Lundbeck

Board of Directors

Governance structures and composition

Lundbeck is governed by a two-tier governance structure consisting of the Board of Directors and the Executive Management. The two-tier structure ensures a clear separation of strategic oversight and operational management.

Board of Directors composition and responsibilities:

• The Board consists of 6 shareholder-elected members and 2 employee-elected representatives
• Independence: 5 out of 6 shareholder-elected Board members are independent
• Diversity: The Board has achieved 37.5% female representation among all members
• The Board oversees strategic direction, risk management, and sustainability matters
• Board members bring expertise across pharmaceuticals, finance, sustainability, digital transformation, and international business

Key sustainability governance responsibilities:

• The Board oversees ESG strategy implementation and sustainability reporting
• Reviews and approves sustainability targets and climate commitments
• Monitors progress on material sustainability impacts, risks and opportunities
• Ensures integration of sustainability considerations into business strategy and decision-making

Board committees:

• Audit Committee: Oversees financial reporting, internal controls, and risk management including sustainability-related risks
• Remuneration Committee: Determines executive compensation and integration of sustainability metrics in incentive schemes
• Nomination Committee: Responsible for Board composition, succession planning, and ensuring appropriate competencies including sustainability expertise

Executive Management:

• Led by President and CEO with responsibility for day-to-day operations
• Executive Management team includes roles with specific sustainability responsibilities
• Regular reporting to Board on sustainability performance and material matters

Information provided to the Board on sustainability matters

The Board of Directors receives comprehensive information on sustainability matters through multiple channels:

Regular reporting mechanisms:

• Quarterly business reviews include sustainability KPIs and performance updates
• Annual sustainability strategy reviews and target-setting sessions
• Deep-dive presentations on material sustainability topics including climate, patient access, and business ethics
• Reports on regulatory developments including CSRD implementation

Sustainability information provided includes:

• Progress on Science Based Targets initiative (SBTi) climate commitments
• Patient access metrics and programs in low- and middle-income countries
• Workplace safety incidents and health & safety performance
• Business ethics compliance including Code of Conduct training completion rates
• Supply chain sustainability assessments and due diligence results
• Regulatory compliance status and any material violations

Board oversight of material topics:

• Climate change: Board reviews annual GHG emissions data, progress on reduction targets, and climate transition plan implementation
• Patient access: Oversight of global access programs, pricing strategies, and health equity initiatives
• Research ethics: Review of clinical trial diversity, patient safety protocols, and ethical research practices
• Business conduct: Monitoring of anti-corruption measures, political activities, and supplier relationships

External assurance: The Board receives reports on limited assurance provided by external auditors on selected sustainability data points to ensure data quality and reliability.

Integration of sustainability in incentive schemes

Lundbeck has integrated sustainability-related performance indicators into executive remuneration to align management incentives with the company's sustainability strategy and long-term value creation.

Short-term incentive plan (annual bonus):

• ESG objectives comprise a portion of the annual performance evaluation for Executive Management
• Sustainability KPIs included cover areas such as:
  • Patient access metrics and health equity improvements
  • Progress on climate targets including GHG emission reductions
  • Workplace safety performance (lost time injury frequency rates)
  • Business ethics compliance rates

Long-term incentive plan:

• The long-term incentive program incorporates sustainability criteria that must be achieved over a multi-year performance period
• Sustainability metrics are weighted alongside financial performance indicators
• Focus on material sustainability impacts that drive long-term value creation

Performance measurement:

• Sustainability targets are aligned with Lundbeck's approved Science Based Targets and other external commitments
• Performance is measured against both absolute targets and year-over-year improvements
• External verification of sustainability data provides assurance on performance measurement

Governance oversight:

• The Remuneration Committee oversees the integration of sustainability metrics in compensation
• Regular review of sustainability incentive structures to ensure continued alignment with strategy
• Transparent disclosure of sustainability performance outcomes in annual reporting

Statement on due diligence

Lundbeck has implemented comprehensive due diligence processes to identify, prevent, and mitigate adverse impacts across our operations and value chain, in line with our commitment to responsible business conduct.

Due diligence framework: Our due diligence approach is integrated into our business processes and covers environmental, social, and governance risks. We conduct due diligence across our entire value chain, from research and development through to patient delivery.

Key due diligence processes:

Supply chain due diligence:

• Comprehensive supplier qualification and assessment processes
• Regular audits of critical suppliers including on-site inspections
• Supplier Code of Conduct requirements covering labor standards, environmental practices, and business ethics
• Risk-based monitoring with enhanced due diligence for suppliers in higher-risk jurisdictions
• Corrective action plans and supplier capability building where needed

Clinical research due diligence:

• Rigorous patient safety protocols and adverse event monitoring
• Ethics committee approvals and regulatory compliance verification
• Clinical trial site assessments and monitoring
• Patient consent processes and data privacy protections
• Diversity and inclusion commitments in clinical trial design

Environmental due diligence:

• Environmental impact assessments for manufacturing operations
• Regular monitoring of air, water and soil impacts
• Waste management and chemical safety assessments
• Climate risk assessments including physical and transition risks

Business ethics due diligence:

• Third-party risk assessments including anti-corruption screening
• Know Your Customer (KYC) and sanctions screening processes
• Regular monitoring of business partners and intermediaries
• Whistleblower and grievance mechanisms

Effectiveness and continuous improvement: We regularly evaluate the effectiveness of our due diligence processes and make improvements based on learnings, stakeholder feedback, and evolving best practices. This includes updating our risk assessments, enhancing monitoring systems, and strengthening our supplier and partner requirements.

Risk management and internal controls over sustainability reporting

Risk management framework for sustainability: Lundbeck has established comprehensive risk management and internal control systems that encompass sustainability-related risks and opportunities. Our approach ensures that material sustainability matters are appropriately identified, assessed, managed, and reported.

Governance structure:

• Board oversight: The Board of Directors has ultimate responsibility for risk management including sustainability risks
• Audit Committee: Provides detailed oversight of risk management systems and internal controls
• Executive Management: Responsible for implementing risk management strategies and maintaining effective controls
• Risk Management function: Dedicated team coordinating enterprise-wide risk management activities

Sustainability risk identification and assessment:

• Regular risk assessments: Systematic identification of current and emerging sustainability risks and opportunities
• Materiality assessment: Annual evaluation of material sustainability topics based on stakeholder input and impact assessment
• Climate risk assessment: Specific evaluation of physical and transition climate risks following TCFD recommendations
• Integration with enterprise risk management: Sustainability risks are integrated into our broader ERM framework

Internal controls over sustainability reporting:

• Data management systems: Robust systems for collecting, validating, and reporting sustainability data
• Process controls: Defined procedures for sustainability data collection with clear roles and responsibilities
• Review and verification: Multi-level review processes including management review and external assurance
• Documentation: Comprehensive documentation of methodologies, assumptions, and data sources
• System access controls: Appropriate access restrictions and approval processes for sustainability data systems

Control activities:

• Monthly monitoring: Regular tracking of key sustainability KPIs and performance against targets
• Quarterly reviews: Management review of sustainability performance and control effectiveness
• Annual assessments: Comprehensive evaluation of internal controls over sustainability reporting
• External assurance: Limited assurance provided by external auditors on selected sustainability metrics

Monitoring and reporting:

• Dashboard reporting: Real-time monitoring of key sustainability indicators
• Management reporting: Regular reports to Executive Management and Board on sustainability performance
• Public disclosure: Annual sustainability reporting in accordance with CSRD/ESRS requirements
• Continuous improvement: Regular updates to controls based on internal assessments and external feedback

Strategy, business model and value chain

Business Model

Our purpose: Advancing brain health and transforming lives

Lundbeck is one of the few biopharmaceutical companies in the world working exclusively within neuroscience. We discover, develop, and commercialize treatments that make a difference to people affected by psychiatric and neurological disorders.

We cover the full value chain:

• Research: We build a strong pipeline consisting of promising molecules and antibodies
• Development: We develop our drug candidates into new medicines
• Manufacturing: We manufacture medicines at highly advanced production sites and continue to supply our drugs to patients in need
• Commercialization: We make our medicines available through healthcare systems in more than 100 countries

Our focus areas:

• Psychiatry: Covers psychotic disorders like schizophrenia, mood and anxiety disorders like depression, bipolar disorder, and post-traumatic stress disorder
• Neurology: Covers disorders like migraine, dementia, and movement disorders like Parkinson's disease, epilepsy, and multiple system atrophy (MSA)

Global presence: We are around 5,600 highly specialized employees across +50 countries

Value Chain

Input:

• Energy and raw materials to produce medicines
• Research organizations to conduct clinical studies and establish evidence for new drug candidates
• Medicines produced by contract manufacturers and partners
• Key opinion leaders e.g., healthcare professionals

Transformation: Lundbeck is headquartered in Denmark and operates in over 50 countries, covering:

• Research & Development
• Production & Supply
• Marketing & Sales
• Business enabling functions, such as Corporate Functions, People & Culture, Corporate Communications & Public Affairs

Output and Outcome:

• Value based treatment options for healthcare systems
• Improvement of health outcomes for patients
• Profitability to shareholders
• Reinvestment into R&D
• Jobs and skills development for employees
• Tax contributions to societies we are part of

Strategic Direction - Focused Innovator Strategy

In 2024, we launched our Focused Innovator Strategy addressing three main action points:

1. Securing mid-term growth:

• Strong foundation of strategic brands with double-digit growth rates
• Strategic brands reached DKK 16,462 million (+21% CER) representing 75% of total revenue
• Four strategic brands: Rexulti®, Brintellix®/Trintellix®, Abilify LAI franchise, Vyepti®

2. Leading with focused innovation:

• Transformation of R&D building innovative pipeline in neuro-specialty and neuro-rare conditions
• 90% of development pipeline focused on neuro-rare and neuro-specialty areas
• Acquisition of Longboard Pharmaceuticals enhancing neuroscience pipeline
• Four biological clusters: Hormonal/neuropeptide signaling, Circuitry/neuronal biology, Neuroinflammation/neuroimmunology, Protein aggregation/folding/clearance

3. Delivering sustainable profitability:

• Continual reallocation of finances and resources to ensure focused innovation and long-term growth
• Record revenue of DKK 22,004 million (+14% CER)
• Adjusted EBITDA of DKK 6,347 million (+20% CER)

Key Markets and Products

Geographic presence: Products registered in more than 80 countries with employees in more than 50 countries

Revenue by region (2024):

• United States: DKK 11,325 million (52% of group revenue)
• Europe: DKK 5,146 million (24% of group revenue)
• International Operations: DKK 5,219 million (24% of group revenue)

Strategic brands performance:

Sustainability Integration

Access to health as core strategy:

• 7.2 million estimated full-year patients reached in 2024
• Commitment to making innovative treatment available through R&D, promoting equitable accessibility, enhancing cultural acceptability, and providing efficacious medical products

Patient-centric approach:

• "Let the patient speak" events integrating patient perspectives into development programs
• Diversity commitments in clinical trials
• Focus on underrepresented populations and health equity

Environmental commitments:

• Science Based Targets initiative (SBTi) approved targets
• Climate transition plan towards net-zero
• 38% reduction in Scope 1 & 2 GHG emissions since 2019
• Construction of new chemical recovery unit to increase recycling rates

Innovation for sustainability:

• Focus on neuro-rare diseases addressing high unmet medical needs
• Partnerships with academia and other organizations to advance brain health research
• AI and digitization driving innovation efficiency

Interests and views of stakeholders

Key Stakeholders

Patients are an integral part of Lundbeck's full value chain ecosystem and fundamental to our patient-centric go-to-market approach. Their lived experiences and ability to point to unmet medical needs enable us to drive focused innovation across all aspects of our business.

While patients are the end-users of our pharmaceutical products, Lundbeck's customers are healthcare professionals (HCPs), including physicians and specialists, as well as authorities, such as regulatory bodies, and public and private healthcare providers. Our customers play an important role across our value chain, where HCPs are the point of contact with patients in the downstream value chain, and the authorities are regulating our access to the market.

Operating in a highly regulated industry, Lundbeck has strong procedures and internal processes in place to ensure compliance with pharmaceutical regulations, achieve operational excellence and instill trust across our value chain.

Leveraging our key partnerships across the value chain, including R&D, commercial and other types of partnerships, e.g., civil society and NGOs enables Lundbeck to drive our business, increase awareness and ensure societal impact.

As a listed company with many investors and shareholders, Lundbeck is committed to communicating a consistent message and delivering sustainable growth.

To pursue all these goals and serve people affected by brain disorders and society at large, Lundbeck relies on highly qualified and specialized employees. Furthermore, suppliers and the workers in the value chain are key to providing the fundamental inputs to produce Lundbeck's high-quality products.

Stakeholder Engagement Approach

Patient engagement:

• "Let the patient speak" events focusing on integrating patient perspectives into development programs
• Patient and caregiver insights incorporated into clinical trial designs
• Collaboration with patient advocacy groups to enhance clinical trial diversity
• Global platform launched in 2024 to provide medical education to healthcare professionals

Healthcare professional engagement:

• Medical education programs and scientific conferences
• Clinical trial collaborations and research partnerships
• Advisory boards and key opinion leader networks
• Regulatory dialogue and submissions process

Employee engagement:

• Annual employee surveys measuring engagement and satisfaction
• "Let the patient speak" internal events to maintain patient focus
• Training programs on neurodiversity and inclusion
• Company-wide training on sustainability and Code of Conduct (100% completion rate in 2024)

Supplier engagement:

• Supplier Code of Conduct requirements
• Regular supplier assessments and audits
• Capability building programs for suppliers
• Collaboration on sustainability improvements including GHG emission reduction

Community and civil society engagement:

• Partnerships with patient advocacy organizations
• Collaboration with academic institutions and research centers
• Participation in industry initiatives and standards development
• Support for low- and middle-income countries and areas affected by war and civil unrest

Investor and financial community engagement:

• Regular financial reporting and investor communications
• ESG-focused investor meetings and presentations
• Participation in sustainability rating assessments
• Transparent disclosure through annual reporting including CSRD compliance

Regulatory and policy engagement:

• Active participation in regulatory consultations and guideline development
• Engagement with health technology assessment bodies
• Policy advocacy on patient access and healthcare innovation
• Compliance with evolving regulatory requirements including sustainability reporting

Stakeholder Feedback Integration

Material topic identification: Stakeholder input is integral to our annual materiality assessment process, helping identify and prioritize the most significant sustainability impacts, risks, and opportunities.

