protocol categories. Categories 3.8 (upstream leased assets), 3.10 (processing of sold products), and 3.14 (franchises) are excluded (not applicable under operational control approach or DSB business model). Emissions from trains resold are not included; emissions from trains leased to other operators are included in category 3.13.

• Primary data: 75% of Scope 3 based on primary data.
• Data period: Mainly January–October 2024, extrapolated to full year. Financial data (for spend-based calculations) uses realised 2024 figures.
• Omissions/recalculation: Scope 3 for 2023 has been recalculated for consistency and error correction (see page 26–27 for details of restatements). In 2024, DSB corrected recognition of Scope 3.9 (customer transport to/from stations) and VAT treatment in Scope 3.1, resulting in +14,268 tonnes CO2e (+6%) adjustment to 2023 Scope 3. DSB will assess in 2025 whether to recalculate the 2019 baseline (recalculation policy: >5% change threshold).

Biogenic CO2: Reported separately. Scope 1 biogenic (7.9 kt CO2e in 2024) based on DEFRA factors and biofuel content (B7 diesel = 7% biofuel). Scope 2 biogenic emissions calculated for location-based (59.4 kt) and market-based (7.7 kt) using biomass share in district heating and biogas in natural gas grid (Energinet monthly data). Scope 3 biogenic emissions not disclosed for 2024 due to limited data availability; DSB estimates these are not material and expects to report in 2025.

GHG intensity: Calculated as ratio of total GHG emissions (location-based or market-based) to net revenue (DKK). In 2024: 0.00003 tonnes CO2e per DKK (location-based) and 0.00005 tonnes CO2e per DKK (market-based).

Baseline and targets: Base year 2019. 2030 targets (SBTi-validated): Scope 1+2 location-based –98%; Scope 3.9 –28%; Scope 3.11 –100%; all other Scope 3 –30%. 2050 net-zero target: –90% total emissions (Scopes 1+2+3).

GHG removals and GHG mitigation projects financed through carbon credits

Danish Climate Forest Foundation partnership DSB has entered into a partnership with the Danish Climate Forest Foundation. For each registered business journey, DSB provides a contribution to the Danish Climate Forest Foundation. The contribution is used for afforestation to increase absorption of CO2.

2024 contributions In 2024, DSB's contribution is expected to finance 6,850 tonnes/CO2e, corresponding to approximately 220,000 m2 of forest, distributed on:

• 6,500 tonnes of CO2 from registered business journeys
• 350 tonnes of CO2 from business travels by air

The contribution ensures that the CO2 emitted is sequestered for the next 100 years. The effect is not included in DSB's climate accounts.

Air travel offsetting Since 2023, DSB has furthermore provided a climate contribution equivalent to the emissions from its own business travels by air.

Implementation timeline The actual afforestation of areas for the 2024 contribution year is expected to be completed in 2025.

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

Disclosure Status

According to the datapoint index:

All E1-9 datapoints are assessed as not material by DSB.

Policies related to pollution

DSB addresses pollution through its Environmental Policy, which sets the framework for efforts to minimise environmental impacts including pollution of air, water and soil.

Environmental Policy

Purpose and application

DSB's Environmental Policy sets the framework for efforts to minimise overall environmental impacts and ensure compliance with applicable legislation across activities. The policy is based on environmental impacts, binding commitments and stakeholders' expectations for work to prevent and minimise environmental impacts.

According to the Environmental Policy, DSB is committed to protecting the environment by preventing pollution of surroundings and minimising environmental impacts. This includes maintaining an overview of current and potential pollution associated with activities across locations.

The commitment to preventing and minimising impacts also covers the consumption of all substances that may contribute to an environmental impact.

Scope

The Environmental Policy applies to all employees of DSB and all people working for DSB.

Material impacts covered

The policy covers the following material impacts:

• Pollution of air
• Pollution of water
• Pollution of soil
• Substances of concern and very high concern

Governance and oversight

The Executive Team is responsible for implementing the Environmental Policy at DSB. The policy is updated as required and reviewed at least once annually to ensure continued relevance and effectiveness. The Executive Team approves the revised environmental policy on an annual basis.

Implementation approach

DSB works in a structured way to prevent and minimise pollution impacts and risks, including:

• Regular testing of environmental emergency response procedures
• Recording incidents in deviation management system to learn from incidents and optimize work routines
• Process for approving chemical products to register and manage which chemicals are used
• Chemical risk assessments for activities using substances of concern
• Obtaining environmental approvals and permits for workshops and washing facilities
• Overflow protection for filling stations and drip trays under relevant chemicals

Availability

The Environmental Policy is available on DSB's website.

Targets related to pollution

The document references ESRS E2-3 on page 74-75 according to the index, but the excerpts provided do not contain the actual content of this disclosure requirement. The excerpts only show:

• The index entry stating "E2-3 Targets related to pollution" appears on pages 74-75
• A cross-reference table on page 51 indicating that datapoint E2-4 Clause 28 relates to "Amount of each pollutant listed in Annex II of the E-PRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water and soil" on pages 74-75

The actual target information from pages 74-75 is not included in the provided excerpts.

Pollution of air, water and soil

Emissions to air

DSB's material direct and indirect emissions to air are primarily related to traction operations. Air pollution derives from train operations across Denmark, with direct local impact consisting primarily of ultrafine and fine particulate matter connected with the burning of diesel for traction operations. Running electric trains contributes indirectly to air pollution, where electricity generation results in local air pollution to a varying extent depending on the method of generation.

Table 9: Pollution to air

Pollution of air has decreased for most emissions. The greatest development is seen for emissions of sulphur dioxide (SO2) at a decrease of 29 percent, primarily driven by improvements in the environmental declaration for electricity generation in Denmark from Energinet. Hydrofluorocarbons (HFC) from refrigerants have increased by 30 percent because DSB has carried out several inspections of both train sets and systems in the DSB 7-Eleven stores.

Figure 7: Particulate emissions

Particulate emissions from train engines increased by 1 percent from 2023 to 2024, corresponding to the increase in diesel consumption. However, particulate emissions per passenger kilometre decreased by two percent in the same period.

Discharges to water and soil

In 2024, DSB had no material discharges to water or soil. There were no discharges to water or soil that exceed the limit values set out in Annex II to Regulation (EC) No 166/2006 of the European Parliament and of the Council (E-PRTR Regulation).

