MT Højgaard Holding

(Section ESRS 2 GOV-1, pp 94-96) MT Højgaard Holding describes its governance structure. The general meeting is the supreme authority and elects the Board of Directors. The Board of Directors has overall responsibility for management and long-term value creation, including integration of ESG impacts, risks and opportunities, supervision of the Executive Board, financial control and risk management. Four board committees support this work: the Audit Committee (financial and ESG reporting, internal control, risk management, whistleblower reports, Code of Conduct and GDPR), the Sustainability Committee (ESG strategy and targets, and annual review of the double materiality assessment), the Remuneration Committee (remuneration and incentive schemes) and the Nomination Committee (board and management composition). For most of 2024 the Board had nine members, seven elected by the general meeting for one-year terms and two employee representatives. Carsten Dilling is Chairman and Morten Hansen Deputy Chairman. The proportion of independent board members was 86% and women made up 43% of shareholder-elected members. The Executive Board consisted of CEO Rasmus Untidt at 31 December 2024. The Board holds ESG-related expertise and can draw on external advice.

(Section ESRS 2 GOV-2, pp 40-41,94) The company explains how the administrative, management and supervisory bodies are informed about and oversee sustainability matters. The Board of Directors receives, at least once annually, reporting on the implementation of processes, and twice a year it is informed of the results of actions and targets. The Executive Board receives regular information on material impacts, risks and opportunities. A CSRD Steering Committee, presided over by the CEO of MT Højgaard Holding and made up of management representatives from each business unit, sets the strategic direction for CSRD implementation and regularly informs the Board of Directors of progress and challenges. The Sustainability Committee reviews the impacts, risks and opportunities from the double materiality assessment each year and recommends the assessment for board approval. During the reporting period, management and the Board addressed issues across all ESG areas, with particular focus on CO2 emissions, green transition opportunities, workplace accidents, diversity and inclusion, value chain social risks, governance and anti-corruption, and regulatory ESG risks. The Board and Executive Board ensure impacts and opportunities inform strategic decisions and significant transactions.

(Section ESRS 2 GOV-3, pp 95-96) MT Højgaard Holding describes how sustainability performance is built into incentive schemes. In 2024, 10% of the Executive Board's bonus in the parent company and in the three business units MT Højgaard Danmark, Enemærke & Petersen and MT Højgaard Property Development was linked to ESG-related KPIs. The KPIs cover the proportion of the under-represented gender, the rate of accidents, recirculated waste and total CO2 emissions from Scopes 1 and 2. Each KPI carries a weight of 2.5% of the total bonus. At MT Højgaard Property Development the 10% is instead split between two ESG KPIs: the proportion of the under-represented gender (5%) and Scope 1 and 2 CO2 emissions (5%). The Remuneration Committee of the Board prepares recommendations for the specific bonus programme, which the Board of Directors then approves. The disclosed variable remuneration linked to sustainability-related targets was 10% in 2024, compared with 0% in 2023. The company gives accounting-policy definitions for how these figures are calculated.

(Section ESRS 2 GOV-4, pp 92-93) The company presents its due diligence statement. MT Højgaard Holding is working to implement the EU Corporate Sustainability Due Diligence Directive (CSDDD) to address negative impacts linked to the Group's and value chain's activities, covering human rights, the environment and climate across own operations, the supply chain and certain downstream activities. The due diligence process has six steps and is based on the OECD Due Diligence Guidance for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights. The six steps are policies and anchoring, risk assessment, initiatives to counter negative impacts, continuous follow-up, communication, and grievance mechanisms. Integration into existing work methods began in 2024 and continues in 2025. Beyond the double materiality assessment, the Group ran two deeper risk assessments: one of fifteen high-use, high-risk material groups against twelve ESG risks, and one of business partners grouped into 36 categories against eight ESG risks. In 2024 the Group expanded internal and external complaint options, adding a third channel available to employees and external stakeholders alongside the whistleblower scheme and complaints to HR.

(Section ESRS 2 GOV-5, p 36) MT Højgaard Holding describes its risk management and internal controls over sustainability reporting. The processes for ESG reporting are described for every business unit and all ESG data are defined in the Group's ESG data manual. Reported ESG data are verified using a four-eyes principle, and the Group continuously monitors and optimises its ESG reporting processes and controls. Risks in ESG reporting are assessed and prioritised with a focus on significant deviations and data quality experience, with typical risks being manual entries and locally deviating data definitions. To mitigate these risks, dedicated employees have been appointed who perform regular controls, analyse developments and carry out spot checks of documentation. Results of risk assessments and internal controls are reported annually to the Audit Committee. In 2024 the area was further strengthened with new appointments within ESG controlling. As with financial reporting, the Board of Directors has overall responsibility for risk management. The Group's external auditors, EY, have issued a statement providing limited assurance on the overall sustainability statement.

(Section ESRS 2 SBM-1, pp 7,26-30,38,41,75) The company describes its business model and strategy. MT Højgaard Holding is a Danish group whose business units develop, plan and execute projects within new builds, civil engineering, infrastructure, refurbishment and building transformation. Key inputs include employees, knowledge, innovation, materials and raw materials, partners and suppliers, and capital raised through operations and credit facilities. Outputs and value creation are described for customers, end-users and the local environment, social development, environmental considerations, safety and well-being, and investors. The Group had an average of 3,029 employees in 2024, and revenue grew 9% to a higher level with earnings growth across the business units. The order book totalled DKK 11.8 billion. The Group has consolidated into three roughly equal pillars in civil engineering, newbuilds and refurbishment. The statement notes the Group has no turnover from coal, oil, gas, chemical production, controversial weapons or tobacco cultivation and production. The double materiality assessment results informed adjustments to the Group's strategic priorities and objectives in 2024.