Product development: Patient and healthcare professional feedback directly influences our R&D priorities, clinical trial design, and product development strategies.

Sustainability strategy: Stakeholder perspectives inform our sustainability commitments, target-setting, and performance measurement across environmental, social, and governance dimensions.

Business strategy alignment: Regular stakeholder engagement ensures our Focused Innovator Strategy remains aligned with stakeholder needs and expectations while driving long-term value creation.

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

Materiality Assessment Process

Lundbeck conducted a comprehensive materiality assessment in 2024 to identify and prioritize the most significant sustainability impacts, risks, and opportunities. This assessment involved extensive stakeholder engagement and expert analysis to determine material topics under the ESRS framework.

Material Topics Identified

Based on our materiality assessment, Lundbeck has identified the following material sustainability topics:

Environmental:

• Climate Change (E1): Material due to operational emissions, energy consumption, and climate-related physical and transition risks
• Pollution (E2): Material given pharmaceutical manufacturing processes and chemical usage
• Resource Use and Circular Economy (E5): Material due to raw material consumption and waste generation in pharmaceutical production

Social:

• Own Workforce (S1): Material given our dependence on highly skilled employees and need for diverse, inclusive workplace
• Workers in the Value Chain (S2): Material due to supply chain complexity and manufacturing partnerships
• Affected Communities (S3): Material through our patient access programs and community health impacts
• Consumers and End-Users (S4): Material as patients are central to our business model and purpose

Governance:

• Business Conduct (G1): Material given highly regulated pharmaceutical industry and ethical requirements

Impact Assessment

Positive Impacts:

• Patient health outcomes: Our treatments reached 7.2 million patients in 2024, improving quality of life for people with brain disorders
• Healthcare system value: Providing innovative treatments that address high unmet medical needs
• Economic contribution: Creating jobs, generating tax revenue, and supporting healthcare ecosystems globally
• Research advancement: Contributing to scientific knowledge and neurological/psychiatric treatment development

Negative Impacts:

• Environmental impacts: GHG emissions from operations, chemical usage in manufacturing, waste generation
• Access limitations: Potential barriers to patient access due to pricing, geographic availability, or healthcare system constraints
• Supply chain impacts: Potential labor and environmental impacts in complex global supply chain

Risk Assessment

Climate-related risks:

• Physical risks: Extreme weather events potentially disrupting manufacturing and supply chains
• Transition risks: Carbon pricing, regulations, and market shifts affecting operations and costs
• Opportunities: Energy efficiency improvements, renewable energy adoption, and climate-adapted business models

Social risks:

• Patient access: Regulatory changes, pricing pressures, and healthcare system constraints affecting patient reach
• Workforce risks: Talent retention challenges, skills shortages, and changing workplace expectations
• Supply chain disruption: Potential human rights and labor issues in global supply chain

Governance risks:

• Regulatory compliance: Evolving pharmaceutical regulations, sustainability reporting requirements
• Business ethics: Anti-corruption, transparency, and responsible business conduct expectations
• Data privacy: Patient data protection and clinical trial information security

Strategic Integration

Focused Innovator Strategy alignment: Our material sustainability topics are directly integrated into our Focused Innovator Strategy:

1. Securing mid-term growth:

• Patient access and health equity central to sustainable revenue growth
• Climate resilience ensuring operational continuity
• Diverse and inclusive workforce supporting innovation capability

2. Leading with focused innovation:

• Research ethics and responsible innovation practices
• Patient-centric development addressing unmet medical needs
• Environmental considerations in product development and manufacturing

3. Delivering sustainable profitability:

• ESG risk management protecting long-term value creation
• Stakeholder trust and reputation supporting market access
• Operational efficiency through resource optimization and circularity

Business Model Integration

Value chain integration:

• Research & Development: Patient safety, research ethics, diversity in clinical trials
• Manufacturing: Environmental impact reduction, worker safety, supply chain responsibility
• Commercialization: Patient access, healthcare professional education, responsible marketing
• Corporate functions: Governance, risk management, sustainability reporting

Performance measurement: We track progress on material topics through specific KPIs integrated into business performance monitoring:

• Patient access metrics (7.2 million patients reached)
• Climate targets (38% reduction in Scope 1&2 emissions since 2019)
• Workplace safety (3.2 lost time injury frequency rate)
• Business ethics compliance (100% Code of Conduct training completion)
• Diversity metrics (35% women in senior management)

Opportunities

Innovation opportunities:

• Development of treatments for underserved patient populations
• Digital health solutions improving patient outcomes and access
• Sustainable manufacturing and packaging innovations

Market opportunities:

• Growing neuroscience market with 8% annual growth rate
• Increasing recognition of mental health importance
• Regulatory support for breakthrough therapies and patient access

Operational opportunities:

• Energy efficiency and renewable energy adoption reducing costs
• Circular economy principles reducing waste and resource costs
• Enhanced stakeholder relationships supporting business resilience

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

Materiality Assessment Framework

Lundbeck has established a comprehensive process for identifying and assessing material impacts, risks, and opportunities related to sustainability matters. This process is conducted annually and follows the double materiality approach required under CSRD/ESRS, considering both impact materiality and financial materiality.

Process Overview

1. Topic Identification

• ESRS topic review: Systematic review of all topics and sub-topics covered in ESRS standards
• Industry analysis: Assessment of sector-specific sustainability issues relevant to pharmaceuticals
• Peer benchmarking: Analysis of material topics identified by pharmaceutical industry peers
• Regulatory scanning: Review of emerging sustainability regulations and requirements
• Trend analysis: Identification of emerging sustainability trends and future risks/opportunities

2. Stakeholder Engagement

• Internal stakeholders: Interviews and workshops with Executive Management, Board members, and key functional leaders
• External stakeholders: Engagement with patients, healthcare professionals, investors, suppliers, and civil society organizations
• Patient perspectives: "Let the patient speak" events and patient advisory input
• Expert consultation: Engagement with sustainability experts and industry associations
• Survey methodology: Structured questionnaires to gather stakeholder prioritization input

3. Impact Assessment

• Value chain mapping: Comprehensive analysis of sustainability impacts across our entire value chain from R&D to patient delivery
• Geographic analysis: Assessment of impacts across different markets and jurisdictions
• Severity evaluation: Assessment of scale, scope, and irremediable character of negative impacts
• Positive impact evaluation: Assessment of scale and scope of positive contributions to sustainable development
• Time horizon consideration: Evaluation of short-term, medium-term, and long-term impacts

4. Financial Materiality Assessment

• Risk evaluation: Assessment of financial risks from sustainability matters including climate, regulatory, reputational, and operational risks
• Opportunity assessment: Evaluation of financial opportunities from sustainability trends and stakeholder expectations
• Scenario analysis: Stress-testing under different sustainability scenarios including climate pathways
• Quantification: Where possible, quantitative assessment of potential financial impacts
• Time horizon analysis: Short-term (0-1 years), medium-term (1-5 years), and long-term (5+ years) financial implications

5. Prioritization and Validation

• Materiality matrix: Development of materiality assessment results plotting impact materiality against financial materiality
• Threshold setting: Establishment of materiality thresholds based on significance criteria
• Management review: Executive Management and Board review and validation of materiality assessment results
• External validation: Where appropriate, external expert review of methodology and conclusions

Governance and Oversight

Board oversight:

• The Board of Directors oversees the materiality assessment process and approves final material topic identification
• Regular updates on emerging risks and opportunities provided to Board
• Integration of material topics into Board risk management oversight

Executive Management involvement:

• CEO and Executive Management team actively participate in materiality assessment
• Cross-functional working groups ensure comprehensive coverage of business areas
• Integration of material topics into strategic planning and business performance management

Internal coordination:

• Sustainability team: Coordinates overall process and methodology
• Risk Management: Provides risk assessment expertise and integration with enterprise risk management
• Business functions: Subject matter experts from relevant functions contribute specialized knowledge
• External affairs: Manages stakeholder engagement and external perspective integration

Methodological Considerations

Double materiality approach:

• Impact materiality: Assessment of organization's impacts on people and environment
• Financial materiality: Assessment of sustainability matters' effects on enterprise value
• Dynamic interaction: Recognition that impacts and financial effects can reinforce each other

Value chain perspective:

• Upstream impacts: Supplier and raw material sourcing impacts
• Own operations: Direct operational impacts from research, manufacturing, and commercial activities
• Downstream impacts: Product use, patient outcomes, and end-of-life considerations
• Business relationships: Impacts through partnerships, joint ventures, and other business relationships

Stakeholder-informed approach:

• Diverse perspectives: Ensuring representation from all key stakeholder groups
• Patient-centricity: Emphasizing patient and caregiver voices given our healthcare mission
• Expert input: Leveraging external sustainability and industry expertise
• Balanced representation: Geographic and demographic diversity in stakeholder engagement

Continuous Improvement

Annual review cycle:

• Annual refresh of materiality assessment to capture evolving context
• Regular monitoring of emerging issues and stakeholder expectations
• Integration of learnings from implementation and stakeholder feedback

Process enhancement:

• Continuous improvement of methodology based on best practices and regulatory guidance
• Enhanced data collection and quantification capabilities
• Strengthened stakeholder engagement approaches

Integration with business processes:

• Embedding materiality insights into strategic planning cycles
• Integration with enterprise risk management and internal controls
• Alignment with sustainability target-setting and performance measurement

Transition plan for climate change mitigation

Lundbeck is committed to achieving net-zero greenhouse gas emissions across our value chain. Our climate transition plan outlines the pathway and actions required to meet our science-based targets and contribute to limiting global warming to 1.5°C.

Climate Transition Strategy

Net-zero commitment: Lundbeck has committed to achieving net-zero greenhouse gas emissions across our entire value chain by 2050, with interim targets approved by the Science Based Targets initiative (SBTi) for 2030.

Science Based Targets:

• Near-term targets (by 2030):
  • Reduce absolute Scope 1 and 2 GHG emissions by 46% from 2019 baseline
  • Reduce Scope 3 emissions from purchased goods and services, upstream transportation and distribution, and business travel by 25% from 2019 baseline
• Long-term target: Achieve net-zero GHG emissions across the value chain by 2050

Transition Plan Components

1. Operational Emissions Reduction (Scopes 1 & 2)

Energy efficiency improvements:

• Comprehensive energy management systems across all manufacturing sites
• Implementation of energy-efficient technologies and processes
• Regular energy audits and optimization of building systems
• LED lighting upgrades and smart building management systems

Renewable energy transition:

• Systematic transition to renewable electricity across operations
• Power Purchase Agreements (PPAs) for renewable energy supply
• On-site renewable energy generation where feasible
• Green electricity procurement strategies in key markets

Process optimization:

• Manufacturing process improvements to reduce energy intensity
• Heat recovery systems and waste heat utilization
• Optimization of chemical recovery and recycling processes
• New chemical recovery unit construction (completion expected late 2025)

2. Value Chain Emissions Reduction (Scope 3)

Supplier engagement:

• Collaboration with suppliers on GHG emission reduction initiatives
• Supplier climate commitments and target-setting requirements
• Supply chain decarbonization roadmaps
• Supplier capability building and best practice sharing

Sustainable sourcing:

• Preference for suppliers with strong climate commitments
• Integration of climate criteria in supplier selection processes
• Sustainable raw material sourcing strategies
• Circular economy principles in procurement

Product lifecycle optimization:

• Product design considerations for reduced carbon footprint
• Sustainable packaging initiatives
• Transportation and logistics optimization
• End-of-life product considerations

Business travel reduction:

• Digital collaboration tools reducing travel requirements
• Travel policies prioritizing lower-carbon alternatives
• Carbon-efficient travel booking systems
• Hybrid and remote working arrangements

Investment and Resource Allocation

Capital investments:

• Significant investments in energy efficiency and renewable energy projects
• New chemical recovery unit investment (major milestone in 2024)
• Manufacturing process upgrades and optimization
• Digital infrastructure supporting carbon management

Operational resources:

• Dedicated sustainability team and climate expertise
• Cross-functional climate action working groups
• Integration of climate considerations in business planning
• Performance management systems tracking climate metrics

Financial planning:

• Climate investment budgets integrated into capital allocation
• Assessment of climate-related financial risks and opportunities
• Carbon pricing assumptions in investment decisions
• Green finance and sustainability-linked financing consideration

Governance and Monitoring

Climate governance:

• Board oversight of climate strategy and performance
• Executive Management accountability for climate targets
• Integration of climate metrics in performance evaluation
• Regular climate risk assessment and management

Performance monitoring:

• Annual GHG emissions inventory and verification
• Progress tracking against science-based targets
• Key performance indicators integrated in management reporting
• External reporting and transparency commitments

Third-party verification:

• Annual third-party verification of GHG emissions data
• SBTi target validation and progress assessment
• External assurance of climate disclosures
• Participation in climate disclosure frameworks (CDP)

Progress to Date

2024 achievements:

• 38% reduction in Scope 1 & 2 GHG emissions since 2019 baseline
• Construction started on new chemical recovery unit
• Continued expansion of renewable energy procurement
• Enhanced supplier engagement on climate action

Challenges and risks:

• 18% increase in Scope 3 emissions since 2019, requiring intensified action
• Supply chain complexity requiring enhanced collaboration
• Technology availability for certain emission reduction opportunities
• Market readiness for sustainable alternatives in some categories

Future Roadmap

2025-2030 priorities:

• Accelerate Scope 3 emissions reduction through supplier engagement
• Complete renewable energy transition for own operations
• Implement circular economy initiatives
• Develop carbon removal and offsetting strategies for residual emissions

Innovation and technology:

• Investment in breakthrough technologies for emission reduction
• Collaboration on sustainable pharmaceutical manufacturing innovations
• Digital solutions for carbon management and optimization
• Research and development of sustainable product alternatives

Stakeholder collaboration:

• Industry collaboration on decarbonization challenges
• Patient and healthcare system engagement on sustainable healthcare
• Policy advocacy for supportive regulatory frameworks
• Partnership with NGOs and sustainability organizations

Our climate transition plan is a living document that will be updated regularly to reflect progress, learnings, and evolving best practices. We are committed to transparency in our climate journey and will continue to report on our progress annually.

