Lundbeck

Governance structure

Reference: pages 39-47. Board composition and diversity datapoints (21 a-e) sit in the Corporate governance section of the Management review, which the content index incorporates by reference.

Lundbeck runs a two-tier structure: the Board of Directors and the Executive Leadership Team (ELT), with no individual on both (page 39). In 2025 the Board had 11 members, seven elected by the General Meeting and four by employees. Four of the seven (57%) are independent. Two of the seven are women, and two of the four employee-elected members are women (page 39). The ELT has eight members, three of them women (38%) (page 40).

The Board's key responsibilities include to "Oversee sustainability matters" (page 39). Three committees advise it: the Audit Committee (which covers the double materiality assessment and sustainability reporting), the Remuneration & Nomination Committee and the Scientific Committee (page 39). The ELT is to "Manage and address sustainability matters" (page 39). Board member competences, including ESG for several members, are on pages 41-42.

Information provided to the Board on sustainability matters

Reference: pages 45, 39-40, 61.

Sustainability governance "is anchored with the Board of Directors and cascades through the Audit Committee and the Executive Leadership Team" (page 45). A cross-functional working group supports it by ensuring regulatory compliance, monitoring impacts, risks and opportunities, and tracking progress on the Sustainability Strategy and targets (page 45).

The governing bodies "receive annual updates on sustainability reporting", and sessions with internal subject matter experts are part of the annual meeting schedules of the Board, Audit Committee and ELT, so they can oversee material impacts, risks and opportunities (page 45). The ELT presents significant decisions on managing material IROs to the Board for approval (page 40). Key DMA decisions are periodically approved by the ELT, the Audit Committee and the Board (page 61).

Sustainability in incentive schemes

Reference: page 40.

10% of the ELT's short-term incentive (STI) program is linked to sustainability. Payouts depend on performance against ESG objectives tied to the Sustainability Strategy targets. For 2025 there are five objectives, each worth 2%: progress on reducing scope 3 GHG emissions from business travel, implementing the Equity-based Tiered Pricing framework, the Code of Ethics completion rate, gender balance in upper management, and inclusion survey scores (page 40).

Only the business travel objective is climate-related, so climate carries 2% of the STI. Remuneration policy and reporting are set out in the 2025 Remuneration Report, which is subject to an advisory vote at the AGM after Board approval (page 40).

Statement on due diligence

Reference: pages 62, 128.

Page 128 maps the five core elements of due diligence (UN Guiding Principles and OECD Guidelines) to pages in the statement: embedding it in governance, strategy and business model (39-40; 54-55; 56-61; 62-63); engaging affected stakeholders (60-61; 62-63; 65; 72; 74; 85; 89; 96-97; 98-105; 108-112; 114-117); identifying and assessing adverse impacts (56-63); taking action (66; 74; 78; 85; 89; 97; 98-99; 100; 103-105; 109; 111; 116-117); and tracking effectiveness (62; 66; 74; 78; 85; 89; 90; 97; 98-99; 100; 103-105; 109; 111; 116-117).

Page 62 says due diligence is embedded in operational processes such as the HSE management system, product quality and patient safety processes. It adds that Lundbeck "has identified the actions needed to advance other aspects of sustainability due diligence in the coming years", including a more centralized way of working in preparation for CSDDD.

Risk management and internal controls

Reference: pages 45-47.

Decentralized teams identify and monitor risks and report to a central risk office, which presents an overview to the ELT and Board for approval. The Board is responsible for risk management procedures, with oversight delegated to the Audit Committee (page 45). Enterprise risk management and the DMA are interlinked (page 45). The key risks table adds ESG links to S4 (page 102), E1 (page 65) and G1 (page 114) for the market strategy, supply, quality and product safety, and legal compliance risk areas (pages 45-46).

Sustainability reporting controls sit inside the global Internal Control Framework, which is based on COSO. Lundbeck says monitoring and risk assessment of these controls "are under implementation" as part of its CSRD roadmap (page 47). Subsidiary managers and financial controllers confirm compliance with reporting guidelines each year, and external auditors report significant findings to the Board (page 47).

Strategy, business model and value chain

Reference: pages 14-17, 54-55.

Lundbeck develops, produces and markets medicines for psychiatric and neurological disorders. Total revenue was DKK 24,630 million in 2025. Products are registered in more than 80 countries and Lundbeck has employees in more than 20 (page 15). It relies on about 5,300 employees (page 14). Revenue by region: U.S. DKK 13,287 million, Europe DKK 5,819 million and International Operations DKK 4,858 million (page 15). Strategic brands are the Abilify LAI franchise, Brintellix/Trintellix, Rexulti and Vyepti (page 16).