Pollution of soil and water at DSB is typically associated with train washing activities, graffiti removal and oil-spill accidents on train lines, in workshops or at railway depots.

Substances of concern and substances of very high concern

Table 10: Consumption of pollutants

The consumption of substances of very high concern reflects DSB's consumption of refrigerants for trains (for engines – not air conditioning systems), and the consumption of substances of concern is related to DSB's consumption of diesel for traction operations, but also gear oil and refrigerants.

Methodology notes

Emissions from diesel for traction operations are calculated based on diesel consumption and key figures for emissions per diesel train type. Emissions to air from electricity are based on calculations using the environmental declaration from Energinet, with fuel distribution in western Denmark (DK1) and eastern Denmark (DK2). Emissions to air from HFCs consist of consumption for trackside installations and trains, based on supplier reports and internal DSB systems estimating refilled quantities of refrigerants. The calculation of substances of very high concern and substances of concern is based on extracts from DSB's chemicals database compared to purchased quantities of chemical products and consumption of diesel for train operations.

Substances of concern and substances of very high concern

Policy and management approach

We avoid to the extent possible the use of substances of concern and substances of very high concern in our activities. This also applies to suppliers who work for us and throughout our value chain, for instance when we buy new trains.

The operation of diesel trains and the maintenance and preparation of trains are the activities primarily leading to consumption of substances of concern and very high concern.

Where avoiding the use of these substances is not possible, we seek to minimise the use. For this purpose, we have a process for approving chemical products to register and manage which chemicals are used in the company.

In addition, we carry out chemical risk assessments in relation to the activity for which the product is to be used, ensuring that we work in a structured manner to minimise our use of substances of concern and very high concern.

Quantities consumed

The consumption of substances of very high concern reflects DSB's consumption of refrigerants for trains (for engines – not air conditioning systems), and the consumption of substances of concern is related to DSB's consumption of diesel for traction operations, but also gear oil and refrigerants.

Table: Consumption of pollutants

Targets

We have developed processes to ensure that we assess and minimise the use of substances of concern and very high concern. Our diesel consumption, which is the primary driver of our emissions of substances of concern, is covered by our climate impact targets. We have no other targets for our efforts to limit the use of substances of concern and very high concern, nor do we expect to set targets for this.

Accounting policies

The calculation of substances of very high concern and substances of concern is based on extracts from DSB's chemicals database compared to extracts on purchased quantities of chemical products and consumption of diesel for train operations.

The calculation for substances of very high concern has been prepared for all relevant chemical products, whereas the calculation for substances of concern is based on a minimum consumption of 1,000 litres or 1,000 kilograms of the individual chemical products.

The calculation is made for January to September, and consumption in October, November and December is based on prior-year consumption.

Three selected suppliers have reported consumption of substances of concern.

Transition plan on biodiversity and ecosystems

Current assessment status In 2024, DSB prepared an initial assessment of impacts on nature and biodiversity.

Direct impacts DSB impacts biodiversity and ecosystems directly as well as indirectly. Our direct impacts arise from the fact that we carry on our activities in areas with a share of potentially valuable nature, which impacts local flora and fauna.

Indirect impacts The indirect impacts arise through the purchase of goods and services in our value chain. Our indirect impacts on biodiversity have been initially mapped. As biodiversity is a new area and calculation methodologies and reporting standards are still subject to significant uncertainty, the indirect impacts are currently not reported.

Risk mitigation in construction projects In connection with our major civil engineering and construction projects, we minimise the risks of nature and biodiversity impacts through engagement of local communities in the form of public meetings and collaboration with the authorities on EIA processes and local development plans.

Threatened species assessment No assessment has been made as to whether our operations impact threatened species, as their vulnerability varies greatly, and therefore it cannot be concluded at present whether their presence on or near DSB's areas of land entails a risk of impact.

Future work plan for 2025 In 2025, work will begin to identify and assess the need for mitigation actions as well as physical, systemic and transition risks related to biodiversity and ecosystems.

Policies related to biodiversity and ecosystems

DSB acknowledges the disclosure requirements for E4-2 (Policies related to biodiversity and ecosystems) on page 77 of its sustainability statement.

According to the index table, E4-2 specifically references:

• 24 (b): Sustainable land/agriculture practices or policies - marked as disclosed on page 77
• 24 (c): Sustainable oceans/seas practices or policies - marked as disclosed on page 77
• 24 (d): Policies to address deforestation - marked as disclosed on page 77

However, the excerpts provided do not contain the actual content from page 77 that would describe the specific policy names, their scope, governance, key principles, or implementation details. The index indicates that policies exist in these three areas, but the substantive policy disclosure is not included in the extracted pages.

Impact metrics related to biodiversity and ecosystems change

Land use footprint

DSB has mapped its direct impact on biodiversity and ecosystems through land use using GIS tools.

Total land assessed: 711 plots covering 650 hectares

Overlap with protected areas:

• Section 3-protected nature, EU habitats and section 25-forests present on assessed land
• Area calculation: sum of area types less any overlap
• Surrounding protected nature included via 50-metre buffer zone (no deduction for overlap made)

Operations on own properties (426 ha total):

• Total impact on land through operations: ~420 hectares
• Urban nature areas: 220 hectares (52% of operational areas)
• Protected nature impacted: 51 hectares total
  • Of which on own properties: 18 hectares

Property development projects (221 ha):

• Direct impact on land: up to 220 hectares
• Protected nature: 66 hectares
  • Of which on own land: 25 hectares

Species and habitat impacts

Threatened species have been omitted from the assessments, as their vulnerability varies greatly. DSB states it cannot be concluded at present whether the presence of threatened species on or near DSB's areas of land entails a risk of impact.

Potential impacts on species and natural habitats on the designation basis for Natura 2000 sites will be investigated from 2025.

Ecosystem condition metrics

No quantified ecosystem condition metrics are disclosed.

Restoration metrics

DSB has entered into a partnership with the Danish Climate Forest Foundation. For each registered business journey, DSB provides a contribution used for afforestation to increase absorption of CO2. Since 2023, DSB has furthermore provided a climate contribution equivalent to the emissions from its own business travels by air. No hectares restored are quantified.

Deforestation footprint

No deforestation metrics are disclosed.