(Section ESRS 2 SBM-2, pp 45-46) The company describes the interests and views of its stakeholders. MT Højgaard Holding engages in dialogue with stakeholders based on international norms and codes and considers the perspectives of those directly affected by its activities and those using its published information. A stakeholder table sets out each group, how the Group interacts with them, their key ESG topics and concerns, and related Group initiatives. Groups include shareholders and financial institutions (regular meetings and market communication, concerned with responsible business conduct, transparency and stable results), clients (project collaboration and industry dialogue, focused on quality, sustainability requirements, certifications and EU Taxonomy, and site working conditions), employees (satisfaction surveys, training and working groups, focused on development, pay, working environment, diversity and inclusion), and consulting engineers and architects (project collaboration on innovation and climate initiatives). Insights from stakeholder dialogue inform the assessment of material topics and the adaptation of ESG actions, targets and overall strategy. Stakeholders' views also feed into the double materiality assessment and due diligence processes, and are communicated through periodic meetings to the Sustainability Committee and the CSRD Steering Committee.

(Section ESRS 2 SBM-3, pp 40-44) The company describes its material impacts, risks and opportunities and their links to strategy and business model. The double materiality assessment shows that eight of the ten ESRS topics are material. These ten topics consist of 37 sub-topics, 19 of which are material for the Group. Consumers and end-users (S4) and Water and marine resources (E3) are assessed as not material, so no reporting is provided for those topics; the potential impacts on consumers and end-users were assessed as moderate because they mainly interact with the client. The material topics span the environment (climate change, pollution, biodiversity and ecosystems, circular economy), social (own workforce, workers in the value chain, affected communities) and governance (business conduct). Compared with the prior year, Consumers and end-users moved to not material, the biodiversity sub-topic Impacts on the state of species became material while Impacts and dependencies on ecosystem services became not material, and the business conduct sub-topic Protection of whistleblowers became material. The company states the material impacts, risks and opportunities are directly related to its business model, and that identified risks and opportunities are not considered to have an essential impact on its financial position.

(Section ESRS 2 IRO-1, pp 40,45) The company describes the process used to identify and assess material impacts, risks and opportunities. The double materiality assessment is prepared by MT Højgaard Holding with the Group's business units and input from external stakeholders, covering own operations and value chain, and is based on EFRAG guidance and a structured process with scoring matrices. It follows three phases: identification and assessment (value chain mapping and research, internal ESG workshops, interviews at a construction site and external interviews), processing and calibration (validation in nine CSRD workstreams and cross-cutting calibration by the sustainability department), and approval. Impacts are assessed on scale, scope, irremediability and likelihood, while risks and opportunities are assessed on the size of the financial impact and likelihood; for current negative impacts, irremediability is assessed instead of likelihood. A topic is considered material if it scores 4 or higher on a 1-5 scale for financial materiality, impact materiality or both. Two supplementary risk assessments of subcontractors and of suppliers and materials further inform the assessment. Results were reviewed and approved by the Sustainability Committee and then by the Board of Directors. Going forward the assessment will be updated in a light version yearly and fully every three years.

(Section ESRS 2 IRO-2, pp 40,166-167) The company sets out the ESRS disclosure requirements covered in its sustainability statement. It confirms the statement was prepared in accordance with the European Sustainability Reporting Standards issued by EFRAG, and that all datapoints included have been assessed as material through the Group's double materiality assessment. A list of ESRS disclosure requirements on pages 166-167 maps each requirement to the relevant section and page and, where applicable, to references to other EU legislation such as SFDR and the Benchmark Regulation. The table shows which requirements are reported, which relate to not material topics (marked not material or n.a.), and which are subject to phase-in. Topics assessed as not material, namely Consumers and end-users (S4) and Water and marine resources (E3), are not reported. Several ESRS 2 requirements are incorporated by reference to other parts of the management review, including the business model (SBM-1) under Overview on page 7, employee headcount by geographical area under Social, corporate governance (GOV-1) on pages 94-95, ESG remuneration (GOV-3) on page 96, and due diligence (GOV-4) on pages 92-93.

(Section ESRS E1-1, pp 56-59) MT Højgaard Holding describes a transition plan to contribute to the shift towards a more sustainable economy, covering own operations (Scopes 1 and 2) and the value chain (Scope 3). The Group states it is not excluded from Paris-aligned EU benchmarks. Its absolute reduction targets were developed in accordance with the methodology of the Science Based Targets initiative (SBTi), but the report states plainly: "the Group has not signed up to the SBTi." The plan for own operations focuses on electrification of the car fleet and machinery, optimising fuel consumption, increasing renewable energy use, and implementing ISO 14001 environmental management systems. For the value chain, actions target purchased materials (increased use of EPDs, lower-emission and recycled or biogenic materials) and sub-contractor requirements. CapEx investments are planned for electrification, energy optimisation and renewable transition, but are not reported externally due to immateriality. The transition plan is approved by the management of each individual company.

(Section ESRS E1-2, p 55) The Group's climate and environmental policy describes its objective to mitigate climate change through efforts to reduce GHG emissions in its own operations and in the value chain. The policy also supports the Group's work on climate change adaptation by providing solutions in areas such as cloudburst protection and coastal protection. It further concerns efforts to use energy-efficient solutions in the initial phases of construction and to expand the use of renewable energy. The policy reflects MT Højgaard Holding's stated commitment to reducing both direct and indirect GHG emissions in the value chain and to integrating climate action as a central part of its business strategy, in line with the Paris Agreement target of limiting global warming to below 1.5 degrees Celsius.

(Section ESRS E1-3, pp 58-59) The Group sets out actions supporting its reduction targets. For own operations (Scopes 1 and 2), companies are replacing fossil-fuel cars and machinery with electric alternatives and optimising fuel consumption; MT Højgaard Danmark focuses on reducing machinery idling time, aiming to cut average idling from a current level of 35% to 20% by 2030, while Enemærke & Petersen introduced speed-limiting measures and GPS systems in vans. Scope 2 actions include more energy-efficient site cabins, sensor-controlled electricity, better insulation and energy dashboards. For the value chain (Scope 3), the Group focuses on procurement of building materials, systematic EPD screening, use of "green concrete" and contract requirements for sub-contractors. CapEx investments are planned for electrification of the car fleet and equipment, energy optimisation and renewable transition; these amounts are set out in the transition plan and are not reported externally due to immateriality, and OpEx costs of the actions are not calculated.

