GN Store Nord

The role of the administrative, management and supervisory bodies

Reference: page 51. Board composition and diversity datapoints are incorporated by reference to "Board of Directors" (pp. 41-43) and "Gender Diversity at Board and Leadership levels" (p. 40).

GN's Executive Leadership Team (ELT) is responsible for monitoring, managing and overseeing implementation of policies, targets and actions related to IRO management. Group Sustainability, reporting directly to the CFO, holds overall responsibility for supporting the business in IRO management, setting strategic direction and preparing this statement.

The Audit Committee holds overall responsibility for overseeing management of ESG-related IROs, reporting to the Board for related decision-making; ESG is a quarterly recurring Audit Committee agenda item, including formal approval of the double materiality assessment, and a bi-annual Board topic.

To implement Better for planet, GN depends on a cross-functional governance structure headed by a senior leadership steering committee covering each of the five strategic pillars, with Global Operations, R&D and the divisions as the key execution functions. Sustainability-related skills on the Board are "currently assessed to be sufficient."

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

Reference: page 51.

Group Sustainability prepares the sustainability statement and "collects and controls ESG data for reporting," reporting to the ELT, which "monitors, manages, and oversees implementation of policies, actions, and targets." The Audit Committee is the body with overall responsibility for overseeing ESG-related IRO management; ESG is a standing quarterly Audit Committee agenda item, including formal approval of the double materiality assessment, and features on the Board's agenda twice yearly.

Progress on Better for planet's four focus areas and five strategic pillars is monitored continuously by subject matter experts and "discussed quarterly in the management teams of all divisions and functions of scale." The Board's annual self-evaluation process includes an assessment of ESG-related skills and expertise; these are "currently assessed to be sufficient across the Board," with any gap to be addressed through Board training or recruitment criteria.

Integration of sustainability-related performance in incentive schemes

Reference: page 52.

ESG-related performance, including diversity objectives, is part of the annual short-term incentive (bonus) objectives for all ELT members, cascaded into operational-level bonus objectives where required. ESG-related objectives for the CEO and CFO are approved annually by the Remuneration & Nomination Committee (RNC); "like in 2024, in the reporting year, 12% of the annual bonus was dependent on these objectives for the CEO and CFO, of which 15% was related to reduction of carbon emissions (2024: 50%)."

The 2025 main objective was integration of ESG into corporate, division, operations and R&D strategies, achieved through the launch of Better for planet, plus an objective on compliance with existing ESG and human rights legislation, and six objectives on decarbonization, recycled/sustainably sourced materials and repairability.

Statement on due diligence

Reference: page 55. GN maps the core elements of due diligence to the relevant sections of the sustainability statement in a table.

This due-diligence table sits alongside the assurance scope the auditor separately reviewed for compliance with Article 8 of the EU Taxonomy Regulation.

Risk management and internal controls over sustainability reporting

Reference: page 55.

GN's sustainability reporting is integrated into the annual reporting process, with a well-established internal approval, controls and external-assurance-preparation process. ESG data is subject to internal control through a dedicated ESG control function in the finance organisation; as "2025 is the second year of CSRD reporting, the control environment is still developing and less mature than in financial reporting."

Using the enterprise risk management methodology (likelihood and impact), GN identifies the main sustainability reporting risks as "the accuracy and completeness of data, especially where ESG data is derived from spend data (versus activity data), where we depend on input from suppliers that is not third-party verified, or where we must estimate." Mitigations: financial-data inputs sourced from the same data used in the financial statements; third-party verified supplier data used where available (e.g. LCAs); estimates based on the closest possible time periods/geographies or third-party datasets such as EcoInvent.

Strategy, business model and value chain

Reference: pages 47-49.

GN's purpose is Bringing People Closer, operating three divisions - Hearing, Enterprise, Gaming - through "an integrated hardware, software, and AI enabled innovation powerhouse." In 2025 GN launched its updated Better for planet sustainability strategy as "a pillar of our overall corporate strategy," built on five pillars (Clean Power and Electrification; Circularity through design; Circularity through material recovery; Expanding TCO Certified; Strengthening our due diligence) delivering four focus areas: reducing carbon footprint (80%/25% scopes 1&2/scope 3 cuts by 2030), advancing circular products (40% sustainable material by 2030), safeguarding value-chain workers' rights, and limiting hazardous substances.

Own operations span hearing aid assembly in Denmark, manufacturing in China and Malaysia, final assembly at regional operation centres, R&D, sales and back-office functions; value chain focus covers six higher-ESG-risk industries: mining, plastic/aluminium production, paper production, freight/business travel, electronics manufacturing and e-waste treatment. GN assessed it "does not need to alter" its strategy or business model to address its IROs.

Interests and views of stakeholders

Reference: page 53.

GN maintains continuous dialogue with employees, value chain workers, consumers and end-users, investors, regulatory authorities, suppliers, and industry/ESG associations, using the outcome as input to business model and strategy. Selected engagement mechanisms: employees - biannual development dialogues, annual employee satisfaction surveys, direct meetings with demographic groups, an employee-elected Board, GN Alertline; value chain workers - annual tier-1 and biannual tier-2 supplier audits, third-party due diligence organisations for conflict minerals/forced labour, GN Alertline; consumers - direct dialogues, customer councils, product feedback channels, surveys; investors - AGM, roadshows, individual meetings; regulatory authorities - industry associations (DI, EHIMA) and direct engagement; suppliers - onboarding ESG requirements, ongoing performance/compliance assessment; industry/ESG associations - working groups, AGMs, joint initiatives.

