DSV A/S

Governance roles

Reference: pages 32-34, 44.

DSV has a Board of Directors (seven members) and an Executive Board (CEO, CFO, COO). "The Board of Directors outlines and supervises the overall vision, strategy and objectives for the Group's business activities. The Executive Board is responsible for the execution of these activities and for the day-to-day management of the Group" (page 32).

Board committees: Audit, Nomination and Remuneration Committees. "The Board have delegated the responsibility for sustainability reporting and compliance with applicable regulation to the Audit Committee. Additionally, the Audit Committee assesses the effectiveness of the measures used to manage IROs across all material topics" (page 44).

Operational layer: a Sustainability Board "chaired by our CEO, the Sustainability Board consists of the Executive Board, divisional CEOs and other management representatives with sustainability expertise... In 2025, all DSV's material IROs were on the agenda to track progress" (page 44).

Composition and diversity (page 33-34): of the seven Board members, six are independent (86%); three are female (43%, equal gender balance under the Danish Gender Balance Act); the three-member Executive Board is currently all male (0% underrepresented gender).

Information to administrative bodies

Reference: page 44.

"Sustainability performance is continuously monitored, and key metrics are reported quarterly to the Executive Board and the Board of Directors." The Sustainability Board (chaired by the CEO) tracks all of DSV's material IROs: "In 2025, all DSV's material IROs were on the agenda to track progress."

Governance of the double materiality assessment sits with the same bodies: "The final list of material topics is reviewed by internal subject matter experts and the Executive Board and approved by the Audit Committee. The DMA is reviewed and updated annually, and any changes in material IROs are presented for approval by the Audit Committee" (page 46).

The 2025 DMA review specifically considered whether the Schenker integration triggered new material IROs, and its conclusion (no new material IROs) was presented through this same governance chain (page 46).

Sustainability in incentive schemes

Reference: page 44.

"Of the total variable share options up for grant in 2025, 20% were based on achievement of sustainability targets set for the benchmark year 2024. Sustainability targets included greenhouse gas (GHG) scopes 1 and 2 reduction target for 2024 compared to the baseline year and various other GHG scope 3 reduction initiatives."

"In order to link sustainability performance with management compensation, variable remuneration to the Executive Board is partly determined based on sustainability targets. These are set in dialogue with the Remuneration Committee and the Chairman of the Board of Directors."

The responsibility for specific topics such as remuneration and diversity is delegated to the Remuneration and Nomination Committees respectively.

Statement on due diligence

Reference: page 150, cross-referencing pages 44-48, 51-60, 67-75, 79-82.

DSV's "Statement on sustainability due diligence" maps the ESRS core due-diligence elements to specific sections: (a) embedding into governance/strategy/business model -> Sustainability governance (p.44) and the DMA (pp.46-48); (b) engaging affected stakeholders -> Engaging with stakeholders (p.45), the DMA (pp.46-48) and Being a people business (pp.67-68); (c) identifying and assessing negative impacts -> the DMA (pp.46-48); (d) taking actions -> Environmental information (pp.51-60), Social information (pp.67-75) and Governance information (pp.79-81); (e) tracking effectiveness -> Environmental data (pp.61-64), Social data (pp.76-78) and Governance data (p.82). A footnote states this page "refers to ESRS GOV-4 paragraphs 30 and 32."

Incorporated by reference to the Corporate Governance chapter: GOV-1 datapoints 20a/21a/21d/21e on Board composition, independence and diversity (pp.32-34).

Risk management and internal controls

Reference: page 44.

"Compliance is supported by internal audits and, where relevant, external audits for sites that have elected to certify their management systems according to ISO standards. Our control environment is established through detailed guidelines, a clear organisational structure and well-defined responsibilities."

"DSV's sustainability metrics are governed by a robust sustainability accounting framework which covers reporting approach and methodology, verification and data management process, and controlling." Operational management of IROs "rests with relevant divisional and country management, while Group functions are responsible for ensuring consistent sustainability practices by implementing an appropriate framework."

The sustainability statement as a whole was subject to a limited assurance engagement by PwC under ISAE 3000 (Revised) (pages 147-148).

Business model and value chain

Reference: page 11, cross-referencing page 47 (material impacts overview).

"DSV is the world's largest freight forwarding and logistics company, operating primarily in the global business-to-business market... While we do warehousing activities based on leased facilities, the transportation of goods is handled by third parties." The business model is described as "flexible and asset light."

Value chain (origin to destination): freight forwarding services (shipment booking, pick-up, warehousing, documentation and customs clearance, cargo consolidation) and logistics/distribution services (picking/packing, labelling, distribution, e-commerce fulfilment, 4PL), with actual transport subcontracted to "container carriers, airlines, road hauliers and railway operators" (page 11).

Services span Road, Air & Sea and Contract Logistics divisions across more than 90 countries, serving verticals including Aerospace and Defence, Automotive, Consumer, Healthcare, Industrials and Technology (page 11). The 2025 Schenker acquisition materially expanded scale: "approximately 150,000 employees (FTE) across more than 90 countries" post-integration (page 67).