(Section ESRS E1-4, pp 55-62) MT Højgaard Holding has set absolute reduction targets for Scope 1 and 2 and for Scope 3 emissions, developed using the SBTi methodology, though the Group has not signed up to the SBTi. Both targets commit the Group to reducing GHG emissions by 42% before 2030 relative to a 2023 base year, in line with limiting global warming to 1.5 degrees Celsius. The base year was changed from 2022 to 2023 in 2024. For Scopes 1 and 2 the base year value is restated to 11,878 tCO2e, with absolute targets of 10,453 tCO2e in 2025 and 6,889 tCO2e in 2030. For Scope 3 the base year value is restated to 463,806 tCO2e, with targets of 408,149 tCO2e in 2025 and 269,008 tCO2e in 2030. Near-term 2025 targets include a 12% CO2 reduction from fuel and energy (Scopes 1 and 2) and a 12% CO2 reduction from purchased materials (Scope 3), both relative to 2023. The Group notes it still needs to define further actions to reach the 42% Scope 1 target by 2030.

(Section ESRS E1-5, p 65) The Group's total energy consumption increased to 63,457 MWh in 2024 (53,918 MWh in 2023), an increase of 17.7%. Energy from fossil sources rose to 55,682 MWh, or 87.7% of total consumption (86.3% in 2023), driven mainly by higher fuel consumption. Of this, fuel from crude oil and petroleum products was 49,202 MWh (77.5%), natural gas 61 MWh (0.1%), and electricity and heat from fossil sources 6,420 MWh (10.1%). Energy from nuclear sources was 444 MWh (0.7%). Energy from renewable sources was 7,330 MWh, or 11.6% of the total (12.9% in 2023). The share of renewable energy purchased through contractual instruments accounted for 30.9% of the Group's total energy consumption in Scope 2. Energy intensity (Scopes 1-2) was 5.8 MWh per DKK million (5.3 in 2023). Energy consumption is based on the market-based energy mix calculated from the general environmental declaration issued by Energinet.

(Section ESRS E1-6, pp 60-62) In 2024, Scope 1 emissions were 13,298 tCO2e (10,869 in 2023), up 22.3% and equal to 3% of total emissions. Scope 2 location-based emissions were 975 tCO2e (1,009 in 2023), down 3.4% and 0.2% of the total; Scope 2 market-based was 2,854 tCO2e. Scope 3 emissions rose 11.5% to 517,202 tCO2e (463,806 in 2023). Total Scopes 1-3 location-based emissions were 531,475 tCO2e (475,684 in 2023), up 11.7%; market-based were 533,354 tCO2e. The largest Scope 3 category was Category 1 Purchased goods and services at 472,362 tCO2e (91.3% of Scope 3), split into building materials 113,542 tCO2e, sub-contractors 332,229 tCO2e and other 26,591 tCO2e. Category 15 Investments rose 626% to 34,013 tCO2e. Emission intensity (Scopes 1-3, market-based) was 48.7 tonnes per DKK million (46.5 in 2023). Regulated ETS emissions were 0%. Biogenic emissions were 37 tCO2e (Scope 1), 707 tCO2e (Scope 2) and 16,069 tCO2e (Scope 3). Emissions are calculated using the financial control method per EFRAG guidance.

(Section ESRS E2-1, pp 66-67) MT Højgaard Holding addresses pollution through its climate and environmental policy together with company-specific health and safety and chemicals policies. The climate and environmental policy emphasises minimising the risk of air pollution and phasing out substances of very high concern, while replacing and minimising substances of concern in building materials. It is primarily focused on pollution in the Group's own operations and applies to all subsidiaries. The company-specific health and safety and chemicals policies emphasise the Group's focus on safety when handling chemicals. The Group frames pollution as a critical factor for both environmental and human health, noting that harmful substances are discharged into air and the environment during the extraction, production and transport of building materials, and that own operations also cause pollution such as NOx emissions from vehicles and dust from construction sites. A particular concern is the use of substances of concern in materials, which may pose health risks to workers and end-users during construction and at the end of a building's service life.

(Section ESRS E2-2, pp 66-67) In 2024 the Group launched a cross-cutting initiative under which business units began calculating quantities of pollutants going forward, and worked on developing a methodology for estimating the load from air pollutants, especially NOx. Most machinery and vehicles that contribute to air pollution are leased, and the lessors are currently unable to provide air pollution data, so such data could not be compiled for 2024. Enemærke & Petersen launched a phase-out initiative to ensure no chemical compositions or products containing substances of very high concern are used, to be extended in coming years to products containing substances of concern. During 2024 MT Højgaard Danmark mapped products containing substances of concern to support future phase-out and to develop a catalogue of alternative products. MT Højgaard Danmark and MT Højgaard Property Development collaborated on a methodology for digitising the chemical content of builds. On the AL-Huset project (with Arbejdernes Landsbank), the Group worked systematically with requirements for chemical content in building materials, targeting DGNB Platinum certification.

(Section ESRS E2-3, pp 38, 66-67) The Group's pollution-related targets are voluntary and not regulatory requirements. Its 2025 targets are to phase out the use of products containing substances of very high concern (SVHC) and to reduce the use of products containing substances of concern (SOC). Because it is not possible to estimate the actual quantities of substances of concern and very high concern used, a quantitative target for their reduction has not been set. However, the target is still described as directly measurable in the form of a reduction in the proportion of used products containing such substances, with achievement assessed using 2024 as the base period. Since the Group has not been able to calculate the load from air pollutants, no targets have been set for air pollution; work will continue in 2025 to obtain data so that targets may be set in this area. In preparing the materiality assessment there was no direct dialogue with affected communities specifically on pollution, though such communities are often consulted during project phases.