The value chain runs from suppliers (energy, raw materials, research organizations, contract manufacturers) through production at four sites to healthcare professionals, authorities and patients. About 20% of revenue is reinvested in R&D (page 14).

The Sustainability Strategy has four pillars: access to health, business ethics, climate change and circularity, and people and communities (page 54). An update is due for sign-off in the first half of 2026 (page 54).

Interests and views of stakeholders

Reference: pages 45, 54-55, 62.

Page 62 sets out engagement by stakeholder group, with the approach and the outcome for each: patients, healthcare professionals, investors and shareholders, employees, partners, and workers in the value chain. Examples are patient feedback sessions and 'Let the patient speak' events, the 'Our Voice' employee survey, employee-elected board members, the Compliance Hotline, and on-site supplier audits.

Lundbeck says engagement to understand stakeholders' interests and views is part of many operational processes, "which we use to inform our strategy and business model" (page 62). Each production site runs local stakeholder analyses (page 62). In the DMA, subject matter experts bring in affected stakeholders' views through their daily engagement and proxy stakeholders such as environmental and social organizations (page 60). The report does not describe a separate stakeholder survey for the DMA.

Material impacts, risks and opportunities

Reference: pages 54-59, 61, 72.

The 2025 DMA confirms E1, E2, E5, S1, S2, S4 and G1 as material (page 56). The IRO tables on pages 57-59 list the material IROs: E1 (2), E2 (4), E5 (2), S1 (3), S2 (1), S4 (8) and G1 (5). Examples are greenhouse gas emissions (actual negative impact), PFAS soil pollution at the Lumsås site, inequality in access to health, product safety and quality, and the risk of pricing, reimbursement and access (financial risk). Each IRO shows a short, mid or long time horizon and where it sits in the value chain.

Lundbeck says its strategy and business model are resilient, "most strongly" in relation to climate change (page 54). It reviewed the shift to a partner-led model in 27 countries, the closure in Pakistan and the planned LuPi divestment and concluded they do not materially affect DMA conclusions (page 53).

Climate-specific resilience analysis is also presented under E1-3 (2025 ESRS numbering).

DMA process

Reference: pages 60-61, 56.

Lundbeck runs its DMA every year, and the process "remains unchanged compared to 2024" (page 60). The long list of 37 sub-topics draws on ESRS 2 AR 16 and the SASB and MSCI benchmarks (pages 56, 60). Internal subject matter experts score impacts from one to five. A matter is material for reporting where an impact scores four or more out of five, and any matter scoring three is reviewed further (page 60).

Financial materiality uses EBIT impact in DKKm on a one to five scale. A risk or opportunity is material when it scores "above one in financial magnitude", a level based on the materiality amount used in the Financial Statements (page 61). Environmental screening uses tools such as the WRI Aqueduct Water Risk Atlas and WWF Risk Filter Suite. Results are approved by the ELT, Audit Committee and Board (page 61).

Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

ESRS content index

Reference: pages 121-122, 126-127.

Lundbeck prints a "List of ESRS disclosure requirements covered in the Sustainability Statement" with a page reference for each requirement, and marks those incorporated by reference to other parts of the Management review (pages 121-122). The index lists E1-1 to E1-7, E2-1 to E2-5, E5-1 to E5-5, S1-1 to S1-6, S1-9, S1-14, S1-16 and S1-17, S2-1 to S2-5, S4-1 to S4-5, and G1-1 to G1-4.

It states: "ESRS E3, E4, and S3 were deemed immaterial and are therefore not disclosed in Lundbeck's 2025 Annual report" (page 122). A separate list of datapoints that derive from other EU legislation gives page references or N/A for each (pages 126-127).

Transition plan

Reference: pages 65-66, 67, 70, 72.

Lundbeck's Transition Plan, launched in 2023, sets out GHG reduction targets that are approved by the Science-Based Targets initiative (SBTi) and compatible with limiting global warming to 1.5°C, and it guides investment decisions (page 65). The aim is climate neutrality by 2050 through a 90% emissions reduction, with the remaining 10% neutralized by certified carbon removals that are not counted toward the targets (page 65).