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

Reference: pages 49-50; per-topic detail pp. 61, 71, 74, 81, 90, 93, 98.

The 2025 update to GN's double materiality assessment (first carried out in 2024) identified 26 material impacts, risks, and opportunities (IROs) across seven ESRS topical standards - E1, E2, E5, S1, S2, S4 and G1 - "including two entity-specific disclosures." The value-chain graphic (p.50) maps each numbered IRO to upstream, own-operations or downstream stages: 7 climate IROs, 2 pollution, 2 resource use, 6 own-workforce, 4 value-chain-worker, 3 consumer/end-user (one combining an opportunity and a positive impact - hearing health), and 2 business conduct.

The 2025 update used desk research, benchmarking and additional stakeholder workshops to "reassess and, where relevant, merge IROs," better capture positive impacts and opportunities, and align more closely with the Enterprise Risk Management process, "without changing the disclosure requirements we report against." GN assessed it does not need to alter its strategy or business model to address these IROs "at a scale and pace beyond our capacity to adjust."

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

Reference: page 49.

GN's double materiality assessment (DMA), first carried out in 2024 from "more than 40 external reports from NGOs, governments, and suppliers, and five internal workshops with 27 subject matter experts," was updated in 2025 using desk research, peer benchmarking and additional stakeholder workshops. The DMA is approved annually by the Audit Committee.

Methodology: impact materiality weighs severity (scale, scope, irremediability) and likelihood equally, prioritising negative impacts, with severity given precedence for human-rights impacts per ESRS 1; financial materiality aligns with Enterprise Risk Management, weighing likelihood and financial impact equally on a gross basis before mitigation, using a 1-5 scoring scale with a materiality threshold of 3 or above (medium scale/scope with a likely, remediable-with-effort outcome for impacts; roughly 10%+ expected EBITA effect with likely outcome for financial risks/opportunities). Time horizons follow the ERM process (0-1 years short-term, 2-3 years medium-term), except climate risks, assessed over a 4-30-year horizon. Biodiversity and water sub-topics were screened using geographic impact assessments and industry/location-specific reports; "we did not consider any biodiversity or water topics to be material."

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

Reference: pages 101-104 (ESRS content index and EU-legislation data-points table); pages 47-50 (material topics narrative).

Following the 2025 DMA, GN's sustainability statement covers ESRS 2 (all general disclosures) and seven material topical standards: E1, E2, E5, S1, S2, S4 and G1. The content index (pp. 101-102) lists, per topic, the specific 2023-numbering disclosure requirements covered - for example E1: GOV-3, SBM-3, IRO-1, E1-1 to E1-7 and E1-9 (E1-8 is not listed); E2: IRO-1, E2-1, E2-2, E2-3, E2-5 (E2-4 and E2-6 are not listed); G1: GOV-1, IRO-1, G1-1 to G1-4 (G1-5 and G1-6 are not listed).

Topics assessed and found not material: E3 (Water and marine resources) and E4 (Biodiversity and ecosystems) - "we did not consider any biodiversity or water topics to be material" (p.49) - and S3 (Affected communities), which does not appear anywhere in the material-topics narrative or IRO table. A separate table (pp.103-104) lists data points derived from other EU legislation (SFDR, Pillar 3, Benchmark Regulation, EU Climate Law) with materiality and page-number flags.

Transition plan for climate change mitigation

Reference: pages 61-62.

GN's climate transition plan consists of "our environmental policy, climate-related incentives for the CEO and CFO, science-based targets, and several decarbonization initiatives," approved by the Board of Directors. "None of our assets or business activities are considered incompatible with or need significant efforts to be compatible with a transition to a climate-neutral economy" and GN "is not excluded from the Paris-aligned benchmarks."

Through Better for planet, the overarching targets are "folded out into supporting targets," with initiatives detailed in a roadmap to 2030 under a strengthened governance framework; emission-reduction initiatives are "anchored within our existing business model and financial planning." A secondary EU Taxonomy-eligible activity (CCM/CCA 7.7, buildings) exceeds the 10% reporting threshold, but GN states it "has not invested significant CAPEX or OPEX in initiatives tied to CCM / CCA 7.7," given its core business's stronger association with the circular-economy objective.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 / the E1 climate-DMA section, where this content is disclosed in the FY2025 report (pages 61-62). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

GN's climate-related risk assessment covered its own operations, key supply-chain activities and customer market locations, excluding "downstream activities beyond the customer's own operations." Physical hazards assessed: extreme weather, heat/water stress, wildfires, sea-level rise; transition events: carbon pricing, regulatory change, changing customer behaviour, material availability.

Scenarios used (pp.61-62): high-emission physical risk - SSP3-7.0; transition risk - IEA Net-Zero Emissions by 2050 (NZE), alongside SSP1-2.6 and IEA STEPS for context. Key assumptions: "poor international cooperation with limited ambition of climate policies and slow uptake of low-carbon technologies" (high-emission scenario); rising carbon cost under NZE but flat under STEPS/high-emission; dramatic renewable grid uptake. No global-average-temperature projection is stated for any scenario, and the report does not date when the analysis was carried out or last updated.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 / the E1 climate risk-assessment section, where this content is disclosed in the FY2025 report (pages 61-62). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

GN's resilience analysis assumed "GN's core business activities and operating model and the distribution of major production facilities do not change," consistent with the Better for planet strategy's time horizon, and that customer/supplier geography broadly persists - assumptions the company says "give rise to uncertainty in the resilience analysis" given "the limited time period of GN's corporate strategy."