(Section ESRS E2-4, pp 66-67) The Group reports on pollution mainly through the distribution of substances of concern in the chemical products used. Of the chemical products used across the Group's projects in 2024, 12.3% contain substances of very high concern, 60.4% contain substances of concern, and 27.3% contain no substances of concern or of very high concern. At present it is not possible to estimate the actual quantities of substances of concern and very high concern in the products used, so these figures cover all products used but not their quantities. The distribution is based on the Avichem chemical management service (COS), which classifies products and reports annually across all chemical products registered on the Group's active projects; it can only be reported for the business units actively using COS, currently MT Højgaard Danmark, Enemærke & Petersen and NemByg. System limitations mean the date of use of products cannot be recorded accurately, so some products may be included even if not used in the accounting year, creating uncertainty. For air pollution, no quantitative data (including NOx) could be compiled for 2024.

(Section ESRS E4-1, p 69) The Group's business model relies on stable ecosystem services, such as climate and weather regulation as well as water and soil quality, to ensure the supply of materials, and the most material risks are associated with the deterioration or collapse of these services. Critical risks include erosion, flooding and unstable water supply. Transition risks in relation to the market and legislation may affect own operations and the value chain, while no material reputational or technology-related risks were identified. For example, new builds and project development are susceptible to growing nature considerations, increasing the focus on renovation and transformation, and political regulation of activities such as dredging and raw materials extraction may complicate both development and the supply of materials. The most critical ecosystem services to the business model and value chain were mapped through the ENCORE database rather than a stakeholder analysis. Analyses of land-related ecosystem services are based on the WWF Biodiversity Risk Filter, while water-related ecosystem services used the WWF Water Risk Filter, based on 2030 scenarios with a temperature rise of 3.5-4 degrees C.

(Section ESRS E4-2, p 68) The Group addresses biodiversity through its climate and environmental policy, which highlights the target of reducing significant negative impacts on biodiversity, in particular from the consumption of natural resources. In addition, the policy supports the Group's intention to combat the risk of deforestation, unsustainable forest and ocean management and any associated social consequences. This is to be achieved by increasing transparency and traceability of biodiversity impacts on the value chain. The Group notes that biodiversity is a relatively new topic for it and the industry but has quickly become central to environmental sustainability. Material negative impacts are seen mainly in the value chain (off-site), in connection with upstream raw materials extraction and production of building materials, where negative impacts related to direct impact drivers of biodiversity loss and the condition of endangered species have been identified. The Group's own operations may potentially impact local biodiversity at and around construction sites (on-site), but no material negative impacts on the extent and condition of ecosystems or on endangered species have been identified from own operations.

(Section ESRS E4-3, p 68) In 2024 the Group made a dedicated effort to increase understanding of the impact of its projects and value chain on biodiversity, with the overall focus on minimising the impact both on-site and off-site. At construction sites near biodiversity-sensitive areas, potentially harmful activities have been mapped to identify on-site impacts, and these insights will be used to implement initiatives such as biodiversity screenings and recommendations that can promote biodiversity in projects. To identify off-site risks, analyses were made of biodiversity-harmful practices in the supply chain based on the Group's materials purchases, forming the basis for future requirements and recommendations to reduce the footprint of purchases. Under Danish environmental legislation, an environmental impact assessment (EIA) must be carried out for major projects, and construction and infrastructure projects are typically subject to EIA requirements. Selected projects in 2024 were subject to biodiversity mitigation measures as a result of EIAs; where the client makes the Group responsible for such measures, they are implemented as an integral part of the project, though the EIA is the client's responsibility and the Group has no influence on its outcome.

(Section ESRS E4-4, p 68) The Group has set qualitative targets to avoid or minimise negative impacts on biodiversity where possible. Its 2025 targets are to identify biodiversity impacts on the value chain (off-site) to minimise its footprint, and to map biodiversity impacts from construction sites (on-site) and develop initiatives. Because the targets are not directly measurable in terms of reducing a quantitative footprint (as is the case for climate change), target achievement is assessed on the basis of implementation of initiatives using 2024 as the base period, with progress on both on-site and off-site biodiversity evaluated through a qualitative assessment of the implementation of targeted actions and processes to mitigate negative impacts. The targets are not based on specific ecological thresholds, as it is assessed that there are currently no widely recognised or applicable ecological thresholds to support target setting, and they are not based on concrete policy or regulation such as the EU biodiversity strategy for 2030 or the Kunming-Montreal Global Biodiversity Framework. No targets are sought to be achieved using biodiversity offsets.

(Section ESRS E4-5, p 70) The Group has active projects overlapping biodiversity-sensitive areas, including six Natura 2000 sites in Denmark, which are protected under the EU Habitats and Birds Directives; none of these sites are classified as Ramsar sites. Activities with potential negative impacts include land artificialisation and repurposing of natural land, major drainage work, dredging of ocean floor sediment and other water disturbances; all dredging was carried out with permission from the Danish Environmental Protection Agency. None of the Group's projects in Greenland overlap with biodiversity-sensitive areas within a five kilometre radius, while four of its projects in the Maldives overlap with marine protected areas, habitats and species management areas. The reported table of Danish construction sites in or near biodiversity-sensitive areas records overlaps such as Sea and coast between Præstø Fjord and Grønsund (22.5 HA), Køge Å (2.3 HA), Odense Å together with Hågerup Å, Sallinge Å and Lindved Å (25.3 HA) and Gudenå and Gjern Bakker / Silkeborgskovene (4.6 HA), with the state of nature rated on a scale of I (high quality) to V (poor quality). A conservative methodology is applied whereby all recorded activities are assumed to have a potential negative impact, and limited knowledge of actual impacts makes precise assessment difficult.

(Section ESRS E5-1, p 71) MT Højgaard Holding's climate and environmental policy governs resource use and circular economy. The policy highlights the Group's contribution to a transition away from the use of new resources towards increased use of recycled resources. It supports efforts to reduce the use of critical raw materials, promote more sustainable procurement practices, and support reuse and recycling. The policy applies to all the Group's activities across geography and to the entire value chain. The Group states that circular solutions must be integrated already at the design and planning phases, so that buildings can be constructed as flexible and adaptable structures with extended service lives that facilitate future recycling. Strategic priorities include increased reuse and recycling of waste, responsible purchasing of materials with lower consumption of raw materials, and more efficient use of resources.