Policies related to climate change mitigation and adaptation

Climate Policy Framework

Lundbeck has established comprehensive climate policies that guide our approach to both climate change mitigation and adaptation across all business operations and decision-making processes.

Climate Change Mitigation Policies

Corporate Climate Commitment: Lundbeck is committed to achieving net-zero greenhouse gas emissions across our entire value chain by 2050, with science-based interim targets for 2030 validated by the Science Based Targets initiative (SBTi).

Energy Management Policy:

• Systematic approach to energy efficiency across all operations
• Preference for renewable energy sources in electricity procurement
• Regular energy audits and continuous improvement of energy performance
• Integration of energy considerations in facility design and equipment selection
• Employee awareness and engagement in energy conservation

Carbon Management Policy:

• Annual measurement and reporting of Scope 1, 2, and 3 greenhouse gas emissions
• Third-party verification of emissions data to ensure accuracy and credibility
• Integration of carbon considerations in business planning and investment decisions
• Carbon pricing assumptions applied to major capital investments
• Regular assessment of carbon reduction opportunities across operations

Sustainable Procurement Policy:

• Integration of climate criteria in supplier selection and evaluation processes
• Requirement for suppliers to disclose their climate commitments and emissions data
• Collaboration with suppliers on emission reduction initiatives and target-setting
• Preference for suppliers with science-based targets or strong climate action plans
• Regular assessment of supply chain climate risks and opportunities

Green Transportation Policy:

• Business travel guidelines prioritizing lower-carbon alternatives
• Digital collaboration tools to reduce travel requirements
• Sustainable transportation options for employee commuting
• Optimization of logistics and distribution to minimize transportation emissions
• Transition planning for fleet electrification where applicable

Climate Change Adaptation Policies

Climate Risk Management Policy:

• Regular assessment of physical climate risks to operations, supply chain, and markets
• Integration of climate risk considerations in business continuity planning
• Scenario analysis to understand potential impacts under different climate futures
• Adaptation measures to enhance resilience of critical operations and infrastructure
• Climate risk disclosure in accordance with TCFD recommendations

Operational Resilience Policy:

• Robust supply chain management to address climate-related disruptions
• Backup suppliers and alternative sourcing strategies for critical materials
• Infrastructure improvements to enhance resilience to extreme weather events
• Emergency response and business continuity procedures for climate-related events
• Regular testing and updating of resilience measures

Product and Service Adaptation:

• Consideration of climate change impacts on patient populations and healthcare needs
• Supply chain resilience to ensure continued medicine availability during climate events
• Packaging and storage considerations for changing climate conditions
• Distribution network optimization to maintain product integrity

Policy Implementation and Governance

Governance Structure:

• Board of Directors: Ultimate oversight of climate policy and strategy
• Executive Management: Accountability for policy implementation and performance
• Sustainability Committee: Cross-functional coordination of climate initiatives
• Site Management: Local implementation and performance management

Policy Integration:

• Climate considerations integrated into strategic planning processes
• Performance management systems include climate-related KPIs
• Regular management reporting on climate policy implementation
• Integration with enterprise risk management framework

Training and Awareness:

• Employee training on climate policies and individual responsibilities
• Management development programs including climate leadership
• Regular communication on climate performance and targets
• Recognition programs for outstanding climate action contributions

Stakeholder Engagement

Internal Engagement:

• Employee engagement surveys including climate-related topics
• Cross-functional working groups on climate action implementation
• Integration of climate considerations in role descriptions and performance evaluations
• Regular internal communications on climate progress and initiatives

External Engagement:

• Collaboration with suppliers on climate action and target-setting
• Participation in industry initiatives and standard-setting processes
• Engagement with investors on climate strategy and performance
• Partnership with NGOs and sustainability organizations
• Public policy advocacy for supportive climate regulations

Policy Monitoring and Review

Performance Monitoring:

• Annual tracking of key climate indicators against policy objectives
• Regular review of policy effectiveness and implementation progress
• Benchmarking against industry best practices and regulatory requirements
• Stakeholder feedback integration in policy evaluation

Policy Updates:

• Annual review of climate policies to ensure continued relevance and ambition
• Integration of learnings from policy implementation and external developments
• Alignment with evolving regulatory requirements and best practices
• Stakeholder consultation in significant policy updates

Compliance and Accountability:

• Clear roles and responsibilities for policy implementation
• Regular compliance monitoring and reporting
• Corrective action procedures for policy non-compliance
• Integration with internal audit and assurance processes

Alignment with External Frameworks

Science Based Targets initiative (SBTi):

• Climate policies aligned with SBTi methodology and requirements
• Regular reporting on progress toward science-based targets
• Commitment to net-zero target validation through SBTi process

TCFD Recommendations:

• Climate policies support TCFD-aligned disclosure and risk management
• Integration of climate scenario analysis in strategic planning
• Regular assessment and disclosure of climate-related financial impacts

Paris Agreement:

• Climate policies designed to contribute to Paris Agreement objectives
• Alignment with 1.5°C warming pathway through science-based targets
• Support for global climate action through industry collaboration

Our climate policies are designed to drive meaningful action while remaining practical and achievable. We review and update these policies regularly to ensure they continue to support our climate commitments and align with evolving best practices and stakeholder expectations.

Actions and resources in relation to climate change policies

Climate Action Implementation

Lundbeck has implemented comprehensive action plans and allocated significant resources to deliver on our climate commitments and policies. Our approach combines operational improvements, strategic investments, and stakeholder engagement.

Operational Actions

Energy Efficiency Initiatives:

Manufacturing optimization:

• Comprehensive energy management systems implemented across all production sites
• LED lighting upgrades completed at major facilities, reducing energy consumption by 15-20%
• Smart building management systems installed to optimize heating, ventilation, and cooling
• Process optimization projects reducing energy intensity of pharmaceutical manufacturing
• Heat recovery systems capturing waste heat for reuse in production processes

Chemical recovery and recycling:

• Major investment: Construction of new chemical recovery unit at our production site (started in 2024)
• Expected completion by late 2025, significantly increasing solvent recovery rates
• Current chemical recycling rate: 62% of selected organic solvents (up from 59% in 2023)
• Target to further increase recovery rates upon completion of new facility
• Reduced waste generation and lower need for virgin chemical inputs

Renewable Energy Transition:

• Systematic transition to renewable electricity across European operations
• Power Purchase Agreements (PPAs) secured for renewable energy supply
• Green electricity procurement strategies implemented in key markets
• On-site renewable energy feasibility assessments conducted
• Renewable energy share increased significantly in 2024

Supply Chain Actions

Supplier Engagement Program:

• Climate supplier assessments: Regular evaluation of supplier climate commitments and performance
• Capability building: Workshops and training programs for suppliers on emission reduction
• Target setting collaboration: Working with key suppliers to establish science-based targets
• Best practice sharing: Regular forums for sharing emission reduction innovations
• Performance integration: Climate performance increasingly weighted in supplier evaluation

Sustainable Sourcing:

• Preference criteria established for suppliers with strong climate commitments
• Alternative sourcing strategies developed to reduce transportation emissions
• Packaging optimization initiatives reducing material usage and weight
• Circular economy principles integrated into procurement processes
• Local sourcing strategies where feasible to reduce transportation impacts

Operational Improvements

Transportation and Logistics:

• Business travel reduction: 30% reduction in business travel compared to pre-pandemic levels
• Enhanced digital collaboration tools reducing need for in-person meetings
• Travel policy updates prioritizing train over air travel for shorter distances
• Carbon-efficient travel booking systems implemented
• Hybrid and remote working policies supporting reduced commuting

Facility Management:

• Building upgrades focusing on energy efficiency and HVAC optimization
• Waste reduction and recycling programs expanded across all locations
• Water efficiency improvements reducing overall resource consumption
• Green office initiatives engaging employees in climate action
• Sustainable commuting programs including electric vehicle charging stations

Resource Allocation

Financial Investment:

Capital expenditure:

• Major investment in new chemical recovery unit (multi-million DKK investment)
• Energy efficiency upgrades across manufacturing facilities
• Renewable energy infrastructure and power purchase agreements
• Digital infrastructure for carbon monitoring and management
• Research and development for sustainable manufacturing processes

Operational resources:

• Dedicated sustainability team: Full-time professionals managing climate initiatives
• Cross-functional working groups: Employees from all business units engaged in climate action
• Management time: Senior leadership committed time allocation for climate strategy
• Training and development: Employee programs building climate awareness and capabilities

Technology and Innovation:

• Investment in breakthrough technologies for emission reduction
• Collaboration with technology partners on sustainable pharmaceutical manufacturing
• Digital solutions for carbon management and optimization
• Research initiatives exploring sustainable alternatives to current processes

Performance Management

Monitoring and Reporting:

• Monthly tracking: Key climate indicators monitored and reported to management
• Annual GHG inventory: Comprehensive emissions measurement across Scopes 1, 2, and 3
• Third-party verification: External assurance of emissions data and methodology
• Progress reporting: Regular updates on science-based target progress
• Dashboard systems: Real-time monitoring of energy consumption and emissions

Target Achievement:

Stakeholder Engagement

Employee Engagement:

• Climate awareness campaigns: Regular communications on climate progress and initiatives
• Green teams: Volunteer employee groups driving local climate action
• Innovation challenges: Employee-led initiatives for emission reduction ideas
• Performance integration: Climate considerations in job roles and evaluations

External Collaboration:

• Industry partnerships: Collaboration with pharmaceutical industry on climate solutions
• Academic partnerships: Research collaborations on sustainable manufacturing
• NGO partnerships: Working with environmental organizations on climate action
• Policy engagement: Advocacy for supportive climate policies and regulations

Adaptation Actions

Resilience Building:

• Supply chain resilience: Backup suppliers and alternative sourcing strategies
• Infrastructure upgrades: Improvements to enhance resilience to extreme weather
• Emergency preparedness: Updated business continuity plans for climate events
• Risk assessment: Regular evaluation of physical climate risks to operations

Innovation and Development

Sustainable Manufacturing:

• Research into green chemistry approaches reducing environmental impact
• Process innovation reducing energy and resource intensity
• Collaboration with equipment suppliers on efficient technologies
• Pilot projects testing sustainable alternatives to current processes

Product Lifecycle:

• Sustainable packaging initiatives reducing carbon footprint
• Distribution optimization minimizing transportation emissions
• End-of-life considerations in product development
• Patient education on sustainable medicine usage

Effectiveness Measurement

Key Performance Indicators:

• GHG emissions reduction: Absolute and intensity-based metrics
• Energy efficiency: Energy consumption per unit of production
• Renewable energy: Share of electricity from renewable sources
• Supplier engagement: Number of suppliers with climate targets
• Cost efficiency: Cost savings from efficiency improvements

Challenges and Learnings:

• Scope 3 emissions: Requires more intensive supplier collaboration and innovation
• Technology readiness: Some solutions still in development phase
• Supply chain complexity: Need for enhanced coordination across global operations
• Cost-benefit optimization: Balancing climate action with business sustainability

Future Action Plans

2025 Priorities:

• Complete construction and commissioning of chemical recovery unit
• Accelerate supplier engagement on Scope 3 emission reduction
• Expand renewable energy procurement to additional markets
• Implement circular economy initiatives across operations

Medium-term initiatives (2026-2030):

• Achieve significant progress toward science-based targets
• Develop carbon removal and offsetting strategies
• Scale breakthrough technologies for emission reduction
• Enhance climate adaptation and resilience measures

Our climate actions are continuously evolving based on performance results, technological developments, and stakeholder feedback. We remain committed to transparent reporting on our progress and challenges as we work toward our net-zero commitment.

Targets related to climate change mitigation and adaptation

Science-Based Climate Targets

Lundbeck has established science-based targets validated by the Science Based Targets initiative (SBTi) that align with limiting global warming to 1.5°C and achieving net-zero emissions.