Five decarbonization levers carry the plan: energy in own operations, sustainable sourcing, optimization and circularity, greening logistics, and cleaner travel (page 65). Page 66 sets milestones by lever and reports 2025 outcomes. Targets and actions are reported to the Climate Steering Committee three times a year and quarterly to the ELT (page 70). Lundbeck says it is not excluded from the EU Paris-aligned Benchmarks. As of 2025 it has not carried out a qualitative assessment of potential locked-in GHG emissions and has not pursued plans for Taxonomy alignment (page 72).

Identification of climate-related risks and scenario analysis

Reference: page 72.

Back-filled from ESRS 2 IRO-1 (E1 climate process, page 72), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Lundbeck runs a scenario analysis on two scenarios, using TCFD and CDP guidance, over a 1-10 year horizon: the IEA Net Zero Emissions by 2050 scenario for transition risk and the RCP8.5 "business-as-usual" scenario, a high-emission pathway with about a 4°C rise, for physical risk (page 72). Physical risk is screened by location, exposure, likelihood, magnitude and duration, supported by an annual business interruption analysis. Under RCP8.5 the risk of wildfires and flooding rises, so Lundbeck plans to secure assets and use dual warehouses in a high-risk area (page 72). The NZE scenario is described as limiting warming to 1.5°C. The one climate-related financial risk in the IRO table, damage to facilities from wild weather events, is a physical risk (page 57). Transition events are screened for reputational, financial, market and regulatory risk, and no assets or activities incompatible with a climate-neutral economy were identified (page 72).

Resilience in relation to climate change

Reference: pages 54, 72.

Back-filled from ESRS 2 SBM-3 and the E1 resilience analysis (pages 54, 72), where this content is disclosed in the FY2025 report. This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

A resilience analysis was carried out in 2025 on the basis of the scenario analysis, covering own operations and the value chain over time horizons aligned with the scenarios and climate targets (page 72). Its critical assumptions include carbon pricing, fuel availability, policy, technology and demand changes. Lundbeck uses the results to build milestones into the Transition Plan, adapt strategy and plan mitigation (page 72). It names limited data on the upper tiers of the value chain as a gap in the picture of risk (page 72). Page 54 concludes that the business model is resilient, "most strongly" for climate change.

Policies related to climate change mitigation and adaptation

Reference: pages 63, 65.

Climate is covered by the Health, Safety and Environment (HSE) policy and the position papers on climate change and environmental footprint. The policy commits Lundbeck to reduce scope 1, 2 and 3 GHG emissions, implement the Transition Plan towards net zero, increase renewable energy (especially through power purchase agreements), apply energy-efficient technology and mitigate climate-related risks (page 65). It applies to global operations, with the ELT and the Climate Steering Committee accountable (page 65).

The HSE policy is set and approved by the HSE Council and the ELT, and operationalized through an HSE management system certified to ISO 14001 and ISO 45001 at the four production sites (page 63). Suppliers and partners are expected to follow the same principles through the Code of Ethics (page 63).

Actions and resources in relation to climate change policies

Reference: pages 65-66, 68.

Page 66 reports each lever against its 2025 milestone. Energy in own operations missed its 41% milestone against the 2019 baseline, although all European sites now buy guarantees of origin for 100% renewable electricity. Optimization and circularity (a new solvent recycling unit at Lumsås) exceeded its milestone. Sustainable sourcing missed its 22% milestone; 51 top suppliers have signed renewable energy agreements. Greening logistics reached a 31% reduction against an 11% milestone, mainly by moving freight from air to sea. Cleaner travel reached 39% against 7%, helped by a travel policy and travel management platform launched in 2025 and a shift to hybrid and electric cars.

Lundbeck bought 1,330 tCO2e of certified sustainable fuels in 2025 (page 68). The report gives no monetary CapEx or OpEx amounts for these actions in pages 65-72.

Targets related to climate change mitigation and adaptation

Reference: pages 66, 67, 70, 72.

Targets are SBTi-approved, set against a 2019 baseline using an absolute contraction method, and cover the seven Kyoto gases (page 70). Page 67 lists them with 2025 status: cut scope 1 and 2 by 42% by 2029 ("Ahead"), cut scope 3 by 25% by 2029 ("Not on track"), and cut scope 1, 2 and 3 by 90% by 2050 ("Not on track").

Scope 1 and 2 (market-based) fell to 23,263 tCO2e, 47% below 2019, while total scope 3 stands 8% above 2019 (pages 64, 67). Lundbeck follows no sector decarbonization pathway for pharmaceuticals, "as there is not yet one defined by SBTi" (page 70).

