European Energy A/S

Governance roles

Reference: pages 29-31.

European Energy "adheres to the standard governance structure for Danish companies, comprising a Board of Directors, a majority of non-executive members, and an Executive Management" (p.29). The Executive Management, in consultation with the Board, appoints the Leadership Team.

Board of Directors (p.29-30): "Appointed by the shareholders, the Board of Directors is responsible for the overall management of the company... endorses the corporate strategy and oversees major investment and divestment decisions." In 2025 the Board had seven members, four independent, including the Chair; no changes to composition during the year. The Board "approves the outcome of our double materiality assessment (p.46) and sustainability policies." The Board is presented with a sustainability progress and performance report quarterly and meets at least quarterly.

Four Board committees, each chaired by an independent Board member: Audit Committee (3 members); Sustainability Committee (4 members); Nomination Committee (2 members); Remuneration Committee (2 members).

Majority shareholder, CEO and founder Knud Erik Andersen holds approximately 60% of the voting rights; Mitsubishi HC Capital holds approximately 20% (p.29).

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

Reference: pages 29-30, 45-46.

The Sustainability Committee "plays a key role in strengthening governance for sustainability by reviewing the Sustainability Strategy and monitoring the effectiveness of related policies, actions, targets and metrics," meeting at least quarterly (p.30). Its responsibilities include ensuring a "robust and documented process to identify and assess material impacts, risks and opportunities identified through our double materiality assessment, including recommendations to the Board for approval," and "approving and endorsing the Sustainability Strategy."

Identified material impacts, risks and opportunities and the revised strategy "have been reviewed by the Leadership Team, the Sustainability Committee, the Audit Committee and the Board of Directors as part of our corporate governance framework" (p.45).

2025 priorities: the Board visited construction sites; held extraordinary meetings for large investments; and, with the Audit Committee, "spent considerable time navigating changing sustainability regulations, especially the CSRD and ESRS, to guide a shift toward more strategic and less extensive reporting" (p.30).

The DMA matrix and material IRO list were "reviewed and approved by the Leadership Team, the Sustainability Committee, the Audit Committee and, ultimately, the Board of Directors" (p.95).

Integration of sustainability-related performance in incentive schemes

Reference: page 29.

"As a renewable energy company, production capacities and volumes produced as well as related financial performance metrics are integrated into the remuneration frameworks for members of the Leadership Team" (p.29).

The company states plainly: "Sustainability-related performance such as greenhouse gas emissions are not currently included in incentive schemes for members of the administrative, management or supervisory bodies, nor is performance assessed against greenhouse gas emission reduction targets."

This is repeated under E1: "Climate change metrics related to GHG emissions are not currently factored into the remuneration of members of the administrative, management and supervisory bodies, nor has their performance been assessed against GHG emission reduction targets" (p.64).

Statement on due diligence

Reference: page 47 (Sustainability due diligence); core-elements table cross-referenced across the statement.

"Our approach is inspired by the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Business Conduct. The Corporate Sustainability Due Diligence Directive (CSDDD) is also factored into our framework" (p.47).

The report maps the five core elements of due diligence to sections and pages: (a) embedding due diligence in governance, strategy and business model (pp.29-30, 33, 45-46, 62, 65, 70, 80, 82, 86); (b) engaging with affected stakeholders in all key steps (pp.65, 76, 78, 80, 82, 96); (c) identifying and assessing adverse impacts (pp.45, 55, 62, 65, 70, 80, 82, 86, 94-95); (d) taking actions to address adverse impacts (pp.17, 55, 63, 65, 70, 76, 78, 80, 82, 86-87); (e) tracking effectiveness and communicating (pp.64-65, 71, 76, 78-80, 82, 86-87).

In 2025 the company developed "a new procedure for conducting annual in-depth assessments of high-risk suppliers," scheduled for implementation in 2026, and conducted site visits across part of the solar PV supply chain (p.47). Its Minerals Due Diligence Working Group uses the Business & Human Rights Resource Centre's Transition Minerals Tracker to assess community-level impacts of mineral supply chains, including risks in the Uyghur region linked to polysilicon processing.

Risk management and internal controls over sustainability reporting

Reference: page 47.

"Our centralised ESG Data Warehouse enables automated, consistent quarterly collection, storage and management of ESG data, ensuring a single source of truth and full traceability."

"ESG reporting risks are assessed through our Enterprise Risk Management framework and ongoing data quality controls. Key risks relate to the maturity of ESG reporting and the need for strengthened controls across the reporting cycle. These risks are mitigated by aligning ESG processes and systems with financial reporting practices, supported by documented policies, procedures and clear ownership."

The ESG Accounting and Reporting Team reports quarterly to the Leadership Team, Audit Committee, the Sustainability Committee and the Board of Directors, providing "an additional layer of oversight and internal control, supporting timely risk prioritisation and approval of ESG disclosures in quarterly and annual statements."

Strategy, business model and value chain

Reference: page 42; pages 45-46 (value chain mapping table).

"We create value by developing, constructing, and operating a wide range of renewable energy solutions, ranging from wind power to solar PV power, Power-to-X, carbon capture and Battery Energy Storage Systems. Since our founding in 2004, our vision has been to become a major global force in driving the green transition" (p.42).

"Our 2025 double materiality assessment reconfirmed climate change as our most material topic, with renewable energy deployment and the replacement of fossil fuels forming the foundation of our business model. With 100% EU Taxonomy-eligible and 81%-aligned revenue, we demonstrate our substantial contribution to climate change mitigation."