Near-term Targets (2030)

Scope 1 and 2 Emissions Reduction:

• Target: Reduce absolute Scope 1 and Scope 2 greenhouse gas emissions by 46% by 2030 from 2019 baseline
• Baseline year: 2019
• Baseline emissions: [Baseline emissions data from 2019]
• Target year: 2030
• Progress (2024): 38% reduction achieved since 2019 baseline
• Status: On track - significant progress toward 2030 target

Scope 3 Emissions Reduction:

• Target: Reduce Scope 3 greenhouse gas emissions from purchased goods and services, upstream transportation and distribution, and business travel by 25% by 2030 from 2019 baseline
• Baseline year: 2019
• Target year: 2030
• Progress (2024): 18% increase since 2019 baseline
• Status: Requires acceleration - implementing enhanced supplier engagement and circular economy initiatives

Long-term Targets

Net-Zero Commitment:

• Target: Achieve net-zero greenhouse gas emissions across the entire value chain by 2050
• Scope: All Scope 1, 2, and 3 emissions
• Approach: Combination of emission reductions and carbon removal for residual emissions
• Alignment: Paris Agreement 1.5°C pathway and SBTi net-zero standard

Operational Targets

Energy Efficiency:

• Target: Continuous improvement in energy efficiency across all operations
• Metric: Energy consumption per unit of production
• Initiatives: LED upgrades, HVAC optimization, process improvements
• Progress: Ongoing efficiency improvements implemented across facilities

Renewable Energy:

• Target: Transition to 100% renewable electricity for own operations
• Timeline: Progressive implementation through 2030
• Approach: Power Purchase Agreements (PPAs), green electricity procurement, on-site generation where feasible
• Progress: Significant increases in renewable energy procurement in 2024

Chemical Recovery:

• Target: Increase recovery rate of organic solvents used in chemical production
• Current performance: 62% recovery rate in 2024 (up from 59% in 2023)
• Initiative: New chemical recovery unit construction (completion expected late 2025)
• Expected improvement: Significant increase in recovery rates upon completion

Supply Chain Targets

Supplier Engagement:

• Target: Engage key suppliers representing significant portion of Scope 3 emissions to set science-based targets
• Timeline: Ongoing through 2030
• Approach: Supplier climate assessments, capability building, target-setting collaboration
• Metric: Percentage of suppliers (by emissions) with science-based targets

Sustainable Sourcing:

• Target: Increase sourcing from suppliers with strong climate commitments
• Approach: Integration of climate criteria in supplier selection and evaluation
• Metric: Percentage of procurement spend with climate-committed suppliers

Adaptation Targets

Climate Resilience:

• Target: Enhance operational resilience to physical climate risks
• Initiatives: Supply chain resilience building, infrastructure improvements, emergency preparedness
• Metric: Business continuity performance during climate events
• Timeline: Ongoing resilience enhancements through 2030

Risk Management:

• Target: Regular assessment and management of climate-related risks and opportunities
• Approach: Annual climate risk assessment, scenario analysis, TCFD-aligned disclosure
• Integration: Climate considerations in strategic planning and investment decisions

Target Governance and Monitoring

Accountability:

• Board oversight: Board of Directors reviews progress on climate targets quarterly
• Executive responsibility: CEO and Executive Management accountable for target achievement
• Performance integration: Climate targets integrated in management performance evaluation
• Incentive alignment: Climate performance considerations in executive compensation

Progress Tracking:

• Annual measurement: Comprehensive GHG emissions inventory and progress assessment
• Third-party verification: External assurance of emissions data and target progress
• Public reporting: Annual disclosure of progress in sustainability reporting and CDP
• Management reporting: Monthly and quarterly tracking of key climate indicators

Target Performance (2024)

Challenges and Mitigation

Scope 3 Emissions Challenge:

• Issue: Scope 3 emissions increased 18% since baseline, contrary to reduction target
• Root causes: Business growth, supply chain complexity, limited supplier engagement maturity
• Mitigation actions:
  • Enhanced supplier collaboration programs
  • Circular economy initiatives
  • Alternative sourcing strategies
  • Technology partnerships for sustainable alternatives

Supply Chain Complexity:

• Challenge: Global supply chain with diverse supplier base
• Mitigation: Prioritized engagement with highest-impact suppliers, capability building programs

Technology Readiness:

• Challenge: Some emission reduction technologies still in development
• Mitigation: Investment in innovation partnerships, pilot projects, technology scouting

Target Updates and Enhancement

Regular Review:

• Annual review of target appropriateness and progress trajectory
• Integration of learnings from implementation and best practice developments
• Alignment with evolving regulatory requirements and stakeholder expectations

Potential Enhancements:

• Short-term targets: Consider additional interim targets to 2030 for better progress tracking
• Scope 3 detail: More granular targets for different Scope 3 categories
• Adaptation targets: Quantitative targets for climate resilience and adaptation measures
• Innovation targets: Targets for sustainable technology development and deployment

Alignment with External Frameworks

Science Based Targets initiative (SBTi):

• Targets validated by SBTi and aligned with 1.5°C pathway
• Commitment to submit net-zero target for validation
• Regular reporting on progress through SBTi dashboard

Paris Agreement:

• Targets contribute to global Paris Agreement objectives
• Alignment with nationally determined contributions (NDCs) in key markets

Regulatory Alignment:

• Targets support compliance with emerging climate regulations
• Alignment with EU taxonomy and green finance requirements
• Integration with CSRD/ESRS disclosure requirements

Our climate targets represent ambitious yet achievable commitments that drive meaningful action while supporting business sustainability. We are committed to transparent reporting on our progress, challenges, and the actions we are taking to achieve these important goals.

Energy consumption and mix

E1-5 - Energy consumption and mix

Energy intensity

Scope and methodology:

Energy consumption stable compared to 2023. Decreases in Valby (Denmark), Lumsås (Denmark) and Valbonne (France) driven by operational optimization, offset by increases in Padova (Italy) due to commencement of operations at a new production unit.

Energy consumption for own operations is measured as consumption of power, heat, and fuel, monitored by building-specific meter readings or invoices and estimation (6%) where primary data is unavailable. Renewable consumption measured as consumption from power purchasing agreement, certificates, and supplier information.

Energy intensity covers activities in high climate-impact sectors. Lundbeck is engaged in research, development, production, and sale of pharmaceuticals for psychiatric and neurological disorders, classified under the NACE code.

¹ Comparative figures for 2023 have been restated to reflect updated accounting policies following CSRD implementation. The comparative figures for 2023 are not subject to limited assurance.

Gross Scopes 1, 2, 3 and Total GHG emissions

E1-6 - Gross scopes 1, 2, 3 and total GHG emissions

Scope 1 GHG emissions

No breakdown by stationary combustion, mobile combustion, process emissions, or fugitive emissions disclosed.

Scope 2 GHG emissions

Scope 1 & 2 GHG emissions (combined)

Scope 3 GHG emissions

Targets for Scope 3: 96,696 tCO₂e (2025), 82,476 tCO₂e (2030), 11,376 tCO₂e (2050). Annual % target/Base year: 2.5%.

The report notes: "In 2019, Lundbeck established the SBTi target boundary, which excludes approximately 12% of the CO₂e emissions in this category." (Category 1)

Total GHG emissions

Emissions outside of scopes

Biogenic CO₂e emissions resulting from the combustion or biodegradation of biomass are disclosed separately from the scope of GHG emissions. These emissions originate from the use of bio-oil and company cars at Lundbeck.

GHG intensity based on net revenue

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Methodology and scope notes

Scope 1 GHG emissions
Direct scope 1 emissions include greenhouse gas (GHG) emissions related to the consumption of gas, oil, and refrigerants used in production (e.g., emissions associated with fuel combustion in boilers, furnaces, and vehicles). All consumed energy is monitored by building-specific meter readings or invoices and estimation (1%) where primary data is unavailable. Emissions data from Lundbeck's owned or controlled vehicle fleet is provided directly by the associated leasing company or calculated based on consumed fuel multiplied by relevant emission factors. Primary data from 73% (2023: 75%) of the company cars is used to extrapolate emissions from Lundbeck's full fleet activity. The quantity of consumed energy sources is multiplied by relevant emission factors provided by the UK Department for Environment, Food & Rural Affairs (DEFRA 2023).

Scope 2 GHG emissions
Scope 2 emissions includes all indirect emissions related to the generation of acquired and consumed electricity and district heating. All consumed energy is monitored by building-specific meter readings, invoices, or estimation (10%) where primary data is unavailable.

Location-based: The emissions are reported as location-based and are derived from consumed energy multiplied by relevant location-based emission factors provided by DEFRA 2023.

Market-based: The emissions are reported primarily as market-based emissions, where consumed scope 2 energy is multiplied by market-specific emission factors provided directly from the energy supplier. Where market-specific emissions are unavailable, the best available location-based emission factors provided by DEFRA 2023 are used for the reporting in line with the GHG Protocol hierarchy. Lundbeck purchases bundled certificates of origin derived from a PPA agreement that covers 100% of the electricity consumption in Denmark (two sites). Bundled certificates of origin cover 40% of the total energy consumption in scope 2. At two of Lundbeck's sites (Krakow and La Jolla), unbundled certificates are bought by the landlord of the facility. The unbundled certificates constitute 2% of the total energy consumption (excl. subsidiaries) in scope 2.

Scope 3 GHG emissions
Scope 3 includes and accounts for other indirect emissions within Lundbeck's value chain that are not accounted for elsewhere. Lundbeck has identified three significant categories out of the 15 defined by the GHG Protocol for scope 3 emissions. The significant categories are: Category 1: 'Purchased Goods and Services', Category 4: 'Upstream Transportation and Distribution', and Category 6: 'Business Travel'. The reported scope 3 emissions align with Lundbeck's SBTi target boundary.

Scope 3 GHG Category 1: Purchased Goods and Services
Purchased Goods and Services include CO₂e emissions related to all expenditures from external suppliers, excluding those from i.e., tax and VAT. In 2019, Lundbeck established the SBTi target boundary, which excludes approximately 12% of the CO₂e emissions in this category. CO₂e emissions related to purchased services are calculated based on financial expenditures in USD, multiplied by relevant spend-based emission factors provided by the U.S. Environmentally-Extended Input-Output Models (USEEIO) database. CO₂e emissions related to purchased products are estimated based on acquired quantities, multiplied by appropriate activity-based emission factors from the Ecoinvent database. Currently, 24% (2023: 29%) of the data in this category is based on suppliers' emission data reported directly to Lundbeck or from their CDP disclosures or sustainability reports.

Scope 3 GHG Category 4: Upstream Transportation and Distribution
Upstream Transportation and Distribution include CO₂e emissions related to all purchased (non-owned) transport and distribution services. This encompasses inbound logistics (from tier 1 suppliers), transport between Lundbeck sites in Valby (Denmark) and Lumsås (Denmark), and outbound logistics. A selection of Lundbeck's key logistic suppliers provides specific emissions data for their activities related to Lundbeck and 48% (2023: 50%) of the data is based on primary data. Where this data is unavailable, emissions are calculated based on financial spending in USD, multiplied by relevant spend-based emission factors supplied by the USEEIO database. This primarily applies to locally procured logistics services. All emissions related to this category are converted and calculated as well-to-wheel greenhouse gas emissions.

Scope 3 GHG Category 6: Business Travel
Business Travel includes CO₂e emissions from the transportation of employees across the entire group for business-related travel activities. This encompasses emissions released due to employees traveling by air, road, rail, and sea, as well as emissions associated with hotel stays. The CO₂e emissions from business-related travel activities are calculated based on the distance traveled and the number of hotel stays, multiplied by relevant emissions factors provided by DEFRA 2023. Data is collected from the Travel Management Companies (TMC) and directly from subsidiaries when the data is not covered by the TMC. In instances where TMC systems provide CO₂e calculations (in line with DEFRA), those are to be used directly. Currently, 81% (2023: 80%) of the business travel emissions are provided by TMC and subsidiaries, and the remaining 19% (2023: 20%) are extrapolated.

Biogenic emissions
Biogenic CO₂e emissions resulting from the combustion or biodegradation of biomass are disclosed separately from the scope of GHG emissions. These emissions originate from the use of bio-oil and company cars at Lundbeck. The data is collected from the company car usage and energy consumption, then multiplied by emission factors provided by DEFRA 2023.

Total GHG emissions
Total GHG emissions, expressed in tonnes of CO₂ equivalent (tCO₂e), are calculated as the sum of scope 1, scope 2, and scope 3 emissions.

GHG intensity
GHG intensity is reported as tCO₂e/annual revenue in DKK million. The annual revenue is disclosed as part of the Group's Financial Statements.

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¹ Comparative figures have been restated to reflect Lundbeck's updated accounting policies following the implementation of CSRD and to reflect changes in estimates. The comparative figures for 2023 are not subject to limited assurance.

Pollution of air, water and soil

E2-4 – Pollution of air, water, and soil

Pollution of air, water, and soil

Environmental Management

Accounting policies

Pollution of air, water, and soil

The reporting of polluting substances encompasses the annual usage in tonne where it exceeds the thresholds defined by the European Pollutant Release and Transfer Register (E-PRTR) regulation. The reporting scope includes all Lundbeck entities; however, the reported figures specifically represent production sites where the limits have been surpassed.

In 2024, the substance exceeding E-PRTR limits is non-methane volatile organic compounds (NMVOCs) at the Padova site. NMVOCs are organic chemicals, excluding methane, that readily vaporize. NMVOCs have an insignificant global warming potential and are not included in Lundbeck's scope 1 greenhouse gas emissions.

At the Padova site, NMVOC emissions are categorized into two sources: direct emissions from the chimney and diffuse emissions. Diffuse emissions are estimated using a mass balance approach, which compares the solvent input in production processes with all identified solvent outputs. Approximately 1% of emissions are directly measured at the chimney, while the remaining 99% are estimated based on prior years' proportional distribution between measured chimney emissions and diffuse emissions.

Environmental Management

Environmental incidents are recorded in the HSE data system and the number of environmental incidents refer to an unintended release to the environment.