(Section ESRS E5-2, p 71) In 2024 the Group continued a number of strategic initiatives to promote better waste sorting and more efficient resource utilisation across projects and companies. MT Højgaard Danmark intensified its focus on preparing practical guidelines for sorting at source and waste management, communicated through the company's knowledge portal and distributed to construction sites to reduce mixed waste that is often not recyclable. Enemærke & Petersen worked with suppliers and manufacturers on take-back arrangements and investigated collaboration with specialist waste buyers able to upcycle specific fractions; the potential to convert residual wood into wood fibre insulation is being explored. MT Højgaard Property Development focused on making resource-efficient initiatives integral to project development, for example avoiding unnecessary demolition of existing buildings on land under development. Resources have been allocated to spread circular-economy expertise to employees working outside traditional sustainability areas.

(Section ESRS E5-3, p 71) The Group has a 2025 target of 75% recirculation of waste, which applies to all companies in the Group. Recirculation of waste includes recovery, recycling and direct reuse. The Group states that the target is not mandatory and that no stakeholders were involved in setting it. To achieve the target, MT Højgaard Holding is working to improve resource efficiency and optimise point-of-use sorting of waste at its construction sites so that waste is managed to maximise its value and support the waste hierarchy, meaning waste is as far as possible directly reused, recycled or subjected to materials recovery. The Group does not have a set target for resource inflows, but has established policies and efforts to optimise material use and reduce dependency on primary raw materials.

(Section ESRS E5-4, p 71) MT Højgaard Holding has identified resource inflows as a material topic due to large consumption of building materials, which involves a substantial draw on raw materials. No quantitative listing for resource inflows is reported under the CSRD (E5-4). The Group is working on developing a measurement methodology that will ensure increased transparency on the total weight of materials used and the proportion of recycled and biogenic content. As this calculation methodology is not expected to be fully developed until 2025, the base period for measuring progress will be determined in connection with its implementation. Until then, the Group will continue to work to strengthen the data basis and improve the reporting of resource consumption to support a more circular material flow. Effectiveness of policies and efforts is tracked through a number of processes, including data on materials consumption (referenced to Scope 3, category 1, of the climate accounts).

(Section ESRS E5-5, pp 72-73) Resource outflows for the Group consist mainly of waste, reported alongside the circular-economy efforts. The Group's waste consists of construction and household waste, the latter accounting for only a small proportion. Construction waste comprises a wide range of materials, of which the largest fractions include concrete, wood, plaster, insulation, plastics, bricks, iron, steel and mixed fractions. Where possible, existing structures are included in new projects to reduce raw material needs and waste volumes. When demolition is unavoidable, demolition plans with detailed resource mapping are prepared to identify materials that can be reused or recycled. Waste is measured in tonnes broken down by management method, including reuse, recycling, materials recovery, energy recovery and landfill, and is divided into hazardous and non-hazardous waste. The waste calculation is limited to the financial control method, covering only activities for which the Group is invoiced directly for a purchased service.

(Section ESRS E5-5, Waste, pp 72-73) In 2024 the Group's total waste volume increased to 19,310 tonnes (15,592 in 2023), an increase of 23.8%, driven mainly by a higher activity level and progress on several major construction projects at stages where waste generation is traditionally high. Total recirculated waste was 12,847 tonnes (66.5%) versus 10,587 tonnes (67.9%) in 2023, so the total recirculation rate, covering waste prepared for re-use, recycling and recovery, fell to 66.5% against the 75% 2025 target. Non-hazardous waste was 18,748 tonnes (97.1%) and hazardous waste 562 tonnes (2.9%), the latter rising 38.5%; no radioactive waste was reported. Within recirculated non-hazardous waste, reuse was 469 tonnes, recycling 5,082 tonnes and recovery 6,933 tonnes; non-recirculated waste of 6,264 tonnes comprised 5,121 tonnes energy recovery (combustion) and 1,142 tonnes landfill. By business unit, MT Højgaard Danmark's rate was 72.8% (77.5% in 2023) and Enemærke & Petersen's fell by 2.1% to 60.7%.

(Section ESRS S1, Policies, p 75) The Group's policies on its own workforce are anchored in the Code of Conduct (CoC), which applies to all employees, including consultants and temporary workers, and covers topics such as child labour, forced labour, equal opportunities, diversity and prevention of workplace accidents. These areas are supported by dedicated policies on human rights, gender equality and diversity, as well as health and safety. The CoC establishes a framework and conduct requirements that comply with Danish legislation and add further conduct expectations. It forms part of employment contracts and onboarding processes and is implemented in the corporate policies. The policies focus on gender, age, political persuasion and other markers of diversity as the basis for correct conduct. The listed policies are the Code of Conduct, the Human rights policy and the Equality and diversity policy.

(Section ESRS S1, Human rights and labour rights, p 81) The Group works closely with employees through different structures depending on the size and nature of each subsidiary, with resources allocated in management or HR functions for dialogue. In small subsidiaries, contact typically takes place directly between management and employees, with operational responsibility held by the CEO. Large companies have established collaboration with health and safety representatives and health and safety organisations, and a dedicated HR function, creating a formal forum for dialogue with employees and their representatives. Engagement varies in frequency and form: small subsidiaries use continuous dialogue and individual interviews, while large subsidiaries use formal meeting structures including half-yearly employee performance reviews (EPR), regular well-being surveys, health and safety and collaboration meetings, and onboarding and exit interviews. Meetings with trade unions and interest groups are also held as required. Employee representatives are involved in following up and determining initiatives, and two employee-elected board members sit on the Board of Directors.

(Section ESRS S1, Human rights and labour rights, p 81) The Group has established various processes and channels so that employees can express concerns and have them handled efficiently. For salaried employees, EPRs, exit interviews and well-being and collaboration surveys are offered, along with a health and safety organisation allowing employees to comment on processes; there are also WPAs, whistleblower schemes and management structures with a limited number of direct reports per manager. Surveys are carried out anonymously and closely followed up. Hourly-paid workers can contact their health and safety representative, trade union representative, the HR department or their trade union, and participate in labour market committee meetings. All employees can report concerns and raise complaints to the HR department, to their immediate superior, or anonymously via the Group's complaints option or whistleblower scheme (described on page 90). All complaints or grievances received are registered centrally to ensure overview and follow-up, and relevant processes are documented in systems and employee handbooks available to all employees.