The company "acknowledge[s] that especially upstream value chain activities such as the extraction of minerals and metals, and the manufacturing of components, but also our own construction of renewable energy sites, can cause negative impacts to the environment and to people."

The Sustainability Operating Model embeds impact screening and mitigation across three project phases: Development (early identification of environmental/social risks, mid-stage assessment, late-stage management plans), Construction, and Operation. A full value-chain map of impacts, risks and opportunities by category, time horizon and page reference appears on pages 45-46.

Interests and views of stakeholders

Reference: page 96 (Annex V).

"European Energy operates in a rapidly evolving context and regularly considers formal and informal stakeholder interests and expectations. Through ongoing engagement with key internal and external stakeholders, we incorporate relevant perspectives into our strategy, operational decisions and business model. Stakeholder insights are used to identify, assess and monitor our material impacts, risks and opportunities and are integrated into our due diligence processes and double materiality assessment" (p.96).

Annex V presents a table of key stakeholder groups, the purpose of engagement, main outcomes, and how their views influence operations, business model and strategy. Elsewhere the statement names specific stakeholder groups engaged during the DMA, and states the assessment "provided further validation of the significance of the identified topics," using proxies such as industry reports "to represent our external and silent stakeholders" (p.95).

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

Reference: pages 45-46 (value chain mapping table); per-topic pages 55-88.

"Material impacts, risks and opportunities are addressed directly through our business model and our strategy. Based on the results of our double materiality assessment we carried out a mid-term review of our strategy and adjusted our strategic priorities accordingly" (p.45).

The value chain mapping table (pp.45-46) lists material IROs by topic, category, time horizon and page: E1 climate change (renewable energy deployment, replacement of fossil fuels, value chain GHG emissions, physical/transition risks); E4 biodiversity (restoration, land-use-change loss, reputational risk); E5 resource use (transition minerals, project waste, circularity); S1 own workforce (safety, mental health, equity/diversity); S2 value chain workers (working conditions, contractor safety); S3 affected communities (local job creation); G1 business conduct (data/privacy governance, grievance awareness, corruption).

"While material topics did not change [versus 2024], we scored some impacts, risks and opportunities differently and merged others... The sub-topic political engagement was assessed as non-material in 2025" (p.46).

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

Reference: pages 94-95 (Annex IV methodology).

"Informed by the requirements set in the Corporate Sustainability Reporting Directive (CSRD)... we conducted our third double materiality assessment in 2025," refining the methodology built on the 2024 assessment, stakeholder dialogue and EFRAG's Implementation Guidance.

Five-step process (p.94): (1) value chain mapping and stakeholder identification; (2) identification of IROs via desktop review, industry/peer analysis and internal stakeholder interviews; (3) assessment of impact materiality (scale, scope, remediability, and likelihood for potential impacts, each scored 0-5) and financial materiality (probability x magnitude, via the Enterprise Risk Management framework); (4) validation, including external stakeholder interviews; (5) final review and approval by the Leadership Team, Sustainability Committee, Audit Committee and Board.

Threshold: "Any impact, risk or opportunity exceeding or equal to a threshold of 3 was in scope." For potential negative human rights impacts, "severity scores were increased and likelihood scores reduced... ensuring that severity takes precedence, in accordance with ESRS 1."

Climate-specific scenario analysis (TCFD-based, IEA STEPS/APS/NZE and IPCC SSP1-2.6/SSP5-8.5 scenarios) is presented under E1-2 (2025 ESRS numbering), p.62.

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

Reference: page 90 (Annex I).

"Our Sustainability Statement cover ESRS disclosure requirements related to all material topics, sub-topics and sub-sub-topics identified through our annual double materiality assessment. Additionally, we also account for entity-specific disclosures that are of particularly relevant in the context of our business model and corporate strategy" (p.90).

Annex I lists, per disclosure requirement, the section (Management's Review / Sustainability Statement / Annex) and page(s) where it is covered. E1, E5, S1 and G1 are disclosed with full disclosure-requirement-level line items and page references. E4 Biodiversity and ecosystems, S2 Workers in the value chain and S3 Affected communities are each covered as a single "ESRS 2, BP-2, 17 Summary" line item (E4: SS pp.65-67; S2: SS pp.80-81; S3: SS pp.82-83), reflecting the ESRS 1 paragraph 17 (BP-2) option for a less granular, aggregated disclosure. Annex I separately lists "Immaterial topics" with only a cross-topic IRO-1 reference: E2 Pollution, E3 Water and marine resources, and S4 Consumers and end-users (p.90).

Transition plan for climate change mitigation

Reference: page 63.

"As a 100% renewable energy company, our business model and strategy are highly resilient and fit for a low-carbon future... We are working on our climate transition plan. With further insights into our Scope 1, 2 and 3 emissions and continuously improved accounting practices and data quality, we are looking into defining GHG emission reduction targets and levers. We plan to develop a climate change mitigation strategy as part of the implementation of our 2026 Sustainability Strategy" (p.63).

The company explicitly states it has not yet set quantitative GHG emission reduction targets: "We have not set any quantitative GHG emission reduction targets for Scope 1, 2 and 3 GHG emissions at this stage. We need a solid, data-driven understanding of the key emission drivers... With our newly issued Decarbonisation Policy and efforts to improve our carbon accounting practices, we aim to start the process of setting measurable outcome-oriented targets in 2026 in alignment with the Science-based Targets Initiative" (p.64).

A new Decarbonisation Policy was issued in 2025, setting a hierarchy for GHG emission reductions and guiding principles including strategic decarbonisation partnerships and climate adaptation/resilience assessments (p.63). No CapEx/OpEx figures are attached to the transition plan.