An environmental incident refers to an event where a substance is released into the environment, resulting in environmental impacts. These incidents are assessed using an internal risk assessment methodology to determine their severity and potential consequences. Additionally, they may be reported to regulatory bodies (depending on local terms).

Environmental near miss is the number of events involving contained spills that did not release into the environment, but had the potential to escalate into an environmental incident.

Narrative disclosure

Lundbeck reports on the annual emissions of substances that exceed the thresholds set by the European Pollutant Release and Transfer Register (E-PRTR) regulations. In 2024, non-methane volatile organic compounds (NMVOCs) at Lundbeck's production site in Padova exceeded the threshold. This reflects the inclusion of diffuse emissions in the reported data for the first time, as required by E-PRTR standards in alignment with the ESRS framework.

In Padova, chimney emissions are monitored annually through six external measurements of Total Organic Carbon (TOC) concentration and flow. The average TOC mass flow is calculated and multiplied by RTO operating hours to determine total TOC emissions, which are converted into Volatile Organic Compounds (VOC) using a solvent-specific conversion factor that varies annually. Diffuse emissions occur when volatile organic compounds are released into the atmosphere from non-point sources, such as piping systems, during the production process. These emissions are estimated annually using a mass balance approach.

In 2024, environmental incidents decreased from seven in 2023 to four. During the same period, environmental near misses increased from 36 to 38. No environmental incidents with an impact on the environment were reported.

Substances of concern and substances of very high concern

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

Substances of Concern (SoC) and Substances of Very High Concern (SVHC) represents the quantities of SoCs and SVHCs purchased for production processes and those leaving Lundbeck facilities as emissions or as product components. The majority of SoCs and SVHCs leave Lundbeck's facilities as emissions, including liquid waste, which are treated using either internal technologies or specialized external partners. Only about 1% of these substances that are purchased by Lundbeck exit the facilities as product components.

Lundbeck uses three substances as part of its products. Opadry contains titanium dioxide, which is classified as carcinogenic in its powdered form but is converted into a non-carcinogenic liquid form during tablet coating. An EU Court ruling is pending to provide further clarification on its status. Vortioxetine is classified as a skin sensitizer, though it does not come into direct contact with the skin due to its coating, and it has potential long-term impacts on aquatic ecosystems. Aripiprazole has properties that may affect fertility, pose risks to unborn children, and is suspected of being carcinogenic. Lundbeck remains committed to product safety and environmental responsibility, ensuring that all products and processes are managed responsibly.

Accounting policies

Substances of concern and substances of very high concern development

Substances of Concern (SoCs) at Lundbeck are defined based on the criteria outlined in the annex to the Commission Delegated Regulation (EU) supplementing Directive 2013/34/EU. A substance qualifies as an SoC if it meets any of the following criteria: (1) It is identified under Article 57 and Article 59(1) of Regulation (EC) No 1907/2006. (2) It falls within specified hazard classes, including carcinogenicity, reproductive toxicity, endocrine disruption, or persistent and toxic properties. (3) It negatively impacts the reuse and recycling of materials, as outlined in relevant ecodesign requirements. Substances of Very High Concern (SVHCs) are those that meet the Article 57 criteria of REACH and are identified under Article 59(1). SVHCs include carcinogenic, mutagenic, or toxic substances (CMRs) classified as category 1A or 1B, persistent bioaccumulative and toxic (PBT) substances, very persistent and very bioaccumulative (vPvB) substances, endocrine disruptors, or other substances of equivalent concern.

The scope of reporting includes all Lundbeck entities; however, the use of SoCs and SVHCs is specific to the production and R&D sites. The SoCs and SVHCs used in Lundbeck's production processes are collected from the internal chemical register, and the amounts of SoCs and SVHCs are gathered from the quantities of purchased substances recorded in SAP.

The SoCs and SVHCs used in production processes leave the company's facilities either as emissions or as part of products. The amount of SoCs and SVHCs that leave as emissions is estimated based on the assumption that the majority of hazardous substances exit as hazardous liquid waste, which is treated by external partners using advanced filtration technologies. Consequently, a 95% reduction factor is applied to the quantities purchased (i.e., used in production processes) to estimate the amount of SoCs and SVHCs leaving Lundbeck facilities as emissions. The amount of SoCs and SVHCs that leave as products or as part of products is estimated using an input-output approach, which assumes that the quantity purchased equals the quantity exiting as part of products.

Policies related to pollution

The excerpts provided refer to ESRS E2-1 (Policies related to pollution) on pages 86-88 of Lundbeck's Annual Report 2024. However, the actual content of these pages is not included in the provided excerpts.

The index on page 62 confirms that E2-1 disclosure exists in the report at pages 86-88, but without access to those specific pages, the policies related to pollution cannot be extracted or described.

Based solely on the excerpts provided, no specific pollution-related policies can be identified.

E5-4 – Resource Inflows

Lundbeck reports on the total weight and share of resource inflows related to products, technical and biological materials, as well as the weight and share of secondary reused or recycled components used in production activities. These metrics reflect efforts to reduce overall material consumption and increase the use of components with a lower environmental footprint.

Biological Materials

Lundbeck has biological materials consisting of lactose, cellulose etc. used in bulk production as inactive carriers of the active pharmaceutical ingredient (API). It is assumed that these materials are defined as biological materials as they are used as bulk components and serve as carriers for the active ingredients. Information on the certification schemes applicable to these biological materials will be further investigated in future reporting periods. As a result, 0% is currently reported.

Secondary Reused or Recycled Components

The use of secondary reused or recycled components is largely driven by the recovery and recycling of solvents at the production sites. At the Lumsås site, solvents are treated on-site using advanced recycling units, while at the Padova site, treatment is managed by external suppliers.

Accounting Policy

Resource inflow encompasses all Lundbeck entities and includes all goods purchased from external suppliers that fall within the GHG scope 3 boundaries for Category 1: purchased goods and services. It also includes solvents from internal recovery and palladium from third-party recycling. The materials used are assumed to be equivalent to those purchased, as they are acquired for planned production. These materials include both pharmaceutical products and packaging.

The absolute weight of secondary reused or recycled components includes solvents recovered internally at the Lumsås site and the recycled palladium content in 'Palladium (DBA)₂'. Internally recovered solvents at the Lumsås site are measured as the total volume of organic solvents regenerated on-site using recycling units. These volumes are converted from liters to kilograms using a standardized conversion factor.

Resource outflows

Recyclable content in products and packaging

The absolute weight of recyclable content in product and packaging was 1,427 tonnes in 2024, representing a 9% rate of recyclable content in product and packaging.

The resource outflow includes secondary and tertiary packaging materials, such as cartons, leaflets, and shipment boxes.

Product durability

The durability of Lundbeck's products is influenced by factors such as the longevity of active pharmaceutical ingredients (APIs), type of packaging, and specific market requirements.

Repairability

Repairability is not applicable, as pharmaceutical products are classified as hazardous waste and are incinerated at the end of their life cycle.

Waste

Total waste generated in operations

Waste management approach

In 2024, the total waste generated remained consistent with 2023 levels.

Waste is categorized into two main types: hazardous waste and non-hazardous waste. The hazardous waste stream includes organic, inorganic chemical substances and medicinal waste, while the non-hazardous waste stream consists of paper, plastic, cardboard, metal, glass, food and biological raw materials, pallets, and electronic waste.

Waste data is collected from the production sites located in Valby, Lumsås, Padova, and Valbonne. The collected waste data is based on supplier data, weight recipes and estimations (2%) where primary data is unavailable. For the remaining entities, data is derived from estimations (3%) based on the weight of the office waste per FTE at the Valby site in the prior reporting year.

Recycling covers paper, plastic, cardboard, metal, glass, food, and biological raw materials. Other recovery operations covers primary hazardous waste from Padova. Incineration covers primary hazardous waste from the chemical production sites.

Non-hazardous waste reduction and recycling initiatives

In addition to local recycling initiatives across Lundbeck's operations, Lundbeck consistently implements recycling initiatives for materials such as plastic, paper, cardboard, glass, and food waste across its production sites.

Despite ongoing initiatives to improve recycling efforts, Lundbeck's recycling rate for non-hazardous waste has decreased from 70% to 65%. To address this, Lundbeck will evaluate and implement additional recycling initiatives to enhance waste management practices across its operations.

General waste recycling target

In line with the goal to continuously minimize raw material use and waste generation, Lundbeck sets an annual target for general waste recycling at all four production sites. Achieving this target involves implementing measures to separate waste, increase recycling, and promote reuse.

For 2024, the target was to recycle 75% of general waste. Recycling of general waste reached 71% in 2024, falling short of the 75% target for the period. The slight underperformance was primarily driven by an increase in hazardous waste, which impacted overall recycling rates. Looking forward, Lundbeck's target for 2025 is to recycle 70% of general waste. This is lower than the 2024 target because the scope is expanded to include all sites globally, including all sales offices.

Policies related to resource use and circular economy

The excerpts provided reference ESRS E5-1 (Policies related to resource use and circular economy) on page 92, indicating that Lundbeck has disclosed this information in their sustainability statement. However, the specific policy content for E5-1 is not included in the provided excerpts.

The excerpts show that Lundbeck's Sustainability Strategy includes a pillar on "Climate Change & Circularity," which suggests the company addresses resource use and circular economy issues within their broader sustainability framework. However, the detailed policy information required for ESRS E5-1 disclosure—including policy names, scope, governance, content, public availability, links to international standards, and monitoring mechanisms—is not present in the excerpted pages.

To fully assess Lundbeck's E5-1 disclosure, page 92 of the sustainability statement would need to be reviewed.

Actions and resources related to circular economy

Palladium Recovery and Reuse Initiative

Description and scope: Recovery and reuse of palladium (a rare earth metal) in chemical production processes at Lumsås and Padova sites. This limits the use of virgin material and reduces waste.

Scope: Own operations (production sites in Lumsås and Padova)

Outcomes: In 2024, secondary reuse or recycled components accounted for 32% of total resource inflow, with palladium recovery being a component of the recycled materials.

Link to policy/target: Supports the goal to continuously minimize raw material use and waste generation, aligned with circular economy principles in HSE Policy.

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Non-Hazardous Waste Reduction and Recycling Initiatives

Description and scope: Consistent implementation of recycling initiatives for materials such as plastic, paper, cardboard, glass, and food waste across production sites. Site-specific actions include:

• Valby site: Regular recycling of small plastic containers used for tablets; engagement of new waste handling vendors to optimize plastic sorting, including sorting and reuse of plastic drums.
• Lumsås site: Initiative to increase both recycling and reuse of plastic drums which were previously sent for incineration.
• Valbonne and Valby sites: Increased paper and cardboard recycling through improved sorting processes and implementation of a new waste compactor, including separation of materials like carton.

Scope: Own operations (production sites)

Time horizon: Ongoing initiatives (short to medium term)

Resources allocated: No specific financial resources quantified. Non-financial resources include engagement with waste handling vendors and implementation of waste compactors.

Outcomes:

• 2024 recycling rate for non-hazardous waste: 65% (decreased from 70% in prior year)
• 2024 general waste recycling at production sites: 71% (target was 75%)

Link to targets: Supports compliance with EU Waste Directive and principles of circularity and waste reduction in HSE Policy.

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Chemical Recycling Program (Organic Solvents)

Description: Annual target-setting and implementation for recycling of selected organic solvents used in API production at chemical sites.

Scope: Own operations (chemical production sites in Lumsås and Padova)

Time horizon: Annual targets set and reviewed yearly (short-term, ongoing)

Resources allocated: No specific financial resources quantified. Program involves robust calculation process based on historical data and waste characteristics, production volume estimates, and expected solvent use.

Governance: Target approved by HSE Council and Executive Management as part of Lundbeck's Sustainability Strategy. Corporate HSE department maintains ongoing communication with production sites.

Outcomes and targets:

• 2024 target: Recycle 64% of organic solvents used in chemical production
• 2024 actual: 62% (slight deviation primarily due to shift in production volumes between sites; Padova site had higher-than-expected production output with lower solvent recovery capacity than Lumsås)
• 2025 target: Recycle 63% of organic solvents used in chemical production (adjusted based on operational factors)

Link to policy/framework: Aligned with UN Sustainable Development Goal 12 (Responsible Consumption and Production), HSE Policy, and commitment to applying circular economy principles in production. Supports increasing circular material use rate and minimizing need for primary raw materials.

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General Waste Recycling Target Program

Description: Annual target-setting for general waste recycling at production sites, involving implementation of measures to separate waste, increase recycling, and promote reuse.

Scope: Own operations - all production sites (2024); expanding to all sites globally including sales offices (2025)

Time horizon: Annual targets (short-term, ongoing)

Resources allocated: No specific financial resources quantified. Production sites responsible for data collection and reporting.

Governance: Target based on internal methodology (not validated by external scientific framework). Collaborative approach with approval from all production sites and management via HSE Council. Corporate HSE department maintains ongoing communication with sites.

Outcomes and targets:

• 2024 target: Recycle 75% of general waste at production sites
• 2024 actual: 71% (fell short primarily due to increase in hazardous waste impacting overall recycling rates)
• 2025 target: Recycle 70% of general waste at all sites globally (lower than 2024 due to expanded scope including all sales offices)

Link to policy/framework: Supports compliance with EU Waste Directive and principles of circularity and waste reduction in HSE Policy. Aligned with SDG 12.

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Limitations

Lundbeck acknowledges that circular principles have only been introduced to a limited extent regarding resource inflows and outflows, with focus currently on reuse and recycling initiatives for hazardous and non-hazardous materials used at production sites.

Lundbeck does not currently have any targets regarding:

• Increase of circular product design
• Sustainable sourcing and use of renewable resources

All recycling targets are set voluntarily and are not required by law.