Phase-in note: quantitative disclosure under ESRS 2 SBM-1 used the ESRS 1 section 10.4 / Omnibus quick-fix phase-in provision in 2025 (page 50).

Stakeholders

Reference: page 45.

Key stakeholder groups and engagement channels (page 45): Customers (market reviews, tender processes, Net Promotor System, ongoing business dialogue up to Executive Board level); Suppliers including freight carriers (dialogue from local/divisional management to the Executive Board); Employees (DSV Global People Survey, manager dialogue); Investors and rating agencies ("more than 500 investor meetings annually", conference calls, roadshows, Capital Markets Day); Authorities (ongoing bilateral engagement nationally and internationally).

"Stakeholder perspectives are continuously considered and presented to the Executive Board and to the Board of Directors as part of their annual review of DSV's Sustainability Strategy." The 2025 dialogue and analysis "confirmed that our current business model and Sustainability Strategy align with stakeholder expectations, requiring no significant amendments" (page 45-46).

Material IROs

Reference: pages 46-48.

DSV's DMA identified nine material topics (pages 47-48): Climate change mitigation and Air pollution (negative impacts, own operations and value chain, actual and potential, "particularly due to scope 3 emissions"); Waste management (negative impact, both, both) - "as a company whose primary economic activity is planning of transportation activities, DSV does not have any significant resource inflows and outflows other than waste"; Working conditions and work-related rights, Employee attraction and development (positive impact and risk, own operations), Diversity and inclusion, Health and safety (material for "both DSV's own workforce and workers in the value chain"); Business integrity (impacts from corruption/bribery plus "risks related to non-compliance with policies and regulations," both own operations and value chain); Supplier relations (positive impact, value chain).

"Although none of the identified climate risks or opportunities exceed the materiality threshold, we continue to monitor and manage these" (page 47). In 2025, two ERM-sourced risks (employee attraction/retention; non-compliance with sustainability regulation) were folded into the DMA. Water and biodiversity were screened and found immaterial (page 48). DSV reports entity-specific metrics (not separate topics) on climate, waste, diversity, turnover and business integrity.

IRO identification process

Reference: pages 46-48.

"Our DMA process consists of three steps - mapping, identification and rating - in order to determine which impacts, risks and opportunities (IROs) are material to our business model." Time horizons: short-term (current year), medium-term (up to 5 years), long-term (beyond 5 years).

Inputs: "stakeholder dialogue and internal and external sources, including DSV and third-party data, due diligence findings, peer and sector studies, media monitoring, risk surveys and scientific research. The assessment prioritises own and third-­party data." Rating scale 1-5 for scope, likelihood and irremediability (impacts) or likelihood and magnitude (risks/opportunities); "Positive impacts are identified and rated only when they reflect a net benefit beyond standard practice, excluding any mitigating actions."

Climate-specific methodology (page 47): location-specific physical-risk analysis across DSV's country operations using "the Intergovernmental Panel on Climate Change's (IPCC) low- and high-emission scenarios ranging from optimistic (limit warming to 1.5°C) to dangerous (approximately 4.4°C)"; transition risk reviewed via regulatory/policy developments, low-carbon technology shifts and ESG-rating/investment-focus shifts.

ESRS disclosure index

Reference: page 149.

DSV publishes an "ESRS disclosure index" (pages 149-150) stating it "lists the ESRS disclosure requirements in ESRS 2 and the seven topical standards which are material to DSV," mapping each disclosure requirement to a page reference (incorporation by reference marked with an asterisk). The index lists all ESRS 2 cross-cutting DRs (BP-1/2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2) and the topical DRs disclosed for E1, E2, E5, S1, S2 and G1.

A companion "Datapoints from other EU legislation" table (pages 151-153) cross-references individual datapoints required under SFDR, Pillar 3, the Benchmark Regulation and the EU Climate Law to their ESRS disclosure requirement and page, and separately flags datapoints assessed as not material (shown with a dash and no page), including specific E1, E3, E4, S3 and S4 datapoints.

Climate change transition plan

Reference: pages 53-56.

"DSV remains committed to reaching net-zero greenhouse gas (GHG) emissions across all scopes by 2050. Our near-term target for 2030 requires us to reduce emissions under our direct control (scopes 1 and 2) by 50% and emissions from our value chain (scope 3) by 30% compared to our 2019 baseline" (page 52). "Our near-term targets was validated by SBTi in 2023, and in 2025, our long-term net-zero target also received formal validation" (page 52).

The transition plan operates through a decarbonisation roadmap of named levers (energy efficiency, phasing out fossil fuels, sustainable fuels, low/zero-emission trucks, renewable energy and charging infrastructure, partnerships and book-and-claim models), financed in part by a Carbon Fee Funding Programme: "since the launch of the Carbon Fee Funding Programme in 2023, 107 projects have been approved. The programme has supported DKK 433.2 million towards investments in our decarbonisation roadmap" (page 53).