(Section ESRS S1, pp 75-81) The Group takes action on material impacts across four topics: diversity and conditions, health and safety, training and development, and human rights and labour rights. On diversity, job postings are prepared for inclusive recruitment, and efforts focus on attracting and retaining more women as trainees, builders and managers; Enemaerke & Petersen ran networking events and school collaborations, and a 2024 analysis of organisational structure underpins action plans on unconscious bias. On health and safety, MT Hojgaard Danmark launched a new working environment strategy focused on cultural change, and Enemaerke & Petersen introduced internal audits; extended risk assessments aim to cut responses from the Danish Working Environment Authority. Well-being initiatives include coaching, stress management, online courses and monthly surveys. On training, apprenticeship and student recruitment efforts were strengthened and a sustainability course was developed. On human rights, the Group optimised complaint registration processes in 2024 and assesses green transition consequences in dialogue with employees.

(Section ESRS S1, pp 75-81) Targets were set for each topic with a view to reducing identified negative impacts and promoting positive impacts, developed with topic experts, the Executive Board and the Board of Directors. Employee representatives are not involved in setting targets, apart from the two employee-elected board members, but are involved in following up and determining initiatives. The 2025 diversity targets are to increase the proportion of women in hourly-paid positions to 5% and in salaried positions to 30%. The 2025 health and safety targets are to reduce the rate of accidents to below 8 and to reduce absence due to illness to less than 3.5%. The 2025 training targets are to strengthen training so that employees in training positions account for 10% of the workforce and to increase the number of training hours per employee to 30.

(Section ESRS S1-6, pp 75-77) The total workforce in 2024 was 3,298 employees, covering people who receive pay directly from the Group, including permanent, temporary, full-time and part-time employees. The average number of full-time employees over the year was 3,298 FTE (3,107 in 2023) and the average headcount was 3,465 (3,376 in 2023), split 38% salaried and 62% hourly-paid. By country, headcount was 2,967 in Denmark, 249 in Greenland, 190 in the Maldives and 58 in Vietnam. By type of contract (headcount), there were 3,366 employees in total (400 female, 2,966 male), of whom 3,195 were permanent (358 female, 2,837 male) and 171 were temporary (42 female, 129 male); there were also 185 non-guaranteed hours employees (26 female, 159 male). Own workforce also includes people who are not employed by the company but have contracts to supply labour, such as consultants and staff hired on contract basis, typically through staffing or temporary employment agencies.

(Section ESRS S1-9, p 77) Women represented 11.3% of the Group's workforce in 2024, up from 10.2% in 2023. The proportion of women in salaried positions rose to 24.4% (23.2% in 2023) and in hourly-paid positions to 2.9% (2.2% in 2023). Among members of management (excluding the Executive Board), women made up 29.6% (23.9% in 2023), representing 18 women and 44 men, and women on the Executive Board rose to 5.2% (0% in 2023). Men made up 88.7% of the Group. The 'other gender' category was 0.0% in 2024 (0.1% in 2023). The age structure was fairly evenly distributed, with 22% of the workforce below 30 years, 47% between 30 and 50 years and 32% over the age of 50; in headcount terms this was 728 employees under 30, 1,571 aged 30 to 50 and 1,067 over 50.

(Section ESRS S1-13, p 80) In 2024 the proportion of employees in training positions fell to 8.1% (8.3% in 2023), as the number of training positions was virtually unchanged while the workforce grew; the majority of training posts are filled by apprentices, with the distribution of apprentices/trainees/students/student assistants/industrial PhDs at 68/3/8/20/1. The number of training hours per employee fell to 27.5 (30.2 in 2023), driven in particular by Enemaerke & Petersen and Raunstrup. Reported for the first time this year, training hours per employee were 27.9 for female employees, 27.5 for male employees, 15.9 for salaried employees and 35.0 for hourly-paid employees. A total of 21.8% of employees completed at least one skills development review during the year (a new datapoint, with no 2023 data), broken down as 43.7% of female employees, 19.0% of male employees, 53.8% of salaried employees and 1.3% of hourly-paid employees; the number of reviews per employee was 0.3.

(Section ESRS S1-14, pp 78-79) The employee health and safety metrics are reported (the non-employees part is subject to the phase-in provision). In 2024 there were 111 workplace accidents with absence (up 13.3% from 98 in 2023) and 138 without absence (139 in 2023). Lost days fell to 928 (982 in 2023). The rate of accidents rose to 18.9 (17.3 in 2023), comprising 29.2 for hourly-paid employees (27.4 in 2023) and 0.9 for salaried employees (0 in 2023). There were 0 fatal accidents among employees and 0 among sub-contractors, unchanged from 2023. 69.8% of the Group's total workforce was covered by a health and safety management system; the two largest companies, MT Hojgaard Danmark and Enemaerke & Petersen, are certified to ISO 45001, giving 100% coverage in those companies. Absence due to illness fell to 3.5% (3.7% in 2023). Total employee turnover was 38.8% (unchanged from 2023), with 1,343 employees leaving; turnover was 48.5% for hourly-paid and 23.4% for salaried employees. The Group received 60 responses from the Danish Working Environment Authority (111 in 2023) and recorded 222 WEA visits.

(Section ESRS S1-16, p 77) The gender pay gap in the Group was -5% in 2024, meaning that on average men in the Group earned 5% less than women. The pay gap indicates the difference between average gross hourly earnings of male and female employees, expressed as a percentage of average gross hourly earnings of male employees, calculated for the total workforce including the Executive Board and broken down by hourly-paid and salaried employees; employees identifying as 'other gender' or who did not wish to disclose are not included. The ratio between the highest paid individual and the rest of the workforce was 14. The Group reported these two key figures for the first time in 2024, and therefore no figures are available for 2023. Reporting on the pay gap and total remuneration is stated to support transparency about pay conditions and highlight any gender-based pay gaps.