Anticipated financial effects were assessed "through a resilience analysis and expressed in terms of potential financial loss or gain (e.g. in revenue, operational costs, asset value)"; because no material short-term financial implications are anticipated, they are not integrated into the financial statements. GN "plan[s] to conduct quantitative analysis including financial modelling" to better evaluate long-term risks and opportunities, and its decarbonization levers (E1-3/E1-4) are the primary contribution to adaptive capacity.

Policies related to climate change mitigation and adaptation

Reference: page 63.

GN's Environmental Policy covers achieving the climate targets and the net-zero-by-2050 commitment. For scopes 1 and 2, where electricity is "a major part of our footprint," the policy prioritises sourcing renewable energy "through instruments that ensure local generation and newly or not yet commissioned projects," with ongoing identification and implementation of site-level energy-efficiency opportunities.

Because the majority of emissions sit in scope 3, GN sets expectations via its updated Supplier Code of Conduct (SCOC), covering supplier climate targets, renewable-energy switching and accurate carbon data provision to support a data-driven strategy. The policy states GN does "not consider carbon offsetting as an alternative to carbon reduction," will "only engage in carbon removal that is independently certified," and will not make product-level carbon-avoidance claims toward its climate targets.

Actions and resources in relation to climate change policies

Reference: pages 64-65.

GN's decarbonization actions in 2025, against six identified levers (renewable energy, energy efficiency, fleet electrification, renewable energy in the supply chain, reducing air freight, low-carbon product design):

• Renewable energy at GN: developed a global renewable-energy roadmap and governance structure, with feasibility assessments for onsite generation; unbundled RECs purchased in 2025 delivered 40% of the market-based scope 2 reduction from baseline.
• Energy efficiency: after-hours HVAC/lighting shutdowns in Malaysia and India cut site energy consumption 4%, an estimated 116 tCO2e (2%) location-based reduction.
• Fleet electrification: 31 of 98 (32%) new 2025 leases were BEV/PHEV, cutting 57 tCO2e.
• Air freight: the global-to-regional share fell to 14% from 17% in 2024, a 10,578 tCO2e absolute reduction in scope 3 category 4.
• Low-carbon materials: 11 new products launched with recycled/biocircular content, an estimated 372 tCO2e reduction.

Ten new product LCAs were completed and five updated in 2025.

Targets related to climate change mitigation and adaptation

Reference: pages 63-64.

GN's near-term targets - 80% reduction in scopes 1 and 2, 25% in scope 3, by 2030 from a 2021 baseline - were validated by SBTi in November 2022 as aligned with limiting warming to 1.5°C, using the absolute contraction approach and cross-sector pathway (IPCC SR1.5 P1 scenario). A long-term target commits to net-zero by 2050 at the latest (90% reduction plus neutralisation of unabated emissions), aligned to SBTi's cross-sector method but not yet SBTi-approved.

2025 progress: scopes 1&2 (market-based) fell to 4,603 tCO2e from a 9,831 baseline (-53%, 66% of the way to the 80% target), though up 10% year-on-year from temporary overlap at two U.S. sites and higher unhedged Danish electricity use. Scope 3 fell to 239,723 tCO2e from a restated 356,424 baseline (-33%), already surpassing the 25%-by-2030 target (131% progress). An estimated 33,216 tCO2e of locked-in use-phase emissions represent 14% of total scope 3.

Energy consumption and mix

Reference: page 66.

Total consumption rose 14% year-on-year, "primarily because of the overlap in operations at our U.S. manufacturing sites." The renewable share rose from 42% to 47%, achieved by procuring 4,510 MWh of bundled RECs (4,500 MWh via the Danish PPA, 10 MWh green tariffs) and 9,758 MWh of unbundled RECs (Malaysia, China, U.S.); the new Sydney site is solar-heated and -cooled onsite. Energy intensity for the high-climate-impact Hearing division (NACE C26.6) rose to 3.43 MWh/DKKm from 2.54. Restatements: 2024 mix figures were corrected for a PPA accounting error and updated national residual-mix data.

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 67-68.

Scope 1 rose 113% in stationary combustion at the Bloomington and Shakopee U.S. sites (temporary overlap, expected to reverse in 2026); mobile emissions fell 11% on fleet electrification. Market-based scope 2 rose 18% on Danish electricity outside the PPA. Scope 3 fell most in category 4 (-26%, air-freight reduction) and category 2 (-24%, a 2024 lease-recognition base effect); GHG intensity (market-based) fell 4% to 14.6 tCO2eq/DKKm on Hearing's lower-carbon revenue mix. Primary data covered roughly 10% of scope 3.

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 70.

GN enabled GHG removals from seven climate change mitigation projects in the prior reporting period, financed through carbon-credit purchases, totalling 263 tCO2eq on completion; no additional removals were initiated in 2025. Four projects are due to retire in 2026 (248 tCO2eq), including "Carbuna" in Germany (39 tCO2eq, 15% of total removals, the only EU-based project). All removals fall under category 5 of the Oxford Offsetting Principles (technological sinks, e.g. direct air capture with geological storage or remineralisation). All projects but one (Running Tide) are externally verified by both the credit's certifying body and Klimate.co; all but one carry a recognised quality standard.

GN "plan[s] to expand upon our current carbon removal portfolio and neutralize residual emissions" outside its own operations and value chain by 2050, monitoring the removals market to maximise safety and reliability.