Methodology notes

• Assessment based on existing and publicly available data
• Mapping conducted using GIS tools
• Five largest human-induced drivers of biodiversity loss assessed according to IPBES framework
• Land use and resource use identified as main drivers of impacts in initial assessment phase
• Indirect impacts estimated using EXIOBASE database (subject to uncertainty)
• Assessment identifies potential negative impacts; actual negative impacts to be mapped from 2025 using risk-based approach

Policies related to resource use and circular economy

DSB has disclosed one policy relevant to resource use and circular economy under ESRS E5-1.

Environmental Policy

Purpose and application

DSB's Environmental Policy sets the framework for efforts to minimise overall environmental impacts and ensure compliance with applicable legislation across all activities. The policy is based on DSB's environmental impacts, binding commitments and stakeholders' expectations for work to prevent and minimise environmental impacts.

The Environmental Policy sets the framework for direct and indirect impacts that arise from own operations and throughout the value chain, both upstream and downstream emissions.

Scope

• The Environmental Policy applies to all employees of DSB and all people working for DSB

Key content and principles

• Making demands, collaborating with suppliers and business partners and making efforts to minimise environmental impacts from resource use by reducing the use of virgin materials and increasing the use of sustainable resources
• Setting out the framework for waste management
• Prioritising preventing and reducing waste through reuse, repair, refurbishing, remanufacture and repurposing before considering recycling

Governance and oversight

• The Executive Team is responsible for implementing the Environmental Policy at DSB
• The policy is updated as required and reviewed at least once annually to ensure continued relevance and effectiveness
• The Executive Team approves the revised environmental policy on an annual basis

Public availability

Not disclosed.

Links to international standards

Not disclosed.

Monitoring and implementation

Not disclosed.

ESRS E5-4 – Resource inflows

Narrative disclosure

DSB has a significant consumption of spare parts stemming from maintenance and preparation activities. These resources, all of which are defined as "High Impact Commodities" by Science Based Targets for Nature, include in particular steel, iron, copper, sand and aluminium. All of these raw materials are characterised by being capable of having a significant negative impact on nature and biodiversity through land use, water consumption, climate change and pollution.

Procurement of new trains represents material, albeit one-off, resource use. One example of the impact in the value chain is DSB's EB locomotives, each of which accounts for direct resource use corresponding to the weight of the locomotive of approximately 90 tonnes.

Data from EXIOBASE, a global database for calculating climate footprint, show that the total resource use associated with a locomotive can be about 3,500 tonnes, half of which derives from the extraction and processing of metals, while almost 40 percent are accounted for by construction materials for buildings and infrastructure in the value chain.

Data limitations

DSB does not currently have weight data on resource use broken down on the materials used to "produce" services. The company is working to procure data with a focus on resource use associated with the maintenance and purchase of trains and the maintenance and construction of buildings.

DSB prioritises collecting data for materials consumption from the purchase of train parts, which constitute the main source of environmental impacts. In 2024, DSB initiated a dialogue with selected suppliers to obtain information about the materials content of the spare parts in weight. Once a procedure has been established through this dialogue for recording such data, the methodology will be extended to other spare parts suppliers.

Other resource inflows

DSB's resource use includes, among other inflows:

• Diesel and electricity for traction operations
• Spare parts and other products and materials for train maintenance
• IT equipment
• Goods for 7-Eleven stores

Quantitative data

No comprehensive weight-based data on total resource inflows is reported for 2024.

Resource outflows

Recyclability and reuse of materials

DSB has processes in place to recycle materials from operations. The company states: "We reduce a significant part of the emissions associated with the procurement of spare parts as a result of the phase-out of diesel. Procurement of spare parts represents the largest contribution to our Scope 3 emissions. We therefore expect that the transition from diesel to electric trains will lead to significant reductions in the consumption of spare parts."

Product durability - Rolling stock

The document describes the upgrading and refurbishment of existing rolling stock to extend service life:

• IR4 electric train sets: "Upgrading of the 44 IR4 electric train sets is on schedule and is expected to be completed by the end of 2026."

• S-trains: "The electric S-train sets are also undergoing a comprehensive upgrade both on the exterior and on the interior... The upgrading of S-trains will continue in 2025, and all train sets will be fully upgraded by the end of 2027."

• IC3 train sets: These diesel train sets remain in operation pending replacement by IC5 electric train sets, with IC4 sets to be phased out first due to being "more energy and climate inefficient than the IC3 trainsets."

The document mentions that when IC5 trainsets are delivered, DSB will phase out older rolling stock, indicating end-of-life considerations.

Circularity considerations in new builds

For the new workshop at Godsbanegården in Copenhagen, DSB states: "During construction, we have chosen materials with lower climate impact, more climate-efficient foundation and edge insulation solutions, and we have focused on life in the choice of materials used in the building."

However, specific recyclability percentages, repairability scores, or quantitative design-for-circularity metrics are not disclosed.

Waste

Waste management approach

DSB states in its Environmental Policy: "Waste must be recycled into new resources" as one of its commitments. The company indicates: "Our different business activities produce different types of waste, and through waste management processes, we seek to minimise our environmental impact."

The accounting policies section describes: "Emissions from the treatment of waste are calculated on the basis of the statement of waste for the year, including building and construction waste. The different categories of waste are assigned an emission factor based on the method of treatment. Emission factors from the EPA (2024) have been used."

For graffiti removal, the document notes: "When we remove graffiti on our trains, it is most often a work process in the open air, where all water that may be generated in the cleaning process is collected on absorbent mats which are disposed of as hazardous waste."

For the new graffiti removal facility: "In the covered facility, water is recycled to minimise water consumption, and we also try to purify it so that it can be discharged to sewer as wastewater... Any excess cleaning water is therefore disposed of as hazardous waste."

Scope 3 waste emissions calculation

The document provides climate impact data related to waste treatment:

• Scope 3.5: Waste emissions in 2024: 2.46 thousand tonnes of CO2e (2023: 2.40)
• Change: +0.06 thousand tonnes (+2%)
• Change from 2019 baseline: -2.68 thousand tonnes (-52%)

The methodology states: "Emissions from the treatment of waste are calculated on the basis of the statement of waste for the year, including building and construction waste."

For convenience goods sold at 7-Eleven stores: "30 percent of convenience goods is assumed to be thrown away in non-DSB bins and is therefore included in this statement (instead of Scope 3.5)."