Energy consumption and mix

Reference: page 71.

Total energy consumption was 160,480 MWh in 2025 (2024, restated: 161,957 MWh). Fossil sources were 94,854 MWh (59%, down from 60%), nuclear 2,398 MWh (2%) and renewable 63,228 MWh (39%, up from 36%). Crude oil and petroleum products (49,998 MWh) are the largest fossil fuel, followed by natural gas (19,497 MWh) and other fossil sources (17,534 MWh).

Energy intensity was 6.7 MWh per DKK million of net revenue (2024: 7.5), with all revenue treated as coming from high climate impact sectors (NACE C21). Fleet fuel is now included and 2024 was restated on the same basis, with more than 30% additional estimated data, according to the footnote. About 9% of total consumption is estimated. LuPi, planned for divestment, accounts for 15% of energy use.

Gross scopes 1, 2, 3 and total GHG emissions

Reference: pages 67-70.

2025 emissions in tCO2e: scope 1 20,345 (2024: 21,853); scope 2 location-based 9,807 and market-based 2,918 (2024: 7,088); total scope 1 and 2 market-based 23,263. Scope 3 in the SBTi boundary was 121,361 (2024: 127,206): purchased goods and services 103,635, upstream transport 6,356 and business travel 11,370. Total GHG was 151,513 location-based and 144,624 market-based. Biogenic emissions were 3,104.

The table excludes 12% of category 1 and 22% of category 4 to match the SBTi boundary. Including them, scope 3 is 137,460 tCO2e and market-based total 160,723 (page 67). Only 34% of category 1 data comes from supplier-reported emissions (page 69). Intensity is 6.0 tCO2e per DKK million (market-based).

GHG removals and carbon credits

Reference: page 65.

The content index lists E1-7 at page 65. The page states that the remaining 10% of emissions in 2050 are to be neutralized "through certified carbon removals", which "will not be counted as emission reductions towards Lundbeck's climate targets" and will be recorded separately in the carbon inventory to avoid double counting.

No removals or carbon credit projects are quantified for 2025. The datapoint list marks the E1-7 GHG removals and carbon credits datapoint (paragraph 56) as N/A (page 126). Biogenic CO2e from bio-oil and company cars is reported outside the scopes (3,104 tCO2e) (pages 67, 70).

Policies related to pollution

Reference: pages 63, 73.

Pollution is covered by the HSE policy and the Position on Environmental Footprint. The policy commits Lundbeck to environmental protection, legal compliance, "prioritizing substitution of hazardous substances" and preventive and mitigating actions through the HSE management system (page 73). It applies to global operations, with the ELT and HSE Council accountable (page 73).

Lundbeck says the policy covers pollutants and substances relevant to its own operations and does not apply to the value chain. Its expectation of suppliers and business partners is expressed through the Code of Ethics (page 73). The management system is certified to ISO 14001 (page 63) and the approach is tied to SDG 12 (page 73).

Actions and resources related to pollution

Reference: page 74.

Page 74 lists four action areas against the four E2 IROs. For air, Regenerative Thermal Oxidizers at Lumsås (2020) and Padova (2004) and an ethanol scrubber at Valby limit NMVOC emissions. For water, an activated carbon filter treats production wastewater at Valby, new products get environmental risk assessments, and leaflets give disposal guidance. For soil, Lumsås and Padova are treated as high-risk sites with incident reporting and emergency plans.

For PFAS at Lumsås, from firefighting foam used until 2011, investigations with the Danish EPA found two contamination hotspots. A water treatment plant is now operating, remediation continues as agreed with the EPA, and Lundbeck has renewed approval to discharge surface water to the ocean (page 74). No monetary amounts are given.

Targets related to pollution

Reference: pages 74-75.

Lundbeck sets no pollution targets. Page 75 says: "In 2025, Lundbeck has set no specific targets related to pollution, beyond strict compliance with legal requirements." It points to page 74 for how it tracks the effectiveness of its actions.

On page 74, effectiveness is tracked by continuous monitoring of emissions to air and water against permit limits, by incident reporting and monitoring for soil, and by ongoing engagement with the Danish EPA and local stakeholders for PFAS.

Pollution of air, water and soil

Reference: page 75.

