GN Store Nord

Denmark|Medical Equipment & Supplies|FY2024|Auditor: PwC|View original report →

Value chain diagram – from the 2024 report (click to enlarge)

GN's value chain showing upstream raw material extraction through own operations (component manufacturing, product assembly, retail) to downstream distribution, product repair, and end-of-life waste treatment.Source: GN Store Nord 2024 annual report, p.48. View original →

ESRS 2General Disclosures

GOV-1The role of the administrative, management and supervisory bodies
Reported

Board of Directors and Executive Leadership Team

Corporate Governance Structure

GN's corporate governance structure ensures effective oversight of sustainability matters:

Board of Directors: The Board of Directors oversees risk management across the value chain and ensures risks are managed effectively. Risk governance at GN is overseen by the Board of Directors, who ensure risks are managed across the value chain.

Executive Leadership Team: The Executive Leadership Team collectively challenges, validates, and prioritizes risks and risk handling activities. Risks are identified and governed by a risk department and the Executive Leadership Team for each division and selected functions.

Risk Management and Sustainability Governance

The Board of Directors annually reviews and approves a comprehensive risk report that has been reviewed and prioritized by the Executive Leadership Team. The Board conducts an annual Top Risk Review in December, where the Board of Directors' risk review takes place.

Sustainability Integration

Sustainability has become increasingly integrated into GN's business strategy over the past years. GN's approach to sustainability is driven by a desire to create real and lasting value for all stakeholders. GN has not set up a separate sustainability governance structure but uses existing business processes to drive the sustainability agenda.

Sustainability is integrated into how GN runs the company, as a consideration in key decisions on how they design products and run operations.

GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies
Reported

Information Provided to Administrative, Management and Supervisory Bodies

Risk Reporting to the Board

The Board of Directors receives comprehensive information on sustainability matters through GN's risk management process:

  • Annual Risk Review: A comprehensive risk report, reviewed and prioritized by the Executive Leadership Team, is presented to the Board of Directors annually for approval
  • Top Risk Review: The Board conducts an annual Top Risk Review in December
  • ESG Risk Integration: Environmental, social, and governance risks are integrated into the overall risk assessment process

Executive Leadership Team Engagement

The Executive Leadership Team meets to collectively challenge, validate, and prioritize risks and risk handling activities, including sustainability-related risks. This information is then consolidated and presented to the Board.

Audit Committee Oversight

The Audit Committee reviews the Organization Risk Governance process, ensuring proper oversight of risk management including sustainability matters.

Sustainability Strategy Communication

The Board and management receive information on GN's sustainability strategy, which focuses on three key areas where GN has the most impact:

  1. Sustainable design – developing product designs that impact the experience of products, not the environment
  2. Decarbonization – reducing carbon footprint as fast as the science tells us
  3. Supply chain responsibility – safeguarding human rights across the full value chain
GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemes
Reported

Integration of sustainability-related performance in incentive schemes

Roles covered

As stipulated in GN's Remuneration Policy, ESG-related performance is part of (annual) short-term incentive (bonus) objectives for all members of the Executive Leadership Team. This supports progress on policies, targets, and actions in mitigating our material IROs across several environmental and social topics.

All members of the ELT have separate targets related to Diversity, Equity, and Inclusion (DEI), focusing on initiatives aimed to increase representation of women in Senior Leadership roles across GN.

Where this is required, these objectives are cascaded down into the monetary short-term incentive objectives on an operational level across relevant divisions and functions.

ESG-related objectives for the CEO and CFO are approved annually by the Remuneration Committee.

Specific sustainability KPIs tied to remuneration

For the year 2024, ESG-related bonus objectives for the Executive Leadership Team consisted of:

  • One overall objective related to reducing carbon emissions across all scopes versus 2023 in support of making progress towards our 2030 climate targets
  • 10 key actions related to:
    • Decarbonization in specific areas
    • Increasing circularity
    • ESG-related supplier engagement
    • Sustainability-related marketing
    • CSRD compliance

All members of the ELT have separate targets related to Diversity, Equity, and Inclusion (DEI), focusing on initiatives aimed to increase representation of women in Senior Leadership roles across GN.

Weighting (% of STI / LTI tied to sustainability)

In the reporting year, 7.2% of the annual bonus was dependent on ESG objectives for the CEO and CFO, with 12% of their annual bonus linked to ESG, of which 50% was related to reduction of carbon emissions.

Performance period and target structure

ESG-related performance is part of annual short-term incentive (bonus) objectives for all members of the Executive Leadership Team.

ESG-related bonus objectives are discussed and approved by the Remuneration Committee on an annual basis.

Link to short-term or long-term incentive

ESG-related performance is integrated into short-term incentive (STI) schemes. The disclosure does not reference any ESG-related long-term incentive (LTI) schemes.

Governance and oversight

ESG-related bonus objectives are discussed and approved by the Remuneration Committee, where the Remuneration Committee is tasked to ensure ESG bonus objectives are aligned with the management of the most material ESG issues as part of the Board of Directors' wider oversight of ESG topics.

Progress on these targets is continuously monitored by subject matter experts in the business and discussed quarterly in ELT meetings.

Reporting

As stipulated in our Remuneration Policy and reported in remuneration reports, annual ESG-related bonus objectives are discussed and approved by the Remuneration Committee.

GOV-3(was GOV-4)Statement on due diligence
Omitted
GOV-4(was GOV-5)Risk management and internal controls over sustainability reporting
Reported

Risk Management and Internal Controls Over Sustainability Reporting

Risk Management Framework

GN has established a comprehensive risk management framework that encompasses sustainability-related risks:

Risk Governance Structure:

  • Risk governance at GN is overseen by the Board of Directors
  • Risks are identified and governed by a risk department and the Executive Leadership Team for each division and selected functions
  • Risks are evaluated based on their impact and likelihood

Risk Assessment Process:

PhaseTimingActivities
Initial risk assessmentQ1Prioritized areas receive automated risk and maturity questionnaires
Executive impact reviewQ4Executive Leadership Team collectively challenges, validates, and prioritizes risks
Financial reviewQ3Meeting with Finance to assess and validate impact of potential financial risks
Board Top Risk ReviewDecemberBoard of Directors' annual risk review
Audit Committee ReviewQ2Audit Committee reviews Organization Risk Governance process

Sustainability Risk Categories Managed

GN systematically manages several categories of sustainability-related risks:

Environmental Risks:

  • Climate change impacts on operations
  • Supply chain environmental risks
  • Product lifecycle environmental impacts

Social Risks:

  • Human rights in the value chain
  • Workforce development and retention
  • Product quality and safety

Governance Risks:

  • Cybersecurity and data protection
  • Regulatory compliance
  • Geopolitical environment impacts

Internal Controls

GN has implemented internal controls over sustainability reporting through:

  • Integration of sustainability considerations into existing business processes
  • Regular monitoring and assessment of sustainability performance
  • Annual review and approval of sustainability-related risks by the Board of Directors

GN's approach ensures that sustainability risks are not managed separately but are integrated into the overall business risk management framework.

SBM-1Strategy, business model and value chain
Reported

Strategy, Business Model and Value Chain

Business Purpose and Strategy

GN's purpose is Bringing People Closer. For more than 155 years, GN has developed technology solutions with the purpose of bringing people closer to one another. Today, GN develops, manufactures, and markets innovative hearing aids for people with hearing loss; headsets, speakerphones, and video equipment for collaboration at work; and a broad range of gear for gaming aficionados.

Business Model

GN operates as an innovation-focused company with deep digital sound and visual processing competencies. As an integrated hardware, software, and AI enabled innovation powerhouse, GN delivers personalized and customer-centric experiences by providing the seamless interface between the user and technology ecosystems.

Three Focused Divisions:

  1. Hearing Division: Develops and markets hearing aids and accessories for people with hearing loss
  2. Enterprise Division: Provides audio and video collaboration equipment and services for businesses
  3. Gaming Division: Creates gaming peripherals and software solutions for gamers

Shared Capabilities Model

GN's business model leverages shared capabilities across divisions:

  • Customer-centric innovation: Unified R&D organization utilizing scale, talent, processes, and facilities
  • Multiplying impact through partnerships: Strategic partnerships with technology leaders like Microsoft, Zoom, Google, and Apple
  • Agile and scalable operations: Integrated manufacturing, sourcing, and supply chain operations
  • People and culture: Fostering engaged employees who thrive, grow, and perform

Value Chain Overview

Research & Development:

  • R&D centers in Denmark, United States, Netherlands, Poland, France, Italy, and China
  • Unique blend of expertise in human ear, audio, video, speech, gaming, wireless technologies, miniaturization, software, and AI
  • DKK 1.9 billion invested in R&D in 2024

Manufacturing:

  • Central and regional manufacturing sites for hearing aids in Australia, China, Denmark, Japan, Malaysia, South Korea, Spain, and United States
  • Enterprise and gaming products produced by carefully selected manufacturers mainly in Asia
  • Components sourced from suppliers primarily in Asia
  • Works with tier 1 manufacturers supported by more than 100 sub-suppliers

Sales and Distribution:

  • Hearing aids sold in around 100 countries with own customer teams in 30+ countries
  • Enterprise products sold via distributors, retailers, and own webstores in 80+ countries
  • Partners handle logistics, local customization, and final packaging from four regional centers in Mexico, Poland, China, and Hong Kong

Value Creation

GN's business model creates value by:

For Customers:

  • Hearing: Helping 11.2 million people with hearing loss lead better lives
  • Enterprise: Improving productivity, performance, and efficiency for businesses
  • Gaming: Enhancing gaming experiences for 160 million gamers globally

For Society:

  • Supporting remote collaboration to reduce carbon emissions from travel
  • Advancing hearing health awareness through initiatives like LISTEN TO THIS
  • Providing active entertainment that builds social connections

For Shareholders:

  • Asset-light business model generating solid cash flows
  • Strong margin focus supported by group-wide synergies
  • Financial targets: 5-8% organic revenue growth and 16-17% EBITA margin by 2028
SBM-2Interests and views of stakeholders
Reported

Interests and Views of Stakeholders

Stakeholder Engagement Approach

GN is committed to consistently creating value for customers, employees, shareholders, and the communities in which we operate. Building on our long history of responding to changing demands from our stakeholders, sustainability has over the past years become increasingly integrated into GN's business strategy.

Key Stakeholder Groups and Their Interests

Customers:

  • Hearing customers: Seek innovative hearing solutions that improve quality of life and social connections
  • Enterprise customers: Require reliable, secure, and efficient collaboration tools that enhance productivity
  • Gaming customers: Demand high-performance gaming peripherals that enhance their gaming experience
  • Interests: Product quality, innovation, reliability, customer service, and value for money

Employees:

  • Interests: Safe and inclusive workplace, career development, fair compensation, work-life balance
  • GN's approach: Fostering a great workplace where aspirations meet opportunities, where talent comes to fuel their professional passion, and where employees feel they truly belong regardless of who they are

Shareholders and Investors:

  • Interests: Competitive returns, sustainable growth, transparent communication, strong governance
  • GN's approach: Delivering competitive shareholder return through combination of dividend payments and share price appreciation, maintaining active dialogue with existing and potential shareholders

Communities and Society:

  • Interests: Positive societal impact, environmental responsibility, local economic development
  • GN's impact: 11.2 million people benefit directly from hearing solutions; supporting remote collaboration to reduce carbon emissions; advancing hearing health awareness

Partners and Suppliers:

  • Interests: Fair business practices, long-term partnerships, mutual growth opportunities
  • GN's approach: Building strong partnerships across the value chain, including technology partnerships with Microsoft, Zoom, Google, and Apple

Healthcare Professionals:

  • Interests: Access to innovative hearing solutions, professional development, patient outcomes
  • GN's initiatives: LISTEN TO THIS initiative to raise awareness of hearing loss and support hearing care professionals with insights into hearing health, brain health, and quality of life

Stakeholder Engagement Methods

Investor Relations:

  • Active dialogue through investor meetings, conferences, and presentations
  • Regular financial reporting and company announcements
  • Roadshows following interim and annual results
  • Coverage by sell-side analysts with research reports

Customer Engagement:

  • Customer-centric innovation approach across all divisions
  • Direct customer teams in 30+ countries for hearing business
  • Channel network of 20,000 resellers for enterprise business
  • Close collaboration with e-sports teams and gaming communities

Industry and Professional Engagement:

  • LISTEN TO THIS global initiative uniting industry leaders, academic institutions, and NGOs
  • Partnerships with major technology companies
  • Collaboration with hearing care professionals through education and training programs

Stakeholder Value Creation

GN's stakeholder engagement is guided by the principle of creating shared value:

  • Customer value: Through innovative products that solve real problems and enhance experiences
  • Employee value: Through inclusive culture, professional development, and meaningful work
  • Shareholder value: Through sustainable growth and strong financial performance
  • Societal value: Through products that improve lives and contribute to social connection and productivity
SBM-3Material impacts, risks and opportunities and their interaction with strategy and business model
Reported

Material Impacts, Risks and Opportunities and Their Interaction with Strategy and Business Model

Material Impacts Overview

GN has identified several material impacts, risks, and opportunities that significantly influence our strategy and business model:

Positive Impacts of GN's Business Model

Social Positive Impacts:

  • Hearing health improvement: GN's hearing instruments help users lead better lives – currently, more than 11.2 million people across the world benefit directly from our hearing solutions
  • Health risk mitigation: As connections between hearing loss, cognition, and health become clearer, untreated hearing loss becomes much more than a daily nuisance but rather a serious health risk
  • Enhanced collaboration: Audio and video solutions help customers choose remote collaboration over carbon-emitting travel or commuting, improving work-life balance with increased workplace flexibility
  • Social connection: Gaming solutions support people of all ages in their social interactions with other gamers, representing a more active form of entertainment than passive viewing

Environmental Positive Impacts:

  • Reduced carbon emissions: Enterprise solutions enable switching from long-distance travel to virtual meetings, reducing enterprises' climate footprint
  • Sustainable design focus: Developing product designs that impact the experience of products, not the environment

Material Risks and Their Strategic Integration

Geopolitical Environment Risks:

  • Impact: Economic uncertainty may decrease discretionary spending; supply chain dependencies in China/Asia face escalating geopolitical instability
  • Strategic Response: Pursuing operations and supply chain strategy to increase agility and resilience; reducing dependency on manufacturing in China; diversifying to serve almost entire U.S. market from manufacturing outside China

Market and Competitiveness Risks:

  • Impact: Highly competitive dynamics, market consolidation, product commoditization, and new competitors
  • Strategic Response: Embedding brand awareness into regional planning; proactive competitive modeling; nurturing relationships and unique propositions through customer-centric innovations; strengthening partnerships