Specific waste data

No comprehensive table with total waste quantities (in tonnes), hazardous vs non-hazardous split, or waste treatment method breakdown (recycling, landfill, incineration) is disclosed in the excerpts provided. Quantitative waste data is presented only in terms of CO2e emissions from waste treatment, not waste volumes or masses.

Policies related to own workforce

DSB references S1-1 on pages 98-99 in its sustainability statement, including human rights policy commitments, due diligence policies on issues addressed by fundamental ILO Conventions 1 to 8, processes and measures for preventing trafficking in human beings, and workplace accident prevention policy or management system.

However, the provided excerpts do not contain the actual content from pages 98-99 that would detail specific named policies related to own workforce.

Corporate Social Responsibility Policy

• Key content/principles: The policy addresses DSB's values and explicitly states that DSB does not tolerate retaliation against persons who report concerns in good faith through the whistleblower scheme. Retaliation constitutes a violation of this policy.
• Monitoring: DSB has established a whistleblower scheme through which employees can raise concerns, including those related to staff conditions. DSB accounts for the number of cases in its annual report and on its website.

The excerpts primarily focus on policies for workers in the value chain (S2-1) rather than own workforce (S1-1). The specific policies related to own workforce referenced in the index are not fully disclosed in the provided text.

Taking action on material impacts on own workforce

Initiatives to strengthen development and career opportunities

In 2024, DSB launched several retention initiatives to make it attractive for employees to continue their careers at DSB, aimed at creating a culture that makes employees feel valued, recognised for their efforts and committed.

Action plans and resources

The retention initiatives are based on concrete action plans that over the next few years are intended to:

• Help reduce the number of resignations where insufficient career and development opportunities are cited as the reason
• Reduce the costs of recruitment activities and productivity losses during the training period
• Focus broadly on both personal and professional development, targeting both new employees and more experienced employees

DSB Growth Programme

What it does: A talent program spanning one year that enhances the professional and personal development of employees at the beginning of their careers, supporting employee development among newly graduates, new employees and administrative employees.

2024 participation:

• 8 employees completed the initial module
• 18 employees are in the process of completing the next module, which ends in January 2025

Væksthuset 2.0

What it does: A development programme offered twice a year, focused on the development of employees who work with informal management and want to help influence DSB.

2024 participation:

• 40 employees signed up for the programme, scheduled to end in January 2025

2025 planned:

• Two courses with 40 employees per module will be completed in 2025

Other initiatives

DSB launched a number of other initiatives in 2024 with a focus on increasing employee wellbeing and commitment, including:

• Working with diversity and inclusion
• Offering development opportunities and career paths to make it attractive for employees to continue their careers at DSB

Impact measurement and effectiveness

DSB measures the impact of initiatives through:

• Various KPIs
• Satisfaction surveys
• Regular evaluations of ongoing projects through feedback from employees, managers and other stakeholders

Satisfaction survey results

2024 results:

• Response rate: 88% (compared with 82% in 2023)
• General level of satisfaction: index 75 (up from 73 in 2023), now on a par with peer organisations in the industry
• Overall level of commitment: index 73 (up from 71 in 2023), now on a par with peer organisations in the industry

Employee satisfaction is measured by means of an annual questionnaire sent to all employees at DSB via an external partner. The results help identify where to implement initiatives to improve wellbeing.

Planning of initiatives going forward

In 2025, based on the results of the 2024 satisfaction survey, DSB will continue efforts to increase focus on general satisfaction. This work is carried out in close collaboration with individual managers locally, who prepare action plans based on their satisfaction surveys. If cross-functional trends are identified, initiatives are taken at group level and rolled out throughout the entire organisation.

Characteristics of the undertaking's employees

Total headcount and FTE

2024:

• Total number of employees: 6,893
• Full-time employees (FTE): 6,286

2023:

• Total number of employees: 6,701
• Full-time employees (FTE): 6,075

Average number of full-time employees (FTE):

Headcount by gender

FTE by gender (2024):

• Women: 1,783
• Men: 4,503
• Total: 6,286

Headcount by country

DSB's operating activities are restricted to Denmark.

Headcount by employment contract type

Distribution by terms of employment (2024):

• Collective agreement: 82%
• Public servants: 13% (921 employees)
• Contract employees: 5%

DSB currently does not have the possibility to differentiate permanent employees from temporary employees in its systems.

Employee turnover

2024:

New hires

Not disclosed in the extracts provided.

Employee age distribution (2024)

Collective bargaining coverage

82% of all employees were covered by a collective agreement in 2024.

Board of Directors gender diversity

Board composition (2024):

• 6 members elected by Minister for Transport at annual general meeting (67% women, 33% men)
• 3 employee-elected members
• 56% of all board members (including employee-elected) considered independent

Executive Board gender composition

• Female: 1 (20%)
• Male: 4 (80%)
• Total: 5 members

Methodology notes

Number of employees: Total number of employees at 31 December 2024. Board of Directors not included.

Full-time employees (FTE): Calculated as average over the entire reporting period. FTE of 1.0 corresponds to full-time; FTE of 0.5 corresponds to part-time working half the hours.

Employee turnover rate: Calculated by dividing total departures during the period by total employees in the same period.

Age distribution: Based on all employees including Executive Board and management levels, calculated at 31 December 2024.

Ethnicity: 13.8% of employees represent ethnicities other than Danish (2024).

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

Disclosure

DSB acknowledges the inclusion of non-employee workers in certain processes but does not disclose quantitative data on the number or characteristics of non-employees in its own workforce.

Whistleblower scheme access

DSB's whistleblower scheme is available to employees, including temporary workers, contractors working at DSB and business partners. This confirms that contractors and temporary workers are part of DSB's workforce considerations, but no headcount or breakdown data is provided.

Methodology

No methodology for counting non-employee workers (headcount vs FTE) is disclosed.

Collective bargaining coverage and social dialogue

Collective bargaining coverage

The employment and pay conditions of DSB's employees are to a high degree determined by central collective agreements entered into with relevant trade unions in the transport sector and in industry.

As a member of Danish Industry (DI), DSB has adopted three of DI's industry-wide agreements: the Industrial Agreement (Industriens Overenskomst), the Collective Agreement for Salaried Employees in Industry (Industriens Funktionæroverenskomst) and the Railway Collective Agreement (Jernbaneoverenskomsten).