2019 baseline was recalculated in 2025 to incorporate Schenker (page 52). Progress: "Total reduction in scopes 1 and 2 emission since 2019 has now reached 20%" (page 57), against a 2026 interim target of 28%.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report (pages 46-47). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

DSV names the scenario range used for physical risk: "DSV has applied the Intergovernmental Panel on Climate Change's (IPCC) low- and high-emission scenarios ranging from optimistic (limit warming to 1.5°C) to dangerous (approximately 4.4°C) to determine climate IROs" (page 47), covering the high-emission-scenario element of paragraph 17(a)(i) in substance, though naming an IPCC pathway range rather than a specific code (e.g. SSP5-8.5).

For transition risk, the report describes a qualitative review, not a named 1.5°C-aligned scenario: "we review global regulatory and policy developments, including... emerging low-carbon technologies, changes in market demand... reputational risks for DSV and shifts in ESG ratings and investment focus" (page 47). No named transition scenario (e.g. IEA NZE 2050) or temperature projection is given - a gap, not one the company flags itself.

Scope: own operations and upstream/downstream value chain, for "a selection of DSV's operations in each country based on their relative importance to global supply chains" (page 47). Result: "none of the identified climate risks or opportunities exceed the materiality threshold" (page 47).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3, where this content is disclosed in the FY2025 report (page 47). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

DSV states plainly that climate risk did not clear its materiality bar: "Although none of the identified climate risks or opportunities exceed the materiality threshold, we continue to monitor and manage these through our due diligence and governance processes" (page 47). No quantified resilience analysis (e.g. scenario-adjusted financial-statement sensitivity) is presented, consistent with that finding.

The qualitative basis for resilience instead rests on the business model itself: "Our asset-light business model provides resilience against physical and transitional climate risks" (page 47) - DSV does not own the transport assets (aircraft, vessels, the bulk of its truck fleet) that carry the largest physical exposure, and third-party freight carriers bear much of the direct climate-risk exposure.

No explicit statement addresses capacity to redeploy or adjust capital, or uncertainty in the underlying assessment - those elements of paragraph 19(b)-(c) are not covered in the report.

Climate policies

Reference: page 51.

Key policies cited under the Climate change mitigation topic (page 51): Sustainability Policy, Building Design Manual, DSV Energy Manual, and "Manuals for energy procurement, including renewable energy and sustainable fuels."

"Our commitment to net-zero emissions in 2050 is described in our Sustainability Policy. We employ supporting processes, manuals, and scalable products and services to effectively translate our ambitions into actions and maintain momentum on our decarbonisation journey" (page 51).

Building-specific policy requirements: "we set strict standards for building design whenever we commission a new real estate project... all new buildings must be able to achieve a 'gold' certification under at least one sustainable construction standard, including DGNB, LEED or BREEAM" (page 55). A fuel-procurement policy restricts biofuel sourcing: "DSV's alternative fuel procurement policy allows only second-generation (non-food biomass) fuels and prohibits the use of first-generation crops and woody biomass" (page 54).

Climate actions and resources

Reference: pages 53-56.

Four decarbonisation levers, in order of impact (pages 53-55): energy efficiency and optimisation (network/route optimisation, LED lighting across "approximately 2,200,000 m2" of facilities); phasing out fossil fuels (sustainable aviation fuel and marine biofuel via a book-and-claim insetting model, more than 600 best-in-class diesel trucks, more than 500 low- and zero-emission vehicles including battery-electric trucks); renewable energy production and charging infrastructure (46 MWp of new renewable generation capacity in 2025, Battery Energy Storage Systems, expanded EV charging); innovation and partnerships (Clean Cargo Working Group steering committee, Smart Freight Centre's Clean Air Transport Initiative and Road Book and Claim community).

Resourcing: the Carbon Fee Funding Programme has backed "107 projects" and "DKK 433.2 million" of investment since 2023 (page 53), split across solar (54.8%), low/zero-emission vehicles (21.0%), electric forklifts (7.6%), sustainable aviation fuel (5.3%), LED (4.1%) and electric operating equipment (3.6%) (page 53). DSV Energy highlights for 2025 include a new BREEAM-Excellent facility in Moerdijk with 8 MWp solar and 14 MWh of BESS in Horsens and Landskrona (page 55).

Climate targets

Reference: pages 51-52.

Near-term (2030, vs 2019 baseline): "reduce emissions under our direct control (scopes 1 and 2) by 50% and emissions from our value chain (scope 3) by 30%." A 2026 stepping-stone target was added in 2025: "a short-term target to achieve a 28% reduction in scopes 1 and 2 in 2026 against the updated baseline" (page 57). Long-term: "carbon net-zero across all emission scopes" by 2050.

"The scopes 1 and 2 targets are aligned with a 1.5°C global warming scenario, while the scope 3 targets are aligned to a well-below 2°C scenario" (page 52) - scope 3 is explicitly not claimed as 1.5°C-aligned. Targets follow an "assumed annual activity growth rate of 3%" and were "validated by SBTi" (near-term in 2023, long-term net-zero in 2025) (page 52).

Target boundary: scopes 1 and 2 in full, plus scope 3 business travel and subcontracted transport - "the remaining GHG scope 3 categories... account for only roughly 2% of our total Scope 3 footprint in 2019 and are considered immaterial" (page 51).