Technology and Innovation Risks:

  • Impact: Need to access and deploy latest technologies in hardware, software, and services; maintain product quality throughout lifecycle
  • Strategic Response: Merged R&D teams into one organization for better scale and utilization of common technologies; customer-first innovation approach; centralized quality function

Cybersecurity Risks:

  • Impact: Products connecting to internet have inherent compromise risks; poor availability or data breaches could impact operations and reputation
  • Strategic Response: Secure practices in software development; Product Security Framework implementation; comprehensive training and risk management

Strategic Opportunities

Market Growth Opportunities:

  • Hearing: Aging population and health awareness drive growth; adoption still relatively low with opportunities for expansion
  • Enterprise: Hybrid work normalization creates demand for collaboration technology; AI integration opportunities through voice interaction
  • Gaming: Gaming becoming mainstream entertainment with growing global market

Technology Leadership Opportunities:

  • AI Integration: Years of combined AI and machine learning expertise across product areas, now utilized in close collaboration
  • Personalization: Increasing user demand for personalized technology experiences aligns with GN's capabilities
  • Sustainability: Growing focus on sustainability presents opportunities for business development and customer attraction

Integration with Business Strategy

One-Company Transformation: The material risks and opportunities have directly influenced GN's transformation into a one-company setup:

  • Simplified organizational structure for stronger resilience
  • Shared capabilities across R&D, Operations, and key functions
  • ~DKK 600 million in cost synergies identified across COGS and OPEX by 2026
  • DKK ~430 million synergies realized in 2024

Financial Targets Aligned with Material Factors:

  • 5-8% organic revenue growth (CAGR) targeting market share gains
  • 16-17% EBITA margin by 2028 leveraging operational synergies
  • 2.0x leverage by 2028 maintaining financial resilience

Sustainability Integration: Material environmental and social impacts drive three focus areas:

  1. Sustainable design – addressing product environmental impact
  2. Decarbonization58% reduction in scope 1 and 2 emissions vs 2021, targeting net-zero by 2050
  3. Supply chain responsibility – safeguarding human rights across value chain

Risk-Opportunity Balance

GN's business model balances material risks through:

  • Geographic diversification mitigating geopolitical risks
  • Technology leadership maintaining competitive advantages
  • Partnership strategy multiplying market reach and capabilities
  • Operational resilience ensuring supply chain flexibility

The material impacts, risks, and opportunities are systematically integrated into GN's strategic planning, risk management, and operational execution, ensuring the business model remains resilient and value-creating across all stakeholder groups.

IRO-1Description of the processes to identify and assess material impacts, risks and opportunities
Reported

Description of the Processes to Identify and Assess Material Impacts, Risks and Opportunities

Risk Identification and Mitigation Process

GN has established a systematic process for identifying and assessing material impacts, risks, and opportunities that operates on an annual cycle:

Annual Risk Assessment Cycle:

PhaseTimingProcess
Initial risk assessment processQ1 (Jan-Mar)Prioritized areas receive automated risk and maturity questionnaires. Responses are automatically calculated into risk likelihood and risk impact. Results are evaluated and challenged by Corporate Risk Governance team and consolidated in meetings with managers from prioritized areas
Audit Committee Risk Governance ReviewQ2 (Apr-Jun)Audit Committee reviews Organization Risk Governance process
Financial reviewQ3 (Jul-Sep)Meeting with Finance to assess and validate impact of potential financial risks
Executive impact reviewQ4 (Oct-Dec)Executive Leadership Team collectively challenges, validates, and prioritizes risks and risk handling activities
Board Top Risk ReviewDecemberBoard of Directors' annual risk review and approval

Risk Governance Structure

Board Level:

  • Risk governance overseen by the Board of Directors
  • Annual approval of comprehensive risk report
  • Ensure risks are managed across the value chain

Executive Level:

  • Executive Leadership Team collectively challenges, validates, and prioritizes risks
  • Risk department works with Executive Leadership Team for each division and selected functions
  • Risks evaluated based on impact and likelihood

Operational Level:

  • Corporate Risk Governance team evaluates and challenges responses
  • Managers from prioritized areas participate in consolidation meetings
  • Finance function assesses and validates financial risk impacts

Double Materiality Assessment Process

GN conducts a double materiality assessment to identify material impacts, risks, and opportunities:

Impact Materiality Assessment:

  • Evaluates actual and potential impacts on people and the environment
  • Considers both negative and positive impacts
  • Assesses impacts across the entire value chain

Financial Materiality Assessment:

  • Evaluates risks and opportunities that affect enterprise value
  • Considers short, medium, and long-term time horizons
  • Assesses likelihood and magnitude of financial effects

Stakeholder Engagement in Risk Assessment

GN's risk identification process incorporates input from various stakeholders:

Internal Stakeholders:

  • Executive Leadership Team participation in quarterly reviews
  • Division and functional managers providing area-specific insights
  • Corporate Risk Governance team providing oversight and challenge
  • Finance team validating financial impact assessments

External Stakeholder Considerations:

  • Customer feedback and market analysis informing competitive risks
  • Supplier and partner input on supply chain and operational risks
  • Regulatory and policy developments affecting compliance risks
  • Industry trends and benchmarking informing strategic risks

Risk Categories Systematically Assessed

GN's process covers multiple risk categories:

Strategic and Market Risks:

  • Geopolitical environment and trade relations
  • Market competitiveness and commoditization
  • Technology advancement and innovation gaps

Operational Risks:

  • Manufacturing and supply chain disruptions
  • IT landscape and cybersecurity threats
  • Product quality and security by design

Financial Risks:

  • Currency fluctuations and interest rate changes
  • Credit risks and liquidity management
  • Investment and M&A risks

ESG Risks:

  • Climate change and environmental impacts
  • Human rights and labor practices in value chain
  • Data privacy and cybersecurity

Continuous Monitoring and Updates

The risk identification and assessment process is dynamic:

  • Quarterly monitoring of key risk indicators
  • Annual comprehensive review and update of risk assessments
  • Event-driven updates when significant changes occur
  • Regular benchmarking against industry best practices

Integration with Business Strategy

The identified material impacts, risks, and opportunities are systematically integrated into:

  • Strategic planning and decision-making processes
  • Business model development and transformation initiatives
  • Financial planning and target setting
  • Operational planning and resource allocation
  • Sustainability strategy and reporting

This comprehensive process ensures that GN maintains a thorough understanding of its material impacts, risks, and opportunities, enabling proactive management and strategic alignment across the organization.

IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Reported

Disclosure Requirements in ESRS Covered by the Undertaking's Sustainability Statement

Material ESRS Topics

Based on GN's double materiality assessment, the following ESRS topics have been determined to be material:

ESRS 2 – General Disclosures:

  • All general disclosure requirements are covered as they provide the foundation for sustainability reporting

Environment:

  • E1 – Climate Change: Material due to GN's climate commitments and carbon reduction targets
  • E2 – Pollution: Material due to product lifecycle impacts and manufacturing processes
  • E5 – Resource Use and Circular Economy: Material due to focus on sustainable design and product lifecycle management

Social:

  • S1 – Own Workforce: Material due to importance of talent retention and employee engagement
  • S2 – Workers in the Value Chain: Material due to global supply chain and manufacturing partnerships
  • S4 – Consumers and End-Users: Material due to direct impact on users' health and wellbeing through products

Governance:

  • G1 – Business Conduct: Material due to global operations and partnership-based business model

ESRS Disclosure Requirements Covered

The following table outlines which disclosure requirements are covered in this sustainability statement:

ESRS 2 – General Disclosures:

  • GOV-1: Role of administrative, management and supervisory bodies
  • GOV-2: Information provided to administrative bodies on sustainability matters
  • GOV-5: Risk management and internal controls over sustainability reporting
  • SBM-1: Strategy, business model and value chain
  • SBM-2: Interests and views of stakeholders
  • SBM-3: Material impacts, risks and opportunities
  • IRO-1: Description of processes to identify and assess material impacts
  • IRO-2: Disclosure requirements covered by sustainability statement

E1 – Climate Change:

  • E1-2: Policies related to climate change mitigation and adaptation
  • E1-3: Actions and resources related to climate change policies
  • E1-4: Targets related to climate change mitigation and adaptation
  • E1-5: Energy consumption and mix
  • E1-6: Gross Scopes 1, 2, 3 and Total GHG emissions

E2 – Pollution:

  • E2-1: Policies related to pollution
  • E2-4: Pollution of air, water and soil
  • E2-5: Substances of concern and substances of very high concern

E5 – Resource Use and Circular Economy:

  • E5-1: Policies related to resource use and circular economy
  • E5-4: Resource inflows
  • E5-5: Resource outflows

S1 – Own Workforce:

  • S1-1: Policies related to own workforce
  • S1-6: Characteristics of the undertaking's employees
  • S1-9: Diversity metrics
  • S1-13: Training and skills development metrics
  • S1-14: Health and safety metrics

S2 – Workers in the Value Chain:

  • S2-1: Policies related to value chain workers
  • S2-4: Taking action on material impacts on value chain workers

S4 – Consumers and End-Users:

  • S4-1: Policies related to consumers and end-users
  • S4-4: Taking action on material impacts on consumers and end-users

G1 – Business Conduct:

  • G1-1: Business conduct policies and corporate culture
  • G1-2: Management of relationships with suppliers
  • G1-3: Prevention and detection of corruption and bribery

Topics Deemed Not Material

The following ESRS topics were assessed but determined not to be material for GN:

Environment:

  • E3 – Water and Marine Resources: Not material due to limited water-intensive operations
  • E4 – Biodiversity and Ecosystems: Not material due to limited direct impact on biodiversity

Social:

  • S3 – Affected Communities: Not material due to limited direct community impacts from operations

Materiality Assessment Methodology

The materiality determination was based on:

Impact Materiality:

  • Assessment of actual and potential positive and negative impacts on people and environment
  • Evaluation across entire value chain including upstream and downstream activities
  • Consideration of severity, scope, and likelihood of impacts

Financial Materiality:

  • Assessment of sustainability matters that trigger financial effects on the undertaking
  • Evaluation of risks and opportunities affecting enterprise value
  • Consideration of short, medium, and long-term time horizons

Reporting Framework Compliance

This sustainability statement is prepared in accordance with:

  • EU Corporate Sustainability Reporting Directive (CSRD)
  • European Sustainability Reporting Standards (ESRS)
  • Additional requirements in the Danish Financial Statements Act

The statement constitutes GN's reporting according to Section 99a, 99b, 99d, and 107d in the Danish Financial Statements Act and section §139c in Danish Companies Act.

E1Climate Change

E1-1Transition plan for climate change mitigation
Reported

Transition plan for climate change mitigation

Scope and coverage

The transition plan covers all GHGs stipulated in the GHG Protocol and all activities in GN's own operations and value chain globally. The plan is integrated into the company's wider strategy and business model.

Target years and milestones

Net-zero target: GN is committed to reaching net-zero GHG emissions by 2050 at the latest, meaning 90% reduction with neutralization of unabated emissions.

Reduction milestones:

TargetScopesBase yearBaseline valueTarget yearTarget valueReduction %Current valueProgress to target %Target reference value*Methodology
Near-term target 1Scope 1 (23%) scope 2 market-based (77%)20219,83120301,96680%4,183725,702Science-based target, approved by SBTi
Near-term target 2Scope 32021349,0062030261,75525%257,107105174,503Science-based target, approved by SBTi
Long-term targetScopes 1 (<1%), 2 (2%) and 3 (98%)2021358,837205035,88490%261,2903035,884Science-based target, not approved by SBTi

*Cross-sector (ACA) reductions pathway based on the year 2020 as the reference year from Pathways to Net-zero –SBTi Technical Summary (Version 1.0, October 2021)

Alignment with 1.5°C and SBTi validation

GN's near-term targets have been set using the Science Based Targets initiative's (SBTi) Criteria v5.0 with the absolute contraction approach and the cross-sector pathway, which is based on the P1 scenario in the IPCC Special Report on Global Warming of 1.5°C. The near-term targets have been approved by SBTi. The net-zero target has been aligned to the SBTi's cross-sector absolute reduction method for long-term targets but has not yet been approved by SBTi.

GN demonstrates commitment to ensure the business is compatible with the transition to a net-zero economy and with the limiting of global warming to 1.5°C in line with the Paris Agreement.

GN is not excluded from the Paris-aligned benchmarks.

Key decarbonization levers and actions

GN has identified six decarbonization levers to meet climate targets and policy objectives:

Scope 1 and 2 levers:

  1. Renewable energy: The share of renewable energy consumed has increased to 39% from a 3% baseline in 2021, primarily through the procurement of Renewable Energy Certificates (RECs). RECs source solar power for headquarters and production facility in Denmark, global manufacturing centers in China and Malaysia, and regional operations center in the United States. In 2025, GN will develop a long-term renewable energy plan for all sites in operational control with more than 50 employees, including assessing potential for onsite generation at major production sites.

  2. Energy efficiency: Based on energy audit recommendations from 2023, several initiatives have been implemented at the global production facility in Malaysia, including modifications to cooling systems and lighting, as well as replacement of process equipment. Energy consumption per unit production has decreased by 37% since 2023, with an absolute reduction in energy consumption and related emissions of 8% and 6%, respectively. In 2025, GN plans to carry out a follow-up energy audit at the Malaysia facility and conduct an energy audit at the production facility in Xiamen, China.

  3. Fleet electrification: Company car policies are updated on an ongoing basis to encourage transition towards electric vehicles.

Scope 3 levers:

  1. Product and packaging design: GN has increased the use of lower carbon materials in new product development, particularly in the Enterprise division. From having used less than 1% recycled or renewable plastic in products in 2021, the proportion of recycled or renewable plastics and synthetic fibers out of total weight of plastic and synthetic fibers has increased to 11.4% across the product portfolio in 2024. Four new products with recycled or renewable plastic were launched in 2024, with more products containing recycled or renewable plastic to be launched in 2025. GN continuously tests recycled and bio-based alternatives for suitability.

  2. Decarbonization of transport and logistics: Reducing air freight is a significant decarbonization lever for GN. In 2024, the share of air freight (by tonkm) from global to regional warehouses was reduced.

  3. Supply chain engagement: Expectations of suppliers to provide accurate carbon data are captured in the Supplier Code of Conduct to enable a data-driven approach to decarbonization strategy.