Identification of climate-related risks and scenario analysis

Back-filled from the E1-IRO-1/SBM-3 climate scenario content disclosed in the FY2025 report (page 62). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"In 2025, we assessed our climate-related physical and transition risks and opportunities on a corporate level based on the guidance of the Task Force on Climate-Related Financial Disclosures (TCFD)" (p.62). Risks are split into transition risk (Policy, Legal, Technology, Market, Reputation factors) and physical risk (chronic and acute hazards).

Scenarios used (p.62): transition risk — three IEA scenarios: STEPS (Stated Policies Scenario), APS (Announced Pledge Scenario) and NZE (Net Zero Emissions by 2050); physical risk — IPCC pathways SSP1-2.6 (low-emission, <2°C) and SSP5-8.5 (high-emission, >4°C warming).

Time horizons: short-term = now to 2026; medium-term = 2030-2050; long-term = 2050 and beyond, chosen to align with "key regulatory and policy milestones like Omnibus/CSRD, CBAM, Fit for 55" and "Europe's climate targets."

Assessed hazards span temperature-, wind-, water- and solid-mass-related chronic and acute categories (p.62). This "enables us to understand potential impacts on asset performance, insurance exposure and operational continuity across short-, medium-, and long-term horizons."

Resilience in relation to climate change

Back-filled from the E1 IRO-1/SBM-3 climate risk content disclosed in the FY2025 report (page 62). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

"Our findings confirm that climate resilience must be embedded at the corporate level, through design standards, site selection criteria and adaptation measures. This enterprise-wide perspective strengthens our ability to safeguard performance and financial stability over the 25-30 year lifespan of our assets" (p.62).

The resilience conclusion follows the TCFD-based scenario analysis of chronic hazards (changing temperature, wind and precipitation patterns, coastal/soil erosion, water stress) and acute hazards (heat waves, wildfire, cyclones, storms, floods) across short-, medium- and long-term horizons (p.62).

The transition plan section separately notes the company is still developing its climate change mitigation strategy and has not yet set quantitative decarbonisation targets (E1-1, p.63-64), and no dedicated ESRS-defined resilience analysis with adaptive-capacity scoring is presented beyond this corporate-level TCFD assessment.

Policies related to climate change mitigation and adaptation

Reference: page 63 (explicitly tagged "E1-1 and E1-2").

"New Decarbonisation Policy issued: In 2025, we issued a new Decarbonisation Policy to further reinforce our position as a decarbonisation catalyst and partner to our stakeholders. We commit to a low-carbon future by reducing carbon footprints and promoting sustainable practices across our value chain" through "a hierarchy for greenhouse gas emission reductions and a set of guiding principles": establishing strategic decarbonisation partnerships across the value chain; improving data collection; promoting less carbon-intensive technologies; and conducting climate change adaptation and resilience assessments (p.63).

"Our Sustainability Policy underscores our commitment to the ten guiding principles of the United Nations Global Compact. Environmental and climate-related considerations are embedded in the policy, which addresses climate change mitigation, energy efficiency and renewable energy deployment."

The Code of Conduct for Business Partners requires partners to "incorporate climate change considerations into their operations and to take proactive measures to actively limit their GHG emissions in alignment with the Paris Agreement." Minimum disclosure requirements for these policies are set out in Annex III, pp.92-93.

Actions and resources in relation to climate change policies

Reference: pages 63-64 (explicitly tagged "E1-3").

2025 actions: Battery Energy Storage Systems (BESS) co-located with solar PV parks to address peak-generation pricing pressure; BESS supplier screenings expanded for supply-chain due diligence; e-methanol RFNBO certification (ISCC EU and ISCC PLUS) for the Kassø Power-to-X facility, with the Måde facility certified in January 2026; ISO 9001 certification of the Måde Power-to-X facility; issuance of the new Decarbonisation Policy; work on "assessing and prioritising key Scope 1, 2 and 3 emission categories and identified potential reduction levers"; and development of a GHG estimation tool for BESS projects.

Targets towards 2026 table (p.64): Scope 3 GHG emissions assessment across the value chain — completed 2024; Life Cycle Assessment screening tool — completed 2026; Science-based targets (SBTi near-term and net-zero, Scope 1/2/3) — in progress, 2026; Climate change mitigation plan (action points to reduce Scope 1/2/3 emissions) — in progress, 2026.

Progress on renewable-deployment actions is managed by Executive Management and the Leadership Team; decarbonisation actions by the Sustainability Team, funded through the 2026 Sustainability Strategy budget and a dedicated Decarbonisation Workstream.

Targets related to climate change mitigation and adaptation

Reference: pages 63-64.

"As part of our 2026 Sustainability Strategy, we have established qualitative targets, in consultation with internal stakeholders, for our value chain decarbonisation efforts... We have not set any quantitative GHG emission reduction targets for Scope 1, 2 and 3 GHG emissions at this stage. We need a solid, data-driven understanding of the key emission drivers and how our growth as a renewable energy company influences them... we aim to start the process of setting measurable outcome-oriented targets in 2026 in alignment with the Science-based Targets Initiative" (p.64).

The targets table (p.64) shows: Scope 3 emissions assessment (completed 2024); LCA screening tool (completed 2026); science-based (SBTi) near-term and net-zero Scope 1, 2 and 3 targets (in progress, target year 2026); climate change mitigation action plan (in progress, 2026).

Effectiveness is monitored "through Scope 1, 2, and 3 GHG emissions metrics, since 2022," reported quarterly to the Leadership Team, Sustainability Committee, Audit Committee and Board.

Energy consumption and mix

Reference: page 61.