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

Reference: pages 61-62; general phase-in note page 54.

GN's climate resilience analysis expresses anticipated financial effects qualitatively, "in terms of potential financial loss or gain (e.g. in revenue, operational costs, asset value), given GN's current corporate strategy, including our climate targets," using the WWF Water Risk Filter, IPCC AR6 WGII projections and the World Bank Carbon Pricing Dashboard alongside product LCAs and GHG accounting. The most significant identified long-term physical risk is supply-chain disruption from extreme weather (floods, storms, heat) affecting China/Southeast Asia manufacturing; the most significant transition risk is higher operating costs from carbon-tax introduction/increases. GN "account[s] for relevant climate-related impacts in our financial planning but, given that we do not anticipate material short-term financial implications, they are not integrated into the financial statements," and plans future quantitative financial modelling.

Granular monetary disaggregation by acute/chronic physical risk and real-estate energy-efficiency-class breakdowns are phased in under GN's general transitional provisions (p.54).

Policies related to pollution

Reference: page 71.

GN's material pollution IROs are scoped narrowly to substances of concern (SoC) and substances of very high concern (SVHC); "the general pollution topic is not material to our operations." The Environmental Policy addresses this negative impact for both own-operations production and outsourced manufacturing, committing to compliance with pollution-related legislation (REACH, RoHS) and substitution "with less harmful alternatives that can fulfil the same purpose, even when not legally required," backed by internal procedures for incidents and emergency situations.

Implementation sits with senior quality and legal management; hearing aids (own-manufactured) are subject to medical-regulatory material-use obligations, while all suppliers providing products or components must complete a declaration of compliance. Policies are accessible to affected stakeholders via the Quality Management System. GN states it does "not engage in the production, distribution, commercialization, or import/export" of regulated substances.

Actions and resources related to pollution

Reference: pages 71-72.

Own operations: in 2025 GN stopped using xylene as a thinner in its Behind-the-Ear printing workshop at the Xiamen site from July, switching to a "more effective and less harmful alternative," cutting an estimated 2 metric tons of hazardous waste per year. GN plans to "assess additional areas" for substitution in 2026.

Value chain: GN complies with REACH and RoHS across all divisions; all relevant suppliers completed a declaration of compliance in 2025, improving visibility into high-risk areas. Managing and phasing out halogens (bromine, chlorine, fluorine) in outsourced manufacturing continues via halogen-free requirements for PCBs and, above 0.5g (25g internally), for mechanical parts/packaging/cables, targeting fluorine phase-out by 2026 below 50 ppm. Full material declarations are obtained for roughly 90% of relevant Enterprise components, with SVHCs reported via the SCIP platform.

Targets related to pollution

Reference: pages 71-72.

GN has not set a quantified numerical target for substance-of-concern or SVHC use, in either own operations or the value chain; the stated objective is qualitative - to "minimize any risk of SoC and to reduce and eliminate the use of SVHC where possible." Effectiveness is instead tracked through continuous compliance monitoring: the TCO Certified certification target for Enterprise/Gaming products (raising requirements over time), completed supplier declarations of compliance in 2025, and phased halogen-elimination requirements (fluorine below 50 ppm by 2026 for mechanical parts, packaging and cables above the internal weight threshold).

GN explains that it will not achieve its policy objective "more effectively than our current processes based on continuous compliance and improvements" - an MDR-T "effectiveness tracking" approach rather than a numeric reduction target.

Substances of concern and substances of very high concern

Reference: page 73.

Substances of concern (litres): total 10,666 (2024: 6,020), driven almost entirely by the "Health & Environmental incl. diesel oil" hazard class (10,666 vs 6,020); "diesel oil continues to account for approximately 99% of the total by weight," used for steam generation critical to disinfection and humidity control.

SVHC (litres): total 1,383 (2024: 3,668), split between PBT/vPvB substances (1,253, Octamethyl Cyclotetrasiloxane) and reproduction-toxic substances (130, down from 246, following the 2025 xylene substitution and other actions). A 2025 restatement corrects a 2024 classification error worth 1,613 kg misclassified as SVHC rather than SoC.

The metric only covers substances added at GN's own manufacturing sites (Xiamen, Malaysia, Præstø, Ballerup, Spain, extrapolated to remaining sites); substances added in outsourced manufacturing fall under phase-in relief and are not reported. All volumes are externally verified.

Policies related to resource use and circular economy

Reference: page 74.

GN's Environmental Policy covers both resource inflows and outflows. On inflows, it commits to reducing material use "by optimizing for efficient resource use in the design of our products and in avoiding unnecessary production waste," introducing recycled or renewable alternatives where feasible, and sourcing biological materials (paper, cardboard) sustainably via third-party certifications such as FSC, ISCC Plus and the Global Recycling Standard to avoid deforestation.

On outflows, the policy commits to minimising waste generation by embedding durability, repairability, recyclability and ease-of-disassembly into product design, and to recovering or maintaining value at end-of-life through reuse, refurbishment, recycling, remanufacturing, out-of-warranty takeback and as-a-service leasing models. GN also commits to compliance with product-recycling legislation, financing recycling infrastructure under the EU WEEE Directive in EU markets and equivalent extended-producer-responsibility schemes in relevant U.S./Canadian states and provinces.

Actions and resources related to resource use and circular economy

Reference: pages 74-75.