In addition, DSB has concluded three collective company agreements: a collective agreement covering sales assistants in DSB Service & Retail A/S' 7-Eleven stores, a collective agreement covering sales assistants in DSB Service & Retail A/S' 'Kaffeexpressen' and a collective agreement covering academic employees at DSB.

Due to DSB's membership of DI, the Management Agreement, an agreement concluded between the Confederation of Danish Employers and the Danish Association of Managers, Maskinmestrenes Forening and Dansk Formands Forening, applies to managers who are members of one of the organisations mentioned.

Distribution of employees by terms of employment (2024)

• 82 percent of all employees were covered by a collective agreement
• 13 percent of all employees were public servants, whose employment and pay conditions are determined by the Danish Employee and Competence Agency under the Ministry of Finance
• 5 percent of all employees were managers employed on contractual terms in accordance with the provisions of the Danish Salaried Employees Act

Collective bargaining coverage and social dialogue

Social dialogue arrangements

All employees employed under a collective agreement and public servants have access to workers' representatives and health and safety representatives.

Managers employed on a contract basis do not have workers' representatives.

All employees – except for managers employed on a contract basis – have workers' representatives, both in the form of health and safety representatives and union representatives. These representatives can raise concerns or demand that issues be discussed in collaboration forums, e.g. in the health and safety and joint consultation committees.

Due to their roles, health and safety representatives and trade union representatives enjoy special protection against dismissal.

Joint consultation committee

DSB has set up a structured and systematic collaboration with employees through a joint consultation committee. Half of the members of the committee are represented by management and the other half are employees.

The joint consultation committee holds four scheduled meetings annually in addition to any extraordinary meetings.

The members of the main joint consultation committee are representatives of DSB's Executive Board and senior trade union representatives from each trade union. DSB's CEO is chair of the committee, and the senior trade union representative of the union of Danish railway workers, Dansk Jernbaneforbund (DJF), is vice chair.

Employee group by type of employment

Accounting policies

Employees covered by collective agreement: All employee groups are categorised according to type of collective agreement. Collective agreements cover apprentices, trainees and hourly-paid workers. DSB employs 921 public servants, corresponding to 13 percent of the total number of employees.

Diversity metrics

Gender diversity on the Board of Directors

¹⁾ Employee-elected board members are not included.

Gender diversity on the Executive Board

Gender diversity at other management levels

In 2024, DSB's management levels 1 and 2 had 51 members, 20 of whom were women, accounting for 39 percent, or an increase of 9 percent compared to 2023.

Age band distribution of total workforce

Age distribution (visual representation shown in source):

• Below 30 years: 10%
• 30-50 years: 72%
• Above 50 years: 18%

Note: The exact year for the age distribution is not explicitly stated in the excerpt, but appears in the context of 2024 reporting.

Methodology notes

Board of Directors: Diversity on the Board of Directors is defined as the proportion of female board members relative to the total number of board members but not including employee-elected board members.

Executive Board: Diversity on the Executive Board is defined as the proportion of female members relative to the total number of members of the Executive Board.

Other management levels: Diversity at other levels of management is defined as the proportion of female members of management levels 1 and 2 to the total number of members. DSB's management level 1 represents all employees employed at the level of deputy director and who have HR responsibilities, while management level 2 consists of employees at level 1 and other employees at lower levels and who have HR responsibilities.

Target

DSB's target for women in management is 37 percent in 2025 and 40 percent by 2030.

Adequate wages

DSB states it is "committed to ensuring adequate wages for all employees" through two mechanisms:

1. All employees, except managers, are remunerated according to collective agreements and local agreements and according to individual salary regulation.

2. DSB has introduced a position structure across the organisation for all staff functions, including all managers, which enables comparison of pay for positions deemed to have the same content and equal complexity. This is done by applying a national benchmark from Mercer to all DSB positions.

Benchmark used

• Collective agreements and local agreements for non-managerial employees
• Mercer national benchmark applied to position structure for comparable positions

Coverage and scope

All employees are covered by the remuneration approach described. No specific percentage of employees assessed against a living wage benchmark is disclosed.

Equal pay analysis

The Remuneration Committee performs an annual analysis of equal pay at DSB, including analysis of pay gaps between genders. The pay gap is calculated at seven percent, with most wage differences in comparable positions explained by different educational backgrounds.

Pay ratio

The difference between the highest paid employee of DSB and the median of all other employees is a factor of 14.

Geographic scope

Primarily Denmark. Freedom of association and collective agreements referenced are specific to the Danish context.

Note: DSB does not disclose use of a living wage benchmark (as distinct from legal minimum wage or collective bargaining wages). The Mercer benchmark is a market comparison tool for position grading, not explicitly a living wage assessment.

Social protection

Coverage of social protection schemes

All DSB employees are covered by social security schemes such as:

• Danish Labour Market Supplementary Pension Fund (ATP)
• Arbejdsmarkedets Erhvervssikring (AES)

Sickness benefits

Full pay during illness:

• All employees except employees of DSB Service & Retail A/S with working hours of less than eight hours per week are entitled to full pay during absence due to illness
• Employees of DSB Service & Retail A/S with working hours of less than eight hours per week are entitled to sickness benefits (not full pay) during absence due to illness

Additional private insurance schemes

DSB has taken out:

• Private workers' compensation insurance for workplace accidents
• Private health insurance

Pension and disability coverage

All employees are covered by a pension scheme which includes:

• Pension savings
• Insurance cover for loss of earning capacity
• Disability insurance
• Death insurance

Scheme type

Coverage is provided through both:

• Public schemes (ATP, AES)
• Private schemes (workers' compensation, health insurance, pension with disability/death cover)

Specific exclusions

DSB Service & Retail A/S employees with working hours less than 8 hours per week: Entitled to sickness benefits only (not full pay during illness)

Health and safety metrics

Coverage of health and safety management system

100% of employees are covered by DSB's health and safety management system. The Health and Safety Policy and the health and safety management system cover all DSB employees and employees in DSB's value chain who perform tasks at DSB's locations.

Work-related fatalities and injuries

Absence due to illness

Methodology notes:

• LTIFR calculation: Lost time injury (LTI) refers to an injury sustained by an employee in connection with the performance of work tasks at the workplace, resulting in one or more working days lost. LTIFR is calculated by dividing the number of workplace accidents resulting in at least one full day of absence by million hours worked.