Energy consumption and mix

Reference: page 63.

Total energy consumption rose from 1,390 GWh (2024) to 2,738 GWh (2025), reflecting the Schenker acquisition: fossil sources 2,111 GWh, nuclear 38 GWh, renewable 589 GWh (page 63).

"With more than 69 GWh self-generated electricity in 2025, our total renewable electricity share reached 53%, which is a 9 percentage point increase compared to 2024" (page 57). The renewable fuel/biofuel share of fleet fuel rose to 11% (2024: 6%). Energy intensity was 11.1 MWh/DKKm (2024: 8.3).

Methodology: "Total energy represents all energy coming from fuels, electricity, district heating and cooling consumed by DSV across all our activities," split into fossil, nuclear and renewable; purchased-energy shares are determined from supplier agreements or, failing that, the GHG Protocol market-based scope 2 hierarchy (page 63). Energy metrics including discontinued operations are footnoted separately (461 GWh total, 443 GWh fossil).

GHG emissions

Reference: pages 61-62.

2025 gross emissions ('000 tCO2e): Scope 1 362 (2024: 202); Scope 2 market-based 215 (2024: 167), location-based 274 (2024: 205); Scope 3 total 19,031 (2024: 13,440), of which category 4 (subcontracted transport) 18,297 and "Other categories" 732. Total GHG emissions market-based: 19,608 (2024: 13,809). The increase is driven by Schenker, included "for only eight months of the year" (page 57).

Methodology: scope 1 and 2 follow the GHG Protocol with DESNZ (2025) emission factors; scope 3 category 4 (the dominant category at >95% of scope 3) uses the EcoTransIT World calculator aligned to ISO 14083 and the GLEC framework, with "a 10% add-on factor" applied to offset shorter calculated vs. real routing distances (page 49). "The only area to be regulated under ETS relates to fuel consumption from vessels and aircrafts," which DSV neither owns nor operationally controls, so scope 1 ETS coverage is 0% (page 61).

Internal carbon pricing

Reference: pages 62-63.

DSV runs an internal Carbon Fee Funding Programme: "we introduced a carbon fee on our transportation activities based on their respective emissions. The aim of this initiative is two-fold: firstly, to incentivise carbon reduction efforts across our operations. Secondly, the fee provides ear-marked financing for our decarbonisation initiatives" (page 53). "The carbon fee is designed to ensure that the DSV entities emitting the most CO2 pay the highest carbon fee" (page 53).

2025 emissions covered by the programme ('000 tCO2e): Scope 1, 168 (46.3% of scope 1 emissions); Scope 2, 150 (69.6%); Scope 3, 12,692 (66.7%) (page 63) - each coverage percentage fell year-on-year (2024: 95.0%/100.0%/96.5%) as Schenker volumes diluted the covered base. "Emissions from company cars, business travel and scope 3 other categories are not covered by DSV's carbon pricing programme" (page 62).

No per-tonne internal carbon price (DKK/tCO2e) is disclosed; the programme is described by coverage share and cumulative funding raised ("DKK 433.2 million" since 2023, page 53), not a stated shadow price.

Pollution policies

Reference: page 59.

"DSV's Sustainability Policy addresses air pollution, alongside other environmental commitments. Additionally, air pollution is monitored and managed as part of our integrated EMS and ISO 14001 certification." Incident handling runs through the Group Crisis Management Policy, and "DSV's Dangerous Goods and Hazardous Materials Policy sets the framework for preventing environmental impact from unsafe handling of dangerous goods" (page 59). Key policies listed: Sustainability Policy, Crisis Management Policy, Group Dangerous Goods and Hazardous Materials Policy, Building Design Manual, DSV Energy Manual, and fuel/energy procurement manuals.

Pollution actions

Reference: page 59.

"Reducing air pollution is closely linked to our climate mitigation strategy and decarbonisation roadmaps, as both rely heavily on reducing fossil fuel combustion. In most cases, eliminating fossil fuels will have a beneficial impact on air quality." Air-pollution mitigation is therefore delivered through the same decarbonisation actions reported under E1 (pages 51-58), plus EMS/ISO 14001 oversight: "171 internal EMS audits, 529 (42%) ISO 14001 certified locations, 96 third-party ISO 14001 audits" (page 59, legacy DSV scope). "In 2025, we recorded no major accidents or environmental violations."

A named fleet action: "with the integration of Schenker, DSV now operates the largest fleet of BEVs in Europe... operating more than 400 electric trucks" (page 60).

Pollution targets

Reference: page 59.

No standalone numeric air-pollution target is stated; the topic panel lists the same actions (decarbonisation roadmap, Carbon Fee Funding Programme, EMS/ISO 14001 audits) as the mechanism for managing air pollution, and the report ties pollution management explicitly to the E1 climate targets: reducing fossil-fuel combustion under the 2030/2050 GHG targets "will have a beneficial impact on air quality" (page 59). No separate target trajectory (e.g. a NOx/SOx/PM reduction percentage) is set or disclosed.