Resource inflows: a requirement of at least 50% recycled/sustainably-sourced bio-based materials (by weight of mechanical parts) for feasible new Enterprise/Gaming developments; expanding the catalogue of recycled/biocircular materials through testing and supplier development, including for electronic components; continued rollout of FSC-certified packaging. In 2025 GN launched 11 products with recycled/biocircular materials (17%-over 50% of mechanical-parts weight).

Resource outflows: repairability - embedding repairability requirements in product development, running 44 repairability assessments on 38 in-market products; recyclability - a design-for-recycling framework planned for 2026, aligned with EN 45555:2019; material recovery - an out-of-warranty repair service (implementation started November 2025), an Enterprise take-back programme issuing Certificates of Destruction, and remanufacturing of returned hearing aids in Malaysia, achieving an 87% remanufacturing rate in 2025 (2024: 65%).

Targets related to resource use and circular economy

Reference: pages 74-75.

GN's headline circular-economy target: 40% recycled or sustainably-sourced bio-based material across the full product portfolio by 2030 (added in 2025 as part of Better for planet), building on a shorter-term 2025 target of 25% (2024 baseline 19.1%, restated to 23%) and a 2026 target of 28%.

2025 progress: the recycled/sustainably-sourced-biological share reached 26%, exceeding the 25% short-term target; recycled content in products and packaging rose from 2% to 3%; FSC-certified packaging share rose from 50% to 58% of total packaging weight.

Other circularity targets: new non-Hearing products scoring B or higher on GN's internal repairability index; expanding remanufacturing of returned products in the Hearing division to wireless accessories and chargers by 2027. GN has no quantified target for the 2026 design-for-recycling framework milestone, tracking it instead as a planned deliverable.

Resource inflows

Reference: page 76.

An estimated 27% of materials used in products and packaging were recycled or sustainably-sourced biological materials in 2025 (2024: 23%). By weight, the largest material categories are cardboard/paper packaging (34%), plastic parts (19%) and other parts including rubber (17%). The 2024 baseline was restated upward because of newly available product-LCA data; LCA coverage rose from 44% to 47% of Enterprise/Gaming volumes, which account for 92% of resource inflows (Hearing: 8%). All resource-inflow metrics are estimated from third-party-verified (ISO 14067) product LCAs allocated at item level.

Resource outflows

Reference: pages 77-79.

Recyclability: the rate of recyclable content across GN products fell to 70% in 2025 (2024: 74%) on increased demand for less-recyclable product categories; packaging recyclability rose to 89% (87%) on continued FSC-certified cardboard rollout in Hearing.

Repairability: GN's assessments cover 57% of the Enterprise/Gaming portfolio by production volume; the number of products designed for critical-component replacement increased year-on-year. Hearing aids are assessed as repairable in practice through the owned remanufacturing setup rather than a formal repairability index, and the remanufacturing rate for returned hearing aids rose to 87% (2024: 65%).

Durability: for Enterprise/Gaming products, warranty period (1-5 years, extendable) is used as the minimum-durability proxy, cross-checked against warranty-period return rates; hearing aids are designed for minimum 5-year durability per Medical Device Directive submission requirements. No industry-average benchmark is available for comparison.

Policies related to own workforce

Reference: page 81; site-specific policies pp. 82 (H&S), 84 (working time, adequate wages), 85 (diversity), 87 (equal pay), 88 (harassment).

As a UN Global Compact member since 2010, GN's operations are guided by the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines for Multinational Enterprises; GN "does not accept child labor and forced labor as defined by the UN Convention on the Rights of the Child" and respects voluntary freedom of association.

Topic-specific policies cover the six material own-workforce impacts: a global Health & Safety policy framework (finalised 2026, with local Xiamen/Johor Bahru H&S policies already in place); a Global Working Time and Registration Policy plus an EU-specific policy implementing the Working Time Directive; country-by-country compliance for adequate wages (no single global policy, given jurisdictional variation); a global Diversity and belonging policy; the Remuneration Policy addressing equal pay; and an Anti-Harassment Policy covering all employees and third-party interactions.

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

Reference: page 53.

Employee engagement runs through biannual development dialogues for all employees, annual employee satisfaction surveys, direct meetings between senior leadership and demographic-specific employee groups, an employee-elected Board of Directors (3 of 10 members in 2025), and the GN Alertline plus regular HR channels for ongoing input. The stated purposes are to "inform and consult employees on (sustainability) strategy and policies," "ensure all voices are heard, including all demographics," and "safeguard and improve employee wellbeing."

At site level, health and safety engagement is more granular: Xiamen and Johor Bahru employees are represented via safety representatives, line managers, H&S committees, whistleblower hotlines, internal/external audits and employee surveys measuring performance against site health targets (p.82).

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

Reference: page 81 (cross-reference), detailed on pages 98-99.

Employees can report concerns confidentially through the GN Alertline, a secure third-party-hosted whistleblower channel accessible via www.gn.com/whistleblower and, for employees, the intranet. The designated investigation unit is the Group Business Ethics & Compliance department, applying a formal Investigation Guideline for step-by-step case handling; all cases are reported quarterly to the Audit Committee. GN commits that anyone reporting in good faith "will not be subject to retaliatory action" under its Non-Retaliation Policy.

Site-level H&S grievance routes add a further layer at Xiamen and Johor Bahru: safety representatives, line managers, H&S committees and internal/external audits (p.82). In 2025 the Alertline received 36 own-workforce cases (2024: 40), of which 16 related to discrimination/harassment (2024: 26); no fines, penalties or confirmed severe human-rights incidents resulted.