Actions table:

Key emission reduction initiativeScopeTimeframeEmissions scopeAchieved emissions reduction (tCO2eq) in 2024Expected outcomes/ emissions reduction (tCO2eq)Associated TargetEU Taxonomy economic activity
Renewable energyOwn operations - Hearing division production facilities and key officesUnbundled RECs were purchased in 2024 in China and the US to cover consumption in 2024Scope 2 (market-based)An absolute reduction of 2,131 tCO2eq from 2021 was achieved, of which 93% was through the purchase of RECs, with the remainder coming from a reduction in consumption at these sitesWe plan to continue sourcing renewable energy for our HQ and our key production sites. We expect to source renewable energy for additional sites in 2025, further reducing market-based Scope 2 emissionsScope 1 and 2 targetN/A
Energy efficiencyOwn operations (Global manufacturing facility, Malaysia)Recommended initiatives from the 2023 energy audit were implemented in 2024Scope 2 (location-based)Energy consumption decreased by 8% from 2023, despite increased production output. This achieved an emissions reduction of 141 tCO2eq (6%)We expect to save approximately 140 tCO2eq in location-based Scope 2 emissions per year from the implemented energy efficiency initiativesLocal target to reduce annual power consumption by 3% in 2024 (from 2023)CCM 7.3
Fleet electrificationOwn operations (Global)We are rolling out new company car policies on an ongoing basis for new lease contractsScope 1Transitioning to electric cars has achieved a reduction of 25 tCO2eq, compared with the scenario where new leases in 2024 were petrol carsReducing the number of fossil fuel cars in our fleet will lead to an increasing annual reduction of our Scope 1 emissions, the majority of which come from car fuelsScope 1 and 2 targetCCM 6.5
Supply-chain decarbonizationValue chain (Enterprise inbound logistics)Minimizing air freight in our inbound logistics (by weight) has been an ongoing initiative since 2021. We will continue to do this and have dedicated short-term bonus objectives to support this initiativeScope 3The absolute emissions reduction from the 2021 baseline is estimated to be 37,909 tCO2eqWe expect further emission reductions from this action in future, but we are not able to quantify these, as freight volumes fluctuateScope 3 targetN/A
Supply-chain decarbonizationValue chain (Hearing division outbound road freight in EMEA)Carbon insetting through purchase of HVO fuels has been implemented from July 2024 onwardsScope 3Through the purchase of HVO fuels, we have reduced transportation emissions by 2.07 tCO2eq in 2024With the continued purchase of HVO fuels at the same rate we expect to reduce Scope 3 Category 4 emissions by around 4.1 tCO2eq annuallyScope 3 targetN/A
Product design: low-carbon materialsValue chain (Products in Enterprise and Gaming & Consumer divisions)The ongoing inclusion of sustainable design requirements in our product development process, including use of recycled materials, has led to emission reductions from new product launches and product updatesScope 331 tCO2eq reduction was achieved for Enterprise products released in 2024 by replacing 6% of the virgin fossil plastic (PC/ABS) weight with recycled or renewable alternativesWe expect that the work we have done to test and incorporate these materials in our new product development will lead to increasing emissions reductions in 2025 and beyondScope 3 target, Resource inflows targetN/A

CapEx / investment commitments

While specific CapEx commitments for decarbonization are not quantified, all decarbonization initiatives are anchored within existing business model and financial planning. GN does not currently have material climate-related financial risks.

The company does not expect alignment of its economic activities with the delegated act on climate objectives to change significantly in the future. However, a small increase in CAPEX and OPEX alignment may be expected in eligible economic activities such as:

  • Construction of new buildings and production facilities (CCM/CCA 7.1)
  • Building renovation measures (CCM/CCA 7.2)
  • Energy efficiency initiatives at facilities (CCM/CCA 7.3)
  • Installation of onsite renewable energy capacity (CCM/CCA 7.6)
  • Electrification of car fleet (CCM/CCA 7.4)

Locked-in emissions and stranded asset analysis

An estimated 41,792 tCO2e are locked-in emissions from the use of GN products sold in 2024, which currently makes up 16% of total Scope 3 emissions. These use phase emissions could still be reduced through firmware updates in the market, but it remains difficult to quantify potential emissions reductions from such initiatives.

As these emissions result from electricity consumption, GN expects significant reduction to take place as a result of the global shift towards renewable energy as part of the transition to a net-zero economy outside GN's direct control. Given the general duration of use of GN products, the company doesn't expect these locked-in emissions to prevent it from reaching net-zero in 2050, regardless of the pace of the transition to renewable energy.

None of GN's assets or business activities are considered incompatible with or need significant efforts to be compatible with a transition to a climate-neutral economy, for example due to significant locked-in GHG emissions or the requirements for alignment to the EU Taxonomy requirements.

Use of carbon credits and removals

GN's policy states that the company does not consider carbon offsetting as an alternative to carbon reduction, and that GN will only engage in carbon removal that is independently certified. GN will not claim any carbon avoidance claims related to its products as part of meeting its climate targets.

The net-zero target includes neutralization of unabated emissions (the remaining 10% after 90% reduction) to reach net zero by 2050.

Governance and incentives

The Board of Directors has approved the climate policy, targets, and incentives.

As stipulated in GN's Remuneration Policy, ESG-related performance is part of (annual) short-term incentive (bonus) objectives for all members of the Executive Leadership Team. For the year 2024, these objectives consisted of one overall objective related to reducing carbon emissions across all scopes versus 2023 in support of making progress towards the 2030 climate targets, and 10 key actions related to decarbonization in specific areas.

For the CEO and CFO, 7.2% of the annual bonus was dependent on these objectives, with 12% of their annual bonus linked to ESG, of which 50% was related to reduction of carbon emissions.

Current performance and outlook

GN is on track to meet the 80% 2030 reduction target for Scope 1 and 2 emissions, having reduced emissions by 58% already versus the 2021 baseline. For carbon emissions in Scope 3, in 2024 GN reached the reduction target of 25% by 2030, having reduced emissions by 26% versus the baseline.

Current emissions demonstrate that the target is achievable but, as there are many factors influencing future emissions, this is no guarantee GN will continue to achieve this target in 2030 and the years in between.

Emissions are largely driven by production volumes, and organic growth is therefore likely to lead to higher emissions. Ensuring GN meets targets on a continuous basis will likely require decoupling organic growth from increased emissions by decreasing the carbon intensity of activities.

To ensure the company will utilize the levers to the extent required to meet these targets, GN will integrate its transition plan into company strategy, as well as supporting divisional and functional strategies, in 2025.

Scenario analysis

The International Energy Agency's Net-Zero Emissions scenario (IEA NZE) was used to identify likely contextual decarbonization when identifying the decarbonization levers GN can act on to reach its climate targets. For example, given that GN's products consume electricity, the expected decarbonization of the power grids in major markets was relevant to understand the trajectory for Scope 3 category 11 emissions, irrespective of any potential improvements to the energy efficiency of products.

A high-level qualitative assessment was carried out using the RCP8.5, IEA Net-Zero Emissions by 2050 Scenario (NZE) and IEA STEPS scenarios.

E1-4(was E1-2)E1-2
Reported

Policies Related to Climate Change Mitigation and Adaptation

Climate Change Policy Framework

GN has established comprehensive policies related to climate change mitigation and adaptation as part of its commitment to protecting the planet and reaching net-zero emissions by 2050, in line with the scientific consensus on limiting global warming to 1.5 degrees Celsius.

Climate Mitigation Policies

Carbon Reduction Strategy: GN has laid out an ambitious strategy to reduce negative impact from its activities, focusing on:

  • Decarbonization: Reducing carbon footprint as fast as the science tells us
  • Net-zero commitment: Achieving net-zero emissions by 2050
  • Science-based targets: Aligning with 2030 climate goals based on climate science

Sustainable Design Policy: GN focuses on sustainable design as one of three key areas:

  • Developing product designs that impact the experience of products, not the environment
  • Supporting the transition to a circular economy through design decisions
  • Integrating sustainability considerations into product development processes

Supply Chain Climate Policy: Climate considerations are integrated into supply chain decisions:

  • Manufacturing and supply chain decisions driven by sustainability ambitions
  • Working with suppliers on climate-related improvements
  • Pursuing operations strategy to increase resilience against climate-related disruptions

Climate Adaptation Policies

Operational Resilience: GN has implemented policies to adapt to climate-related physical risks:

  • Supply chain diversification: Reducing dependency on single geographic regions to increase resilience
  • Geographic flexibility: Developing capability to serve markets from multiple manufacturing locations
  • Risk mitigation strategies: Implementing robust risk mitigation strategies for extreme weather and climate change impacts

Business Continuity: Policies ensure business continuity in face of climate impacts:

  • Balancing operations between different facilities to reduce climate risk exposure
  • Regional manufacturing options to enhance resilience
  • Enhanced systems for improved stability and capacity during climate-related disruptions

Integration with Business Strategy

Strategic Integration: Climate policies are integrated into business strategy:

  • Sustainability viewed as an investment rather than a cost
  • Climate considerations drive design, manufacturing, and supply chain decisions
  • Policies support business development opportunities through sustainability focus

Stakeholder Engagement: Climate policies consider stakeholder expectations:

  • Growing focus on sustainability from customers, employees, and other stakeholders
  • Policies designed to attract sustainability-minded customers and employees
  • Compliance with growing product-related sustainability legislation

Governance and Implementation

Policy Governance:

  • Climate policies integrated into existing business processes rather than separate sustainability governance structure
  • Board oversight through risk management framework
  • Executive Leadership Team involvement in climate-related decision making

Continuous Improvement:

  • Regular assessment of climate policies against evolving scientific consensus
  • Updates to policies based on stakeholder feedback and regulatory developments
  • Integration of climate considerations into all key business decisions

These policies demonstrate GN's commitment to addressing climate change through both mitigation of its environmental impact and adaptation to climate risks, ensuring long-term business resilience while contributing to global climate goals.

E1-5(was E1-3)E1-3
Reported

Actions and Resources Related to Climate Change Policies

Climate Action Implementation

GN has implemented comprehensive actions and allocated significant resources to support its climate change mitigation and adaptation policies:

Carbon Reduction Actions

Achieved Emissions Reductions:

  • 58% reduction in scope 1 and 2 carbon emissions vs 2021 baseline
  • 26% reduction in scope 3 carbon emissions vs 2021 baseline
  • Progress toward 2030 climate goals and net-zero emissions by 2050

Operational Decarbonization:

  • Implementation of energy efficiency measures across operations
  • Transition to renewable energy sources where feasible
  • Optimization of manufacturing processes to reduce energy consumption

Supply Chain Climate Actions

Manufacturing Diversification:

  • Reduced dependency on manufacturing in China as part of climate resilience strategy
  • Capability to serve almost entire U.S. market from manufacturing outside China
  • Diversification strategy ongoing to enable flexible response to climate-related disruptions

Supply Chain Resilience:

  • Enhanced inbound logistics visibility to proactively manage climate-related disruptions
  • Onboarding new vendors that can produce outside of traditionally climate-vulnerable regions
  • Regional manufacturing options investigation to reduce climate exposure
  • Risk diversification strategy focused on climate resilience

Sustainable Design Actions

Product Development:

  • Integration of sustainability considerations into product design processes
  • Focus on developing products that minimize environmental impact
  • Support for circular economy transition through design decisions
  • Compliance with growing product-related sustainability legislation

R&D Investment:

  • DKK 1.9 billion invested in R&D in 2024
  • Portion of R&D focused on sustainable technology development
  • Innovation in products and services supporting climate goals

Resource Allocation

Financial Resources:

  • Significant capital allocated to supply chain diversification and resilience
  • Investment in sustainable manufacturing technologies
  • Resources dedicated to achieving sustainability certifications

Human Resources:

  • Dedicated teams working on sustainability integration across business processes
  • Training and development programs on climate-related topics
  • Executive Leadership Team involvement in climate-related decisions

Technology Resources:

  • Enhanced systems for improved stability and capacity during climate disruptions
  • IT infrastructure modernization to support sustainable operations
  • Advanced monitoring systems for tracking climate performance

Partnership and Collaboration Actions

Technology Partnerships:

  • Collaboration with technology partners on sustainable solutions
  • Integration with partners' sustainability initiatives
  • Joint development of climate-friendly technologies

Supply Chain Collaboration:

  • Working with tier 1 manufacturers and more than 100 sub-suppliers on climate initiatives
  • Long-term strategic partnerships with focus on sustainability
  • Proactive communication and problem-solving for climate-related supply chain issues

Operational Climate Actions

Facility Management:

  • Balancing operations between different facilities to optimize climate performance
  • Energy efficiency improvements across global facilities
  • Transition to sustainable facility management practices

Transportation and Logistics:

  • Optimization of distribution networks from four regional centers in Mexico, Poland, China, and Hong Kong
  • Reduction of transportation-related emissions through efficient logistics
  • Partners responsible for final packaging to optimize lead-time and reduce emissions

Monitoring and Reporting Actions

Performance Tracking:

  • Regular monitoring of emissions reduction progress
  • ESG ratings tracking: AA rating from MSCI, 10.6 (low risk) from Sustainalytics, B rating from CDP Climate Change
  • Annual reporting on climate performance in accordance with CSRD requirements

Continuous Improvement:

  • Annual review and update of climate action plans
  • Integration of climate performance into business decision-making
  • Benchmarking against industry best practices and scientific recommendations

These comprehensive actions and resource allocations demonstrate GN's commitment to implementing its climate policies effectively and achieving its ambitious climate targets while building operational resilience against climate-related risks.