• Serious workplace accidents: Workplace accidents involving absence of more than 21 calendar days.

• Absence due to illness: Defined as average absence due to illness as a percentage of possible working hours. In 2024, DSB changed both the definition and calculation method to reflect the methodology applied in NETSTAT statistics issued by the Confederation of Danish Employers (DA) and Danish Industry (DI).

• Workplace accidents due to violence and threats: Number of workplace accidents with and without absence caused by violence and threats from external persons, calculated on the basis of incidents reported to HR Health & Safety.

• The 2023 comparative figures for LTIFR (previously reported as 11.1) and absence due to illness (previously reported as 5.2%) were restated to reflect the updated calculation methodology.

• All workplace accidents are reported regardless of whether they result in absence, with total workplace accidents recorded at 877 in 2024.

• No fatal accidents were recorded in 2024.

Compensation metrics

Pay gap

DSB is committed to ensuring equal pay between genders in the same jobs at the same level. Objective criteria are applied for pay supplements, pay grading and payroll reporting, including relevant work experience, profile and qualifications for the position concerned.

The Remuneration Committee performs an analysis of equal pay at DSB once every year. This analysis also involves an analysis of any pay gaps between genders.

Unadjusted gender pay gap: 7%

The majority of the highest paid positions are still filled by men; however, the proportion of men has decreased compared to prior years. Most of the wage differences in comparable positions may be explained by different educational backgrounds.

Remuneration ratio

The difference between the highest paid employee of DSB and the median of all other employees of DSB is a factor of 14 (14:1).

Methodology

Pay gap calculation:

((Average gross pay level male employees – Average gross pay level female employees)/Average gross pay level male employees) x 100

Remuneration ratio calculation:

Annual total remuneration for DSB's highest-paid individual/median of the employees' total annual remuneration (minus the highest-paid person).

Incidents, complaints and severe human rights impacts

Incidents of discrimination and harassment

In 2024, DSB recorded 26 cases related to discrimination, including harassment and abusive behaviour, and necessary measures were taken in all cases. All matters have been dealt with.

Breakdown by reporting channel:

• 1 report relating to discrimination, including harassment, was registered through DSB's whistleblower scheme. The case was referred to DSB's safety line and subsequently handled there.

• 26 reports relating to discrimination, including harassment, were registered through DSB's safety mailbox. Remedial action has been taken in all cases. In addition, 3 cases related to harassment were reported to the immediate superior and processed by DSB. In one case, DSB paid compensation of DKK 0.01 million for incidents of abusive behaviour. One concern was reported through DSB's whistleblower scheme, while three concerns were reported through DSB HR Negotiation & Employment Law.

• 8 concerns were reported through DSB HR Negotiation & Employment Law, of which 3 concerned discrimination, including harassment. Due to the nature of these concerns, they were referred to DSB's safety mailbox, which has taken the necessary measures in all matters. The remaining 5 cases related to other staff matters that cannot be characterised as discrimination, including harassment.

Severe human rights impacts

DSB did not register any cases of a serious nature relating to violation of human rights or violation of labour rights in 2024.

Fines, penalties and compensation

In one case in 2024, DSB paid compensation of DKK 0.01 million for incidents of abusive behaviour.

Grievance mechanisms

DSB has established multiple grievance mechanisms:

• Safety mailbox: For employees and other parties with work ties to DSB to report abusive behaviour, including bullying, harassment, violence and threats
• Whistleblower scheme: Available to both employees and stakeholders to report concerns either in their own name or anonymously
• DSB HR Negotiation & Employment Law: For reporting concerns related to employment relationships
• Workers' representatives: All employees (except managers employed on a contract basis) have workers' representatives in the form of health and safety representatives and union representatives

All reports are registered and examined. Reports through the whistleblower scheme are screened by an external law firm before being handed over to DSB's internal audit department.

Policies related to value chain workers

Supplier standards and requirements We demand high standards from all our suppliers and business partners. Not only in relation to the goods and services they provide, but also in relation to how they demonstrate social responsibility and treat their employees.

Human rights requirements Our suppliers must respect fundamental human rights, including the prohibition on the use of child labour and of forced labour or the exploitation of involuntary labour.

Ethical guidelines in contracts Ethical guidelines have been incorporated into our supplier contracts, which demand that suppliers meet occupational health and safety standards, maintain proper pay and working conditions and respect fundamental human rights, to mention just a few requirements.

Scope of application These requirements apply to all suppliers and business partners in DSB's value chain.

Policies related to affected communities

DSB has indicated that policies related to affected communities (S3-1) are not material to the organization.

According to the materiality assessment disclosed in the ESRS datapoint table, the following S3-1 disclosures are marked as "Not material":

• Human rights policy commitments (datapoint 16)
• Non-respect of UNGPs on Business and Human Rights, ILO principles or OECD guidelines (datapoint 17)
• Human rights issues and incidents (S3-4 datapoint 36)

No specific policies related to affected communities have been disclosed in the provided excerpts.

Processes for engaging with affected communities about impacts

Local community involvement in station improvements We involve local communities in and around the station improvements.

Civil engineering and construction projects In connection with our major civil engineering and construction projects, we minimise the risks of nature and biodiversity impacts through engagement of local communities in the form of public meetings and collaboration with the authorities on EIA processes and local development plans.

Local projects and partnerships DSB has launched a number of local projects to get more people in Denmark to take the train and reduce road congestion.

Example: Køge Municipality collaboration One of these projects is in Køge, where DSB and Køge Municipality in 2023 joined forces to make it more attractive to travel on public transport at work and in people's leisure time. The collaboration has helped us gain knowledge and data about the local conditions, enabling us to develop more relevant local marketing efforts.

The collaboration has contributed to overall passenger growth on the line between Køge and Copenhagen, and more local initiatives are on the way in Køge Municipality. These include an expansion of parking facilities at Køge Nord Station, which will make it more attractive for commuters on Zealand to take the train the last stretch towards Copenhagen.

Community feedback and response Also north of Copenhagen, a local project has made a difference for our customers. In the summer of 2024, it became free of charge to take bicycles on Kystbanen and on the regional trains between Elsinore, Copenhagen Central Station and Næstved. This project built on the positive experience gained from S-trains and required reconstruction of a number of coaches on the regional trains to increase their bicycle capacity from 4 to 16.