Air pollution metrics

Reference: page 64.

"Total reported air pollutants from DSV's direct energy consumption related to own operations from buildings, own fleet, and company cars increased in 2025 compared to 2024. The increase is driven by a greater volume of road operations following the Schenker acquisition" (page 60). 2025 figures: NOx 574.3 tonnes (2024: 401.3, +43%); SOx 1.1 tonnes (2024: 0.7, +57%); PM 9.0 tonnes (2024: 5.5, +64%) (page 64).

Methodology: "NOx, SOx and PM emissions are based on scope 1 energy consumption multiplied by emission factors from EMEP/EEA Air Pollutant Emission Inventory Guidebook and GREET model from Argonne National Laboratory" (page 64). Only direct (scope 1) pollutants from owned/controlled sources (buildings, owned/leased fleet, company cars) are measured; third-party subcontracted transport pollutants are out of scope.

Resource use and waste policies

Reference: page 60.

"DSV's Sustainability Policy addresses... Our stand-alone Waste Management Policy establishes detailed standards for the handling of waste in accordance with the EU Waste Framework Directive. These policies aim to reduce waste, promote recycling and reuse, and ensure that hazardous materials are safely stored, handled and disposed in order to prevent negative impacts on the environment... and on people" (page 60). As a freight-forwarding and contract-logistics company, "DSV does not have any significant resource inflows and outflows other than waste," and the policy framework is correspondingly scoped to waste rather than raw-material circularity (page 48).

Waste actions

Reference: page 60.

"In 2025, our main focus has been to establish an effective governance framework that supports the achievement of our 2030 target... actively cascading targets across the organisation, enhancing data quality and identifying concrete actions at both divisional and regional levels." Following the Schenker integration, "findings from the assessment indicated that waste management performance and maturity levels at both Schenker and DSV are comparable" (page 60).

Named waste-reduction initiatives: "printing of barcodes directly onto boxes, thereby eliminating the need for separate labels; repurposing cardboard waste as fill-in materials; and introducing paper tape to reduce plastics and packaging waste" (page 60). Supported by the same EMS/ISO 14001 framework used for E2 ("171 internal EMS audits, 529 (42%) ISO 14001 certified locations").

Waste target

Reference: page 60.

"Our goal is to prepare 60% of our total waste for reuse and recycling by 2030 against a 2024 baseline." The company flags the dependencies involved: "Achieving this target is dependant on the development of national and regional waste handling infrastructure in the countries where we operate, strengthening of our supplier networks, and building partnerships at local and regional levels" (page 60).

2025 performance against the target: "the share of waste prepared for reuse and recycling reached 52.1% in 2025. The combined data for this year is slightly lower than last year's figure of 52.8%, which represented DSV only," attributed to the Schenker acquisition scattering waste streams geographically (page 60).

Resource outflows

Reference: page 64.

DSV's resource outflows are, per its own materiality screening, essentially limited to waste (page 48). The quantified outflow data is the waste-composition table: total waste generated by own operations, 129,986 tonnes in 2025 (2024: 66,266), split 2,253 tonnes hazardous and 127,733 tonnes non-hazardous (page 64). 88,839 tonnes (68%) were diverted from disposal and 41,147 tonnes directed to disposal.

"As DSV generates waste from packaging materials used in transportation and warehousing operations, proper waste management is a material environmental topic" (page 60); hazardous waste (2,253 tonnes) arises mainly from operational handling rather than product outflows, consistent with the asset-light, no-significant-inflows finding above.

Waste

Reference: pages 64-65 (waste metrics tables); accounting policies page 64.

Total waste generated (tonnes): 129,986 (2025) vs 66,266 (2024) vs 70,349 (2023), split hazardous 2,253 / non-hazardous 127,733 (2025) (page 64).

Diverted from disposal: 88,839 t total - hazardous: preparation for reuse 18, recycling 392, other recovery 389; non-hazardous: preparation for reuse 1,171, recycling 66,662, other recovery 20,740 (page 64-65).

Directed to disposal: 41,147 t total - hazardous: incineration, landfill, other disposal 1,454 t directed to disposal; non-hazardous: incineration 3,991, landfill 34,531, other disposal 1,171 (page 65).

Share of waste prepared for reuse and recycling: 52.1% (2025) vs 52.8% (2024, legacy DSV only) vs 49.9% (2023) (page 65). "DSV waste treatment 2025: reused and recycled 52%, landfill 28%, other recovery methods 16%, incineration 3%, other disposal methods 1%" (page 60). Methodology follows EU Waste Framework Directive categories and EU Directive 2008/98/EC Annex III for hazard classification (page 65).

Own workforce policies

Reference: pages 67-75.

Key policies (page 67): Sustainability Policy, Code of Conduct, Policy for Succession Planning and Senior Recruitments, Global Learning & Development Policy, Global Employee Benefit Policy, Diversity & Inclusion Policy, Human Rights Policy, Health & Safety Policy.