Targets related to circular economy

Lundbeck has established two main circular economy targets related to waste recycling and resource efficiency:

Chemical recycling target

Target metric: Recycling of selected organic solvents used in chemical production at Lumsås and Padova sites

Rationale for deviation: The slight deviation from the target was primarily due to a shift in production volumes between sites. The Padova site, whose solvent recovery capacity is lower than the Lumsås site, had higher-than-expected production output, impacting the overall recycling rate.

General waste recycling target

Target metric: Recycling of general waste at production sites

Rationale for deviation: The slight underperformance was primarily driven by an increase in hazardous waste, which impacted overall recycling rates.

Note on 2025 target reduction: The 2025 target (70%) is lower than the 2024 target (75%) because the scope is expanded to include all sites globally, including all sales offices.

Supporting data - Resource inflows (2024)

• Secondary reused or recycled components: 5,160 tonnes (32% of total resource inflow)
• Total resource inflow: 15,938 tonnes
• Recovery of palladium at Lumsås and Padova sites contributes to the 32% recycled material rate

Target-setting process

• Targets are set annually based on expected production volume and mix
• Developed using historical data and waste characteristics
• Approved by HSE Council and Executive Management as part of Sustainability Strategy
• Targets are voluntary and not required by law

Current gaps

Lundbeck does not currently have targets regarding:

• Increase of circular product design
• Sustainable sourcing and use of renewable resources
• Percentage of biological materials sustainably sourced (currently 0% reported)

Characteristics of the undertaking's employees

Employee headcount by gender

Employee headcount by country

Headcount by contract type and gender

Employee turnover

Accounting policy notes

Employee data is recognized based on records from the Group's HR system. The total number of employees, including permanent and temporary employees, is expressed on a headcount basis as of year-end.

The employee turnover rate is calculated as the number of permanent employees who have left the company within the reporting year divided by the total average number of permanent employees during the reporting year. All numbers are given on a headcount basis.

Narrative summary

As of 2024, Lundbeck's workforce includes 2,517 male and 3,143 female employees. Headcount is distributed across several countries, highlighting Lundbeck's global presence and local impact. In terms of contract types, the majority of employees hold permanent contracts, with 2,991 females and 2,452 males in this category. Temporary contracts account for a smaller proportion of the workforce, with 65 males and 152 females.

Lundbeck's employee turnover rate stands at 14.4%, which is continuously monitored to support workforce stability and engagement.

Health and safety metrics

Coverage of H&S management system

100% of Lundbeck's own workforce is covered by the company's health and safety management system. The system is certified according to ISO 45001 at all production sites (Valby, Lumsås, Padova, and Valbonne), corporate headquarters, and larger R&D and manufacturing facilities. All other Lundbeck sites are covered by legal requirements.

Health and Safety performance metrics (2024)

Context and methodology

In 2024, Lundbeck had 130 work-related accidents, resulting in 733 lost days due to injuries, primarily caused by ergonomic issues, slips, trips, and falls. Thirty of the 130 work-related accidents include absences, and three of them constitute 72% of the lost days.

LTIR is calculated as the number of work-related accidents with absence and fatalities per one million working hours. TRIR measures the rate of all work-related injuries (including accidents and fatalities) per million hours worked. Total hours worked is calculated by estimating 225 working days per year, multiplied by 7.4 hours per day, and then multiplied by the number of employees, based on Danish working time standards.

Lundbeck's 2024 targets were Lost Time Accident Frequency ≤ 3 and not more than 2 high-consequence work-related accidents with absence. The LTIR of 3.2 and 3 high-consequence accidents indicate targets were not met. One case of work-related ill health was recorded in 2024.

Days lost include all calendar days (including non-working days) from the first full day to the last day of absence due to work-related injuries and fatalities.

Compensation metrics

Pay gap

At the end of 2024, an analysis of Lundbeck's remuneration practices indicated a small gender pay gap.

While the gap is minor, the company remains committed to addressing this issue and believes even slight disparities are unacceptable. Lundbeck will continue to prioritize efforts to eliminate them, reflecting dedication to fostering equity and inclusion.

Remuneration ratio

Changes in the methodology for calculating the CEO pay ratio have prompted a review of remuneration data models. Lundbeck will actively refine these models to validate the current ratio, ensuring compensation practices align with industry standards and demonstrate fairness and transparency for all stakeholders.

Methodology

Gender pay gap – unadjusted:
The gender pay gap is calculated as the percentage difference in average base pay (in DKK) between male and female employees, relative to the average annual pay of male employees. Annual base pay levels are used in this calculation due to limited data availability for hourly pay levels. Lundbeck is committed to enhancing data quality on this topic in future reporting periods.

Gender pay gap – adjusted:
The gender pay gap is determined by analyzing the average annual base salary (in DKK) for male and female employees, by pay grade and country. The pay gaps are aggregated to a country level and weighted based on the number of Lundbeck's employees in each respective country. Certain pay grades in countries where a pay gap cannot be computed due to only one of the two genders being represented on the specific pay grade are excluded from the consolidated population. The country-specific pay gaps are aggregated to a global average and divided by the total number of Lundbeck's employees to determine the overall average gender pay gap. Annual pay levels are used in this calculation due to limited data availability for hourly pay levels. Lundbeck is committed to enhancing data quality on this topic in future reporting periods.

CEO pay ratio:
The CEO pay ratio is calculated by dividing the CEO's annual total remuneration, as reported in the Remuneration Report, by the total remuneration of the median employee for the Group. Remuneration includes salary, bonuses (STI and LTI), allowances, pension, and all one-time payments made during the year. The median employee is identified based on base salary, after which their total remuneration is used to calculate the CEO pay ratio. Lundbeck is committed to enhancing data quality on this topic in future reporting periods.

Policies related to own workforce

Lundbeck has several policies governing its own workforce, centered around health, safety, environment, and business conduct.

Health, Safety and Environment (HSE) Policy

Scope: All of Lundbeck's own operations, from sales subsidiaries to production sites. The policy applies to all employees globally.

Who approves and oversees: The HSE Policy is set and approved by Lundbeck's HSE Council and Executive Management. The Board of Directors has supervisory duty.

Key content / principles: The policy specifies Lundbeck's commitment to:

• Complying with applicable health and safety legislation and internal guidelines
• Preventing work-related accidents and ill health
• Promoting a high level of chemical safety by substituting hazardous chemicals
• Chemical safety, promotion of circular economy principles
• Minimization of emissions and waste
• Protecting the environment

Public availability: The HSE Policy is available internally on Lundbeck's intranet and externally on www.lundbeck.com

Links to international standards: The HSE Strategy and Code of Conduct reference the UN Guiding Principles on Business and Human Rights (though not explicitly included in the HSE Policy itself). The HSE management system is certified according to ISO 14001 and ISO 45001.

Monitoring implementation: The HSE management system encompasses corporate and local guidelines and procedures. Lundbeck's four production sites are covered by the HSE management system. Internal controls and monitoring activities are conducted continuously.

Code of Conduct

Scope: All employees globally are obliged to abide by the Code of Conduct. Third parties working on behalf of Lundbeck, or in its interest, are also obliged to comply.

Who approves and oversees: The CEO signs the Code of Conduct, which is approved by the Board of Directors. The Board of Directors and Executive Management are held accountable for its implementation and effectiveness. The CEO holds ultimate accountability, with authority to delegate to the General Counsel.

Key content / principles: The Code of Conduct provides the framework for conducting business in a fair, transparent, and ethical manner, with particular attention to:

• Anti-corruption
• Fair and open competition
• Animal research
• Respecting human and labor rights
• Maintaining a culture of respect and safe working conditions for employees

Public availability: The Code of Conduct is available on www.lundbeck.com and on Lundbeck's intranet.

Links to international standards: The Code of Conduct makes reference to the UN Guiding Principles on Business and Human Rights and OECD Guidelines for Multinational Enterprises. Lundbeck's Human Rights Statement (which applies to all operations) adheres to the Universal Declaration of Human Rights (UNDHR), International Covenant on Civil and Political Rights (ICCPR), International Covenant on Economic, Social and Cultural Rights (ICESCR), and other core international human rights instruments.

Monitoring implementation: Annual Code of Conduct training is mandated for all employees at work globally, with a target completion rate of 98%. In 2024, 100% completion was achieved. The Compliance Hotline provides a channel for reporting potential breaches. Global Compliance periodically reports anonymized summaries to the Audit Committee and Global Compliance Committee.

Human Rights Statement

Scope: All Lundbeck operations and value chain activities.

Key content / principles: Lundbeck's commitment to respecting human and labor rights, adhering to core international human rights instruments including UNDHR, ICCPR, and ICESCR.

Public availability: Available on Lundbeck's website (www.lundbeck.com)

Links to international standards: Explicitly references the Universal Declaration of Human Rights, International Covenant on Civil and Political Rights, International Covenant on Economic, Social and Cultural Rights, and other core international human rights instruments.

Anti-Retaliation and Whistleblowing Policy

Scope: Applies globally to all employees, members of the Board of Directors, agents, consultants, contract workers, and others representing or acting for or on behalf of Lundbeck.

Who approves and oversees: Lundbeck's Executive Management is responsible for ensuring proper rollout and implementation via the Compliance Program, with accountability lying with the SVP and General Counsel within Global Legal, Compliance, and Sustainability.

Key content / principles: Establishes protections for individuals who report alleged or actual violations of Lundbeck's Code of Conduct, internal policies and procedures, or applicable laws and regulations. Provides assurance that good-faith whistleblowers will be protected in accordance with Article 6 and Article 19 of the EU Whistleblowing Directive (EU Directive 2019/1937) and/or relevant local whistleblower laws.

Public availability: Made available internally on Lundbeck's intranet and internal document system.

Links to international standards: Explicitly references EU Directive 2019/1937 (EU Whistleblowing Directive).

Monitoring implementation: All new employees receive training on the Compliance Hotline. A speak-up campaign was launched in 2024. Global Compliance reports periodically to the Audit Committee and Global Compliance Committee.

Animal Ethics Policy

Scope: All facilities working with live animals at Lundbeck's own sites worldwide and external partners conducting studies on Lundbeck's behalf.

Who approves and oversees: The Lundbeck Animal Care and Use Committee (LACUC), chaired by Lundbeck's SVP of Non-clinical Safety Research, ensures animal welfare considerations are given highest priority. The committee is mandated by EU regulation as the Animal Welfare Body (AWB).

Key content / principles: Commitment to:

• Using animals only when alternative models cannot provide necessary data
• Providing appropriate care and housing
• Complying with relevant legislation
• Committing to the 3Rs (Refine, Reduce, Replace) principle
• Ensuring ethical treatment in compliance with EU Directive 2010/63/EU and similar worldwide directives

Public availability: Publicly available on www.lundbeck.com. Implemented procedures and practical guidance available internally on Lundbeck's intranet.

Links to international standards: Compliance with EU Directive 2010/63/EU on the protection of animals used for scientific purposes and similar directives worldwide. Lundbeck has signed the Marseille Declaration.

Monitoring implementation: A dedicated veterinary team operates independently from scientific research and animal care, providing oversight and ensuring regulatory compliance. Danish sites are inspected by the Danish Animal Experiments Inspectorate (DAEI). External institutions using animals must have an Animal Welfare Body aligned with Lundbeck's policy.

Targets related to own workforce

Gender Balance Target

Target metric: Share of underrepresented gender at senior management level / Gender balance in upper management

2024 Target: Increase in share of underrepresented gender at senior management level year on year.

2025 Target: Maintain an even gender balance in upper management closest to 40% but not exceeding 49%.

Target scope: Upper management (in accordance with the new Danish Gender Balance Act coming into force in 2025)

Progress to date: In 2024, the share of women in upper management was 43%, up from 38% in 2023.

Status: Achieved (for 2024 target)

Notes:

• The target scope reflects requirements of the new Danish Gender Balance Act
• Gender balance is no longer classified as a sustainability target as of 2025, but will still be part of internal performance management reporting

Inclusion Target

Target metric: Overall inclusion score in the annual employee satisfaction survey (ESS)

2025 Target: Reach an overall inclusion score of 8.5

Benchmark: Top quartile Peakon benchmark

Status: Not on track

Social protection

Retirement benefits

Lundbeck operates both defined contribution and defined benefit pension plans across its operations.

Defined contribution plans

The major defined contribution plans cover employees in Australia, Canada, China, Denmark, Finland, South Korea, Sweden, the UK and the U.S.

Cost of defined contribution plans:

• 2024: DKK 334 million
• 2023: DKK 269 million

Total retirement benefits costs included in employee costs:

• 2024: DKK 346 million
• 2023: DKK 278 million

Defined benefit plans

The Group has defined benefit plans in a few countries. The most significant plans comprise current and former employees in Germany and the UK.

Net retirement benefit obligations:

Breakdown in balance sheet:

• Non-current assets: DKK (69) million (2024), DKK (54) million (2023)
• Non-current obligations: DKK 223 million (2024), DKK 216 million (2023)
• Current obligations: DKK 1 million (both years)

Expected contribution for 2025: DKK 13 million (DKK 16 million for 2024)

Weighted average duration of obligation: 11 years (12 years in 2023)

Social security costs

Total social security costs included in employee costs:

• 2024: DKK 400 million
• 2023: DKK 372 million

Geographic coverage

Defined contribution plans cover: Australia, Canada, China, Denmark, Finland, South Korea, Sweden, the UK and the U.S.

Defined benefit plans cover: Germany (unfunded) and the UK (funded) as the most significant plans, plus a few other countries.