The project has been well received by our customers, who especially take advantage of the opportunity to bring their bikes free of charge on weekends. The Danish Cyclists' Federation is also pleased with the pilot project, which they would like to become a permanent arrangement.

Policies related to consumers and end-users

DSB has disclosed several policies relevant to consumers and end-users under ESRS S4-1.

International principles and conventions

DSB has endorsed and acts in compliance with internationally recognised instruments, including:

• The UN Global Compact
• The ILO Convention
• The UN Universal Declaration on Human Rights
• The European Convention on Human Rights

DSB's compliance with the above international principles is implemented in DSB's Corporate Social Responsibility Policy.

The company confirms non-respect of UNGPs on Business and Human Rights and OECD guidelines is addressed (referenced on page 118 in the data points table).

Accessibility Policy

Purpose and application: DSB's Accessibility Policy supports the company's ambition to build 'A sustainable way forward with room for all of us'. The company provides for the needs of different groups in society and offers assistance at stations to vulnerable people, among others, in the form of physical escort to and from the platform and help getting on or off the train.

Scope:

• The policy applies to all users wishing to use DSB's services
• The Accessibility Policy covers all DSB employees

Governance: The Executive Vice President, Finance and CFO of DSB is the owner of the policy, while the Executive Team has overall responsibility for approving the policy.

Monitoring Policy

Purpose and application: DSB's Monitoring Policy supports the company's strategy of ensuring that customers and employees should be able to move around freely and stay safe on trains, at stations, in workshops and other locations. The policy also defines the targets, framework and terms for building, maintaining and developing a robust and professional monitoring system across DSB's entities, which will safeguard DSB's values, support crime prevention efforts and ensure a sense of security for employees and customers.

Scope: The Monitoring Policy covers all DSB employees.

Governance: The Executive Vice President, Finance and CFO of DSB is the owner of the policy, while the Executive Team has overall responsibility for approving the policy. The policy is approved once annually and in case of significant changes.

Data Protection Policy

Purpose and application: DSB's Data Protection Policy lays down the framework for how the company handles data about employees and customers.

Scope: The Data Protection Policy covers all DSB employees.

Governance: The Executive Vice President, Procurement & Legal Affairs is the owner of the policy, while the Executive Team has overall responsibility for approving the policy.

Data Governance and Data Ethics Policy

Purpose and application: DSB's Data Governance and Data Ethics Policy supports the company's handling of data, including how data is managed as an asset in the governance of DSB, i.e. carefully according to their confidentiality, integrity and availability.

Scope: The Data Governance and Data Ethics Policy covers all DSB employees.

Governance: The Executive Vice President, Finance and CEO of DSB is the owner of the policy.

Safety Policy

Purpose and application: DSB's Safety Policy is the cornerstone of the company's safety management and safety culture. The policy underlines that safety is a fundamental prerequisite for everything DSB does. The policy is an integral part of daily work and aims to help prevent injuries, accidents and damage to equipment and infrastructure. The policy represents a promise to customers and business partners to take safety seriously.

Scope: The Safety Policy covers all DSB employees.

Governance: The day-to-day responsibility for the policy lies with the Chief Safety Officer, and the safety organisation contributes to awareness of the policy messages among DSB's employees. The Board of Directors of DSB has overall responsibility for approving the policy.

Processes for engaging with consumers and end-users about impacts

Customer engagement through multiple channels DSB engages with customers through various mechanisms:

Commuter engagement In pursuing our business activities, DSB collaborates with various stakeholders, including our customers and local communities (for instance in the form of meetings with commuter clubs and an annual commuter rally).

Digital engagement platforms

• DSB's app: Our largest sales channel with more than 1.8 million unique users, generating revenue to the tune of DKK 2.3 billion
• DSB Plus loyalty programme: More than 1.8 million customers now have a profile, with more than 1.2 million having signed up for the bonus programme

Customer experience and feedback

• We collect and implement valuable customer experience with a view to optimising operations management
• Regular reputation tracking and customer satisfaction monitoring (DSB's reputation score of 72.9 in 2024, above the average of 70.1)

Service accessibility

• It is still possible to buy tickets and other services at our stations, on our website and at our customer centres
• Customer centres provide direct access for customer inquiries and feedback

Station experience DSB manages and develops almost 200 stations across Denmark. Customers should feel well guided at clean and secure stations. In the period to 2030, we are investing more than DKK 1 billion in station improvements.

Safety and security initiatives

• We collaborate with the 'Natteravnene', a project that contributes to the sense of safety at the stations
• Partnership with 'Livslinien' on focused efforts to prevent suicide on the railway

Traffic information and communication Traffic information supports operations management by providing frequent information to our employees and customers. Traffic information is collected and disseminated in close collaboration with Banedanmark.

Taking action on material impacts on consumers

DSB references ESRS S4-4 disclosure on pages 119 and 121-122, addressing material impacts related to consumer security and safety. The company focuses on two main consumer impact areas: customer safety and customer security (safety on trains and at stations).

Customer Security Programme

Scope: Own operations (trains and stations)

Actions taken:

• Deployment of security guards on the S-train network, particularly during evening hours
• Installation of surveillance cameras at stations and on trains
• Operation of a safety line for customer support
• Awareness campaigns to promote knowledge of security measures among customers

Time horizon: Ongoing operational measures (no specific timeframe disclosed)

Resources allocated: Not quantified

Expected outcomes/KPIs:

• Customer security rating on trains: target level 8.7/10 (achieved in 2024)
• Customer security rating at stations: target level 8.2/10 (achieved in 2024)
• Note: DSB does not set long-term targets for customer security metrics

Accessibility Services

Scope: Own operations (train services)

Actions:

• Disability assistance services provided on DSB trains and for external train operators
• Child guide journeys offered on specific Friday and Sunday departures

Time horizon: Ongoing operational services

Resources allocated: Not quantified

Performance indicators (2024 vs 2023):

Policy linkage

Actions are linked to DSB's focus on creating "a secure atmosphere at our stations and on our trains" as stated in the materiality assessment. The company identifies "Impact on customer safety" and "Impact on customers' security on DSB's premises" as material topics under S4.

Risk mitigation approach

DSB addresses the identified material risk of "potential risk of negative impact on reputation" and "potential risk of loss of customers to other modes of transport" through enhanced security measures and inclusive travel experiences.