Lundbeck reports emissions of substances that exceed E-PRTR thresholds. In 2025 only NMVOC at the Padova site did, at 88 tonnes (2024: 94 tonnes). The report states a 7% reduction on 2024 and notes diffuse emissions are now included for the first time (page 75). About 1% of Padova's NMVOC is measured at the chimney, and the other 99% is estimated from prior-year proportions and a mass balance (page 75).

Lundbeck recorded seven environmental incidents (2024: four), none with consequences for the environment. Near misses fell from 38 to 27 (page 75). LuPi accounts for 13% of production volume (page 75). The datapoint list marks the E-PRTR pollutant datapoint at page 75 (page 126).

Substances of concern and substances of very high concern

Reference: page 76.

Page 76 reports both limbs. Generated, used or procured: 1,540 t of substances of concern (2024: 1,858 t) and 17 t of substances of very high concern (2024: 35 t), split by hazard class: human health (H3xx) 483 t, environmental (H4xx) 318 t, both 739 t. Leaving facilities as emissions, products or part of products: 95 t of substances of concern (2024: 118 t) and 2 t of very high concern (2024: 2 t).

Lundbeck estimates the emissions share by applying a 95% reduction factor to purchased quantities, on the assumption that most hazardous substances leave as liquid waste treated by external partners. The products share assumes quantity purchased equals quantity leaving in products. Data come from the internal chemical register and SAP purchase records.

Policies related to resource use and circular economy

Reference: pages 63, 77.

The HSE policy and the position papers on environmental footprint, climate and water commit Lundbeck to upholding circular principles, minimizing consumption, emissions and waste, reusing resources including recovery and recycling of selected organic solvents in API production, and applying environmental standards to packaging and suppliers (page 77). It applies globally, with the ELT and the Climate Steering Committee accountable (page 77).

Lundbeck states there are "no dedicated policies specifically covering the transition away from virgin resources, sustainable sourcing, or the use of renewable resources", but it has set milestones for renewable resources in the Climate Transition Plan (pages 66, 77). Its 2030 aspirations include moving from a linear to a more circular manufacturing model (page 77).

Actions and resources related to resource use and circular economy

Reference: pages 77-78.

Lundbeck says a dedicated circularity action plan "has yet to be developed", and most efforts go into chemicals and solvents at Lumsås and Padova (page 77). Three action areas are listed (page 78):

• Solvent recovery: a new recovery unit at Lumsås, started in late 2024 and due in 2026, should recover over 600 m3 of additional solvent a year. At Padova, recoverable solvents go to a third party.
• Palladium recycling: secondary reused or recycled components, including palladium, made up 26% of resource inflow (2024: 32%).
• Non-hazardous waste: reusable ampoule trays, internal reuse of wooden pallets, and no plastic covers on production clothing.

No monetary amounts are given.

Targets related to resource use and circular economy

Reference: pages 78-79.

Two 2025 targets are tracked, both part of the Sustainability Strategy (page 78):

• Recycle 63% of organic solvents used in chemical production: not achieved, at 62%. A shift in the production mix in the fourth quarter lowered recovery (page 79).
• Recycle 70% of general waste at all sites globally: achieved (page 79). Valbonne contributed most to the improvement, mainly through updated handling of construction waste (page 80).

Lundbeck says the targets help ensure that initiatives at different sites contribute consistently to reducing overall waste and raising recovery rates (page 78).

Resource inflows

Reference: pages 79, 81.

The overall weight of products, technical and biological materials was 13,552 tonnes in 2025, down 15% from 15,938 tonnes. Secondary reused or recycled components weighed 3,537 tonnes (2024: 5,160 tonnes), or 26% of inflow (32%), a fall of 31%. These components are solvents recovered at Lumsås and recycled palladium (pages 78, 81).

Lundbeck treats lactose, cellulose and similar inactive carriers as biological materials, is still assessing whether certification schemes apply to them, and reports 0% as sustainably sourced (page 79). Inflow covers all purchased goods within the GHG category 1 boundary (page 81).

Resource outflows

Reference: pages 79-81.

Recyclable content in product and packaging was 1,345 tonnes in 2025 (2024: 1,427 tonnes), a rate of 10% (2024: 9%). It covers cartons, leaflets and shipment boxes bought for secondary and tertiary packaging (page 81). Recovery of organic solvents in production held at 62% (page 79).

Lundbeck says repairability is not applicable, because pharmaceutical products are classified as hazardous waste and are incinerated at end of life. Durability depends on the active ingredient, the packaging and market requirements (page 81). Waste figures are in the Waste entry below.