E1-6(was E1-4)E1-4
Reported

Targets Related to Climate Change Mitigation and Adaptation

Climate Targets Overview

GN has established ambitious climate targets aligned with scientific consensus on limiting global warming to 1.5 degrees Celsius:

Carbon Emissions Reduction Targets

Long-term Target:

  • Net-zero emissions by 2050 in line with scientific consensus on limiting global warming to 1.5 degrees Celsius

Medium-term Targets:

  • 2030 climate goals for significant emissions reduction (baseline year: 2021)

Achieved Progress (as of 2024):

ScopeTarget Progress2024 Achievement vs 2021 Baseline
Scope 1 and 2Significant reduction58% reduction
Scope 3Significant reduction26% reduction

Adaptation Targets

Supply Chain Resilience:

  • Target: Capability to serve almost entire U.S. market from manufacturing outside China
  • Status: Implementation ongoing as part of diversification strategy

Operational Resilience:

  • Target: Achieve resilient global supply chain able to withstand climate-related disruptions
  • Actions: Ongoing diversification of manufacturing footprint and distribution networks

Supporting Targets

Sustainable Design:

  • Target: Integrate sustainability considerations into all product design processes
  • Focus: Develop products that impact user experience, not environment
  • Support: Transition to circular economy through design decisions

Supply Chain Engagement:

  • Target: Work with all tier 1 manufacturers and key sub-suppliers on climate initiatives
  • Current scope: Working with tier 1 manufacturers supported by more than 100 sub-suppliers

Performance Monitoring

ESG Performance Tracking:

  • External validation through ESG ratings:
    • MSCI: AA rating (indicating strong climate performance)
    • Sustainalytics: 10.6 (low risk) rating
    • CDP Climate Change: B rating

Internal Monitoring:

  • Annual tracking of emissions reduction progress against 2021 baseline
  • Regular assessment of climate target achievement
  • Integration of climate performance into business reporting

Target Alignment

Science-based Alignment:

  • Targets aligned with 1.5°C global warming limitation as per scientific consensus
  • 2021 established as baseline year for climate targets
  • Regular review against evolving climate science

Business Integration:

  • Climate targets integrated into overall business strategy
  • Financial targets towards 2028 consider climate resilience
  • Operational planning incorporates climate target achievement

Future Target Development

Continuous Enhancement:

  • Regular review and potential enhancement of climate targets
  • Alignment with evolving regulatory requirements
  • Integration with industry best practices and stakeholder expectations

Scope Expansion:

  • Potential expansion of targets to cover additional scopes and activities
  • Enhanced granularity in target setting across business divisions
  • Integration with circular economy targets

These targets demonstrate GN's commitment to achieving significant climate impact reduction while building resilience against climate-related risks, supporting both global climate goals and long-term business sustainability.

E1-7(was E1-5)Energy consumption and mix
Reported

Energy consumption and mix

Total energy consumption and renewable share

In 2024, 38.5% of GN's energy consumption came from renewable sources (up from 2.9% in 2021), including purchase of 4,886 MWh of bundled RECs (4,500 MWh from a power purchase agreement in Denmark, the remainder from green tariffs) and 7,454 MWh of unbundled RECs in Malaysia, China, and the U.S., where GN has hearing aid production facilities. All purchased RECs came from solar or wind power generation.

Energy consumption by source

Energy sourceMWh (2024)
Fossil sources
Fuel consumption from coal and coal products-
Fuel consumption from crude oil and petroleum products11,613
Fuel consumption from natural gas2,064
Fuel consumption from other fossil sources-
Consumption of purchased or acquired electricity, heat, steam, and cooling from fossil sources5,220
Total fossil energy consumption18,897
Share of fossil sources in total energy consumption59%
Nuclear sources
Consumption from nuclear sources366
Share of consumption from nuclear sources in total energy consumption1%
Renewable sources
Fuel consumption for renewable sources (biomass, biogas, renewable hydrogen, etc.)-
Consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sources12,754
The consumption of self-generated non-fuel renewable energy-
Total renewable energy consumption12,754
Share of renewable sources in total energy consumption*40%
Total energy consumption32,017

*Including renewable sources in the grid mix

Energy intensity (high climate impact sector)

MetricUnit2024
Total energy consumption from activities in high climate impact sectorsMWh18,072
Net revenue from activities in high climate impact sectorsDKKm7,104
Energy intensity MWh/ DKK million-2.54

GN's Hearing division falls under NACE Code C26.6: Manufacture of irradiation, electromedical, and electrotherapeutic equipment.

Methodology

Energy purchased directly from the vendor is included. Where actual energy consumption from invoices is unavailable, consumption is estimated based on the relevant historical period. For electricity and heat, supplier-specific energy mix was used where available. Otherwise, national grid mix was assumed.

E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissions
Reported

Gross Scopes 1, 2, 3 and Total GHG emissions

Summary of GHG Emissions

GN Store Nord has disclosed comprehensive GHG emissions across all scopes for 2024, with multi-year comparison to the 2021 baseline.

Scope 1 Emissions

GHG Emissions (tCO2eq)2021 (Baseline)2024
Gross Scope 1 GHG emissions2,4472,748
Percentage Scope 1 GHG emissions from regulated emissions trading scheme (%)--

Scope 1 sub-breakdown (narrative): Stationary emissions decreased 15% from 2021 baseline. Fugitive emissions decreased 44% from 2021 baseline, largely caused by lower cooling consumption in Denmark. Mobile emissions increased 20% since 2021 from an increase in company car use after the Covid-19 pandemic.

Scope 2 Emissions

GHG Emissions (tCO2eq)Calculation methodEmission Factors2021 (Baseline)2024
Gross location-based Scope 2 GHG emissionsIEA, EPA, DEFRA6,2645,748
Gross market-based Scope 2 GHG emissionsEnergy attribute-specific, Supplier specific and residual mixes7,3841,435

Scope 1 & 2 GHG emissions (market-based): 9,831 tCO2eq (2021) → 4,183 tCO2eq (2024)

Scope 3 Emissions by Category

GHG Emissions (tCO2eq)Calculation methodEmission Factors2021 (Baseline)2024
Scope 3 GHG emissions349,006257,107
1 Purchased goods and servicesSpend-based and LCAsEcoinvent, Supplier specific, DEFRA164,916135,345
2 Capital goodsAverage spend-basedDEFRA17,13112,632
3 Fuel and energy-related activitiesAverage-data methodDEFRA8591,100
4 Upstream transportation and distributionDistance-based and average-dataDEFRA, Supplier specific90,24539,932
5 Waste generated in operationsWaste-type-specificDEFRA93230
6 Business travelDistance and spend-basedDEFRA2,6309,605
7 Employee commutingDistance-basedDEFRA9,6177,258
8 Upstream leased assetsAsset-specificIEA, EPA, DEFRA1,8701,922
9 Downstream transportation and distributionDistance-based and average dataDEFRA8,9535,749
11 Use of sold productsDirect use-phase emissions (electricity)IEA, EPA, DEFRA50,49541,792
12 End-of-life treatment of sold productsWaste-type-specificDEFRA2,1971,542

Scope 3 categories not reported: Categories 10 (Processing of sold products), 13 (Downstream leased assets) and 14 (Franchises) are not relevant to GN and are not reported. Category 15 (Investments) is not deemed material.

Total GHG Emissions

GHG Emissions (tCO2eq)2021 (Baseline)2024
Total GHG emissions (location-based)357,717265,603
Total GHG emissions (market-based)358,837261,290

Biogenic Emissions

Biogenic EmissionsEmission Factors2021 (Baseline)2024
Biogenic CO2 emissions in Scope 1DEFRA0.100.13
Biogenic emissions in the value chainEcoinvent, DEFRA-4,956-4,780

GHG Intensity

GHG emissions intensity (tCO2eq/ DKK million)2021 (Baseline)2024
Total GHG emissions (location-based) per net revenue19.414.8
Total GHG emissions (market-based) per net revenue19.414.5

Methodology and Scope Notes

Scope 1: Direct emissions from combustion of purchased fuels onsite for heat and in vehicles owned or leased by the company, as well as fugitive emissions from refrigerant gases in production facilities. Emissions calculated using DEFRA factors. Fuel or electricity consumption from vehicles obtained from invoices or system-generated reports from vendors. Where consumption data unavailable, distance-based method used.

Scope 2: Indirect emissions from purchased electricity and district heating for production sites and offices and electric or hybrid vehicles. Only fuel, electricity, and heat purchased directly from the vendor by GN is accounted. Market-based approach uses GHG emission attributes from RECs, supplier-specific and residual mix factors; otherwise location-based factors used. Emission factors applied do not separate percentage of biomass or biogenic CO2.

Scope 3: Reporting based on GHG Protocol guidance. Actual data used where available; otherwise industry averaged data or estimates used. Where activity data quality insufficient, spend data used as proxy. All transport-related emissions calculated on Well-to-Wheel basis.

  • Category 1: Indirect procurement calculated using categorized spend data. Cradle-to-gate LCAs used for direct procurement.
  • Category 2: Calculated using categorized spend data for PPE.
  • Category 3: Upstream emissions from energy consumption at sites and fleet vehicles where GN has operational control.
  • Category 4: Calculated using supplier-specific reported emissions or distance and chargeable weight data. Includes some outbound freight emissions GN does not pay for.
  • Category 5: Collection and treatment emissions for waste from four of five major production sites and headquarters; remaining sites estimated.
  • Category 6: Air travel, train travel and hotel stay from ticket data, uplifted using spend data.
  • Category 7: Based on employee survey scaled for country-level changes in employee numbers.
  • Category 8: Energy use at sites not in Scopes 1 and 2, calculated with market-based approach.
  • Category 9: Warehousing or retail activities not owned or purchased by GN, estimated using energy intensity per unit floorspace.
  • Category 11: Power consumption of all GN products using LCA measurements, estimated use cases and product lifetimes. Locked-in emissions from products sold in 2024: 41,792 tCO2eq (16% of total Scope 3).
  • Category 12: Collection and waste treatment calculated using averaged products and packaging weights by market locations.

Primary data usage: Primary data from suppliers used in categories 1, 3, 4, 7 and 8, estimated at 14% of total Scope 3 emissions.

Data period: Categories 1 (direct procurement Enterprise, Gaming & Consumer), 3, 4, 7 and 11 calculated from 12 months data. Categories 1 (indirect and direct procurement Hearing), 4, 5, 6, 8, 9 and 12 calculated from 10 months data. Category 2 calculated for 9 months.

Restatement: 2021 baseline restated due to divestments, data quality improvements, methodological changes and updated emission factors. Scope 1 and 2 (market-based) restated from 10,507 to 9,831 tCO2eq (-6.4%). Scope 3 restated from 425,547 to 349,006 tCO2eq (-18%). Key changes include: updated LCA data, removal of radiative forcing from air transport, supplier-specific data improvements, and alignment with GLEC framework.

E1-9(was E1-7)E1-7
Omitted
E1-10(was E1-8)E1-8
Omitted
E1-11(was E1-9)E1-9
Omitted

E2Pollution

E2-1E2-1
Reported

Policies Related to Pollution

Pollution Prevention Policy Framework

GN has established policies to address pollution risks and impacts across its operations and value chain as part of its commitment to minimize negative environmental impact:

Product-Related Pollution Policies

Sustainable Design Policy:

  • Focus on developing product designs that impact the experience of products, not the environment
  • Integration of pollution prevention considerations into product development processes
  • Compliance with growing product-related sustainability legislation
  • Support for circular economy transition to minimize waste and pollution

Product Quality and Safety:

  • Comprehensive quality management to ensure products operate without defects throughout lifecycle
  • Centralized quality function enhances teamwork and ensures high-quality results
  • Product security framework implementation to prevent environmental and safety risks

Manufacturing and Operations Pollution Policies

Manufacturing Standards:

  • Implementation of pollution prevention measures across:
    • Central and regional manufacturing sites for hearing aids in Australia, China, Denmark, Japan, Malaysia, South Korea, Spain, and United States
    • Careful selection of manufacturers for enterprise and gaming products mainly in Asia
  • Working with tier 1 manufacturers supported by more than 100 sub-suppliers on environmental standards

Supply Chain Environmental Standards:

  • Integration of pollution prevention requirements into supplier selection and management
  • Long-term strategic partnerships include environmental performance criteria
  • Enhanced monitoring systems to track environmental performance across supply chain

Chemical and Material Management

Substances of Concern Management:

  • Policies addressing substances of concern and substances of very high concern in products
  • Compliance with chemical regulation requirements across global markets
  • Material selection criteria incorporating pollution prevention considerations

Waste Management:

  • Implementation of waste reduction and proper disposal practices
  • Focus on resource efficiency and circular economy principles
  • Balancing operations between different facilities to optimize environmental performance

Air, Water and Soil Protection

Emission Control:

  • Policies to minimize air emissions from manufacturing and operations
  • Integration with broader carbon reduction strategy achieving 58% reduction in scope 1 and 2 emissions
  • Monitoring and control of industrial emissions across global facilities

Water and Soil Protection:

  • Implementation of measures to prevent water and soil contamination
  • Proper handling and disposal of potentially harmful substances
  • Environmental management systems at key facilities

Regulatory Compliance

Multi-jurisdictional Compliance:

  • Policies ensure compliance with pollution-related regulations across:
    • Global operations in 30+ countries with direct sales
    • Manufacturing locations across multiple continents
    • Distribution networks covering 100+ countries

Continuous Monitoring:

  • Regular assessment of regulatory requirements and policy updates
  • Integration of new pollution-related regulations into business processes
  • Annual review of environmental policies and performance

Integration with Business Strategy

Strategic Integration:

  • Pollution prevention integrated into existing business processes
  • Board oversight through risk management framework
  • Executive Leadership Team involvement in environmental policy decisions

Innovation and Development:

  • DKK 1.9 billion R&D investment includes focus on sustainable technology development
  • Research into cleaner production technologies and processes
  • Development of products with reduced environmental impact throughout lifecycle

Stakeholder Engagement

Supply Chain Collaboration:

  • Working with suppliers and manufacturing partners on pollution prevention
  • Enhanced communication and problem-solving capabilities for environmental issues
  • Integration of environmental requirements into partnership agreements

Customer and Community Engagement:

  • Transparent communication about product environmental performance
  • Response to growing stakeholder focus on environmental responsibility
  • Sustainability-minded customer and employee attraction through environmental policies

These comprehensive pollution-related policies demonstrate GN's commitment to minimizing negative environmental impacts across its operations and value chain while maintaining compliance with global environmental regulations.

E2-2E2-2
Omitted
E2-3E2-3
Omitted
E2-4Pollution of air, water and soil
Reported

Pollution of air, water and soil

Material Impact Assessment

GN's double materiality assessment identified pollution to water, soil, and food as a material impact. The assessment states:

"Industries such as manufacturing, mining, fossil fuel extraction, paper, and e-waste have the potential to lead to negative impacts in terms of pollution of water, soil, and food."

This impact is classified as:

  • Type: Impact (I)
  • Nature: Negative (N)
  • Actual/Potential: Potential (PT)
  • Scope: Value Chain (VC)

Additionally, GN identified the use of substances of (very high) concern as a material impact:

"Substances of (very high) concern are used by both by GN during manufacturing and by value chain industries such as mining and component manufacturing. This can lead to damage to the environment and human health."

This impact is classified as:

  • Type: Impact (I)
  • Nature: Negative (N)
  • Actual/Potential: Actual (A)
  • Scope: Both own operations and value chain

Policy and Compliance

GN states that managing pollution impacts is "anchored in compliance with all relevant legislation in this area, while we anchor this requirement to our suppliers through our due diligence processes based on our code of conduct."

The company notes that "these impacts do not have a significant impact on our business model and strategy."

Quantitative Disclosures

No quantitative emissions data disclosed.