(Section ESRS S1-17, p 81) In 2024, three complaints were registered, received via channels for employees including through the HR department or the employees' own managers (three complaints in 2023). Two of these complaints were categorised as discriminatory treatment. None of the reported complaints were submitted through the National OECD Contact Point or categorised as severe human rights incidents. In one incident of discriminatory treatment, the injured party received DKK 20,000 in compensation for failure to act on abusive behaviour. The metrics table records 2 incidents of discriminatory treatment (3 in 2023), 3 complaints via channels for employees (3 in 2023), 0 complaints via the National OECD Contact Point, DKK 20,000 in fines etc. resulting from employee complaints, 0 severe human rights incidents among employees (including 0 incidents in violation of the UN Guiding Principles and the OECD Guidelines), and DKK 0 in fines etc. connected with severe human rights incidents. The Group states it does not tolerate any form of discriminatory treatment.

(Section ESRS S2-1, pp 84-85) MT Højgaard Holding identifies suppliers and sub-contractors as key to its business model, creating a responsibility to promote decent working conditions across the value chain. The main policies are the human rights policy and the Supplier Code of Conduct (CoCe). The human rights policy covers both own employees and workers in the value chain and follows the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises and the ILO Declaration on Fundamental Principles and Rights at Work. It explicitly sets a zero-tolerance approach to forced labour and child labour throughout the value chain and addresses compliance with labour rights. The Supplier Code of Conduct sets the rules and conduct required of business partners, requiring respect for ILO labour standards, a safe working environment, freedom from forced and child labour, protection against precarious work, and workers' right to unionise. It also sets requirements for employee training and adequate protective equipment. The Group reports there have been no cases of non-compliance with the policies in the value chain.

(Section ESRS S2-1, pp 84-85) The Group assesses how actual and potential impacts on value chain workers relate to its strategy and business model, including its dependency on global suppliers and sub-contractors. It assesses whether negative impacts are widespread or systematic, whether they arise from individual events or specific business relationships, and whether particular groups are exposed, for example risks of child or forced labour in specific supply chains or regions. The transition to more sustainable materials is treated as an essential part of identifying and preventing potential negative impacts, ensuring the green transition does not impair working conditions in the value chain. The general process to ensure workers in the value chain are heard is through the whistleblower scheme, the Group's other complaint channels and the Group's inspections of pay and working conditions. Workers in the value chain are informed about complaint procedures via the Group's websites, and an internal awareness campaign has been launched, with both initiatives allowing anonymity. The report states that workers in the value chain or their legitimate representatives have not been involved in setting the target or following up on its effectiveness.

(Section ESRS S2-3, pp 84-85, 92-93) Workers in the value chain can raise concerns through the Group's whistleblower scheme, its other formal complaint channels and its inspections of pay and working conditions. Concerns may be reported anonymously through the formal complaint channels, which is why workers in the value chain are considered to have confidence in the complaint procedures. The Group's options for raising complaints are further described in the section on corruption and whistleblower actions on page 90. Responsibility for dialogue sits partly centrally in MT Højgaard Holding's internal control unit, which handles whistleblower reports and performs inspections, with formal complaints handled together with informal complaints raised at construction sites. Anchoring and follow-up procedures depend on the nature of the complaint. Through inspections of pay and working conditions the Group prevents, hears about and remedies negative impacts or human rights violations through correction and compensation, with correction carried out immediately after inspection, which is considered effective. Identified violations and dialogue on them feed into decisions on future prevention and remediation. Effectiveness is monitored through the number of enquiries and an internal evaluation of the dialogue.

(Section ESRS S2-4, pp 84-85, 92-93) In 2024 the Group strengthened its proactive inspections of pay and working conditions among sub-contractors to prevent and mitigate negative consequences for value chain workers, with prioritised resources across subsidiaries. The proactive inspections generally cover all sub-contractors in the relevant construction chain and aim to ensure that all workers at the Group's construction sites have pay and working conditions complying with applicable collective agreements, that any violations are handled and corrected, and, where relevant, that housing conditions meet requirements. Sub-contractors are selected for control based on risk assessments for each building project and previously identified violations. Inspections carried out rose to 31 in 2024 (25 in 2023) and 43 suppliers were subjected to inspection (41 in 2023), driven mainly by MT Højgaard Danmark, with control efforts expanded to more Group companies including NemByg and Raunstrup for the first time. The proportion of suppliers with an identified violation fell to 51.2% in 2024 (58.5% in 2023), while the proportion of violations subject to penalties rose to 90.9% (75.0% in 2023), reflecting stricter compensation requirements such as back-payments to affected workers. No severe human rights problems or incidents were identified in the up- and downstream value chains during 2024.

(Section ESRS S2-5, p 84) The Group's 2025 targets for workers in the value chain are to strengthen due diligence in the value chain and among suppliers and sub-contractors exercising responsible practices, and to increase the Group's inspections of sub-contractors' social conditions. The level of inspections is expected to increase in 2025. Progress towards achieving the target is assessed on the basis of the number of inspections and the number of suppliers subjected to inspection, together with an analysis of violations and remedial actions. The report states that workers in the value chain or their legitimate representatives have not been involved in setting the target or following up on its effectiveness.

(Section ESRS S3-1, p 86) MT Højgaard Holding treats consideration for communities affected by its construction and civil engineering projects as a priority and aims to contribute positively through social initiatives and support to local communities. The key policies are the Code of Conduct (CoC), the Code of Conduct for suppliers and the climate and environmental policy. These policies oblige the Group's employees to be responsible and show respect for affected communities, including responding to any improvement potential for users and the local environment, especially in the case of nuisance from construction sites. The Group is committed to the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises. The policies respect the rights of local communities in accordance with international standards. The Group balances the need for development with the interests of the people and communities affected by its operations while supporting them through social initiatives and local job creation, and assesses that its green transition also has a positive impact on local communities.