Waste

Reference: pages 79-81.

Total waste generated in 2025 was 11,677 tonnes: 9,543 tonnes hazardous and 2,134 tonnes non-hazardous (2024: 9,600 tonnes total). Diverted from disposal: 2,557 tonnes (2024: 2,112). Directed to disposal: 9,120 tonnes (2024: 7,486), of which 8,387 tonnes were incinerated and 157 tonnes went to landfill. Non-recycled waste is 9,120 tonnes: 8,469 tonnes hazardous (89% of hazardous waste) and 651 tonnes non-hazardous (31%).

Page 80 attributes the rise to construction waste at Valby and Valbonne, new canteen food waste data, and a change in waste stream handling at Lumsås. The text gives increases of 51% for non-hazardous and 19% for hazardous waste. LuPi accounts for 18% of hazardous waste. Data cover the four production sites, with 2% and 3% estimated (page 81).

Policies related to own workforce

Reference: pages 63, 84, 88.

Health and safety is covered by the HSE policy, HSE management system, Code of Ethics, a Health and Safety position and a Well-being commitment, which refer to the UN Guiding Principles on Business and Human Rights (page 84). Inclusion is covered by the ID&E policy, with the Neurodiversity commitment, Well-being commitment and Reward Promise (page 88). The ELT, HSE Council and the EVP, People, Culture & Sustainability are accountable (pages 84, 88).

Lundbeck says discrimination "is not tolerated in any form". Because of its broad scope, the ID&E policy "does not individually mention specific grounds for discrimination" and has no reference to the UN Guiding Principles (page 88). Lundbeck has been a UN Global Compact signatory since 2009 (page 88) and holds the Migraine-Friendly Workplace certification (page 84).

Taking action on material impacts on own workforce

Reference: pages 85, 89.

Health and well-being (page 85): the global 'Take Care' campaign (be active, be social, be mindful) with a monthly topic, a digital platform with over 250 short videos, a revised performance management process and leadership training for all people leaders to build psychological safety. Effectiveness is tracked through the accident target and the 'Our Voice' survey.

Inclusion and retention (page 89): a Global talent management framework, mandatory training on unconscious bias and cultural awareness, the ID&E Academy, structured recruitment scorecards under the 'Reducing bias initiative' (since 2022), a pay toolbox for managers, and a pay transparency dashboard for managers in EU countries. Lundbeck is preparing for the EU Pay Transparency Directive in 2026 (page 88). No budget or resource amounts are given.

Targets related to own workforce

Reference: pages 86, 92-93.

Three 2025 targets (pages 86, 92):

• Lost time injury rate of 3 or lower: achieved, at 1.8.
• Even gender balance in upper management at H. Lundbeck A/S, closest to 40% but not above 49%: achieved, at 42% women.
• Inclusion score of 8.5 in the annual employee survey: not achieved, at 8.2 on a 10-point scale.

Health and safety targets are reviewed and approved yearly by the HSE Council (page 87). The two ID&E targets are proposed by the global ID&E office, endorsed by the ELT and approved by the Board each year (page 93). Lundbeck sets no formal well-being target and uses the inclusion score as an indicator of well-being and psychological safety (page 85).

Characteristics of the undertaking's employees

Reference: page 91.

Lundbeck had 5,268 employees at year-end 2025 (2024: 5,660): 2,912 women and 2,356 men, none reported as other or not reported. Permanent employees number 5,039 and temporary employees 229, with no non-guaranteed hours employees. By country: Denmark 2,167, United States 1,090, France 297, Poland 276, China 267 and other countries 1,171.

Turnover was 22.4% (2024: 14.4%), with 1,225 leavers (2024: 796). Excluding the shift to a partner-led commercial model, turnover was 13.1%. Lundbeck ties the higher turnover to the shift to a partner-led model in 27 countries (602 employees) and the closure in Pakistan (22 employees) (page 91). Data come from the HR system on a year-end headcount basis.

Diversity metrics

Reference: pages 92-93.

Board (11 members): two women and five men among the seven elected by the General Meeting (29% underrepresented gender), two women and two men among the four employee-elected (50%), and 36% across the Board. Upper management at H. Lundbeck A/S: 43 people, 18 women and 25 men, 42% women (2024: 45 people, 42%). Group upper management: 58 people, 24 women and 34 men, 41% (2024: 62 people, 42%). The ELT registered with the Danish Business Authority has four men, so 0% underrepresented gender (page 93).