Business conduct policies and corporate culture

Ethical standards and governance As an independent public institution owned by the Danish State, DSB has a special obligation to maintain correctness and the highest ethical standards in our day-to-day operations and the way we operate our business.

Legal framework DSB is managed according to company law rules while being subject to public law rules regarding regulatory tasks. The Public Administration Act and the Danish Act on the Parliamentary Ombudsman apply to cases concerning employees and the railway activities carried out in the context of the provision of negotiated traffic.

Corporate culture development DSB's purpose 'A sustainable way forward with room for all of us' guides the corporate culture. We want to create a culture that makes our employees feel valued, recognised for their efforts, feel that they are being listened to and feel committed.

Five promises as guiding principles We support the strategy through our daily actions. We have therefore formulated five promises which are the guiding principles in our day-to-day work:

1. Customers arrive on time
2. A safe, simple and comfortable journey
3. Reasonable fares for everyone
4. DSB is run responsibly and efficiently
5. A more sustainable journey

The promises create coherence in decisions and daily choices, supporting the execution of our strategy and the realisation of our targets.

Workplace values We balance a will to act and create results with a focus on ensuring a sustainable working life where everyone feels included and valued. We are positive-minded, curious and implement changes with enthusiasm to make DSB better.

Transparency and disclosure DSB discloses information as soon as possible to the Danish Business Authority or other relevant parties on material matters concerning the company which may be assumed to be of importance to DSB's future, owner, business partners, creditors, employees or other stakeholders.

Management of relationships with suppliers

Supplier standards and requirements We demand high standards from all our suppliers and business partners. Not only in relation to the goods and services they provide, but also in relation to how they demonstrate social responsibility and treat their employees.

Contractual ethical guidelines Ethical guidelines have been incorporated into our supplier contracts, which demand that suppliers meet occupational health and safety standards, maintain proper pay and working conditions and respect fundamental human rights, to mention just a few requirements.

Human rights and labor standards Our suppliers must respect fundamental human rights, including:

• The prohibition on the use of child labour
• The prohibition on forced labour or the exploitation of involuntary labour
• Proper pay and working conditions
• Occupational health and safety standards

Strategic supplier relationships To ensure stable operations development, DSB invests in cutting-edge IT systems and maintains close relationships with key suppliers for:

• Rolling stock maintenance and supply of spare parts
• Infrastructure collaboration (e.g., with Banedanmark for traffic information)
• Technology solutions to support customer experience

Supplier performance management DSB works closely with suppliers to ensure delivery of goods and services that support the company's sustainability and operational objectives. This includes collaboration on:

• New electric rolling stock delivery and maintenance
• Workshop construction to sustainable standards (DGNB Gold certification)
• Technology development for improved customer solutions

Climate and environmental requirements We demand ambitious climate reduction targets from suppliers as part of our overall strategy to reduce the climate impact of our suppliers and ensure that emissions from all our activities reach net zero by 2050.

Incidents of corruption or bribery

Confirmed incidents

DSB reported zero confirmed incidents of corruption or bribery in 2024.

According to the company's disclosure: "We have no knowledge of or suspicion that anyone at DSB or our main suppliers was involved in corruption or bribery in 2024, and therefore there were no cases or fines."

Convictions and fines

No convictions or legal decisions (criminal or administrative) related to anti-corruption or anti-bribery laws were recorded in 2024.

No fines were paid for violations of anti-corruption or anti-bribery laws in 2024.

Disciplinary actions

No employees were dismissed or disciplined due to corruption or bribery in 2024.

Contracts terminated

No contracts with business partners were terminated or not renewed due to corruption or bribery in 2024.

Investigation and speak-up mechanisms

Whistleblower scheme: DSB operates a whistleblower scheme that allows employees, temporary workers, contractors, and business partners to report concerns either in their own name or anonymously. All reports are registered and screened by an external law firm before being handed over to DSB's internal audit department. The head of the internal audit function, who reports to the Audit Committee, administers the scheme.

In 2024, 20 reports were filed through the whistleblower scheme. None of these concerned corruption or bribery. The 8 cases taken under active consideration concerned other matters such as harassment, discrimination, insufficient financial responsibility, fraud, data disclosure, and intoxicated employees.

Anti-corruption approach: DSB has zero tolerance of corruption and bribery and takes a risk-based approach to procurement. When entering into contracts with suppliers, DSB requires compliance with Ethical Guidelines that include anti-corruption requirements. In 2024, DSB conducted a risk assessment of its largest and most important suppliers, which showed that 95% stated they have a policy to ensure their business is not involved in corruption, money laundering, or terrorist financing.

Training: All employees who make purchases must complete e-learning courses covering DSB's Procurement Policy, responsibility, and ethical guidelines. All new employees must complete a Corporate Social Responsibility e-learning module as part of onboarding, which includes DSB's rules for receiving gifts. An awareness campaign was published in November 2024 focusing on rules for receiving gifts.

DSB is a member of Danish Industry (DI) and subject to EU public procurement rules. All purchases are handled through the procurement department with system-supported follow-up on compliance with policies, guidelines, and processes. Approximately 400 employees (6% of all employees) are requisitioners who have direct contact with suppliers.

Payment practices

Payment terms

DSB's general payment terms are 30 days net, which applies to 87 percent of all DSB's suppliers. The payment terms do not distinguish between suppliers on the basis of their size and/or geographical location. Thus, for small and medium-sized undertakings, the same terms apply as for large enterprises.

Average payment time

The average payment time was 34 days for all suppliers in 2024.

On-time payment performance

Most of the payments, corresponding to 89 percent, were made on time. Where the payment terms are not met, corresponding to 11 percent, this is typically due to disagreement about delivery, quality of the goods or objections to the invoice.

Legal proceedings

There are no pending legal proceedings regarding late payment.

Accounting policies

Data from DSB's financial system showing both the invoice due date, which is the day the invoice must be paid, and the settlement date, which is the day the amount is charged to the bank account. The difference between payment dates shows the number of invoices paid on time / late. Average number of days is for all suppliers.

Data also show that a large proportion of invoices are paid on the due date stated on the invoice. That could for instance be current month or 14 days net.

Invoices and payment times from small and medium-sized enterprises have not been determined separately. The same terms apply as for large enterprises.