The mandatory disclosure requirements reference states:

Disclosure RequirementData PointMaterialPage Number
ESRS E2-4Amount of each pollutant listed in Annex II of the E-PRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water and soilx (not material)-

This indicates that GN has assessed E2-4 quantitative disclosures as not material and has not provided emissions data for pollutants to air, water, or soil.

Materiality Exclusions

GN's materiality assessment process excluded water and biodiversity impacts:

"We assessed our operational footprint, including our water use and impact on biodiversity...to assess whether we have significant negative impacts on water use or drivers of biodiversity loss. Through this process, we established that we currently have no material IROs related to water and biodiversity."

E2-5Substances of concern and substances of very high concern
Reported

Substances of concern and substances of very high concern

Policy and management approach

GN's Environmental Policy addresses pollution-related negative impacts in terms of substances used during both production in our own operations and outsourced manufacturing. Our policy commitments include compliance with all pollution-related legislation related to the use of substances of concern and very high concern, such as REACH and RoHS, and the substitution of substances with less harmful alternatives that can fulfil the same purpose, even when not legally required. This policy is supported by internal procedures on controlling and limiting the impact of incidents and emergency situations.

The implementation of these policy commitments is managed by senior management functions in our quality and legal functions. In support of achieving our policy intentions, we continuously evaluate and test performance to ensure compliance with legal requirements. Products that are manufactured in our own operations (hearing aids) are subject to medical regulatory requirements, which include obligations on material use. For products for which manufacturing is outsourced, all suppliers providing products or components to GN are required to complete a declaration of compliance to conform with our policies.

During 2024, all relevant suppliers have completed a declaration of compliance to show adherence to our policies in this area. This has enabled a better view of any high-risk areas in our value chain, as well as a better understanding of potential negative impacts relating to pollution of water, soil, and food, driven as a result of the use of hazardous substances.

Own operations actions

To support our policy objectives in this area, as well as moving beyond compliance with our internal policies through our health and safety processes, we phased out the use of dichloromethane as a cleaning agent in 2024, replacing it with a more effective and less harmful alternative.

As another action in 2024, at our manufacturing facility in Xiamen, we have significantly reduced our consumption of isopropyl alcohol (estimated annual reduction of 69% in liters consumed in 2024 versus 2023) by installing onsite recycling capability.

In 2025, we aim to work with stakeholders in our R&D, quality and legal functions to understand additional areas where we can take actions in substituting substances with less harmful alternatives throughout our production processes.

Value chain actions

As part of our policy objectives, a key focus is the continuous evaluation of compliance regarding the use of harmful substances by our suppliers. During 2024, all relevant suppliers have completed a declaration of compliance to show adherence to our policies in this area.

For products for which we depend on outsourced manufacturing, our focus is on phasing out halogens, specifically bromine, chlorine and fluorine. For Jabra products, we set requirements for suppliers and verify compliance through in-house testing. We expect to phase out bromine and chlorine in 2025 (where we have set a control limit that these substances cannot exceed 900 parts per million (ppm) individually or 1,500 ppm when combined) for flame-retardant parts, where phase out of these halogens in batteries will likely take longer. We have completed phase out of these substances for all other parts. We expect to phase out fluorine by 2026 for the same parts (where this substance cannot exceed 50 ppm).

Our current setup ensures compliance with our control limits but does not give us precise volumes of substances used in our value chain. With the aim of being able to report actual volumes in accordance with phased in data points in ESRS E2 for substance use in the value chain in future, we have commenced an action in 2024, running until 2026 to change our processes so that we obtain full material declarations from all suppliers for substances of very high concern.

Accounting policies

Total amount of substances of concern and substances of very high concern used in own operations

To report the total volume of substances of (very high) concern for production sites, we have collected usage or purchasing data for the substances that are in scope at our manufacturing sites in China, Malaysia, Denmark, and Spain. The total quantities used at these sites have been extrapolated to account for the remainder of our manufacturing sites where we have similar activities. Total amounts have been grouped by their respective hazard class as well as the level of severity within a given hazard class. All volumes are reported in litres. The metrics and use of substances of (very high) concern is externally verified at all sites and in accordance with local environmental legislation.

The hazard of a substance divides health, environmental and physical hazards into separate hazard classes such as reproductive toxicity, skin sensitization, carcinogenicity etc. The severity of the hazard within each class is described by the category. Some classes have five categories; other classes have only one category. Category 1 always represents the most severe hazard within that class. The higher the category number, the lower the severity of the hazard. Each substance can have more than one hazard class and several of the substances used will therefore be accounted for in more than one hazard class.

We include all substances used in the production process within our own operations, including any applicable substances which leave our facilities.

We will not report this metric for substances products or components for which manufacturing is outsourced, as these fall under the phase in provision given that these substances are added to components or products in our value chain. As such, our reported metric only includes substances added to products or components in our own operations, i.e., as part of manufacturing of hearing aids.

Quantitative data

Overview of substances of very high concern

Hazard classSubstanceAmount in litres generated, used or procured during production
PBT (Article 57d) or vPvB (Article 57e) *Octamethyl Cyclotetrasiloxane-
Totals for Toxic for reproduction (Article 57c)246
Toxic for reproduction (Article 57c) **Bis(2-hydroxy-3-tert-butyl-5-methylphenyl)methane-
Toxic for reproduction (Article 57c)Diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide246

*Refers to the REACH regulation and covers substances that have Persistent, Bioaccumulative and Toxic properties or substances that have very Persistent and very Bioaccumulative properties. Very small amounts of substances that has these properties, are used.

**Very small amounts of substances are used.

Overview of substances of concern

Hazard classAmount in litres generated, used or procured during productionAmount in litres leaving facilities as products
Hazard - Carcinogenity215-
Category 1150-
Category 265-
Hazard - Chronic hazard to the Aquatic Environment6,04179
Category 1269-
Category 2625-
Category 31,41879
Category 43,729-
Hazard - Germ Cell Mutagenity3-
Category 23-
Hazard - Reproductive Toxicity1,135-
Category 174-
Category 21,061-
Hazard - Respiratory Sensitisation3,096-
Category 13,096-
Hazard - Skin Sensitisation6,020-
Category 16,020-
Hazard - Specific Target Organ Toxicity, repeated exposure2,861807
Category 1385807
Category 22,476-
Hazard - Specific Target Organ Toxicity, single exposure1,326-
Category 16-
Category 21,320-
E2-6E2-6
Omitted

E5Resource Use and Circular Economy

E5-1E5-1
Reported

Policies Related to Resource Use and Circular Economy

Circular Economy Policy Framework

GN has established comprehensive policies related to resource use and circular economy as part of its commitment to sustainable design and minimizing environmental impact:

Sustainable Design Policies

Design for Sustainability:

  • Focus on sustainable design as one of three key sustainability areas
  • Developing product designs that impact the experience of products, not the environment
  • Support for transition to circular economy through design decisions
  • Integration of circular economy principles into product development processes

Product Lifecycle Approach:

  • Consideration of resource use throughout entire product lifecycle
  • Design for durability, repairability, and end-of-life management
  • Minimization of material use while maintaining product performance and quality

Resource Efficiency Policies

Manufacturing Resource Optimization:

  • Resource efficiency measures across global manufacturing operations:
    • Central and regional manufacturing sites in Australia, China, Denmark, Japan, Malaysia, South Korea, Spain, and United States
    • Optimization of resource use in contract manufacturing partnerships
  • Balancing operations between different facilities to optimize resource utilization

Supply Chain Resource Management:

  • Integration of resource efficiency requirements into supplier management
  • Working with tier 1 manufacturers and more than 100 sub-suppliers on resource optimization
  • Long-term strategic partnerships include resource efficiency criteria

Waste Reduction and Circular Practices

Waste Minimization:

  • Implementation of waste reduction practices across operations
  • Focus on circular economy principles to minimize waste generation
  • Proper waste management and disposal practices at all facilities

Material Recovery and Recycling:

  • Policies supporting material recovery and recycling initiatives
  • Integration of recycled materials where technically and economically feasible
  • End-of-life product management to support circular economy

Operational Resource Policies

Facility Resource Management:

  • Resource efficiency measures across global operations:
    • R&D centers in Denmark, United States, Netherlands, Poland, France, Italy, and China
    • Office locations in 30+ countries with direct sales presence
    • Distribution centers in Mexico, Poland, China, and Hong Kong

Logistics Optimization:

  • Regional distribution strategy to optimize resource use in logistics
  • Partners responsible for local logistics to minimize transportation resource consumption
  • Supply chain diversification to improve resource efficiency

Technology and Innovation Policies

R&D Resource Focus:

  • DKK 1.9 billion R&D investment includes focus on resource-efficient technologies
  • Innovation in materials and processes to reduce resource consumption
  • Unified R&D organization enables sharing of resource efficiency expertise across divisions

Digital Solutions:

  • Development of digital solutions that reduce physical resource requirements
  • Software and AI innovations that extend product lifecycles
  • Remote collaboration solutions helping customers reduce resource consumption

Regulatory and Standards Compliance

Regulatory Alignment:

  • Compliance with growing product-related sustainability legislation related to resource use
  • Adherence to circular economy regulations across global markets
  • Integration of resource-related regulatory requirements into business processes

Industry Standards:

  • Implementation of industry best practices for resource use and circular economy
  • Participation in circular economy initiatives and standards development
  • Annual review of resource use policies and performance

Business Integration Policies

Strategic Integration:

  • Resource use and circular economy integrated into business strategy
  • Board oversight through risk management framework
  • Executive Leadership Team involvement in resource-related decisions

Value Chain Integration:

  • Resource efficiency considerations throughout entire value chain
  • Integration with broader sustainability strategy including climate goals
  • Alignment with one-company transformation synergies for resource optimization

Stakeholder Engagement Policies

Customer Engagement:

  • Communication about product resource efficiency and circular economy features
  • Response to growing stakeholder focus on sustainability including resource use
  • Sustainability-minded customer attraction through circular economy policies

Supply Chain Collaboration:

  • Enhanced communication and problem-solving capabilities for resource efficiency initiatives
  • Collaboration with partners on circular economy practices
  • Integration of resource efficiency into partnership agreements

Performance and Monitoring Policies

Resource Use Monitoring:

  • Systematic tracking of resource consumption across operations
  • Integration of resource efficiency metrics into business performance measurement
  • ESG performance tracking includes resource use indicators

Continuous Improvement:

  • Regular assessment and enhancement of resource use policies
  • Integration of circular economy best practices
  • Innovation in resource efficiency and circular economy approaches

Product-Specific Resource Policies

Hearing Aids:

  • Focus on miniaturization to reduce material requirements
  • Long product lifecycles and repairability considerations
  • Battery efficiency and sustainable battery management

Enterprise Equipment:

  • Durable design for professional use environments
  • Resource-efficient manufacturing of audio and video equipment
  • Software solutions extending hardware lifecycles

Gaming Peripherals:

  • Resource-efficient design of gaming hardware
  • Focus on product longevity and user upgradability
  • Material selection for reduced environmental impact

These comprehensive policies demonstrate GN's commitment to resource efficiency and circular economy principles across its operations, products, and value chain, supporting both environmental goals and business sustainability.

E5-2E5-2
Omitted
E5-3Targets related to resource use and circular economy
Reported

Targets related to circular economy

Target 1: Recycled or renewable material in newly developed products

  • Target metric: Use of recycled or renewable material as percentage of total weight of mechanical parts (plastics, metals, fabrics and other non-electronic parts) in all newly developed products
  • Target value: At least 50%
  • Target year: 2025
  • Baseline year: 2021
  • Baseline value: 0%
  • Scope: All newly developed products
  • Type: Intensity-based (percentage of total weight)
  • Validation: Voluntary target set internally in 2021 based on internal consultation of experts in R&D, product management and sourcing
  • Progress to date (2024): Three products launched in 2024 meeting this target already. On track to meet target.

Target 2: Recycled and bio-based material use across full product portfolio

  • Target metric: Share of recycled and bio-based material use across full product portfolio
  • Target value: 25%
  • Baseline year: 2024
  • Baseline value: 19.1%
  • Scope: Full product portfolio
  • Type: Intensity-based (percentage)
  • Validation: Internal target
  • Progress to date (2024): Overall use of 19.1% achieved across full product portfolio in 2024

Target 3: FSC certification for packaging

  • Target metric: FSC certification for all paper and cardboard packaging
  • Target value: 100% of paper and cardboard packaging in new products
  • Target year: 2025
  • Baseline year: Not disclosed
  • Baseline value: Not disclosed
  • Scope: All paper and cardboard packaging in new products
  • Type: Absolute (100%)
  • Validation: Internal target
  • Progress to date (2024): 71% of cardboard and paper packaging is FSC certified by weight. FSC-certified cardboard and paper used for packaging for the majority of products in 2024. On track to meet target.

Target 4: Repairability of new products

  • Target metric: Internal repairability index score for all new products
  • Target value: 4 or higher (on a scale from 0-5)
  • Target year: 2025
  • Baseline year: Not disclosed
  • Baseline value: Not disclosed
  • Scope: All new products for which development starts in 2025 (except Hearing)
  • Type: Absolute (minimum score)
  • Validation: Internal target
  • Progress to date (2024): 16 products assessed on internal repairability index in 2024, where most are considered (highly) repairable
E5-4Resource inflows
Reported

ESRS E5-4: Resource Inflows

Overview

Resource use associated with the manufacture of GN's products and packaging is a highly material topic. Multiple material types, including plastics, metals, textiles, cardboard and adhesives, are required to make GN products and packaging. GN purchases intermediary and finished products from suppliers. The total weight of these products that are used across GN's own product and packaging portfolio is reported below, including breakdown of broad material types to provide greater insight into GN's resource consumption and management of transition risks related to critical raw materials.

An estimated 20% of the materials used in GN's products and packaging was either recycled or sustainably sourced biological materials in 2024.

Total Resource Inflows

Metric2024
Total weight of material (metric tons)11,178
Percentage of biological materials that is sustainably sourced (FSC)17%
Total weight of recycled materials (metric tons)309
Percentage of recycled materials3%

Resource Inflows by Material Type (by weight)

Material TypePercentage of Total
Cardboard and paper packaging34%
PCBs and electronic components23%
Plastic parts12%
Metal parts and magnets11%
Batteries8%
Cables and power adaptors4%
Textiles4%
Other parts (incl. rubber)2%
Plastic packaging1%
Other packaging1%

Recycled and Certified Materials

CategoryPercentage
Uncertified virgin materials80%
FSC-certified packaging and biocircular plastics17%
Recycled materials3%

Biological Materials

For GN, biological materials refer to paper, cardboard and bio-based plastics used in products and packaging. Within this, GN sources FSC-certified packaging and ISCC Plus-certified biocircular plastics. The percentage of biological materials that have either of these certifications is reported above (17% of total materials are FSC-certified).