"Our approach is guided by several global policies that establish minimum global standards for human rights, working conditions, diversity and inclusion, and health and safety" (page 67). The Human Rights Policy addresses forced labour, child labour, passport retention, recruitment fees, discrimination, working hours, living wages and collective bargaining (page 73), and applies "to the entire DSV Group" with Board oversight of implementation.

Engaging with own workforce

Reference: pages 67-68.

"We have established various processes to ensure that employees are informed about strategic and employee-related developments, and to facilitate ongoing dialogue between management and employees," including "workers councils, engagement surveys, collective bargaining, and continuous performance and development dialogues" (page 67-68). "In 2025, 41% of DSV's employees globally were covered by collective bargaining agreements, compared to 30% in 2024" (page 68).

"We also conduct annual employee surveys, where all employees are invited and encouraged to participate and share their perspectives. In 2025, the survey focused on our employees' experiences concerning the integration process." "Our Group People & Organisation (P&O) function tracks the results and ensures that all teams engage in follow-up dialogues" (page 68).

Remediation channels

Reference: pages 67-68, 80.

"DSV's whistleblower system, Integrity Line, is also available to ensure that anyone, DSV employees as well as third parties, can securely and anonymously report concerns or knowledge of misconduct" (page 68), hosted "by an external, independent provider" and "available in 42 languages" (page 81). The Whistleblower Policy "prohibits any form of retaliation against anyone who has raised a concern in good faith."

Other channels: direct manager, P&O, local management. "In 2025, we registered 551 cases through DSV Integrity Line representing a 101% increase compared to 2024" (page 81), of which 60 were substantiated, 440 unsubstantiated/out of scope and 51 remained open at year-end.

Actions on own-workforce impacts

Reference: pages 67-75.

Diversity and inclusion: mandatory D&I e-learning for managers and P&O staff, a dedicated D&I working group, and the "Women in Leadership" programme (page 70-71). Employee attraction/development: DSV Academy training (online, leadership, sales, operational, compliance), ">1,060,000 hours of learning activities completed" and ">35,000 generic e-learning activities" in 2025 (page 69).

Health and safety: a four-pillar Occupational Health & Safety Management System ("Safe Systems, Safe People, Safe Equipment, Safe Workplace"), "156 internal health and safety audits" and "90" third-party ISO 45001 audits in 2025 (page 75). Human rights: an annual four-step Human Rights Programme (global risk assessment, self-assessment, corrective actions, training); "in eight entities, corrective actions were implemented to address identified incidents of non-conformities" out of ten assessed in 2025 (page 73).

Own-workforce targets

Reference: pages 67-75.

Diversity: a three-tier global target for women at senior management levels by 2030; "in 2025, the proportion of female managers was 35%, which is on par with 2024 at 35%" (page 70-71). Separately, "DSV A/S has set a target to increase the proportion of women at other management levels to 27% by 30 June 2026" (page 33).

Health and safety: "Legacy DSV 2025 target for maximum work-related accidents was 3.5. The target for 2026 is a maximum of 6.0 work-related accidents per million working hours. We maintain our target of zero fatalities" (page 75). The 2025 rate came in at 6.0 (2024 legacy DSV: 3.9), and one fatality (a driver in South Africa) was recorded against the zero-fatality target (page 75).

Employee characteristics

Reference: page 76.

Total employees (FTE): 151,751 (2025) vs 73,338 (2024) vs 73,577 (2023); headcount 137,504 (2024: 65,810). By region (headcount): Europe 71,763, Middle East/Africa 13,496, Asia Pacific 26,533, Americas 25,712; major countries Germany 17,801, United States 14,852 (page 76). By gender: male 85,133, female 52,127, other 10, not reported 234.

"With the integration of Schenker in 2025, we almost doubled the number of our colleagues to approximately 150,000 employees (FTE) across more than 90 countries" (page 67). Contract type: 93% permanent, 7% temporary, "close to 0%" non-guaranteed hours. Employee turnover: 20.9% (2024: 20.2%), 15.4% adjusted for synergy-related terminations.

Diversity metrics

Reference: page 77.

Top management (Executive Board + Group Executive Committee) gender distribution, 2025: 92% male, 8% female (2024: 100% male, 0% female) (page 77). Senior-management tiers (page 70-71): Executive Board/Group Executive Committee/EVP tier at roughly 15% female, rising through the EVP/VP/Managing Director tier (~25-28%) to the Director/Senior Manager tier (~30%), against a 2030 target trajectory.

Workforce-wide: 38% female / 62% male (page 67). Employee age distribution: under 30 years 19%, 30-50 years 57%, over 50 years 24% (2024: 21/58/21) (page 77). Headcount by contract type and gender is also tabulated (permanent: male 78,848, female 48,356; temporary: male 5,945, female 3,592) (page 71).

Adequate wages

Reference: page 77 (accounting policy); result disclosed page 69.

"In 2025, we conducted an analysis of remuneration practices across employee groups. The assessment confirmed that all employees receive adequate wages" (page 69) - i.e. 0% of employees paid below the adequate-wage threshold.