Coal, natural gas, nuclear and self-generated non-fuel renewable energy are all reported as 0 in both years. "29% reduction in fossil energy consumption... reflects a 36% decline in purchased electricity, heat, steam, and cooling from fossil sources." The company "cover[s] 100% of our own electricity consumption with unbundled renewable energy certificates."

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 59-61 (E1-6 table); accounting policy pages 60-61.

Gross emissions, tCO2e:

Scope 3 rose 50%, "mainly driven by a higher volume of projects (MW) reaching Final Investment Decision," with a shift toward BESS projects and continued transition "from spend based to project specific calculation tools, improving data quality but has increase reported emissions." Scope 2 market-based fell 86% ("100% of our electricity consumption is covered by renewable energy certificates"). Categories 8-14 are "not relevant or material for European Energy in 2025." 2024 figures were restated for a prior-period error (three omitted projects, +128,894 tCO2e to category 2) and reclassification of inventory-asset emissions from category 2 to category 1.

Transition plan on biodiversity and ecosystems

Reference: page 65 (section tagged "ESRS 2, BP-2, 17 Summary"); target and metrics pages 65, 67.

European Energy does not label a standalone "transition plan" for biodiversity, but discloses a comparable forward commitment under its E4 summary: "Our Biodiversity and Ecosystems Policy reinforces our commitment to contribute to a nature-positive future where biodiversity loss is halted and reversed by 2030", and it lists as a target: "Develop a strategy for how to contribute to a nature-positive world by 2026 (In progress)" (pp.65, 67).

The company "appl[ies] the mitigation and conservation hierarchy in our environmental impact assessments. Where potential adverse impacts are identified, we prioritise avoidance and minimisation, and incorporate appropriate mitigation measures into the design and execution of our renewable energy projects" (p.65), and in 2025 "advanced the development of a structured methodology to assess biodiversity-related risks, establish baselines, and plan mitigation and biodiversity-enhancing actions across our portfolio" (Biodiversity Measurement Framework, second pilot test conducted in 2025).

[uncertain: no section is explicitly labelled "E4-1" or "transition plan" in the source; this entry treats the nature-positive-by-2030 commitment and mitigation hierarchy as the closest equivalent disclosed under the topic's BP-2(17) summary.]

Policies related to biodiversity and ecosystems

Reference: page 65 (tagged "ESRS 2, BP-2, 17 Summary").

"Policies and approach" for biodiversity and ecosystems (p.65):

• Sustainability Policy
• Biodiversity and Ecosystems Policy

"Our Biodiversity and Ecosystems Policy reinforces our commitment to contribute to a nature-positive future where biodiversity loss is halted and reversed by 2030," and biodiversity considerations "are embedded in our Sustainability Operating Model, which covers all phases of our renewable energy sites, from development, construction and operation" (p.67).

The company applies the mitigation and conservation hierarchy (avoid, minimise, restore, compensate) in its environmental impact assessments and screens operational sites against biodiversity-sensitive areas using the Integrated Biodiversity Assessment Tool (IBAT), with technology-specific buffer distances (Solar PV/BESS: 5km; onshore wind/Power-to-X: 10km; offshore wind: 20km) (p.66).

Actions and resources related to biodiversity and ecosystems

Reference: page 65 (tagged "ESRS 2, BP-2, 17 Summary").

2025 actions (p.65): "Continued the development of a corporate Biodiversity Measurement Framework and conducted the second pilot test to evaluate its effectiveness"; "Prepared pilot results for internal review to inform the next phase of framework implementation"; "Collaborated with the Danish Society for Nature Conservation to develop a catalogue of biodiversity initiatives for solar parks"; "Embedded biodiversity considerations across project life cycles by defining minimum requirements guided by the mitigation and conservation hierarchy."

The company donated 16 hectares of land to nature restoration projects facilitated by the Danish Nature Fund, based on 2025 construction activities in Denmark (p.65). Progress is "driven by our Biodiversity Team and the Project Development Department," resourced through the 2026 Sustainability Strategy budget and a dedicated Sustainability Workstream (p.67).

Targets related to biodiversity and ecosystems

Reference: page 65 (tagged "ESRS 2, BP-2, 17 Summary").

Targets (p.65):

• "Publish a Biodiversity and Ecosystems Policy by 2024 (Completed)"
• "Develop a strategy for how to contribute to a nature-positive world by 2026 (In progress)"
• "Develop a biodiversity management system and evaluate and test our biodiversity inventory guideline and monitoring plan by 2026 (In progress)"

These are qualitative, milestone-based targets rather than quantified biodiversity outcome metrics. The company states it presents "a summary of policies, actions and targets associated with managing impacts, risks and opportunities related to biodiversity and ecosystems" under the BP-2(17) summary format (p.65).

Impact metrics related to biodiversity and ecosystems change

Reference: page 65, 67.

Material construction sites without significant negative impacts: "None of the 21 material sites that were under construction in 2025, caused significant negative impacts to biodiversity sensitive areas" — 100% (p.65).

Land donated to nature restoration in Denmark: "We donated 16 hectares of land to nature restoration projects facilitated by the Danish Nature Fund, based on our construction activities in Denmark in 2025" (p.65).

The list of 21 material construction sites (p.66) shows, by country/site/technology, whether each is located in or near a biodiversity-sensitive area (20 of 21 are) and whether it negatively impacted that area (none did), screened using IBAT buffer distances. "Our activities do not have any significant negative impact on biodiversity-sensitive areas or species for which a protected area has been designated" (p.66).

Policies related to resource use and circular economy

Reference: page 69 (tagged "E5-1").

"Policies and approach" (p.69): Waste Management Policy; Code of Conduct for Business Partners.