Taking action on material impacts on own workforce

Reference: pages 82-88 (per-impact sections tagged S1-5; S1-4).

Actions against GN's six material own-workforce IROs: H&S - a global H&S organisation (established October 2025) driving ISO 45001 certification, internal audits (twice-yearly Johor Bahru, annually Xiamen), a June 2025 "safety month" in Xiamen; working time - a central HR policy hub and a review of local production-site procedures against the global standard; adequate wages - annual global controls confirming pay at or above local minimum wage; diversity/belonging - an inclusive-language platform extended company-wide, a psychological-safety campaign, leadership-development integration, 12 cultural celebrations, and continued shortlisting-governance for women in leadership; pay inequality - annual pay-gap analyses and independent reviews, with a strengthened 2025 methodology using an independent third party's regression model; harassment - mandatory annual anti-harassment e-learning, though "GN does not track the effectiveness of the Anti-Harassment Policy."

Targets related to own workforce

Reference: pages 82, 85.

GN has not set a single company-wide own-workforce target framework; instead it sets site- and topic-level targets. Health & safety at Xiamen and Johor Bahru: zero major external-audit non-conformities (met in 2025); Johor Bahru 100% H&S training completion (met, up from 95% in 2023); Xiamen zero fatalities/lost-time injuries (met). Diversity: no group-level senior-leadership target beyond the legally required parent-company target under the Danish Gender Balance Act (p.40). Adequate wages, working time and pay inequality: no quantified targets set; GN states for wages that it "has not established additional targets... beyond ensuring that all GN employees receive wages at or above the legally mandated minimum," tracking effectiveness instead through continuous monitoring, annual controls and independent pay-gap reviews. Harassment: no effectiveness target is tracked.

Characteristics of the undertaking's employees

Reference: page 89.

Total headcount at 31 December 2025: 8,190 employees (2024: 8,145) - 4,080 male, 4,045 female, 10 non-binary, 55 not reported. 6,751 on permanent contracts (82%), 819 temporary (10%, 68% of them in Operations), 620 non-guaranteed-hours (all in the U.S., estimated at 40% of the U.S. workforce). Employee turnover was 1,118 employees, a 13.7% rate (2024: 15.2%).

The largest country populations are Denmark (1,888), the United States (1,550), China (1,404) and Malaysia (1,013), each with year-on-year growth except the U.S. (down from 1,608). Employee headcount is measured at year-end; gender is self-reported in Workday, with "Other" denoting non-binary identification and "Not reported" where employees decline to disclose.

Diversity metrics

Reference: pages 85-86.

Senior Leadership gender split (Group level, 2025): 26.1% women (6 of 23), 73.9% men (17 of 23) - up from 25% women (5 of 20) in 2024. A 2025 restatement, including managers on garden leave to align with the Danish Gender Balance Act, revised the 2024 figure to 26.3% women (5 of 19).

Age distribution (2025): roughly 60% of the 8,190-strong workforce is aged 30-50, with younger and older employees making up roughly 20% each. GN notes it is "aware of the series of recent Executive Orders in the United States" and, while remaining committed to equal-opportunity employment, does not set or track diversity-related targets or quotas for its U.S. businesses specifically.

Adequate wages

Reference: pages 84-85.

GN is committed to ensuring adequate wages globally, complying with country-specific legislation and/or collective agreements rather than a single global policy, given jurisdictional variation. As in 2024, all GN employees in 2025 were paid wages exceeding the applicable local minimum or collective-agreement requirement in every country of operation, verified through an annual global control confirming base-salary compliance against the national minimum-wage benchmark. No additional quantified target beyond the legal/collective-agreement floor is set; GN instead continuously monitors employee pay against defined pay ranges across all locations "to ensure that pay remains aligned with market standards and internal equity principles," with local HR teams responsible for ongoing compliance monitoring.

Health and safety metrics

Reference: page 83.

Following a 2025 DMA update, GN's H&S reporting was narrowed to the Xiamen and Johor Bahru manufacturing sites, assessed as where the most material H&S impacts occur; 2024 comparatives were restated on the same basis, alongside a concurrent data-quality improvement, so year-on-year comparison should be read with care.

All three 2025 incidents were non-severe; one led to lost time. No fatalities occurred from work-related injury or ill health at either site.

Compensation metrics (pay gap and total compensation)

Reference: page 87.

Unadjusted gender pay gap (base salary, all active employees): 36.9% in 2025 (2024: 38.3%), attributed mainly to a higher proportion of men in senior, higher-paid positions and to differing pay levels/gender composition across GN's international locations. Adjusted gender pay gap, GN's entity-specific metric comparing comparable-role base salary within the same country: 4.3% in 2025 (2024: 3.3%), calculated from 2025 using a strengthened methodology - an independent third-party regression model controlling for job complexity, experience, performance and location.

Total remuneration ratio (CEO annual total remuneration to median total remuneration): 46.4 in 2025 (2024: 43.5). No quantitative pay-gap targets are set; GN's ambition is stated qualitatively as minimising pay gaps "and ensure equal pay for equal work."

Incidents, complaints and severe human rights impacts

Reference: page 88.

Employees and external stakeholders can report confidentially through the third-party-hosted GN Alertline; the designated Group Business Ethics & Compliance department investigates, with all cases reported quarterly to the Audit Committee. GN states it "has not incurred any fines, penalties or compensation for damages related to reported incidents and complaints and has not identified any severe human rights incidents connected to GN's workforce."