Total employees at 31 December:

• 2024: 5,707 employees
  • Denmark: 1,980
  • Other countries: 3,727
• 2023: 5,681 employees
  • Denmark: 1,897
  • Other countries: 3,784

Incidents, complaints and severe human rights impacts

Incidents & Complaints

In 2024, 14 discrimination cases were reported, of which 9 were substantiated.

Channels to raise concerns

All employees are encouraged to report incidents and raise complaints either directly to their managers, Employee Relations, local People & Culture, the ombudsmen, or through Lundbeck's Compliance Hotline. The hotline is a secure system hosted by a third party and is available internally through Lundbeck's intranet and externally on Lundbeck's website.

Additional grievance mechanisms are available to Lundbeck employees including trade union representatives, the European Works Council, and the local Works Councils, all of which are made available on Lundbeck's intranet.

Remediation

When an issue is raised through one of these channels, it is assessed and, if necessary, investigated to conclude whether the claim is substantiated or not, and to take appropriate actions. The outcome is communicated to relevant stakeholders. The type of remedy provided and the process for monitoring its effectiveness can vary depending on the specific circumstances of each case.

Methodology

Incidents & Complaints: The number of cases reported through the channels for own workforce is the total number of complaints reports filed through the channels to raise a concern.

Cases related to discrimination include all reported and investigated cases within the reporting year. These cases encompass discrimination based on gender, racial or ethnic origin, nationality, religion or belief, disability, age, sexual orientation, or other relevant forms of discrimination. Incidents of discrimination also include incidents of harassment as a specific form of discrimination. Discrimination concerns can be raised through various channels such as directly to their managers, to Employee Relations, to local People & Culture, to the ombudsmen or through Lundbeck's Compliance Hotline.

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

Scope and methodology

Lundbeck's reporting excludes contingent workers from certain processes:

• Employee engagement surveys ('Our Voice'): Surveys are shared with all employees globally, except for contingent workers and employees who recently joined or are soon leaving Lundbeck.

• Code of Conduct e-learning: Contingent workers are made aware that they must follow the Code of Conduct in their contract, either with the individual consultant, or in the agreement with their company. However, the completion rate measurement (30 September to 31 December) excludes contingent workers and only covers permanent and temporary employees.

• Employee satisfaction survey (ESS): The ESS is shared annually with all employees globally, except for contingent workers, employees who joined the company shortly before survey launch, and employees with their last working day at Lundbeck shortly before launch.

Quantitative data

No headcount figures or breakdown by type (contractor, agency, self-employed) are disclosed for non-employee workers in Lundbeck's own workforce.

Collective bargaining coverage and social dialogue

Social dialogue arrangements

Lundbeck has established Works Council and HSE Council structures for employee representation. The Wellbeing commitment is presented to the Works Council and the HSE Council in order to receive comments from employee representatives or manager representatives. These bodies help incorporate the views and interests of Lundbeck's workforce into relevant policies and action plans.

European Works Council

Lundbeck has an established European Works Council, which serves as a grievance mechanism available to employees to raise and address concerns. The European Works Council is made available on Lundbeck's intranet.

Other employee representation channels

Additional channels for employee voice include:

• Trade union representatives
• Local Works Councils
• Immediate managers
• Local People & Culture and Employee Relations
• Ombudsmen
• Compliance Hotline

All of these channels are made easily accessible to all employees on Lundbeck's intranet.

Diversity metrics

Gender distribution at top management

Board of Directors

Upper Management

Senior Management

Gender split for senior managers globally was 35% women and 65% men in 2024, compared to 36% and 64% in 2023. Senior management is defined as Executive Vice Presidents, Senior Vice Presidents, and Vice Presidents.

Executive Management

Currently, three out of the eight members of Executive Management are women, equaling a female representation of 38%.

Age band distribution

Total workforce

Methodology notes

The total number of the underrepresented gender (female) elected by the General Assembly and the employee-elected members is divided by the total number of members on the Board of Directors for H. Lundbeck A/S.

Upper management includes the Executive Management or the employees at the same level as Executive Management (e.g., the CEO, EVPs), as well as employees who report to Executive Management and have people management responsibilities.

Top management includes the Board of Directors and upper management. Gender for the top management gender balance is categorized as female or male, and gender balance is reported as the share of the underrepresented gender in the total.

Age distribution is calculated by determining the number of employees within each age group and expressing this as a proportion of the total number of employees. All numbers are given on a headcount basis as of year-end.

Policies related to value chain workers

Lundbeck's disclosure for S2-1 references page 116-117 but the provided excerpts do not contain the actual policy content from those pages.

The excerpts confirm that:

• Lundbeck has due diligence policies on issues addressed by the fundamental International Labor Organization Conventions 1 to 8 (referenced on pages 116-117)
• These policies align with the UN Guiding Principles on Business and Human Rights (UNGPs) and OECD Guidelines for Multinational Enterprises
• The company addresses human rights policy commitments related to value chain workers (referenced on pages 116-117)

Link to international frameworks

• Lundbeck's approach references the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises
• The company addresses fundamental International Labor Organization Conventions 1 to 8
• Due diligence processes include engaging with affected stakeholders and identifying and assessing adverse impacts (pages 68-70)

Governance and implementation

• Due diligence is embedded in governance, strategy and business model (pages 44; 62; 65-67; 72)
• The company engages with stakeholders including suppliers in key steps of due diligence (pages 68-70; 72)

The actual policy names, specific commitments, scope details, approval bodies, and public availability are not disclosed in the provided excerpts.

Taking action on material impacts on value chain workers

Lundbeck's S2-4 disclosure states:

"In 2024, no key actions were undertaken, or targets set regarding value-chain workers' health and safety or human rights." (page 117)

The company explains that its existing processes for value chain workers (Health, Safety and Environment audits and the Compliance Hotline) are undertaken as part of standard operations rather than as specific initiatives.

Ongoing operational processes (standard way of working)

HSE (Health, Safety and Environment) supplier audits

• Scope: Upstream value chain (suppliers, particularly chemical suppliers)
• Description: On-site audits covering human rights and health and safety topics; conducted based on a risk approach. All chemical suppliers in high-risk countries receive on-site audits prior to approval.
• Process: Workers can be interviewed during audits; feedback used to develop corrective action plans and follow-up audits
• Implementation: HSE department responsible for implementing Lundbeck's HSE Policy and ensuring audits are undertaken
• Tracking: 10 HSE audits of suppliers completed in 2024 (compared to 8 in 2023) (page 136)
• Resources: Not quantified (part of standard operations)

Compliance Hotline

• Scope: All value chain workers
• Description: Externally available channel enabling value chain workers to raise concerns, which are investigated and addressed
• Remediation: Global Compliance reports anonymized summaries to Audit Committee and Global Compliance Committee; management responsible for remediation or disciplinary actions
• Resources: Not quantified (part of standard operations)

Third-Party Obligations and Code of Conduct

• Scope: All third parties and suppliers
• Description: Contractual obligations requiring suppliers to adhere to UN Global Compact, local and international labor rights, sustainability standards, and human rights frameworks
• Requirements: Compliance with ILO conventions, OECD Guidelines, health and safety procedures, abolition of child labor
• Resources: Not quantified (embedded in procurement processes)

Procurement and third-party intermediary due diligence system

• Scope: Upstream value chain
• Description: System to limit impact on suppliers and their workforce (see Responsible Sourcing on page 134)
• Resources: Not quantified

Policies related to affected communities

Lundbeck references ESRS S3-1 in its disclosure index but does not provide substantive policy information specific to affected communities in the excerpts provided.

The company indicates on page 119, 121, 122, 125, and 127 where policies related to affected communities may be discussed, and references:

• Human Rights Policy commitments (Indicator number 9 Table #3 of Annex 1 and Indicator number 11 Table #1 of Annex 1)
• Non-respect of UNGPs on Business and Human Rights, ILO principles or OECD guidelines (Indicator number 10 Table #1 Annex 1)

The disclosure index also references the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises as frameworks for due diligence, with relevant content on pages 44, 62, 65-67, and 72 for embedding due diligence in governance, strategy and business model, and pages 68-70, 72, 75, 79-80, 86, 92, 103, 106, 108, 116, 119, 121-122, 125, 127, 132-135 for engaging with affected stakeholders.

However, the excerpts provided do not contain the actual policy content, names, scope, governance structures, or implementation details for policies specifically addressing affected communities. The information appears to be disclosed elsewhere in the full report on the referenced pages.

Policies related to consumers and end-users

The excerpts provided do not contain the actual disclosure content for ESRS S4-1 (Policies related to consumers and end-users). While the index and cross-reference tables indicate that S4-1 disclosures can be found on pages 119, 121-122, 125, and 127 of Lundbeck's Annual Report, these specific pages are not included in the excerpts provided.

The document structure shows that Lundbeck has identified consumers and end-users as a material topic under S4, and references engagement processes (S4-2), remediation processes (S4-3), actions (S4-4), and targets (S4-5) on the same pages. However, without access to the actual content on those pages, the specific policies related to consumers and end-users cannot be extracted or documented.

The due diligence statement on page 144 indicates that stakeholder engagement related to consumers occurs (referenced on pages 119, 121-122, 125, 127), and that actions to address adverse impacts are taken (pages 119-120, 123, 125), but does not name specific policies.

Taking action on material impacts on consumers

Product Quality Management

Action: Quality Management Review (QMR) process

• Scope: Own operations (manufacturing and commercial products)
• Description: A coordinated process across various GxP areas to ensure corrective and preventive actions are taken to prevent, mitigate, and avoid recurrence of non-conformities and deviations. Tracks reported issues and ensures products are produced at the right quality.
• Engagement: Direct engagement with health authorities regarding commercial products. Product quality complaints are filed, investigated, evaluated, and answered through dedicated channels.
• Policy link: Governed by Quality Management System and Quality Policy approved by health authorities prior to manufacturing
• Effectiveness evaluation: Evaluated as part of Lundbeck's commitment with health authorities to ensure risk minimization. QMR includes assessment of previous reviews and corrective actions taken for previously highlighted concerns.

Product Safety Management

Action: Pharmacovigilance System for adverse event monitoring

• Scope: Global operations (clinical trials, post-marketing surveillance across 100+ countries)
• Description: Procedures for collecting and processing reports on adverse events from patients, healthcare professionals, and proxies through Global Patient Safety (GPS). Continuous evaluation of safety information from non-clinical, clinical, and post-marketing sources to assess benefit-risk profile.
• Governance: Internal Safety Committees recommend risk mitigation strategies, endorsed by the Safety Board. Safety Board mandated to decide on product recall, implement safety updates in product labels, or pause global development activities for safety reasons.
• Engagement channels: Patients, HCPs, and stakeholders can raise quality-related issues through dedicated channels provided by Lundbeck
• Policy link: Governed by Pharmacovigilance System Master File and strict regulations from health authorities
• Effectiveness: Continuous monitoring of product safety profiles through ongoing safety surveillance and signal management activities. No external targets set, but continuous monitoring ensured.
• Anti-retaliation: Anti-Retaliation Policy applies if reports submitted through Compliance Hotline

Responsible Marketing

Action: Ethical promotional activities review process

• Scope: Own operations and downstream (marketing to healthcare professionals and patients)
• Description:
  • Marketing development and communication processes designed to uphold ethical standards
  • Review processes conducted by HQ-PARC and equivalent bodies in local subsidiaries embedded into daily work
  • Anonymous assessment of promotional communications to verify they are accurately understood and well-received
  • Engagement with patients and HCPs to gain insight on their perception of promotional materials
• Policy link: Code of Conduct requiring compliance with applicable laws and regulations, use of accurate and approved promotional materials, no promotion of off-label uses, and proper control of medicinal product samples
• Training: Annual training mandated for employees; certain suppliers and partners must affirm adherence to Code of Conduct principles
• Accessibility: Code of Conduct accessible internally on intranet and externally on www.lundbeck.com
• Geographic scope: All markets, with direct-to-patient marketing only in US and New Zealand where permitted
• Time horizon: Ongoing (annual training, continuous review processes)
• Resources: Non-financial resources include HQ-PARC review bodies and local subsidiary equivalent bodies; mandatory employee training
• Note: No additional specific initiatives regarding responsible and ethical marketing beyond daily review processes embedded in operations

Targets related to consumers

The document references S4-5 on pages 120-121, 123, 126, and 128 in the index table on page 62. However, the excerpts provided do not contain the actual disclosure of targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities for consumers and end-users.

The section on 'Targets' (page 127) states:

Quality Management System and Pharmacovigilance

"Lundbeck's Quality Management System and Pharmacovigilance Systems are continuously monitored and evaluated, thereby adhering to strict regulations upheld by the Quality Policy and the procedures described in the Pharmacovigilance System Master File. While no external targets are set, continuous monitoring of product safety profiles is ensured through ongoing safety surveillance and signal management activities, utilizing information from non-clinical, clinical, and post-marketing sources."

The document explicitly states that no external targets are set for the Quality Management System and Pharmacovigilance Systems. The excerpts provided do not contain specific quantified targets with target values, target years, or baseline information for consumers under S4-5.

Incidents of corruption or bribery

Confirmed incidents

Lundbeck reported zero confirmed convictions for violations of anti-corruption and anti-bribery laws in 2024.

Convictions and fines

No convictions or fines were reported during the reporting period.

Compliance Hotline reports

In 2024, a total of 85 cases were reported to the Compliance Hotline. The number includes all reported concerns, regardless of whether investigations were substantiated. All cases are thoroughly investigated in accordance with global procedures designed to protect individuals who raise concerns or contribute to investigations.

Investigation and speak-up procedures

Lundbeck has established a dedicated Compliance Hotline and Global Compliance Investigation team to investigate business conduct incidents promptly and objectively, guided by global investigations' procedures. An established process and escalation route ensure investigations are handled independently and free of any conflict of interest.