Age distribution (page 92): under 30, 10%; 30-50, 55% (2024: 56%); over 50, 35% (2024: 34%). Upper management means the ELT plus employees at the same level and their direct reports with people management duties (page 93).

Health and safety metrics

Reference: pages 86-87.

All of the workforce (100%) is covered by the health and safety management system, certified to ISO 45001 at sites in Denmark, Italy and France and headquarters, and by legal requirements elsewhere (page 87). Results for 2025 (2024 in brackets): 0 fatalities (0); 105 work-related accidents (130); lost time injury rate 1.8 per million hours (3.2); total recordable injury rate 11.2 (13.8); 441 days lost (733); 0 ill health cases (1) (page 86).

Days lost came mainly from three traffic-related incidents and five same-level falls (page 86). The lost time injury rate beat the 2025 target of 3 (page 86). Hours worked are estimated at 225 days a year at 7.4 hours a day per employee (page 87).

Compensation metrics (pay gap and total compensation)

Reference: page 94.

The unadjusted gender pay gap was 10.5% in 2025 (2024: 8.7%). The CEO pay ratio was 39.6 times (2024: 40.7). Lundbeck also reports an adjusted gap of 0.2% (2024: 0.5%), which it defines itself.

The 2025 calculation now includes variable pay (sales incentives and short- and long-term incentives), so the 2024 figures are not restated and are hard to compare. The gap uses annual base pay because hourly pay data are limited, and covers permanent and temporary employees paid directly by Lundbeck, with two exceptions for sales staff without incentive payments and new hires outside the US and Denmark. The CEO ratio divides the CEO's total remuneration by that of the median employee. Lundbeck says it will refine its remuneration data models.

Incidents, complaints and severe human rights impacts

Reference: page 95.

15 harassment and/or discrimination cases were reported through the channels for own workforce in 2025 (2024: 14), of which three were substantiated (2024: nine). No complaints were filed with OECD National Contact Points, and fines, penalties and compensation are shown as nil. Lundbeck says the decrease does not point to a material issue and reflects "normal year-to-year variation" (page 95).

Cases cover discrimination on grounds such as gender, ethnic origin, religion, disability, age or sexual orientation, and include harassment as a form of discrimination. The datapoint on non-respect of the UN Guiding Principles and OECD Guidelines (paragraph 104(a)) is marked N/A (page 126). The report gives no separate count of severe human rights incidents.

Policies related to value chain workers

Reference: pages 96-97.

Two documents apply: the Human Rights Statement and the Code of Ethics external partner principles with the Third-party obligations, with the General Counsel accountable (page 96). The Human Rights Statement commits Lundbeck to the Universal Declaration of Human Rights, ICCPR, ICESCR, other core human rights instruments and the fundamental ILO conventions (page 96).

External partners must abide by the UN Global Compact principles and Lundbeck's Third-Party Obligations: abolish child labor, keep HSE procedures, and provide the right to rest, a minimum income, protection against coercion and discrimination, and freedom of association (page 97). The obligations do not refer to human trafficking, though Lundbeck says they support its elimination. Workers were not directly engaged when drafting them (page 97).

Taking action on material impacts on value chain workers

Reference: page 97.

Actions are part of normal operations rather than a dedicated program. HSE supplier audits cover health, safety and human rights topics, with on-site audits of all chemical suppliers in high-risk countries and global contract manufacturers. Audit results are tracked and ongoing issues followed up, and Hotline cases follow a strict investigation procedure. Lundbeck runs a procurement and third-party intermediary due diligence system to limit impact on suppliers' workforces (page 97).

Lundbeck states that "no additional actions were developed or targets established in 2025" specifically on value chain workers' health and safety or human rights (page 97). Audit counts on page 118 are not split by this topic: 14 external HSE audits (2024: 6) and 85 third-party and supplier audits (2024: 82).

Targets related to value chain workers

Reference: page 97.

Lundbeck sets no targets for value chain workers. The report states: "we have not set specific sustainability targets regarding workers in the value chain", because these processes are carried out as part of the normal work of Lundbeck's departments (page 97). It also says no additional actions or targets were established in 2025 on value chain workers' health and safety or human rights (page 97).

Effectiveness is tracked through HSE supplier audit results and Compliance Hotline cases (page 97).

Policies related to consumers and end-users

Reference: pages 98-99, 102-103, 108, 111.