Policies related to value chain workers

Reference: pages 90-92.

GN identified four material value-chain-worker IROs: inadequate working conditions, inadequate H&S, diversity/gender-equality issues, and child/forced labour, concentrated in industries "at tier 2 or beyond supplier level" - mining, plastic/steel/aluminium/paper production, and electronics manufacturing/e-waste - where GN has "limited visibility" to assess impacts directly, plus agency workers at the Malaysia manufacturing site.

Policy commitments cover all value-chain workers across all operating geographies: the Supplier Code of Conduct (SCOC), based on the RBA counterpart and aligned with ILO Conventions, the UN Guiding Principles and the UN Global Compact, is supported by the Sustainability ESG Policy, a Modern Slavery Statement and a Conflict Minerals Policy. Tier 1 and tier 2 suppliers undergo annual ESG audits; new suppliers complete a compliance survey; GN requires exclusion of minerals from conflict-affected and high-risk areas including the DRC and adjoining countries.

Processes for engaging with value chain workers about impacts

Reference: page 53.

Value-chain-worker engagement runs through annual audits of all tier-1 suppliers and biannual audits of tier-2 suppliers, third-party audits, and "credible proxies, such as third-party due diligence organizations for conflict minerals and forced labor." The stated purposes are ensuring compliance with UN Global Compact principles and the SA8000 standard, and identifying/correcting working-condition and worker-rights issues.

GN also uses the GN Alertline as a reporting channel accessible to value-chain workers. As part of Better for planet's development, GN says it engaged with value chain workers "via credible proxies, such as our own audits, RBA audit findings and EcoVadis scorecards" (p.92), reflecting the limited-visibility constraint on direct engagement described under S2-1.

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

Reference: page 90 (cross-reference), detailed on pages 98-99.

Value-chain workers can raise concerns via the GN Alertline, the same secure, third-party-hosted whistleblower channel used for GN's own workforce, accessible externally at www.gn.com/whistleblower. The Group Business Ethics & Compliance department investigates cases under a formal Investigation Guideline, with quarterly reporting to the Audit Committee, and GN's Non-Retaliation Policy applies to good-faith reporters regardless of employment relationship.

Supplier-level remediation runs in parallel: annual tier-1 and biannual tier-2 supplier audits (p.53) surface breaches of the SCOC, with major violations subject to mandatory corrective action, mirroring the equivalent supplier-audit mechanism GN describes for pollution-related compliance (p.71). No dedicated case-count metric specific to value-chain workers is separately broken out from the combined own-workforce/value-chain Alertline figures on page 88.

Taking action on material impacts on value chain workers

Reference: page 92.

In 2025 GN onboarded 86% (83 of 96) of its largest material and component suppliers onto EcoVadis, against an 80% target, and conducted 86 supplier audits across China and Southeast Asia, working with suppliers to close all findings through corrective action plans. GN also conducted a human rights impact assessment as part of developing Better for planet.

Progress toward the 2030 human-rights due-diligence programme (p.91): 62% of manufacturing partners/ROCs completed an RBA Self-Assessment Questionnaire (target 100%) and 68% completed a VAP audit with a minimum Silver result (target 100%); 86% of top-80%-spend suppliers are onboarded on EcoVadis (target 100%). Planned actions include mapping/assessing risk for 80% of tier-1/tier-2 spend, finalising a new supplier-engagement routine by end-2027, updated ESG-audit checklists, RBA Academy training rollout, and continued responsible-minerals due diligence via Greensoft Technology for 3TG/cobalt in CAHRAs.

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

Reference: page 92; infographic p.91.

GN's overarching 2030 target is to strengthen human-rights due diligence for value-chain workers through increased use of EcoVadis and the RBA platform. Component targets, each with a 2025 baseline and 2030 target: EcoVadis score (reporting company) - baseline 57/100, target 70/100; RBA Self-Assessment Questionnaire completion for manufacturing sites/ROCs - baseline 0%, target 100%; RBA Validated Assessment Program (VAP) audits with minimum Silver result - baseline 0%, target 100%; top-80%-spend material/component suppliers onboarded on EcoVadis - baseline 86% (already exceeding the original 80% target). Supporting actions extend RBA-aligned requirements to prioritised high-risk indirect-procurement suppliers and continue legislative compliance work on forced labour and conflict minerals across all markets.

Policies related to consumers and end-users

Reference: pages 94-96.

GN identified three material consumer/end-user IROs: risk of privacy-law non-compliance, risk of health-and-safety-standard violation, and hearing health (a combined positive impact and opportunity, entity-specific).

Hearing health is not addressed by a dedicated policy - it is core to the Hearing division's business activity, pursued via 5-8% annual organic revenue growth ambitions and initiatives such as LISTEN TO THIS. Data privacy: a Data Privacy Code of Conduct and Data Privacy Policy govern GDPR and equivalent-regime compliance (HIPAA, PIPL, PIPEDA); a Data Ethics Policy addresses algorithmic bias, transparency and accountability in GN's use of data, including alignment with the EU AI Act. Product safety: hearing-aid safety policies cover the full lifecycle under the EU Medical Device Regulation (2017/745) and Radio Equipment Directive (2014/53), including design safety, quality control and post-market surveillance.

Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions

Reference: pages 94, 96.