(Section ESRS S3-2, pp 86-87) The Group integrates the views of affected communities through materiality assessments and risk management processes and works to minimise risks through planning, open communication and close dialogue. Identified material negative impacts relate to residents and communities around construction sites who may experience direct nuisance or inconvenience and lack of engagement. A phase model shows how the perspectives of affected communities are typically included across project development and tenders, execution and handover, using collaborative processes and channels for dialogue such as information and dialogue meetings, written information to neighbours, project e-mail and hotlines, notice boards and signs, resident coordinators, and evaluation via questionnaires or interviews. The type and intensity of interaction varies by project, including specific initiatives for vulnerable groups such as older people with low digital skills or people with limited language skills. In many cases the client acts as a substitute for affected communities and dialogue is conducted with the client's representatives; for end-users dialogue is often ensured through contractual obligations, for example by appointing a resident coordinator. The report states that affected communities have not been directly involved in setting the group targets or evaluating results.

(Section ESRS S3-3, pp 87, 90) To ensure effective remediation of negative impacts, the Group uses structures such as information meetings, direct contact at the construction site and complaint procedures. All enquiries from affected communities are systematically followed up, categorised and evaluated to prevent recurring issues, and efforts are continuously adjusted so that the desired results are achieved quickly, with processes adapted to the size, type and context of each project. Responsibility for dialogue and remediation lies with the persons responsible for the construction phases, such as design managers or project managers, who monitor and adapt efforts. In the event of a lack of trust or persistent issues, preventive and remedial actions are intensified. In addition to the project channels, affected communities may use the Group's complaints procedures and whistleblower scheme, described on page 90, including how anyone making an enquiry is protected against retaliation if they report concerns or lodge complaints. Effectiveness is assessed by following up on enquiries and analysing whether the desired results have been achieved, drawing on feedback from project and client meetings and patterns in enquiries.

(Section ESRS S3-4, pp 86-87) The Group respects the human rights of affected communities and focuses on minimising the identified negative impacts from construction sites, which for affected communities may involve managing noise, dust and access routes, while the focus for end-users is often on minimising the impact on their daily lives, especially in connection with staged renovations or new builds. In 2024 a number of initiatives strengthened dialogue and cooperation with affected communities, with a special focus on renovation projects where MT Højgaard Danmark optimised processes for information and dialogue through residents' meetings. MT Højgaard Property Development, given its role as client, implemented strengthened procedures for organising open house events before and during project start-up and established processes to make employees more visible and accessible on construction sites. The Group also supports local communities and social initiatives through local job creation, with Enemærke & Petersen and MT Højgaard Danmark creating job opportunities for young people outside the labour market through cooperation with social enterprises, cooperation with TAMU, and an agreement with Lokalsjakket in Gellerup. In 2024 the Group did not identify any severe human rights problems or legal disputes related to local communities.

(Section ESRS S3-5, p 86) The Group's 2025 targets for affected communities are to take into account affected communities in the construction process, support local communities and social initiatives, enable the calculation of contributions to employing people who are outside the labour market, and strengthen employment initiatives targeted at people who are outside the labour market and contribute to solving challenges in local communities. The targets are designed to reduce the negative impact of projects and to reduce social challenges in local communities by increasing employment among marginalised groups and creating positive social impacts through training and job opportunities. The Group plans to track the effectiveness of the targets in evaluating employment processes for people who are outside the labour market. The report states that affected communities have not been directly involved in setting the group targets or evaluating results.

(Section ESRS G1-1, p 89-90) MT Højgaard Holding states that integrity, accountability and transparency in business conduct, supported by a strong and healthy corporate culture, are crucial to delivering quality projects and creating value. Responsible business conduct is treated as a core objective. The Group relies on several policies: a Code of Conduct for employees, a Supplier Code of Conduct, an anti-corruption policy and a whistleblower policy. The anti-corruption policy sets out a zero-tolerance approach to corruption, bribery and sanctions violations. The whistleblower policy complies with the EU Whistleblower Directive and applies to both employees and external stakeholders. There is no separate business conduct training policy, as this is integrated into the above policies. Corporate culture is developed through clear policies, training programmes, internal communication and continuous evaluation, with the Board of Directors and Executive Board setting the direction and following up on themes such as diversity, inclusion and responsible conduct. During the year, the sub-topic Protection of whistleblowers changed to material for the Group.

(Section ESRS G1-3, p 90) The Group applies a zero-tolerance approach to corruption and bribery and gives prevention and controls high priority. It has established central procedures for the prevention, detection and management of corruption and bribery. Preventive measures include a two-factor approval procedure for invoices, which ensures consistency between invoice and delivery. Suspicions or incidents are handled reactively by an internal control unit that works independently of management layers and projects, is anchored in MT Højgaard Holding and reports to the Board of Directors; the unit handles reports from internal and external stakeholders via secure reporting channels and ensures documentation and follow-up. In 2024, the Group launched an anti-corruption and anti-bribery training programme, available online to all employees and mandatory for employees in risk functions, including the Executive Board, management, project management, procurement and contract management. In 2024, 57.7% of employees in risk functions completed the programme; as this is a new reporting area, 2023 data were not compiled. The Code of Conduct training is a mandatory part of onboarding.

(Section ESRS G1-4, p 90) No violations of anti-corruption laws were reported in 2024, and the Group received no judgments or fines as a result of corruption or bribery-related incidents. In 2024, there was one internal corruption incident involving employees, which resulted in the dismissal of one employee. The reported figures show incidents of corruption or bribery at 1 in 2024 (1 in 2023), of which 1 had employment law consequences in each year, with 0 judgments and decisions and DKK 0 in fines in both years. The Group received 1 report via the whistleblower scheme in 2024 (3 in 2023), and 0 cases were reported via the Group's complaints procedure. In 2024 a campaign was launched to raise awareness of the whistleblower scheme and reporting procedures, advertised on websites and intranets and with posters at construction sites in Danish, English and Polish. For 2025, further initiatives are planned to strengthen the fight against corruption and bribery based on a supply chain risk assessment.