Recycled Materials

Secondary intermediary products are used in the form of post-consumer recycled plastic pellets, with varying percentages of recycled content, depending on the product. Total recycled materials used amounted to 309 metric tons in 2024, representing 3% of total material weight.

Methodology

All resource inflows metrics are estimated using GN's product lifecycle assessments (LCAs), as these contain verified component-level data, including material composition and measured weight. The LCAs available are allocated at the item level across the product portfolio. All LCAs are third-party verified according to ISO 14067.

For products currently lacking an LCA, a reference LCA is allocated. Professional judgement is applied in the selection of a reference that will best represent the product or part. An uplift is conducted for items that cannot be represented by an LCA, based on the calculated average per unit volume purchased or produced. For Enterprise, Gaming & Consumer products, one unit packaging per unit product has been assumed.

Note on data limitations: The general basis for preparation section notes that "for resource inflows, due to lack of data, manufacturing waste and tertiary packaging for some products are not included."

E5-5Resource outflows
Reported

Resource outflows

Recyclability and repairability

GN has established targets related to resource outflows:

  • Recyclability target: Increase the rate of recyclable content across products and packaging to 80% by 2030 (from 64% in 2021 baseline)
  • Repairability target: Increase the rate of repairable products to 100% by 2030 (from 56% in 2021 baseline)

2024 Performance:

  • Rate of recyclable content in products and packaging: 75% (up from 74% in 2023)
  • Rate of repairable products: 72% (up from 70% in 2023)

Design for circularity approach

GN's approach to resource outflows focuses on three key areas:

  1. Repairability: Designing products to be repaired and refurbished to ensure extended product lifetimes
  2. Recyclability: Designing products for disassembly and recovery of valuable materials at end-of-life
  3. Service-based models: Offering services that enable product return for sustainable processing

Product durability

GN products are designed for durability with typical product lifetimes varying by division:

  • Hearing aids: Designed for multi-year use with typical warranty periods
  • Enterprise products: Built for professional use with extended service life
  • Gaming products: Designed for intensive use by gamers

Repairability initiatives

In 2024, GN:

  • Released updated versions of Jabra Evolve 65 and several Jabra Engage headsets, making them compatible with EU regulation around batteries and repairability
  • Operates repair centers to enable product repair (see page 48 value chain diagram)
  • Offers spare parts through CE 5.2 Sale of spare parts (eligible under EU Taxonomy)

Recyclability methodology

The rate of recyclable content is calculated using recyclability assessments based on material composition, not accounting for ease of sorting or local recycling capabilities. This represents a high-level assessment subject to measurement uncertainty (see page 41).

E5-5(was E5-5-Waste)Waste
Reported

Waste

Waste generation and management

GN's waste management approach follows the waste hierarchy, prioritizing prevention, reuse, recycling, and recovery over disposal. The company has established targets to minimize waste directed to disposal.

Target: Reduce the total amount of waste directed to disposal to <10% of waste generated by 2030 (from 17% in 2021 baseline)

2024 Performance: 9% of waste directed to disposal (down from 10% in 2023)

Waste data

Waste category2024 (tonnes)2023 (tonnes)
Total waste generated1,3571,462
Waste diverted from disposal1,2321,317
Waste directed to disposal125145

Waste diverted from disposal breakdown:

  • Preparation for reuse: 61 tonnes
  • Recycling: 969 tonnes
  • Other recovery operations: 202 tonnes

Waste directed to disposal breakdown:

  • Incineration: 93 tonnes
  • Landfill: 32 tonnes
  • Other disposal operations: 0 tonnes

Hazardous waste

GN generated 33 tonnes of hazardous waste in 2024 (down from 36 tonnes in 2023), representing approximately 2.4% of total waste.

Waste management approach

Waste generation data covers GN's major production sites and offices. For sites without complete pollution data, estimates are made using data from sites with similar activities (see page 41 for measurement uncertainty). The waste management hierarchy guides GN's approach, with focus on:

  1. Prevention and reduction at source
  2. Reuse and preparation for reuse (61 tonnes in 2024)
  3. Recycling (969 tonnes, representing 71% of total waste)
  4. Recovery operations (202 tonnes)
  5. Disposal as last resort (125 tonnes, or 9% of total)

GN's waste reduction initiatives are integrated into operational processes at manufacturing facilities and offices globally.

S1Own Workforce

S1-5(was S1-6)Characteristics of employees
Reported

Characteristics of the undertaking's employees

Total headcount and FTE

At the end of the reporting period (December 31, 2024), GN's total employee headcount is 8,145 employees.

Number of FTEs:

  • Year-end 2024: 7,347 FTEs
  • Year-end 2023: 7,165 FTEs
  • Average 2024: 7,201 FTEs
  • Average 2023: 7,435 FTEs

Employee headcount by gender

GenderNumber of employees (headcount) 2024
Male4,098
Female3,969
Other12
Not reported66
Total employees8,145

Employee headcount by geographical area/country

By region:

RegionNumber of employees 2024
Africa7
Asia & Pacific3,390
Europe2,939
Middle East21
North America1,697
South/Latin America91

Countries with at least 50 employees (2024):

CountryNumber of employees (headcount)
Denmark1,841
United States of America1,608
China1,427
Malaysia997
India338
Spain193
Germany172
United Kingdom169
Japan161
Australia156
Poland166
France122
Taiwan92
Brazil89
Canada89
Italy83
Korea, Republic of73
Netherlands72
Singapore64

Employee headcount by contract type and gender

Contract typeFemaleMaleOtherNot disclosedTotal 2024
Total employees3,9694,09812668,145
Permanent employees3,0233,5328596,622
Temporary employees631243-6880
Non-guaranteed hours employees31532341643

Notes on contract type:

  • Permanent contracts: 7,265 employees (89.2%)
  • Temporary contracts: 880 employees (10.8%)
  • Non-guaranteed hours workers: 643 employees (included in permanent count)
  • Until September 2024, non-guaranteed hours were not systematically captured. Estimates were made for Denmark, US, China, and Malaysia, with 40% of US workforce under such conditions.

Employee turnover

2024:

  • Total employee turnover: 1,234 employees
  • Turnover rate: 15.2%

Note: Employee turnover includes both voluntary and involuntary permanent turnover for both white-collar and blue-collar employees.

Senior and Extended Leadership diversity

Senior Leadership (as defined in section 3(5) of the Danish gender balance act - Executive Management, Executive Leadership Team, and other managers reporting to Executive Management):

Metric20242023
Total number4745
Underrepresented gender (%)1918
Target (%)3025
Target year20302025

Extended Leadership (defined by GN's job grades equivalent to Mercer IPE score 56 or above):

Metric20242023
Total number360341
Underrepresented gender (%)2322
Target (%)3025
Target year20302025

Geographical split of shareholders

While not employee data, the report provides shareholder geographical distribution:

  • Denmark: 40%
  • North America: 25%
  • Europe: 35%
  • Rest of World: <1%
S1-13(was S1-14)Health and safety metrics
Reported

Health and safety metrics

Coverage of health and safety management system

20% of all GN employees are covered by a health and safety management system. This includes global manufacturing employees most at risk of being impacted, where 70% of employees based in Xiamen and Johor Bahru are covered by a health and safety management system.

Work-related accidents and fatalities

Metric2024
Number of fatalities as a result of work-related injuries and work-related ill health0
Number of work-related accidents50
Rate of work-related accidents (per 1,000,000 hours worked)3.4

Methodology notes

Coverage: As GN's health and safety processes are currently decentralized, only 20% of all GN employees (primarily manufacturing employees in Xiamen and Johor Bahru) are covered by a health and safety management system. A global HSE organization is being established in 2025 to expand coverage.

Fatalities: Data relates to GN's own employees as well as others working on GN sites. There were no fatalities in 2024.

Work-related accidents: The number of work-related accidents relates to GN's own employees only (does not include contractors).

Rate calculation: The rate of work-related accidents was calculated as the number of accidents per one million hours worked. Employee working hours were collected from local systems and GN's HR management system (Workday). For locations where employees do not register hours, contractual hours were used.

Days lost: Not disclosed for 2024.

S1-15(was S1-16)Compensation metrics (pay gap and total compensation)
Reported

Compensation metrics (ESRS S1-16)

Pay gap

GN's unadjusted gender pay gap in average salaries for all men and women employed during 2024 was 38.29%.

Several factors significantly impact this unadjusted gender pay gap, notably the organizational structure and the balance of men and women across different organizational levels, where GN has more men than women in senior positions that are typically associated with higher pay.

Another factor heavily impacting the unadjusted gender pay gap is material differences in pay levels across GN locations combined with employee gender representation in various countries. GN operates globally with around 8,145 employees based in 45 countries. More than 70% of employees are located in Denmark, the U.S., China, and Malaysia. The pay levels in China and Malaysia are significantly lower compared to the U.S. and Denmark. Furthermore, the majority of employees in China and Malaysia are blue-collar workers (50% and 89%, respectively) with corresponding lower levels of pay compared to white-collar workers. In both China and Malaysia, more than 70% of female employees are employed in blue-collar positions, which significantly affects the unadjusted gender pay gap.

GN has in 2024 established an adjusted gender pay gap calculation model to analyze the pay between male and female employees who perform similar work in the same country. For 2024, GN had an overall adjusted gender pay gap of 3.26%. Although this is a relatively small adjusted gender pay gap, the in-depth analysis does show some areas in the organization where the difference in pay between men and women performing similar work are more material, and thus actions are being taken. This adjusted gender pay gap analysis will be conducted annually.

Remuneration ratio

The ratio of annual total remuneration to GN's CEO vs the median annual total remuneration of GN employees is 43.47. The total remuneration includes the following components: base salary, allowances, variable pay components, long term incentives, pension, and benefits. The median total remuneration is calculated by identifying the median-paid employee and comparing this employee's total remuneration with the highest paid individual, the CEO.

Methodology

Unadjusted gender pay gap: The calculation is estimated based on hourly base salary on an aggregated organizational level, as GN currently doesn't have centralized data for all total remuneration components for all employees. The gender pay gap is calculated as the difference between average hourly base pay of male and female employees expressed as a percentage. All active employees during the calendar year are included in the calculation. GN will work towards obtaining the data in a centralized system to include employee total remuneration in the calculations for future reporting periods.

Adjusted gender pay gap: Adjusted gender pay gap is calculated for each career sub-level applying the general gender pay gap formula. Weighted average is calculated of all the sub levels in all countries. Adjusted gender pay gap is calculated as a weighted average per country as GN operates in many countries with a wide variety of pay levels and significant gender split. All the active employees during the calendar year are included in the calculation.

Total remuneration ratio: To calculate total remuneration ratio the median employee's salary is measured against the highest paid individual. Total remuneration for the median employee is defined on the basis of base salary analysis where an employee with a median base salary across all GN employees is selected and remaining total remuneration components are calculated. All the active employees during the calendar year are included in the calculation. GN will work towards obtaining the data in a centralized system to include employee total remuneration in the calculations for future reporting periods.

More information on total remuneration ratio can be found in the Remuneration Report for 2024.

S1-9(was S1-10)Adequate wages
Reported

Adequate wages

Benchmark used

GN compares employee wages against national minimum wage established by legislation or collective bargaining agreements. The company states: "Compared with country-specific legislation and/or collective agreements, all GN employees are paid an adequate wage above minimum wage requirement in all GN locations."

The company does not use a living wage benchmark. GN explicitly notes: "As GN adheres to country-specific legislation and/or collective agreements, a global policy has not been defined."

Material impact identified

GN has identified a material potential negative impact (S1 - Working conditions: Adequate wages) stating: "While GN pays all employees a minimum wage, this may not represent an adequate wage and can lead to poorer quality of life for affected employees."

Coverage

All GN employees globally are assessed. The disclosure states: "all GN employees are paid an adequate wage above minimum wage requirement in all GN locations" and "The first year's control on adequate wages has been carried out from a global perspective ensuring that all employees receive at least the country's minimum wage in base salary alone."

Geographic scope

Global coverage across all GN locations.

Targets

No targets set. GN explicitly states: "GN has not set any additional targets related to adequate wages."

Methodology

The methodology compares base salary against:

  • National minimum wage established by legislation, or
  • Collective bargaining agreements

Local HR departments "continuously monitor and ensures adherences to local legislation and/or collective agreements."

Monitoring

GN monitors pay positioning of all employees "compared to identified pay ranges" to ensure fair and competitive pay. The first year's global control was carried out in 2024.

Value chain

GN has also identified adequate wages as a material impact in its value chain (S2), stating: "Most industries in GN's value chain pay workers at least a minimum wage, while some value chain industries may even pay workers below a minimum wage. In all cases, where this does not represent an adequate wage, it can negatively impact the health and well-being of value chain workers."

S1-1Policies related to own workforce
Reported

Policies related to own workforce

GN has implemented several policies for managing material impacts related to own workforce.

UN Global Compact membership

As a member of the UN Global Compact since 2010, GN is committed to safeguarding human rights and labor rights principles in its own workforce. GN operations and business activities are guided by:

  • UN Guiding Principles on Business and Human Rights
  • ILO Declaration on Fundamental Principles and Rights at Work
  • OECD Guidelines for Multinational Enterprises

Scope: All GN employees globally

Key content: GN upholds human rights principles through the implementation of policies and procedures which prevent discrimination, harassment, advance diversity, and ensure fair and equal treatment of its workforce.

Diversity, Equity and Inclusion Policy

Scope: All employees at every level

Key content: Outlines beliefs and aspirations for equal treatment and opportunities for all employees. Addresses IROs related to equal pay, harassment and diversity.

Implementation: To prevent discrimination and promote an inclusive culture, GN has launched various communication campaigns, provided training, and established employee resource groups. GN encourages an open dialogue and feedback to continuously improve its policies and internal procedures.

Anti-harassment Policy

Scope: All employees

Key content: Promotes respectful culture and aims to raise awareness about bullying and how to report inappropriate behavior. Designed to eliminate discrimination and uphold human rights principles.

Non-Retaliation Policy

Scope: All employees

Key content: Protection for employees raising concerns without fear of retaliation or repercussions.

Channels: Employees can raise concerns confidentially through GN's whistleblower hotline (GN Alertline) or regular HR channels. The GN Alertline is a secure and confidential reporting tool hosted by an independent third party. All investigations are handled by designated and trusted GN employees.

Health and Safety Policies and Processes

Scope: Particularly relevant for blue-collar employees at major manufacturing sites

Key content: GN has internal procedures on controlling and limiting the impact of incidents and emergency situations. Workplace accident prevention policy or management system is in place.