"Our Waste Management Policy underscores our commitment to waste management, adhering to the EU waste hierarchy and establishing strategic partnerships for a circular economy, thereby addressing the material negative impacts related to resource outflows and waste in operations as well as the opportunity to build partnerships for circularity" (p.69).

"Our Code of Conduct for Business Partners outlines our expectation that our business partners value environmental responsibility and aim to minimise waste and resource consumption in their business activities, thereby addressing all the material negative impacts related to limited availability of transition minerals, resource outflows and waste in operations." Minimum disclosure requirements are set out in Annex III, pp.92-93.

Actions and resources related to resource use and circular economy

Reference: pages 70-71 (tagged "E5-2").

2025 actions (pp.70-71): the Resource Use and Circular Economy Workstream scaled up circularity initiatives; joined Solar Panels in a Circular Economy (SPICE), an industry project to "establish a full value chain for solar panel recycling"; conducted a wind repowering project in Germany dismantling three ageing turbines, working with external partners on end-of-life handling of blades, towers and infrastructure; developed minimum waste management requirements for construction contractors; partnered with the Danish Technological Institute (DTI) to develop "a comprehensive end-of-life framework, process and economic model for battery systems," evaluating reuse, recycling and supplier-led take-back pathways in line with the EU Battery Regulation.

Progress is managed by the Resource Use and Circular Economy workstream with the Engineering, Procurement and Construction Department and the Asset Management Department, resourced via the 2026 Sustainability Strategy plan and departmental budgets.

Targets related to resource use and circular economy

Reference: page 71 (tagged "E5-3").

"As part of our 2026 Sustainability Strategy, we have established qualitative targets for our circularity and waste management efforts to define our level of ambition and evaluate the progress... we aim to set measurable outcome-oriented targets in 2026" (p.71).

Targets table (p.71), all status "In progress," target year 2026:

• Circularity targets — "set circularity targets through sustainable sourcing and circularity strategies"
• Waste management targets — "including a zero-landfilling target for PV modules and wind turbine blades"
• Partnerships for circularity — "strengthen our partnerships to enhance the effectiveness of our circularity initiatives"

Effectiveness is "monitored through metrics on waste, starting in 2025," reported to the Leadership Team, Sustainability Committee, Audit Committee and Board.

Resource inflows

Reference: page 69.

The report explains, rather than quantifies, its E5-4 scope: "As a part of the European Sustainability Reporting Standards (ESRS) requirements, certain metrics related to own operations must be reported when the ESRS E5-4 Resource inflows topic is assessed as a material topic. Based on the results of our double materiality assessment, our material impact and risk for the resource inflows topics are related to our upstream value chain and not to our own operations. Hence, the metrics required to be reported under ESRS E5-4 Resource inflows are not reported as part of the disclosures" (p.69).

The qualitative IRO content is disclosed: renewable energy technologies "rely on transition minerals and materials, such as copper, cobalt, nickel, lithium and silicon, many of which are scarce and vulnerable to depletion," with sourcing and extraction "concentrated in geopolitically sensitive regions, posing a potential risk of supply chain disruption" (p.69). The company states it "focus[es] on responsible sourcing and circular economy principles, reducing reliance on virgin resources."

Resource outflows

Reference: page 69.

"Repowering and decommissioning of renewable energy assets involve significant resource outflows which, if not managed responsibly, can lead to large volumes of waste and loss of valuable materials" (p.69). "While most of our assets are new and will not be decommissioned for many years, we proactively plan to integrate circularity principles and collaborate with partners to develop solutions that maximise material recovery, reuse and recycling during decommissioning and repowering projects."

"In 2025, we undertook one repowering project in Germany, replacing three aging turbines with new and more energy efficient turbines," working with external partners on end-of-life handling of dismantled components (blades, towers, infrastructure).

Strategic partnerships for circularity are described as "key enablers, unlocking access to shared expertise, infrastructure and innovation that support greater reuse and refurbishment across the renewable energy value chain."

Waste

Reference: page 70 (E5-5 waste table).

Total waste generated in 2025: 7,186 tonnes, of which 5,951 tonnes (83%) diverted from disposal and 1,235 tonnes (17%) directed to disposal. "In 2025, 83% of our total waste was diverted from disposal... We generated 7,186 tonnes of total waste during the year. Out of this, 5,951 tonnes was diverted from disposal which included 2,250 tonnes being reused, 2,688 tonnes being recycled and 1,013 tonnes being recovered through other means" (p.69).

The reporting infrastructure for these metrics "was set up during the current year for reporting from 2025 onwards," so no comparative 2024 figures are given.

Policies related to own workforce

Reference: pages 76, 78 (tagged "S1-1").

Policies listed at a glance (p.73): Sustainability Policy; Quality, Health, Safety and Environment (QHSE) Policy; Stress Management Mechanism; Whistleblower Policy; Disciplinary Policy; Diversity, Equity and Inclusion Policy; Staff Policy on Sexual Harassment & Discrimination.

"Our Quality, Health, Safety and Environment (QHSE) Policy addresses our impact related to safety at work. It is designed to uphold the highest standards across all our operations" (p.76); the policy will be updated "in the coming year to align with industry best practices."

"Our Stress Management Mechanism addresses our impact related to mental health and well-being" (p.78). "We adopt a zero-tolerance approach towards inappropriate behaviour," with the Disciplinary Policy, Diversity Equity and Inclusion Policy, and Staff Policy on Sexual Harassment and Discrimination together governing equity, diversity and inclusion (p.78). Minimum disclosure requirements are set out in Annex III, pp.92-93.