Hearing health: GN exceeded its 2021-set target to help 10 million people by 2025, reaching 12.1 million people helped in 2025 (2024: 11.2 million), through the launch of the world's smallest AI-powered hearing aid (ReSound Vivia), a new Mental Health section on the LISTEN TO THIS platform (1,500+ hearing-care professionals signed up as of October 2025), a Copenhagen Fashion Week collaboration with HAN Kjøbenhavn, product-donation efforts, and a Washington event with the Danish Ambassador to the U.S. on hearing and cognitive health.

Product safety: 25 external audits in 2025, including 15 by Notified Bodies; training deepened on regulatory requirements, risk management, cybersecurity and AI-related compliance; a trigger-based CAPA process auto-initiates root-cause analysis on KPI breaches. Data privacy: a new third-party privacy/security awareness-training tool rolled out in early 2025; an ongoing GDPR risk-assessment programme, including AI Act alignment; "zero trust" technology initiatives reducing intrusion risk.

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

Reference: pages 94, 96.

Hearing health: original target - help 10 million people with hearing loss by 2025 - was exceeded in 2024 (11.2 million) and reached 12.1 million in 2025; no successor numeric target is disclosed for 2026 onward.

Product safety: a deviation-response-time target of 20 days (formally defined 2024, triggered by three consecutive months of KPI underperformance); the 2025 average response time was 17 days, below target, set using quantitative incident-data/KPI trends and qualitative internal-audit/stakeholder input from cross-functional Quality, Regulatory Affairs, Risk Management and Product Development teams.

Data privacy: "besides compliance with international and local regulations, GN has not set targets related to data privacy," relying instead on continuous internal-procedure review and effectiveness assessment against GDPR, HIPAA, PIPL and PIPEDA.

Business conduct policies and corporate culture

Reference: pages 98-99.

GN's GN Business Ethics & Compliance program is designed to "prevent, detect, and respond to misconduct," built on compliance policies, training and communication, whistleblower-hotline investigations, anti-corruption compliance reviews, third-party due diligence and economic-sanctions management. The GN Ethics Guide - Code of Conduct, available in ten languages, sets ethical standards for all employees, Board members and business partners, supported by local Compliance Champions who promote awareness and run local training.

Mandatory annual anti-corruption training applies to all employees, including consultants. GN also maintains a Gifts and Hospitality Policy and a third-party management programme. The Group Business Ethics & Compliance team conducts regular on-site compliance reviews focused on anti-corruption/anti-bribery controls, identifying vulnerabilities and supporting compliance with laws including the U.S. FCPA and UK Bribery Act, alongside broader combined reviews with Group Legal and Group Financial Reporting & Controlling.

Management of relationships with suppliers

Reference: pages 90-92.

GN has established procedures and policies "for managing relationships with suppliers to ensure structured procurement processes and fair behavior with business partners," including small and medium enterprises. All supplier contracts include stipulations governing late payments and relationship-management guidelines, supported by the Supplier Code of Conduct (SCOC) and reinforced by annual tier-1/biannual tier-2 supplier ESG audits.

Human-rights and conflict-minerals due diligence toward suppliers runs through the RBA and EcoVadis platforms, with 2025 progress of 86% top-80%-spend suppliers onboarded on EcoVadis and 62% of manufacturing partners completing an RBA self-assessment questionnaire. New suppliers must complete a survey verifying compliance with applicable labour law, including anti-slavery and anti-trafficking provisions, and GN requires exclusion of minerals from conflict-affected and high-risk areas, supported by its Greensoft Technology partnership for 3TG/cobalt due diligence.

Prevention and detection of corruption and bribery

Reference: page 99.

GN maintains a "zero-tolerance stance on bribery and corruption," set out in its Anti-Corruption Policy, which "defines expectations and mandatory controls to prevent corrupt practices across the organization and provides guidance on reporting misconduct or seeking clarification." This is communicated through internal awareness campaigns, e-learning and in-person training, and reinforced by the Gifts and Hospitality Policy and third-party management programme.

The Group Business Ethics & Compliance team conducts regular on-site anti-corruption compliance reviews, with three stated objectives: identifying and assessing local compliance challenges; advising the business on managing specific compliance risks; and supporting compliance with applicable laws (the U.S. FCPA, UK Bribery Act) and GN policies. The team also performs broader, planned combined reviews with Group Legal and Group Financial Reporting & Controlling.

Targets related to business conduct

Back-filled from GN's Business conduct chapter (G1-1/G1-3), where this content is disclosed in the FY2025 report (pages 98-99). This disclosure requirement did not exist as a standalone code under the 2023 ESRS the report was prepared against; it was previously captured under MDR-T.

GN does not disclose a quantified numeric target for corruption prevention (e.g. a target incident count or training-completion percentage). Effectiveness is instead tracked through recurring monitoring mechanisms: mandatory annual anti-corruption training for all employees and consultants; regular on-site anti-corruption compliance reviews conducted by the Group Business Ethics & Compliance team, explicitly designed to "identify and assess local compliance challenges," "advise the business on how to manage specific compliance risks" and "support the business in ensuring compliance" with applicable law and GN policy; and quarterly Audit Committee reporting of all GN Alertline cases, including corruption-related concerns. This is GN's MDR-T "effectiveness tracking in the absence of a stated target" limb.

Incidents of corruption or bribery

Reference: page 99.

"Consistent with the previous year, GN has not recorded any convictions or fines related to violations of anti-corruption or anti-bribery laws." Fines, penalties and compensation related to anti-corruption or anti-bribery violations are covered by an internal policy requiring mandatory engagement of Group Legal, giving that function visibility of any such instances, which is the basis for the confirmed-zero figures above.