Policies sit by IRO: the Focused Innovator Strategy for innovation (page 98), the Patient Centricity Strategy for patient voice (page 99), the Access to Health Strategy and Position on Pricing and Patient Access, updated in 2025 (pages 102-103), the Pharmacovigilance System Master File and Quality manual for product safety and quality (page 108), and the Code of Ethics with EFPIA and IFPMA standards for marketing (page 111).

The Access to Health Strategy aligns with SDG 3, the WHO right to health principles and guidelines on medicine donations (page 102). The Human Rights Statement underlies the commitment to patients' health as a human right (page 112). The ELT, CEO and the SVP of Corporate Communication & Public Affairs hold accountability, depending on the policy (pages 98-111).

Taking action on material impacts on consumers and end-users

Reference: pages 98-99, 100, 103-105, 109, 111.

Innovation and patient voice: patient insights built into trial design, the #1VoiceSummit, and monthly open office hours (page 100). Access (pages 103-105): a global Equity-Based Tiered Pricing framework launched in 2025, and two patient access metrics. Product donations through International Health Partners (IHP) reached 4,291 patients in low- and middle-income countries in 2025. Lundbeck committed DKK 5 million to Red Cross psychosocial support in Ukraine over 2024-2025 and paid DKK 3.5 million in 2025. It also ran a human rights impact assessment on closing operations in Pakistan (page 103).

Product safety (page 109): mandatory quality and patient safety e-learning for all employees, an annual quality management review, and pharmacovigilance KPIs. Lundbeck says it met all internal pharmacovigilance evaluation thresholds in 2025. Marketing (page 111): promotional review committees; no additional initiatives are planned.

Targets related to consumers and end-users

Reference: pages 99, 101, 106, 110, 112.

One formal S4 target is set: donate treatment for at least 3,000 patients in low- and middle-income countries through donation partnerships, achieved with 4,291 patients (page 106). Lundbeck also tracks two patient access metrics, Access Coverage at 77% (2024: 72%) and Time to Access Indicator at 61% (56%), and reports 27.8 million patients reached (page 106).

For innovation, Lundbeck says progress is assessed "even in the absence of formal sustainability targets" (page 99). For product safety it says "no formal sustainability targets are set" and relies on internal pharmacovigilance KPIs (pages 109-110). For responsible marketing it uses "no specific targets or indicators" to measure progress (page 112).

Business conduct policies and corporate culture

Reference: pages 63, 114-115.

The new Code of Ethics, which replaced the Code of Conduct in 2025, is the overarching framework. Bespoke policies sit beneath it: a guide on interactions with high-risk stakeholders, an Anti-retaliation and whistleblowing policy (which Lundbeck says adheres to the EU Whistleblowing Directive), a Competition law policy, a third-party intermediary due diligence procedure and an Animal ethics policy (pages 114-115). The Board and the Global Compliance Committee are accountable for the Code, and the CEO signs it (pages 63, 114).

All employees and relevant consultants take annual Code of Ethics e-learning, new employees are trained at onboarding, and Board members receive training when they join (pages 63, 115). The datapoint list marks the G1-1 datapoints on the UN Convention against Corruption and whistleblower protection as N/A (page 127).

Targets related to business conduct

Reference: page 118.

Back-filled from the business conduct chapter, where targets are covered by MDR-T rather than a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS, and this statement was prepared under the 2023 ESRS.

Lundbeck states that it tracks its commitment to anti-corruption and bribery through two targets, approved by the Global Compliance Committee (page 118):

• Annual Code of Ethics training completed by at least 98% of employees: achieved, at 100%.
• Four out of five employees confident in raising an ethical or compliance concern: achieved, at 92%.

Both are measured through the e-learning completion rate and the 'Our Voice' survey (pages 116, 118).

Incidents of corruption or bribery

Reference: pages 118-119.

No convictions for violation of anti-corruption or anti-bribery law were recorded in 2025 or 2024, and fines are shown as nil (page 118). The Compliance Hotline took 79 reports (2024: 85), all assessed or investigated, and Lundbeck says the decrease reflects normal variation (page 118).

Audits totaled 356 (2024: 342): 129 internal and 227 of external partners. Third-party intermediary due diligence screenings rose to 380 from 240, driven by an ad hoc vendor rescreening in one market and project-related screening (page 118). The datapoint list gives page 118 for fines and pages 114-115 for anti-corruption standards (page 127). Counts cover confirmed convictions only (page 119).