Methodology: "an employee's wage is considered adequate when it meets or exceeds the applicable statutory minimum wage in the country of employment. Where no applicable minimum wage exists, the relevant collective bargaining agreement (CBA) rate is applied. If neither a statutory minimum wage nor an applicable CBA rate is applicable, the living wage benchmark as defined by the Fair Wage Network database, is used" (page 77). The disclosure was newly introduced in 2025: "A new disclosure on adequate wages has been introduced in line with ESRS S1-10, based on the 2025 DMA results" (page 50).

Health and safety metrics

Reference: page 78.

Own workforce covered by health and safety management system: 100% (2025, 2024, 2023) (page 78). Work-related accidents (number): 1,458 (2025: employees 1,198, non-employees 260); rate 6.0 per million hours worked (employees 5.8, non-employees 7.0) (page 78). Fatalities: 1 in 2025 (non-employee; 0 employees) (page 78); "we regretfully reported one fatality involving a DSV driver in South Africa" (page 75).

37% of legacy-DSV locations (472 sites) are ISO 45001 certified, with 156 internal and 90 third-party (Bureau Veritas) health and safety audits in 2025 (page 75). Phase-in note: the specific sub-datapoint "number of work-related ill health cases and number of days lost due to injuries, accidents, fatalities and work-related ill health" was deferred under the ESRS 1 / Omnibus quick-fix phase-in relief in 2025 (page 50) and is not quantified here.

Compensation metrics

Reference: page 77.

"In 2025, the average salary of female employees was 5.6% lower than the average male salary" (2024: 3.9%) (page 71, 77). "In 2025, the CEO remuneration ratio compared to median DSV employee salary was 137" (2024: 102) (page 71, 77).

Methodology: the pay gap "represents the percentage difference between the average hourly wages of male and female employees, based on the male average pay... incorporating both hourly and salaried employees"; the remuneration ratio "compares the annualised pay of the Group CEO with the median of all employees, both hourly and salaried, excluding CEO" (page 77). Estimation approaches for variable remuneration are described in the Basis for Preparation (pages 49-50), noting improved 2025 data availability for variable pay by gender and authorisation level.

Incidents and complaints

Reference: page 78.

"Local P&O functions reported a total of 39 confirmed work-related cases of discrimination and harassment across our global operations [in 2025]" (2024: 146) (page 73, 78). "In addition, seven confirmed cases of other work-related social and human rights incidents were reported" (2024: 6) (page 73, 78). "Fines, penalties, or compensations were paid in nine of the reported confirmed cases of work-related discrimination and harassment and other work-related social and human rights incidents. The total amount was approximately DKK 1.4 million. The nine cases were reported in DSV's US entities" (page 73).

"In 2025, no cases of severe human rights violations were reported" (page 73) - zero severe human rights incidents and zero associated fines (page 78).

Value chain worker policies

Reference: pages 72-75.

"DSV's Human Rights and Responsible Sourcing Policies define the rights of workers and our responsibility, standards and commitments for respecting and promoting these rights in our own operations and our value chain" (page 72). The Group Health & Safety Policy "applies to all DSV employees and non-employees. It also extends to value-chain workers when they are performing work at any DSV locations" (page 74). The Supplier Code of Conduct sets parallel standards: "All suppliers are required to provide adequate training and equipment to ensure the health and safety of workers throughout DSV's value chain" (page 75).

DSV observes "the ILO Declaration on Fundamental Principles and Rights at Work, the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights and the Children's Rights and Business Principles" (page 72).

Engaging with value chain workers

Reference: pages 72-75.

"Both own workforce and value chain workers are covered by DSV's Human Rights Programme. Findings are reported to DSV's senior management and Executive Board. These findings are analysed and supplemented with input from value chain workers to continuously assess and improve the efficiency of DSV policies and actions" (page 72).

The main formal channel is DSV's whistleblower system: Integrity Line is "enabling employees and third parties, including workers in the value chain, to safely report concerns or knowledge of misconduct" and is "available in 42 languages," with anonymous reporting "where permitted by local law" (page 81).

Remediation for value chain workers

Reference: pages 72-75.

Value chain workers can use the same Integrity Line whistleblower channel as own-workforce employees ("third parties, including workers in the value chain," page 81). "Our internal investigation team is responsible for conducting objective investigations and providing recommendations for proportionate and appropriate disciplinary and corrective actions" regardless of who raised the concern (page 81).

DSV's Human Rights Programme extends corrective action to the value chain: of the ten entities assessed in 2025, "in eight entities, corrective actions were implemented to address identified incidents of non-conformities with our policies" (page 73), with findings from value-chain-worker input feeding back into policy and programme design (page 72).

Actions on value chain worker impacts

Reference: pages 72-75.

"Specific supplier vetting and audit requirements are established for high-risk suppliers as part our Responsible Sourcing Policy and accompanying framework" (page 73). In 2025, "we consolidated data from our internal audits and third-party industry risk assessments to identify potential areas of heightened risk and systemic challenges. Based on these findings, we introduced specific due diligence requirements for manpower suppliers in the Middle East" (page 81).