Governance and oversight: GN provides channels for raising concerns, including potential human rights impacts, and has established internal procedures for handling cases to ensure remedy for its employees.

Link to international standards: Policies are designed to comply with requirements related to fundamental International Labour Organisation Conventions 1 to 8.

Human Trafficking Prevention

Key content: Processes and measures for preventing trafficking in human beings are in place.

Resource allocation: GN ensures adequate resource allocation for addressing each material impact with clearly defined roles and responsibilities. Execution of actions is anchored in GN's existing governance structures, which defines roles and responsibilities, and ensures sufficient resource allocation.

Monitoring: To evaluate effectiveness of actions implemented, GN conducts assessment and collects the necessary data for analysis. The results are reviewed by senior management to identify areas that require attention, allowing for necessary amendments to be made where needed. For longer term initiatives, GN performs continuous assessments to address any emerging issues promptly.

S1-16(was S1-17)Incidents, complaints and severe human rights impacts
Reported

Incidents, complaints and severe human rights impacts

Policies and Management Approach

GN has implemented a dedicated "Anti-Harassment Policy" to promote a respectful and inclusive culture. The Policy aims to address the identified material potential negative impact on the health and well-being of employees because of violence and harassment. The policy raises awareness of bullying and harassment and outlines actions to take when such cases are observed. It defines harassment, provides examples of various types, specifies channels for reporting violence and harassment cases, and refers to GN's Non-Retaliation Policy.

All cases reported through the GN Alertline are thoroughly investigated directly by the whistleblower investigation unit. Cases outside of this scope are handled by Group People & Culture with support from the Group Business Ethics & Compliance department. All cases are reported to the Audit Committee on a quarterly basis.

Harassment cases reported through the GN Alertline are handled by Group Business Ethics & Compliance department and Group People & Culture.

Key Initiatives

A key initiative in 2024 was the launch of GN's annual mandatory anti-harassment e-learning program, with the main purpose of educating all employees on identifying, preventing, and responding to harassment in the workplace. In 2025, GN will create a strategic roadmap for harassment management which includes a governance model, company protocol, incident reporting system and training.

Incidents and Complaints

There have been no fines, penalties and compensation for damages as a result of the incidents and complaints reported.

GN has not identified any cases of severe human rights incidents connected to GN's workforce.

Accounting Policies

All cases reported through the GN Alertline are included in this metric. The GN Alertline is a secure and confidential reporting tool hosted by an independent third party. This hotline is available to all employees and external stakeholders and can be accessed on the GN Group website via www.gn.com/whistleblower and for employees also via GN's intranet.

Tracking Effectiveness

Currently, GN does not track the effectiveness of the Anti-Harassment Policy, but does launch an annual mandatory anti-harassment e-learning for all employees. GN also has the GN Alertline, where relevant cases are thoroughly investigated and reported to the Board's Audit Committee on a quarterly basis.

S1-6(was S1-7)Characteristics of non-employee workers
Reported

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

Agency workers

GN has identified agency workers working on GN sites in countries with weak worker protection controls as workers at high risk of impact and therefore in scope for assessment. This specifically covers agency workers at the manufacturing site in Malaysia.

No quantitative disclosure of the number of agency workers, breakdown by type, or methodology for counting (headcount vs FTE) is provided in the sustainability statement.

S1-8(was S1-9)Diversity metrics
Reported

Diversity metrics

Gender distribution at senior leadership

In 2024, the share of females in Senior Leadership positions is 26.3% (5 females out of 19 individuals) and share of males is 73.7% (14 males out of 19 individuals).

Senior Leadership definition: Leadership positions equivalent to a Mercer IPE score 56 or above, comprising Executive Management, Executive Leadership Team, and others with managerial responsibilities reporting directly to Executive Management.

Gender distribution - total workforce

GenderNumber of employees (headcount)
Male4,098
Female3,969
Other12
Not reported66
Total employees8,145

Age band distribution - total workforce

Age groupNumber of employees
Below 301,682
30-504,961
Over 501,502

Reporting note: The share of workers per age group shows 30-50 year olds make up the majority of the workforce (approximately 60%), with younger and older workers making up roughly 20% each.

Methodology notes

Gender reporting: Information about gender is recorded in GN's HR management system, Workday. Employee headcount is disclosed as "Not reported" when employees do not provide gender information during the onboarding process. Category "Other" refers to employees who identify themselves as non-binary.

Cut-off date: December 31, 2024.

S2Workers in the Value Chain

S2-1Policies related to value chain workers
Reported

Policies related to value chain workers

GN Store Nord has established several policies addressing value chain workers, covering human rights, supplier conduct, modern slavery, and conflict minerals.

Human Rights Policy Commitments

  • Scope: All value chain workers across all geographies in which GN operates, covering upstream, own operations, and downstream activities
  • Governance: Board of Directors approved this policy and receives updates on compliance on a biannual basis at a minimum
  • Key content:
    • Commitment to safeguarding human rights
    • Enables identification, assessment, management, and remediation of material impacts, risks and opportunities
    • Addresses working conditions, equal treatment and opportunities, child labor and forced labor
    • Commitment to UN's principles of responsible business as signatory of UN Global Compact since 2010
    • No cases of non-respect to UNGC principles observed in the last reporting period
  • International standards: UN Global Compact, UN Guiding Principles on Business and Human Rights (UNGPs), OECD Guidelines, Fundamental International Labor Organisation Conventions 1 to 8
  • Implementation monitoring: Due diligence processes informed by OECD guidance, engagement initiatives with suppliers, audits and site visits with tier 1 and 2 suppliers, dedicated due diligence for upstream value chain beyond tier 2

Supplier Code of Conduct

  • Scope: All suppliers and business relationships for activities in upstream, own operations, and downstream across all GN companies, including all subsidiaries and affiliates
  • Governance: Managed by GN's Group Business Ethics and Compliance department, which is responsible for ensuring all requirements are implemented in engagements with suppliers
  • Key content:
    • Updated in 2023 to align with Responsible Business Alliance (RBA) industry best practices
    • Covers all 9 identified impacts, risks and opportunities under value chain workers topic
    • Sets minimum requirements for suppliers to operate in accordance with this code
    • Additional detailed standards set out in other policies and contractual clauses
    • Failure to observe this code requires corrective action; long-term non-compliance may lead to termination of business relationship
    • Suppliers expected to comply with all pollution-related legislation and proactively minimize or eliminate emissions and discharges
    • Expectations for grievance mechanisms to be available to all workers in the value chain
  • International standards: Responsible Business Alliance (RBA) standards, UNGPs, OECD Guidelines
  • Implementation monitoring: 46 supplier audits conducted across China and Southeast Asia in 2024, major findings related to occupational health and safety, excessive overtime hours, overuse of dispatched workers, and inadequate parental leave; all major findings either resolved or subject to mandatory corrective action

Modern Slavery Statement

  • Scope: Upstream value chain and activities
  • Governance: Managed by senior management and compliance functions who oversee overall implementation with suppliers
  • Key content:
    • Seeks to manage potential negative impacts related to child labor and other forms of forced labor in value chain
    • Published in accordance with UK Modern Slavery Act requirements
    • Supports Code of Conduct, requiring suppliers to adhere to and reflect GN's company values and dedication to uphold human rights
    • Guides purchasing and supplier selection policies and procedures
    • Requires potential new suppliers to complete survey to verify compliance with applicable labor law, including laws that ban slavery and human trafficking
    • Approval of supplier dependent on satisfactory survey results
    • Encourages all suppliers to be certified or follow requirements of SA8000 (international Social Accountability Standard) which prohibits any form of forced labor
  • International standards: UK Modern Slavery Act, SA8000
  • Implementation monitoring: Forced labor taskforce established, use of FRDM (Freedom) platform for supply chain risk management powered by data analytics and AI to monitor tier 1 and 2 suppliers who pose high risk of forced or child labor violations; high-risk suppliers requested to complete comprehensive assessment and provide documentary evidence

Conflict Minerals Policy

  • Scope: Upstream activities, such as mining and extraction of raw materials in products
  • Governance: Managed by senior management and compliance functions
  • Key content:
    • Directs action related to child labor and other forms of forced labor
    • Supports efforts of human rights organizations to end violence and atrocities in Central Africa connected to conflict minerals
    • Requires suppliers to exclude conflict minerals originating from Democratic Republic of the Congo and adjoining countries from GN products
    • Encourages suppliers to only use externally certified smelters and refiners
  • Implementation monitoring: Works with Greensoft Technology who perform due diligence focusing on 3TG conflict minerals and cobalt in upstream value chain, particularly in DRC and surrounding countries; in 2024 received requested information from all relevant suppliers for both conflict minerals and cobalt (using cobalt reporting templates)

Environmental Policy

  • Scope: Own operations and value chain
  • Governance: Board of Directors approved the policy
  • Key content: Includes expectations of suppliers to provide accurate carbon data to enable data-driven approach to decarbonization strategy
  • Implementation monitoring: Supplier decarbonization maturity integrated into overall supplier performance assessments

Non-Retaliation Policy

  • Key content: Protects individuals against retaliation when raising concerns; GN committed to dealing with any employee who takes action and/or participates in an investigation in fair and respectful manner

Data Privacy Code of Conduct

  • Scope: All employees in GN
  • Key content: Describes processes for collecting, processing, and protecting consumer and end-user data; guides how all employees process and protect consumer and end-user data that GN handles
S2-3(was S2-4)Taking action on material impacts on value chain workers
Reported

Taking action on material impacts on value chain workers

Overview of IROs

GN has identified 9 material impacts, risks, and opportunities (IROs) related to value chain workers:

  • 7 material, potential negative impacts related to working conditions (secure employment, working time, adequate wages, social dialogue, freedom of association, collective bargaining, work-life balance, and health & safety)
  • 1 material negative, potential impact related to equal treatment and opportunities (gender equality, violence and harassment, and diversity)
  • 1 material potential impact related to child labor and other forms of forced labor in regions with systemic forced labor

Key Actions Completed in 2024

Supplier Audits

  • Action: Conducted 46 supplier audits across China and Southeast Asia in 2024
  • Scope: Upstream value chain (tier 1 and tier 2 suppliers)
  • Findings: Major human rights-related findings were connected to:
    • Occupational health and safety
    • Excessive overtime hours
    • Overuse of dispatched workers
    • Inadequate parental leave
  • Outcomes: All major findings have either been resolved or are currently subject to mandatory corrective action. No major findings related to severe human rights issues such as forced or child labor.

FRDM Platform Implementation

  • Action: Use of FRDM (Freedom) platform for supply chain risk management
  • Scope: Tier 1 and 2 suppliers with high risk of forced or child labor violations
  • Description: AI-powered software to monitor suppliers. High-risk suppliers are requested to complete comprehensive assessments and provide documentary evidence substantiating the absence of forced or child labor abuses.
  • Resources: Software platform integration

EcoVadis Platform Implementation

  • Action: Finalized implementation of EcoVadis supply chain data platform
  • Scope: Upstream value chain
  • Progress: Onboarded 47 total suppliers across China and Southeast Asia to the platform
  • Integration: Set up integration between EcoVadis and supplier management system tools
  • Expected outcomes: Monitor, measure, and manage impacts and risks; gain insights on social indicators
  • Target achievement: Achieved 2024 ESG target for Executive Leadership Team to acquire scorecards from more than 50% of suppliers approached (17 out of 26 suppliers, 65%)

Planned Actions for 2025

Expanded FRDM Platform Use

  • Action: Expand FRDM platform to include more robust supplier screening on modern slavery and conflict minerals
  • Scope: Upstream value chain
  • Time horizon: 2025 (short-term)
  • Activities: Bolster due diligence processes by acquiring more documentation from suppliers with identified risks and facilitating further dialogues on improvement plans during site visits and regular audits

EcoVadis Platform Expansion

  • Action: Onboard more suppliers to EcoVadis and introduce standardized process for tracking supplier performance
  • Target: Onboard at least 80% of largest and most strategic suppliers (at least 75 out of 93 suppliers) to EcoVadis
  • Current baseline: 0% (of the target group of 93)
  • Time horizon: 2025 (short-term)
  • Expected outcomes: Additional insights in managing all 9 IROs; bolster policy implementation and due diligence initiatives

Human Rights Impact Assessment

  • Action: Undertake a human rights impact assessment in line with the UN Guiding Principles
  • Time horizon: 2025 (short-term)
  • Expected outcomes: Enhance ability to identify, measure, monitor, and remediate salient human rights impacts

CSDDD Compliance

  • Action: Extend supplier audit processes to account for CSDDD requirements; adjust supplier contracts; update Supplier Code of Conduct if required
  • Time horizon: 2025 (short-term)
  • Link to policy: New EU due diligence regulation (CSDDD) compliance

Engagement and Remediation

Value Chain Worker Engagement

  • Action: Engage with value chain workers via credible proxies during audits
  • Frequency: Tier 1 contract manufacturers audited annually; tier 2 suppliers audited every second year
  • Standards: Based on UN Global Compact principles and SA8000 standard
  • Process: Random selection interviews with management functions (HR, operations) covering working hours, treatment, safety, and salary

Whistleblower Hotline

  • Action: Maintain whistleblower hotline available to all employees, external parties, and value chain workers
  • Link to policy: Non-retaliation policy to protect individuals against retaliation when raising concerns

Supporting Policies

  • Supplier Code of Conduct: Updated against best industry practices under RBA; covers policy commitments on modern slavery, conflict minerals
  • Modern Slavery Policy: Zero tolerance approach prohibiting any form of forced labor; managed by senior management and compliance functions
  • Conflict Minerals Policy: Requires suppliers to exclude conflict minerals from DRC and adjoining countries; focuses on impacts and risks related to forced and child labor in mining and extraction

Resources Allocated

Non-financial resources:

  • Senior management and compliance functions oversee policy implementation
  • Third-party platforms: FRDM platform, EcoVadis platform
  • Integration with supplier management systems
  • Annual supplier audits (46 in 2024)

Note: No specific financial resources (capex/opex amounts) disclosed for these actions.

S4Consumers and End-Users

S4-1Policies related to consumers and end-users
Reported

Policies related to consumers and end-users

GN has implemented several policies to manage product safety and data privacy related risks. As data privacy and product safety are strictly regulated by international and local laws, targets are mainly determined based on these regulations.

Data Privacy Code of Conduct

Purpose and content: The Data Privacy Code of Conduct guides how all employees process and protect consumer and end-user data that GN handles. It describes processes for collecting, processing, and protecting consumer and end-user data.

Scope: The policy applies to all employees in GN.

International standards: The policy ensures compliance with the General Data Protection Regulation (GDPR) and other relevant data protection regulations.