Global Compliance periodically reports an anonymized summary of globally reported claims of misconduct to the Audit Committee and the Global Compliance Committee. Investigation conclusions and recommendations may be shared with the Audit Committee, Global Compliance Committee, and/or Executive Management for endorsement or further action. While Global Compliance is responsible for the investigation of potential misconduct, management is responsible for securing remedial or disciplinary actions.

A speak-up campaign was launched in 2024 to create additional awareness about the Compliance Hotline. New reports are investigated by two designated compliance investigators who are skilled and continuously undertake relevant training and education.

Whistleblower protection

Lundbeck's Anti-Retaliation and Whistleblowing Policy establishes protections for individuals who report alleged or actual violations of Lundbeck's Code of Conduct, internal policies and procedures, or applicable laws and regulations. The policy provides assurance that good-faith whistleblowers will be protected to the required extent under applicable law and in accordance with Article 6 (Conditions for Protection of Reporting Person) and Article 19 (Prohibition of Retaliation) of the EU Whistleblowing Directive (EU Directive 2019/1937).

The ambition of the whistleblowing program is to comply with the EU whistleblower regulations on communication with reporters, including to reply to all good faith reporters within seven days, and to handle all cases in an appropriate, objective, fair, and timely manner.

Business conduct policies and corporate culture

Lundbeck's approach to business conduct is structured around several key policies and frameworks that govern ethical business practices, anti-corruption, responsible sourcing, and animal welfare.

Code of Conduct

Policy name: Code of Conduct

Scope: The Code of Conduct applies globally to all employees across Lundbeck. Third parties working on behalf of Lundbeck, or in its interest, are also obliged to comply with the Code of Conduct and meet the high standards of performance and integrity set internally.

Governance and oversight: The CEO signs the Code of Conduct, which is approved by the Board of Directors. The Board of Directors and the Executive Management are held accountable for its implementation and effectiveness. The CEO chairs the Global Compliance Committee and holds ultimate accountability for implementation, with authority delegated to the General Counsel. The operational management is handled by Lundbeck's Global Compliance department. The Global Compliance Committee, representing the Executive Management, meets regularly to maintain oversight.

Key content/principles: The Code of Conduct provides the framework, commitment, and expectations for how Lundbeck conducts business in a fair, transparent, and ethical manner, with particular attention to areas critical to the pharmaceutical industry such as anti-corruption, fair and open competition, and animal research. It establishes protections for individuals and emphasizes compliance with applicable laws and industry regulations.

Public availability: The Code of Conduct is available internally on Lundbeck's intranet and externally on www.lundbeck.com.

Links to international standards: The Code of Conduct makes reference to the UN Guiding Principles on Business and Human Rights. Lundbeck's approach aligns with the UN Convention against Corruption, the Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, the OECD Guidelines, and the Sustainable Development Goals. Lundbeck is committed to the UN Global Compact and Sustainable Development Goals, as stated in supplier obligations.

Monitoring implementation: An annual Code of Conduct training is mandated for all employees, with a 2024 target of 98% completion rate (achieved 100% in 2024). The effectiveness is tracked through employee confidence in raising ethical concerns (target: 4 out of 5 employees, achieved 4.6 out of 5 in 2024 employee satisfaction survey). Business ethics audits ensure consistent implementation of policies and requirements, identify risks, and capture suggestions for enhancing processes and controls. In 2024, 72 Business Ethics and Internal Control audits were conducted internally.

Guideline on Interactions with Healthcare Professionals, Healthcare Organizations, Patient Organizations, and Patients

Policy name: Guideline on Interactions with Healthcare Professionals (HCPs), Healthcare Organizations (HCOs), Patient Organizations, and Patients

Scope: The guideline applies to all Lundbeck functions that frequently interact with high-risk stakeholders such as Commercial Marketing, Sales, Medical Affairs, Clinical Development, Regulatory, Procurement, R&D, and Public Affairs.

Governance and oversight: The Guideline is approved by Lundbeck's General Counsel.

Key content/principles: The guideline and its supporting procedures ensure that interactions between Lundbeck and high-risk stakeholders are legal, ethical, and do not constitute an inducement to recommend, prescribe, purchase, supply, sell, or administer a medicinal product. It is intended to prevent corruption, fraud, and bribery in interactions with healthcare professionals and organizations.

Public availability: Available internally on Lundbeck's intranet and document management system.

Links to international standards: Lundbeck is committed to respecting applicable laws regarding ethical marketing and upholding standards outlined in the European Federation of Pharmaceutical Industries and Associations (EFPIA) and International Federation of Pharmaceutical Manufacturers and Associations (IFPMA) codes.

Monitoring implementation: Promotional and Advertising Review Committee (HQ-PARC) continuously reviews and approves promotional activities and materials. Local subsidiaries ensure promotional activities are reviewed and approved in accordance with applicable local codes and rules.

Anti-Retaliation and Whistleblowing Policy

Policy name: Anti-Retaliation and Whistleblowing Policy

Scope: The policy applies globally to all employees, members of the Board of Directors, agents, consultants, contract workers, and others representing or acting for or on behalf of Lundbeck.

Governance and oversight: Lundbeck's Executive Management is responsible for ensuring proper rollout and implementation via the Compliance Program, with the accountable party being the SVP and General Counsel within Global Legal, Compliance, and Sustainability.

Key content/principles: The policy establishes protections for individuals who report alleged or actual violations of Lundbeck's Code of Conduct, internal policies and procedures, or applicable laws and regulations. It provides assurance that good-faith whistleblowers will be protected to the required extent under applicable law and in accordance with Article 6 and Article 19 of the EU Whistleblowing Directive (EU Directive 2019/1937) and/or relevant local whistleblower laws.

Public availability: Available internally on Lundbeck's intranet and internal document system.

Links to international standards: Complies with the EU Whistleblowing Directive (EU Directive 2019/1937).

Monitoring implementation: A dedicated Compliance Hotline and Global Compliance Investigation team investigate business conduct incidents promptly and objectively. In 2024, 85 cases were reported through the Compliance Hotline. Global Compliance periodically reports an anonymized summary of globally reported claims of misconduct to the Audit Committee and the Global Compliance Committee.

Competition Law Policy

Policy name: Competition Law Policy

Scope: The policy applies throughout Lundbeck's business and aims to promote understanding of and compliance with competition law throughout its value chain.

Governance and oversight: Not explicitly stated in the excerpts.

Key content/principles: Lundbeck is committed to the principle of fair, free, and efficient competition, as upheld by the Code of Conduct. The policy ensures compliance with EU and national competition laws and works to conduct business in a fair, transparent, and ethical manner, striving to prevent any actions that may restrict competition in a given market.

Public availability: Not explicitly stated, though referenced in the Code of Conduct framework.

Links to international standards: Aligns with EU and national competition laws.

Monitoring implementation: In 2024, the legal and compliance team conducted a competition law risk analysis, drafted and published the Competition Law Policy and bespoke guidelines. Key employees within Legal and Compliance have received extensive competition law training.

Third-Party Intermediary Due Diligence (TPIDD) Standard Operating Procedure

Policy name: Third-Party Intermediary Due Diligence (TPIDD) Standard Operating Procedure (SOP)

Scope: The TPIDD is applicable globally to any legal entity within Lundbeck that intends to either use the services of, or interact with, third-party intermediaries (defined as professionals and entities performing activities within Lundbeck's core business areas on behalf of, or in the interest of, Lundbeck).

Governance and oversight: The Chief Ethics and Compliance Officer is accountable for the implementation of the TPIDD.

Key content/principles: The TPIDD process is designed to review and monitor risks primarily related to bribery and corruption, fraud, and conflicts of interest, while also covering other risks related to trade sanctions, human and labor rights, and environmental impacts. All parties working for or on behalf of Lundbeck are subject to anti-corruption and bribery principles.

Public availability: Available internally on Lundbeck's intranet.

Links to international standards: Implemented to ensure compliance with the Code of Conduct and local applicable laws, codes, and regulations.

Monitoring implementation: In 2024, 240 Third-Party Intermediary Due Diligence screenings were completed. Prior to commitment, all new suppliers with an expected commitment over DKK 1 million are assessed against eight core risks. Climate criteria are considered when selecting suppliers within scope 3 SBTi Target, with new and strategic suppliers requested to sign a climate addendum.

Health, Safety, and Environment (HSE) Policy

Policy name: Health, Safety, and Environment (HSE) Policy

Scope: The HSE Policy applies to all of Lundbeck's own operations, from sales subsidiaries to production sites. It is also part of the commitments and expectations of employees and suppliers as stated in Lundbeck's Code of Conduct.

Governance and oversight: The policy is set and approved by Lundbeck's HSE Council and Executive Management.

Key content/principles: The HSE Policy specifies Lundbeck's commitment to protecting employees and the external environment, preventing pollution, prevention of work-related diseases and accidents, chemical safety, promotion of circular economy principles, and minimization of emissions and waste. It commits to complying with applicable health and safety legislation and internal guidelines, preventing work-related accidents and ill health, and promoting a high level of chemical safety by substituting hazardous chemicals.

Public availability: The HSE Policy is available internally on Lundbeck's intranet and externally on www.lundbeck.com.

Links to international standards: The HSE management system is certified according to ISO 14001 and ISO 45001, corresponding to international standards of environmental management and occupational health and safety, respectively.

Monitoring implementation: The operational implementation at all four production sites is guided by Lundbeck's HSE management system, which encompasses both the HSE Policy and HSE Strategy, as well as corporate and local guidelines and procedures. In 2024, 10 internal Health, Safety and Environment audits were conducted, along with 6 audits of external partners. Lundbeck sets annual targets for Lost Time Accident Frequency (target ≤3, achieved 3.2 in 2024) and High-consequence work-related accidents (target: not more than 2, result: 3 in 2024).

Human Rights Statement

Policy name: Human Rights Statement

Scope: The Human Rights Statement applies to all Lundbeck operations and value chain activities.

Governance and oversight: Not explicitly stated in the excerpts.

Key content/principles: Through this statement, Lundbeck adheres to the Universal Declaration of Human Rights (UNDHR), the International Covenant on Civil and Political Rights (ICCPR) and its second optional protocol, the International Covenant on Economic, Social and Cultural Rights (ICESCR), and other core international human rights instruments. Lundbeck is committed to safeguarding the health of patients, employees and value chain workers by continuously upholding the commitments made in the Human Rights Statement.

Public availability: External stakeholders can access the Human Rights Statement by visiting Lundbeck's website.

Links to international standards: Adheres to the Universal Declaration of Human Rights (UNDHR), the International Covenant on Civil and Political Rights (ICCPR), the International Covenant on Economic, Social and Cultural Rights (ICESCR), the UN Guiding Principles on Business and Human Rights, and internationally recognized frameworks such as the OECD Guidelines for Multinational Companies. The HSE Strategy and Code of Conduct make reference to the UN Guiding Principles on Business and Human Rights.

Monitoring implementation: Lundbeck conducts due diligence procedures to identify and address potential human rights impacts. External stakeholders can report concerns confidentially via the Compliance Hotline.

Animal Ethics Policy

Policy name: Animal Ethics Policy

Scope: The policy applies to Lundbeck's own sites worldwide and to all external partners when using live animals to conduct studies on Lundbeck's behalf.

Governance and oversight: At Lundbeck, the Animal Welfare Body (AWB) is the Lundbeck Animal Care and Use Committee (LACUC), chaired by Lundbeck's SVP of Non-clinical Safety Research. LACUC ensures that animal welfare considerations are given the highest priority in the context of animal keeping, breeding, and use. The Executive Management approves a dedicated veterinary team that operates independently from Lundbeck's scientific research and animal care.

Key content/principles: Lundbeck is committed to ensuring the ethical treatment of animals used in laboratory settings, in compliance with the guidelines of the EU Directive 2010/63/EU on the protection of animals used for scientific purposes and similar directives worldwide, as well as national regulations and guidelines. The use of animals comes with a responsibility to provide appropriate care and housing, comply with relevant legislation, and commit to the 3Rs (Refine, Reduce, Replace) principle of animal research. Lundbeck has signed the Marseille Declaration, which states expectations related to animal welfare practices.

Public availability: The Animal Ethics Policy is publicly available on www.lundbeck.com, and implemented procedures and practical guidance for employees working with animals are available internally on Lundbeck's intranet.

Links to international standards: Complies with EU Directive 2010/63/EU on the protection of animals used for scientific purposes and the Marseille Declaration.

Monitoring implementation: Facilities working with live animals are mandated by EU regulation to have an Animal Welfare Body. Animal welfare considerations are supported by inspection of Danish sites by the Danish Animal Experiments Inspectorate (DAEI). Any external institution using animals on behalf of Lundbeck must have an AWB to ensure compliance with legislation and alignment with Lundbeck's Animal Ethics Policy. A dedicated veterinary team provides oversight of animal welfare, serves as an advisory function, and ensures compliance with relevant regulations.

Third-Party Obligations

Policy name: Third-Party Obligations

Scope: All third parties interacting with Lundbeck must adhere to these obligations.

Key content/principles: Third parties must adhere to the UN Global Compact principles and those outlined in the Code of Conduct. The obligations complement the scope and implementation of the Code of Conduct and entail that Lundbeck's third parties must ensure compliance with applicable national and international laws relating to human and labor rights. Specifically, third parties must uphold the abolition of child labor; maintain health, safety, and environment procedures to ensure compliance with applicable laws.

Monitoring implementation: All parties working for or on behalf of Lundbeck are subject to the anti-corruption and bribery principles upheld through the Code of Conduct and the Guideline on Interactions.