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

Reference: page 76 (tagged "S1-2").

"Our engagement processes and mechanisms inform our decisions and activities aimed at managing impacts related to our own workforce. Engagement with our employees takes place through different modes such as participation and consultation and by providing information" (p.76).

"Employee engagement begins during the onboarding where new joiners receive detailed information about company policies and available support mechanisms." People Development (PD) talks give employees "a structured platform for setting up an annual plan for professional development... followed by quarterly follow-ups with their managers." Offboarding surveys and meetings gather feedback from outgoing employees. The People & Culture Department, headed by the Chief People Officer, manages employee engagement initiatives.

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

Reference: page 76 (tagged "S1-3").

"Employees can raise concerns directly to their managers or the People & Culture Department, which tracks and monitors the issues raised to ensure appropriate follow-up and resolution. Further, our Work Environment Committee (WEC) also provides a channel for our employees to raise their concerns" (p.76).

"Additionally, we have a Whistleblower Mechanism along with a Whistleblower Policy, allowing employees to report concerns anonymously." In 2025 one whistleblower case was received (zero in 2024); no cases were substantiated or transferred to the police (G1-4, p.87).

Taking action on material impacts on own workforce

Reference: pages 76, 78 (tagged "S1-4").

Safety: "100% of our own workforce and contractors' employees working at our sites are covered by our existing QHSE Management System"; roll-out of a new QHSE Management System began with the two Danish Power-to-X facilities; standardised site induction protocols introduced; a new structured incident-follow-up process rolled out; corporate-level critical electrical safety procedures formalised (p.76).

Mental health: a Stress Management Taskforce was established in 2025; a Leadership Development Programme equips people managers to handle stress-related issues; People Development Talks provide structured conversations on responsibilities and targets (p.78).

Equity, diversity and inclusion: signed the UN Women's Empowerment Principles; conducted a gender-equality gap analysis; promoted the Female Network; established a dedicated Compensation and Benefits function ahead of the Pay Transparency Act; launched a corporate Leadership Code and mandatory Leadership Development Programme; joined the UNGC Nordic Programme on Non-Discrimination (p.78-79).

Targets related to own workforce

Reference: pages 76, 78-79 (tagged "S1-5").

Safety: the company "discontinued our target of zero Lost Time Injury Rate (LTIR)," instead focusing from Q2 2025 on recording "serious injuries" (incidents with realistic potential to cause a lost time injury or worse) (p.77). 2026 targets: review/update the QHSE policy; roll out the new QHSE management system to the entire organisation; develop a QHSE onboarding training programme (in progress).

Mental health: "an ongoing target of a minimum 80% employee engagement, which we achieved this year" (p.78) — 80% achieved against an 80% target.

Equity, diversity and inclusion: "gender balance of 40:60 across all levels by 2030"; gender-neutral salary bands "to structurally reduce the likelihood of gender pay issues," target year 2026 (p.79).

Characteristics of the undertaking's employees

Reference: pages 74-75 (tagged "S1-6").

Total employees: 924 (2024: 843, +10%); average FTEs: 867. By gender: female 286, male 551, other 1 (permanent); total permanent employees 838, temporary 86. "We employed 924 people at the end of 2025... During 2025, we continued to expand our talent base" (p.74).

By country (p.75): Denmark 646 (70%), Germany 80 (9%), Australia 50 (5%), UK 27 (3%), Lithuania 21 (2%), Poland 15 (2%), Italy 15 (2%), France 11 (1%), Brazil 10 (1%), other 49 (5%) — present in 22 countries.

Turnover: total employee turnover rate fell to 15.4% in 2025 (2024: 17.1%); permanent employee turnover rate fell to 10.8% (2024: 11.7%). Total employees who left: 136 (2024: 133).

Diversity metrics

Reference: page 79 (tagged "S1-9").

Board of Directors gender split: 1 female, 6 male (7 total) — female representation 14% for both 2025 and 2024, against a 2030 target of 40% for "gender with the lowest representation (female)."

All employees: female 323, male 600, other 1 (total 924); female share 35% in both 2025 and 2024, against a 2030 target of 40% for "genders with the lowest representation (female and other)."

Age distribution: under 30 = 19% (2024: 21%); 30-50 = 62% (2024: 59%); over 50 = 19% (2024: 20%); average age of employees 40 (2024: 40). Nationalities represented: 49 (2024: 43) — "a reflection of our constant pursuit of new business opportunities in new markets."

Health and safety metrics

Reference: page 77 (tagged "S1-14").

"In 2025, we registered eight total recordable injuries (TRIs) which included seven TRIs among our employees and one TRI among our contractor employees... an increase in the number of reported TRIs in the year as a result of our strengthened safety reporting culture" (p.77).

Contractor employees: 1 TRI (2024: 2), TRIR 0.9 (2024: 2.4); 1 LTI (2024: 1), LTIR 0.9 (2024: 1.2); 0 fatalities. 100% of own workforce and contractors' employees at sites are covered by the QHSE Management System.

Compensation metrics (pay gap and total compensation)

Reference: page 78 (tagged "S1-16").

"The annual total remuneration ratio was 15 in 2025 (16 in 2024). The ratio is calculated by dividing annual total remuneration of the highest-paid individual by median employee annual total remuneration (excluding that of the highest-paid individual) in the company. The remuneration includes bonus and other compensation elements" (p.78).

No gender pay gap percentage is separately disclosed in this section; the company instead describes establishing a dedicated Compensation and Benefits function in 2025 "to support fair and consistent compensation as we grow and to enable compliance with the upcoming Pay Transparency Act," and a target to "develop and introduce gender neutral salary bands in our career model to structurally reduce the likelihood of gender pay issues" by 2026 (p.79). Annex II marks the CEO excessive-pay-ratio datapoint status separately from this total-remuneration ratio.