Health and safety extends to value chain workers at DSV sites via the shared OHSMS (page 74), and Human Rights Programme training reached "more than 900 employees" across the ten assessed entities in 2025, alongside the corrective actions noted under S2-3 (page 73).

Business conduct policies

Reference: pages 79-80.

"Our Code of Conduct and Supplier Code of Conduct set clear standards throughout our operations and outline the behaviour expected from our employees, business partners and suppliers," supported by "our Whistleblower, Global Citizenship and Responsible Sourcing policies" (page 79). The Code of Conduct covers "Anti-bribery and corruption, Use of information and data privacy, Environmental impact, Speak up, Donations and contributions, Conflicts of interest, Careful selection of suppliers, Competition, Export controls and sanctions, Human rights" and "is available in twelve languages" (page 80).

"Where local laws and regulations differ from the Codes of Conduct, the stricter standard must always be applied" (page 79). In 2025, "approximately 22,700 employees were in scope for the Code of Conduct training. The completion rate was 100%" (page 80).

Supplier relations

Reference: page 81.

"Our suppliers are mainly large aviation and shipping companies, as well as small to medium-sized road hauliers, the latter generally being more vulnerable to liquidity fluctuations and administrative burdens. In DSV, we proactively collaborate with our small and medium-sized transport suppliers, offering fair terms that are tailored to their operational needs" (page 48, 81).

Third-party risk management: "Global requirements for supplier risk management are defined at Group level and apply to all DSV supplier relationships... All suppliers with an annual spend over 100,000 EUR must sign the Supplier Code of Conduct. Supplier risk is determined based on the country in which the supplier operates as well as the types of services provided" (page 81). High-risk suppliers face a due diligence questionnaire; in 2025 DSV "introduced specific due diligence requirements for manpower suppliers in the Middle East" (page 81).

Corruption and bribery prevention

Reference: pages 79-80.

"DSV maintains a strict zero-tolerance approach towards any form of bribery or corruption in alignment with the UK Bribery Act, the US Foreign Corrupt Practices Act and other applicable local legislation" (page 80). "In 2025, we introduced a dedicated Anti-Corruption Guidance as part of our ongoing commitment to provide clear guidance on our integrity standards for all employees" (page 81).

The compliance programme "incorporates proactive risk management processes, continuous training initiatives and ongoing monitoring... assessed annually according to the US Foreign Corrupt Practices Act Guidelines issued by the US Department of Justice" and covers "tone from the top, risk assessments, due diligence, communication, training, investigations and internal audits" (page 80). Detection runs through the Integrity Line whistleblower system: "we registered 551 cases through DSV Integrity Line" in 2025, a 101% increase on 2024 (page 81).

Business conduct targets

Part of the MDR-T/GDR-T disclosures; G1-3 became a standalone numbered target DR only in the 2025/2026 ESRS.

Reference: page 79.

DSV states a measurable, outcome-oriented target: "100% employees at risk trained in DSV's Code of Conduct every 24 months" by 2026 (page 79). 2025 performance against it: "approximately 22,700 employees were in scope for the Code of Conduct training. The completion rate was 100%, which is in line with our 2025 target. We maintain the 100% training target for 2026" (page 80).

Effectiveness tracking beyond the target itself: "the effectiveness of our whistleblower system is tracked by use of metrics and targeted questions in the DSV Global People Survey. This allows us to assess employees' knowledge of the whistleblower system and their willingness to report incidents" (page 81), and the compliance programme's design and effectiveness are reassessed annually against the US DOJ FCPA guidelines (page 80).

Corruption and bribery incidents

Reference: page 82. (Flagged in DSV's EU-legislation datapoint table as datapoint 24(a), "Fines for violation of anti-corruption and anti-bribery laws," material with page 82, even though this DR is not separately listed as its own row in the primary ESRS disclosure index, which groups it under the G1-3 pages 79-80 entry.)

"Convictions for violation of anti-corruption and anti-bribery laws (number)": nil in 2025, 2024 and 2023 (page 82). "Fines paid for violation of anti-corruption and anti-bribery laws (DKKm)": nil across all three years (page 82). "We monitor any convictions related to violations of anti-bribery and corruption laws. No such violations were reported in 2025" (page 81).

Workforce at risk covered by anti-corruption and anti-bribery training: 100% (2025, 2024, 2023) (page 82). Whistleblower reports (a related, though not corruption-specific, metric): 551 in 2025 (2024: 274; 2023: 136) (page 82).

Payment practices

Reference: page 81.

"In 2025, the average invoice payment period across all accounts payable was 45 days, compared to 41 days last year. The percentage of payments aligning with standard payments terms was 52% in 2025, which was broadly consistent with 53% in 2024" (page 81).

"In 2025, DSV registered 13 ongoing legal proceedings related to late payments in France and Poland, whereas no such cases were recorded in 2024" (page 81). Context: "DSV's main transportation suppliers are large companies, whereas the road haulage sector is made up of mainly micro-, small- or medium-sized enterprises that are more vulnerable to long payment terms and other administrative burdens" (page 81), and "standard payment terms vary depending on the specific division, market, country and individual supplier" (page 81).