Implementation monitoring: GN continuously reviews internal procedures and follows regulations to protect consumer and end-user data and ensure the effectiveness of policies and actions implemented. In connection with CSRD implementation, the process is formalized from 2024. Key ongoing initiatives include:

  • GDPR risk assessment: Questionnaires are sent to business process owners via GN's compliance application to assess data privacy risks across all business processes including alignment with the EU AI Act
  • Zero trust technologies initiative to reduce intruders' ability to breach GN systems and data
  • Third-party awareness training software for privacy and security (to be rolled out and completed in 2025)
  • Product Cyber Security Center of Excellence (CoE) launched in 2024

Data Privacy Policy

Purpose and content: The Data Privacy Policy aims to provide direction to identify and meet the requirements regarding maintenance of privacy as well as the protection of personal identifiable information. The policy describes rules and restrictions for international transfer of personal data, how to collect, process, store, and inform personal data, etc.

Scope: The policy is in accordance with applicable laws, regulations, and contractual agreements.

International standards: The policy ensures compliance with relevant data protection regulations including:

  • General Data Protection Regulation (GDPR)
  • Health Insurance Portability and Accountability Act USA (HIPAA)
  • Personal Information Protection Law (China) (PIPL)
  • The Personal Information Protection and Electronic Documents Act (Canada) (PIPEDA)

Link to UNGPs and OECD Guidelines: According to the data points table, ESRS S4-1 data point 17 relates to "Non-respect of UNGPs on Business and Human Rights and OECD guidelines" (referenced on page 104, though not included in the excerpts provided).

Data ethics principles

GN is committed to act ethically responsible with data and comply with ethical principles. By actively considering data ethics, GN intends to ensure human dignity, equality, fairness, responsible use of data, transparency, and awareness by minimizing risk of algorithm bias and discrimination, lack of transparency, lack of control, and lack of responsibility and accountability. GN is implementing appropriate organizational and technical security measures to ensure that any use of data happens in a safe and secure manner.

Product safety

While product safety is mentioned as a material risk related to hearing aids, specific product safety policy details are referenced but not fully disclosed in the excerpts provided. The excerpts note that for hearing products, GN follows the 2017/745 Medical Device Regulation which defines specific safety requirements applicable for all hearing aids and associated accessories.

S4-3(was S4-4)Taking action on material impacts on consumers
Reported

Taking action on material impacts on consumers

Data Privacy

Scope: Own operations and value chain

Policies: Data Privacy Code of Conduct and Data Privacy Policy ensure all GN employees have the knowledge to mitigate risks and ensure GN complies with relevant data protection regulations including GDPR.

Actions implemented:

1. Zero Trust Initiative

  • Description: Network security initiative that assumes individuals, devices, and services attempting to access company resources cannot automatically be trusted, even if inside the network
  • Expected outcome: Significantly reducing any intruders' ability to breach GN systems and data
  • Status: Implemented

2. Third-party awareness training software for privacy and security

  • Description: Comprehensive awareness training program for privacy and security
  • Time horizon: Rollout to be completed in 2025
  • Expected outcomes:
    • Increased employee awareness about data privacy risks
    • How to report data privacy breaches
    • How to set up GN systems according to data privacy laws
    • Save time for preparing training
    • Provide more professional high quality training program
  • Resources: Third-party software implementation (non-financial)

3. Product Cyber Security Center of Excellence (CoE)

  • Description: Brings together experts from across GN to focus on cyber security of GN products
  • Scope: Initially supports Enterprise and Hearing divisions
  • Time horizon: Launched in 2024; will run as long as required to support policy objectives
  • Expected outcomes: Ensures compliance with growing number of cyber security regulations being introduced globally
  • Link to policy: Builds on ongoing work in Cyber Security and supports meeting policy objectives related to cyber security

Targets

Compliance targets: GN complies with privacy regulations including:

  • GDPR (General Data Protection Regulation)
  • HIPAA (Health Insurance Portability and Accountability Act USA)
  • PIPL (Personal Information Protection Law - China)
  • PIPEDA (Personal Information Protection and Electronic Documents Act - Canada)

GN's ambition is to ensure all employees have proper knowledge of data privacy and that GN protects all personal data. GN continuously reviews internal procedures and follows regulations to protect consumer and end-user data. The process is formalized from 2024 in connection with CSRD implementation.

Data Ethics

GN is committed to act ethically responsible with data and comply with ethical principles. GN is implementing appropriate organizational and technical security measures to ensure any use of data happens in a safe and secure manner, with periodic reviews taking into consideration evolving standards.

G1Business Conduct

G1-4Incidents of corruption or bribery
Reported

Incidents of corruption or bribery

Confirmed incidents, convictions and fines

GN has not registered any convictions and fines related to violation of anti-corruption or anti-bribery laws in 2024.

Investigation and speak-up mechanisms

GN has established a whistleblower hotline, the GN Alertline, which is a secure and confidential reporting tool hosted by an independent third party. This hotline is available to all employees and external stakeholders and can be accessed on the GN Group website via www.gn.com/whistleblower and for employees also via GN's intranet.

Concerns can be submitted verbally and in writing. The Group Business Ethics & Compliance department serves as GN's designated investigation unit in compliance with the Danish whistleblower law. GN has appointed Group Business Ethics & Compliance department as the designated whistleblower investigation unit, in compliance with Danish law. Oversight of these investigations lies with GN's Audit Committee, which is updated quarterly on findings and recommendations on cases received through the GN Alertline.

GN's Ethics & Compliance Program is built on the principles of "Prevent, Detect, and Correct" misconduct. This effort includes compliance policies, training, communication, monitoring, and audits. GN's Group Business Ethics & Compliance department regularly conducts onsite compliance reviews across all levels of GN, with a focus on anti-corruption and anti-bribery. The department also performs broader planned reviews in collaboration with Group Legal and Group Financial Reporting & Controlling.

Policies and training

GN's Anti-Corruption Policy outlines expectations and requirements to prevent bribery and corruption. It also provides guidance for employees on how to report misconduct or seek clarification on concerns. The policy is communicated through internal awareness campaigns, e-learnings and in-person training sessions.

Anti-corruption and anti-bribery training is mandatory for all employees incl. consultants on an annual basis.

Accounting policy

Fines, penalties and compensation related to violations of anti-corruption or anti-bribery laws are covered by GN's internal policy and process on mandatory engagement of Group Legal, who therefore have visibility of any such instances.

G1-1Business conduct policies and corporate culture
Reported

Business conduct policies and corporate culture

GN Store Nord has implemented several policies to address business conduct and corporate culture:

GN Ethics Guide

Scope: All GN employees, including members of the Board of Directors

Governance: Managed and updated by the Group Business Ethics & Compliance department

Key content:

  • GN Alertline (whistleblower hotline)
  • Ethical decision-making
  • Business conduct
  • Employment practices
  • Compliance with laws and regulations
  • Conflict of interest
  • Bribery
  • Third-party management

Monitoring and implementation:

  • All employees and consultants are required to complete annual mandatory Ethics Guide e-learning
  • In-person training offered where needed
  • All new employees must read and acknowledge the GN Ethics Guide as part of onboarding

Public availability: Available on GN's website in ten different languages at www.gn.com/documents and for employees via GN's intranet

Alignment with international standards: Aligned with generally accepted standards of ethical business conduct as well as applicable regulations

Non-Retaliation Policy

Scope: All employees and external stakeholders

Key content:

  • Ensures protection of whistleblowers
  • Protects individuals against retaliation when raising concerns
  • Covers the GN Alertline, a secure and confidential reporting tool hosted by an independent third party

Governance: Group Business Ethics & Compliance department serves as GN's designated investigation unit in compliance with Danish whistleblower law. Oversight lies with GN's Audit Committee, which is updated quarterly on findings and recommendations

Public availability: GN Alertline accessible on the GN Group website via www.gn.com/whistleblower and for employees via GN's intranet

Alignment with international standards: Incorporates the EU Whistleblower Directive into compliance framework

Anti-Corruption Policy

Scope: All employees including consultants

Key content:

  • Expectations and requirements to prevent bribery and corruption
  • Guidance for employees on how to report misconduct or seek clarification on concerns
  • Defines purpose, scope, ownership, and responsibilities related to anti-corruption management
  • Key terminology related to anti-bribery and anti-corruption
  • Processes to prevent and detect misconduct

Governance: Defined ownership and responsibilities for anti-corruption management

Monitoring and implementation:

  • Anti-corruption and anti-bribery training is mandatory for all employees including consultants on an annual basis
  • Communicated through internal awareness campaigns, e-learnings and in-person training sessions
  • GN's Group Business Ethics & Compliance department regularly conducts onsite compliance reviews across all levels of GN, with a focus on anti-corruption and anti-bribery
  • Department also performs broader planned reviews in collaboration with Group Legal and Group Financial Reporting & Controlling
  • GN's Ethics & Compliance Program built on principles of "Prevent, Detect, and Correct" misconduct
  • No convictions or fines related to violation of anti-corruption or anti-bribery laws registered in 2024

Data Privacy Code of Conduct

Scope: All employees in GN

Key content:

  • Guides how all employees process and protect consumer and end-user data that GN handles
  • Processes for collecting, processing, and protecting consumer and end-user data

Data Privacy Policy

Key content:

  • Provides direction to identify and meet requirements regarding maintenance of privacy and protection of personal identifiable information
  • Rules and restrictions for international transfer of personal data
  • How to collect, process, store, and inform personal data

Alignment with international standards: In accordance with applicable laws, regulations, and contractual agreements including GDPR

Monitoring and implementation:

  • GDPR risk assessment ongoing, with questionnaires sent to business process owners via compliance application
  • Assessment covers data privacy risks across all business processes including alignment with EU AI Act
  • Third-party awareness training software for privacy and security being implemented, to be rolled out and completed in 2025

Data Ethics Policy

Key content:

  • Commitment to act ethically responsible with data and comply with ethical principles
  • Ensures human dignity, equality, fairness, responsible use of data, transparency, and awareness
  • Minimizes risk of algorithm bias and discrimination, lack of transparency, lack of control, and lack of responsibility and accountability
  • Appropriate organizational and technical security measures to ensure safe and secure use of data

Public availability: www.gn.com/dataethicspolicy

Monitoring: Periodic review of data ethics taking into consideration input from employees and partners, development in trends, technology, legislation, and ethical data values

Supplier Code of Conduct

Scope: All suppliers and business relationships for activities in GN's upstream, own operations, and downstream. Applies to all GN companies, including all subsidiaries and affiliates

Governance: Managed by GN's Group Business Ethics and Compliance department, responsible for ensuring all requirements are implemented in engagements with suppliers

Key content:

  • Updated in 2023 to align with industry best practices set out by the Responsible Business Alliance (RBA)
  • Covers human rights, labor rights, working conditions, equal treatment, child labor, forced labor
  • Pollution-related requirements for suppliers
  • Expectation of grievance mechanisms being available to all workers in the value chain
  • Failure to observe code requires corrective action; long-term non-compliance may lead to termination of business relationship

Alignment with international standards: Aligned with Responsible Business Alliance (RBA) best practices

Environmental Policy

Scope: Own operations and value chain

Governance: Board of Directors approved the policy

Key content:

  • Commitment to reduce GHG emissions in line with scientific consensus
  • Science-based targets for 2030 and commitment to be net-zero no later than 2050
  • For Scope 1 and 2 emissions, prioritizes sourcing renewable energy through instruments ensuring local generation
  • Identifies energy efficiency opportunities in production process optimization and HVAC system settings
  • Expectations of suppliers to provide accurate carbon data
  • Significant decarbonization levers and criteria for prioritizing initiatives: impact and GN's degree of influence
  • No carbon offsetting as alternative to carbon reduction
  • Only independently certified carbon removal to be used
  • No carbon avoidance claims related to products as part of meeting climate targets
  • Addresses pollution-related impacts: compliance with all pollution-related legislation (REACH, RoHS)
  • Substitution of substances with less harmful alternatives even when not legally required

Monitoring: Supported by internal procedures on controlling and limiting impact of incidents and emergency situations

Sustainability ESG Policy

Scope: GN and all subsidiaries, covering full value chain

Governance: Board of Directors approved the policy and oversees compliance, receiving updates on a biannual basis at minimum. Most recently updated in February 2024

Key content:

  • Overarching policy document covering how GN considers social sustainability across full value chain
  • Human rights policy commitments on value chain workers
  • Respect for human rights, including labor rights
  • Abolition of child labor and other forms of forced labor
  • Commitment to prevent child or forced labor in own or business partners' operations

Alignment with international standards: GN signatory of UN Global Compact since 2010, committed to UN's principles of responsible business

Modern Slavery Statement

Scope: Upstream value chain and activities

Governance: Managed by senior management and compliance functions, who oversee overall implementation with suppliers

Key content:

  • Seeks to manage potential negative impacts related to child labor and other forms of forced labor in value chain
  • Guides purchasing and supplier selection policies and procedures
  • Requires potential new suppliers to complete survey to verify compliance with applicable labor law, including laws that ban slavery and human trafficking
  • Approval dependent on satisfactory survey results
  • Encourages all suppliers to be certified or follow requirements of SA8000 (international Social Accountability Standard prohibiting forced labor)

Alignment with international standards: Published in accordance with UK Modern Slavery Act requirements. References SA8000 standard

Conflict Minerals Policy

Scope: Upstream activities, such as mining and extraction of raw materials, especially considering impacts and risks related to forced and child labor

Governance: Managed by senior management and compliance functions

Key content:

  • Directs action to end violence and atrocities in Central Africa connected to conflict minerals
  • Requires suppliers to exclude conflict minerals originating from Democratic Republic of the Congo and adjoining countries from GN products
  • Encourages suppliers to only use externally certified smelters and refiners

Monitoring:

  • Works with Greensoft Technology who perform due diligence focusing on 3TG conflict minerals and cobalt in upstream value chain, particularly in DRC and surrounding countries
  • In 2024, received requested information from all relevant suppliers for both conflict minerals and cobalt
G1-6Payment practices
Reported

Payment practices

Standard contractual payment terms

The typical payment terms for customers is between 30 and 60 days.

Supplier payment procedures

GN has established procedures and policies for managing relationships with suppliers to ensure a structured approach to procurement processes and fair behavior with business partners. All supplier contracts include stipulations for governing late payments and guidelines to manage relationships with suppliers, as well as SMEs. These procedures are supported by various policy commitments, such as GN's Supplier Code of Conduct and Statutory Corporate Governance Reports.

Note

The company does not expect to have contracts with payment terms exceeding one year. As a consequence, the transaction prices are not adjusted for the time value of money.