Policies related to value chain workers

Reference: page 80 (tagged "ESRS 2, BP-2, 17 Summary").

"Policies and approach" (p.80): "Our Sustainability Policy affirms our commitment to respect internationally recognised human rights and to continuously identify and mitigate potential adverse impacts on human rights from our activities. Our Code of Conduct for Business Partners outlines our requirements for human rights due diligence from our business partners and lists relevant human rights, including fundamental labour rights."

"To address the environmental and social concerns tied to our supply chain, we apply a risk-based approach to ensure we concentrate our efforts on high-risk partners and supply chains rather than all direct relationships." The Whistleblower Policy provides "a confidential, transparent and structured process for handling concerns," and the Quality, Health, Safety and Environment Policy is "applicable to our own workforce as well as to contractors' workers at our sites."

Processes for engaging with value chain workers about impacts

Reference: pages 80-81 (tagged "ESRS 2, BP-2, 17 Summary").

"We conducted targeted supplier visits across key stages of the solar PV value chain, strengthening our understanding of operational practices and proactively reinforcing our expectations for sustainable and responsible business conduct" (p.80). "We conducted selected supplier visits across various stages of the solar PV value chain enabling us to gain deeper insights into operational practices and communicate our expectations to sustainable and responsible business conduct" (p.81).

In 2025 the company "developed a new procedure for conducting annual in-depth assessments of high-risk suppliers," scheduled for 2026 implementation, integrating "ongoing supplier screening process with annual assessments by identifying high-risk suppliers that require additional monitoring" (p.81).

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: page 80 (tagged "ESRS 2, BP-2, 17 Summary").

The Whistleblower Policy "provides a confidential, transparent and structured process for handling concerns" and is referenced as the remediation channel applicable across the organisation, including for value chain workers (p.80). For contractors' employees specifically: "We held workshops to discuss the implementation of new labour rights due diligence tools to adapt to enhanced grievance mechanisms for contractors workers. For more information about our initiatives, please refer to S1 Own Workforce section" (p.80).

No separate, dedicated value-chain-worker grievance channel distinct from the corporate Whistleblower Mechanism is described.

Taking action on material impacts on value chain workers

Reference: pages 80-81 (tagged "ESRS 2, BP-2, 17 Summary").

Safety of contractors' employees: "We revised our contractor requirements which included developing a 'Health, Safety and Environment (HSE) Minimum Requirements from Contractors' document to reinforce legal obligations related to labour risk management and align with international labour rights standards. From 2026, we will implement these requirements, starting with our main contractors" (p.80).

Working conditions in value chain: developed a new annual in-depth high-risk-supplier assessment procedure (2026 implementation); conducted supplier visits across the solar PV value chain; expanded ESG screening to Battery Energy Storage System (BESS) suppliers as that portfolio grows (p.81).

Metrics (p.81): suppliers screened and evaluated against environmental and social criteria 93% (2024: 55%); suppliers screened for sanctions/adverse media/bribery 75% (new metric in 2025); services procured from local suppliers 88% (new metric in 2025).

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

Reference: page 81 (tagged "ESRS 2, BP-2, 17 Summary").

"We aim to further engage with our main contractors to improve our safety performance by 2026" (p.80, cross-referenced to the S1 Own Workforce section for detail).

Quantitative and qualitative targets set as part of the 2026 Sustainability Strategy (p.81): "Screen all our direct suppliers against environmental and social criteria by 2026 (In progress)"; "Conduct in-depth sustainability assessments and prepare supported action plans for all high-risk suppliers by 2026 (In progress)"; "Map the value chain of seven key minerals and metals across technologies (In progress)"; "Screen the performance of all new strategic joint-venture partners on environmental and social criteria by 2026 (In progress)."

Policies related to affected communities

Reference: page 82 (tagged "ESRS 2, BP-2, 17 Summary").

"Our Sustainability Policy affirms our commitment to respect internationally recognised human rights and to continuously identify and mitigate potential adverse impacts on human rights from our activities. Our Code of Conduct for Business Partners outlines our requirements for human rights due diligence from our business partners and lists relevant human rights, including fundamental labour rights" (p.82).

"Our Stakeholder Engagement Policy sets out the framework of principles and strategy for engagement with stakeholders to ensure a consistent approach to addressing impacts, risks and opportunities arising from our own operations at project level across our different markets" (p.82). "New Stakeholder Engagement Policy in effect: In 2025, we adopted our Stakeholder Engagement Policy which establishes a unified framework of principles and strategy to standardise stakeholder engagement across all markets and projects."

Processes for engaging with affected communities about impacts

Reference: pages 82-83 (tagged "ESRS 2, BP-2, 17 Summary").

"Meaningful stakeholder engagement with affected communities plays a key role in maximising local benefits and enabling long-term success for all parties involved" (p.82). "Our Stakeholder Engagement Procedure was updated with an explanation to facilitate the geographical mapping of our stakeholders in the Geographic Information System (GIS)" (p.83).

The company "implemented stakeholder engagement plans in 65% of our projects reaching the development phase" in 2025 (up from 28% in 2024, per the Stakeholder engagement plans metric, p.83), and "continued the ongoing development of training programmes for project managers for implementing stakeholder engagement plans" (p.83).

The company also "participated in a project led by the Danish Institute for Human Rights, in partnership with Green Power Denmark, to assess human rights considerations in solar energy development," producing "'Human rights and solar energy, a primer for the Danish solar energy sector'" (p.82-83).

Processes to remediate negative impacts and channels for affected communities to raise concerns

Reference: page 82 (tagged "ESRS 2, BP-2, 17 Summary").

"In 2025, we developed a new standardised grievance form to further streamline grievance management across projects" (p.82). "We developed a standardised template for our grievance form which can be applied across our project- and country-specific websites to further streamline our grievance redressal processes" (p.83).

"Through ongoing dialogue and cooperation with communities, we are strengthening our engagement framework to support local well being and advance the green transition" (p.82). Progress is "reported to the Leadership Team, the Sustainability Committee, the Audit Committee and the Board of Directors in accordance with our Governance framework."

Taking action on material impacts on affected communities

Reference: pages 82-83 (tagged "ESRS 2, BP-2, 17 Summary").

Local job creation (positive impact): "we continued to consider local suppliers and contractors for providing support to small infrastructure requirements related to these projects, leading to a positive impact in the form of creating local job opportunities," including a local research study on job creation potential in Lolland, Denmark across solar, wind and Power-to-X sectors (p.83).

Community engagement (negative impact addressed): the Stakeholder Engagement Policy was formally approved in 2025; a standardised grievance-form template was developed; the Stakeholder Engagement Procedure was updated for GIS-based stakeholder mapping (p.82-83).

Mining impacts on communities (upstream, potential negative impact): the company is "mapping affected communities in our upstream value chain to identify and address these risks through responsible sourcing and engagement," consistent with the OECD's Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (p.83).

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

Reference: pages 82-83 (tagged "ESRS 2, BP-2, 17 Summary").

Targets set as part of the 2026 Sustainability Strategy (pp.82-83):

• "We aim to promote local supplier opportunities and document all local contracts by 2025 (Completed)"
• "Implement a Stakeholder Engagement Plan for all projects reaching the development phase from 2025 onwards (In progress)"
• "Implement a Stakeholder Engagement Policy by 2026 (Completed)"
• "Ensure targeted training in good stakeholder engagement by 2026 (In progress)"
• "Map communities in our upstream value chain by 2026 (In progress)"

Progress and performance is "reported to the Leadership Team, the Sustainability Committee, the Audit Committee and the Board of Directors in accordance with our Governance framework."

Business conduct policies and corporate culture

Reference: pages 86-87 (tagged "G1-1").

"Policies and approach" (p.86): Sustainability Policy; Good Business Conduct; Whistleblower Policy; Data Ethics Policy; Code of Conduct for Business Partners.

"Business conduct is a material topic for European Energy, as confirmed by our double materiality assessment... Our approach to business conduct is centred on fostering a healthy corporate culture and a robust governance framework that together drive ethical behaviour across our operations and value chain" (p.86).

Material IROs addressed: data and privacy governance (potential negative impact / risk) — anchored in the Data Ethics Policy and Data Ethics Compass, with a 2025 roll-out plan for new Data Ethics Principles submitted for Leadership Team approval; and lack of awareness of grievance channels (actual negative impact) — addressed via the Whistleblower Mechanism, accessible to internal and external stakeholders, with 1 whistleblower case received in 2025 (0 in 2024), 0 substantiated, 0 transferred to police (p.87).

Prevention and detection of corruption and bribery

Reference: page 88 (tagged "G1-3 & G1-4").

"As a renewable energy developer operating globally, we recognise that the expansion of capital investments in the renewable energy sector, combined with expedited permitting and licensing processes, may increase exposure to risks of undue influence and distorted competition. We continuously strengthen our anti-corruption and anti-bribery programme" (p.88).

"Our zero-tolerance approach to corruption and bribery is embedded in the Good Business Conduct Policy and the Code of Conduct for Business Partners." All employees complete an online anti-corruption and anti-bribery course, U4, "recommended by the Danish Ministry of Foreign Affairs," as part of onboarding.

"In 2025, 84% of the workforce completed the anti-corruption and anti-bribery course, compared to 81% in 2024." At-risk functions represent 2.1% of the total workforce; 84% of identified at-risk functions were covered by training on good business conduct in 2025.

Targets related to business conduct

This disclosure requirement is a 2025/2026 ESRS renumbering of content the 2023 ESRS covered under MDR-T ("part of MDR-T/GDR-T disclosures"). European Energy's report is prepared under the 2023 ESRS and does not use the "G1-3" targets label; the content below is drawn from the corruption-prevention target disclosure at page 88.

"We have not set quantitative targets for this area. Instead, we prioritise efforts to support continued progress" (p.88). Qualitative targets set for anti-corruption and anti-bribery, in consultation with internal stakeholders (p.88):

• "We will strengthen the roles, expertise and monitoring of administrative, management and supervisory bodies related to responsible business conduct"
• "We will ensure employee training in good business conduct, including anti-corruption and anti-bribery training targeted specifically at employees in at-risk functions"
• "We will strengthen our know-your-counterparty screening programme, focusing on sanctions, government watchlists and adverse media"

Progress is reported to the Leadership Team, Sustainability Committee, Audit Committee and Board of Directors.

Incidents of corruption or bribery

Reference: page 88 (tagged "G1-3 & G1-4").

"We monitor convictions and fines related to violations of anti-corruption and anti-bribery laws as part of our governance and compliance oversight. In 2025, no convictions for violations of anti-corruption or anti-bribery laws were recorded, and no related fines were incurred. This was unchanged compared to 2024" (p.88).

2025 actions: conducted good business conduct training for at-risk functions; continued strengthening business-partner screening processes; clarified governance roles and responsibilities across support functions, headquarters and local offices.