MT Højgaard Holding

Reference: page 68

MT Hojgaard Holding describes its governance structure. The general meeting is the Group's supreme authority; the Board of Directors has overall responsibility for the Group's management and long-term value creation, including strategy and objectives, supervision of the Executive Board, financial oversight and risk management. Three 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, monitoring progress and the annual review of the double materiality assessment) and the Nomination and Remuneration Committee (board and management composition, remuneration policy).

In 2025 the Board had eight members: six elected by the general meeting for one-year terms and two employee representatives. Morten Hansen is Chairman and Knut Akselvoll is Deputy Chairman, having taken over from Carsten Dilling at the 19 March 2025 AGM. The proportion of independent shareholder-elected board members was 100.0%, and the under-represented gender reached 50% of shareholder-elected members (43% in 2024), meeting the Group's 2028 target early. The Executive Board comprised CEO Rasmus Untidt throughout 2025. The Board held six ordinary meetings, two strategy days and a board seminar, and conducted an externally facilitated evaluation of its own effectiveness.

Reference: page 34

The Board of Directors is described as MT Hojgaard Holding's supreme governing body with overall responsibility for monitoring ESG impacts, risks and opportunities, and it approves the Group's double materiality assessment and all ESG targets annually. ESG-related topics are addressed three times a year as part of the Board's annual cycle. The Sustainability Committee advises on ESG strategy, monitors progress and annually reviews the DMA before it is submitted to the Board for approval, holding four regular meetings in 2025 and also participating in three Audit Committee meetings to monitor ESG reporting. The Audit Committee discussed sustainability at three meetings in 2025, and the frequency of ESG risk reporting increased from annual to semi-annual as ESG risks were integrated into the Group's overall risk management framework.

The Executive Board has overall responsibility for setting and monitoring ESG targets and for integrating ESG matters into strategic decisions, and receives ongoing feedback on progress and due diligence which it reports to the Board. The temporary CSRD Steering Committee established in 2024 was discontinued in 2025 following successful implementation of the new reporting requirements, with coordination now handled through a Sustainability network.

Reference: page 66

MT Hojgaard Holding describes how sustainability performance is linked to incentive schemes. In 2025 the Group's bonus scheme was revised and split into a Long-Term Incentive (LTI) programme and a Short-Term Incentive (STI) programme, and the weighting of ESG-related KPIs increased from 10% to 20% of total bonus. In the LTI programme, the proportion of the under-represented gender and Scopes 1 and 2 emissions each account for 10% of the total LTI bonus. In the STI programme, the rate of accidents and recirculated waste each carry a 10% weighting. The LTI programme covers 47 managers across the Group's companies, including the Executive Boards of MT Hojgaard Holding, MT Hojgaard Danmark and Enemaerke & Petersen, while the STI programme covers only the executive boards of those companies.

The Nomination and Remuneration Committee of the Board of Directors prepares recommendations for the bonus programme, which the Board of Directors then approves. The disclosed variable remuneration linked to sustainability-related targets was 20% in 2025, up from 10% in 2024.

Reference: page 67

The company presents its due diligence statement, describing a systematic, risk-based process integrated into existing practices and risk management, consisting of five steps: embedding due diligence in governance, strategy and business model; engaging with affected stakeholders; identifying and assessing negative impacts; managing negative impacts; and tracking and communicating the effectiveness of actions. The process also supports the Group's compliance with the EU Taxonomy's minimum safeguards.

The work is based on the Group's double materiality assessment (page 36) and sustainability strategy (page 33), and is supplemented by two in-depth risk assessments covering materials and business partners (subcontractors and other suppliers) to examine negative impacts and risks in the value chain in greater detail. ESG risks are also incorporated into the Group's ERM process, assessed semi-annually and reported to the Audit Committee. Specific initiatives to manage negative impacts are described under each material topic: Climate change (pages 44-48), Circular economy (pages 49-50), Own workforce (pages 57-60) and Business conduct (pages 65-66). Results are communicated through the annual ESG reporting and the Group's website.

Reference: page 42

MT Hojgaard Holding describes its risk management and internal controls over sustainability reporting. Processes for ESG reporting are described for each individual business unit, and all ESG data are defined in the Group's ESG data manual. All reported ESG data are verified according to the four-eyes principle, and the Group continuously monitors its processes and controls to ensure efficiency and data quality. Risks in ESG data are assessed and prioritised with a focus on significant deviations and data quality, with typical risks comprising manual entries and local variations in data definitions. To mitigate these risks, dedicated employees have been appointed who regularly perform oversight assignments, analyse developments and carry out spot checking; results are reported annually to the Audit Committee.

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.

Reference: page 8

The company describes its business model and strategy. MT Hojgaard Holding's business units develop, plan and carry out newbuild, civil engineering and infrastructure, and refurbishment and service projects, drawing on inputs of employees, knowledge and innovation, materials and raw materials, partners and suppliers, and capital raised through operations and credit facilities. Outputs and value creation are described for clients, end-users and the local environment, social developments, environmental considerations, safety and well-being, and investors.

In 2025 a new group strategy for 2026-28 was prepared and the double materiality assessment updated; the ESG strategy rests on three pillars (environment, social, governance) addressing both risks and opportunities from the sustainable transition, including climate adaptation, energy transition, low-emission construction and building transformation. Average headcount and geographical breakdown are reported under Social data (page 61: Denmark, Greenland, the Maldives and Vietnam). Following the 2025 update, MT Hojgaard Property Development was integrated into MT Hojgaard Danmark and no longer forms a separate reporting segment.

Reference: page 40

The company describes the interests and views of its stakeholders. MT Hojgaard Holding maintains ongoing dialogue with nine prioritised stakeholder groups: clients, employees, consulting engineers and architects, suppliers and subcontractors, local communities and end-users, public authorities, educational institutions, industry organisations and shareholders/financial institutions. A table sets out for each group the interaction channels used, their key ESG topics and concerns, and related Group initiatives; for example, suppliers and subcontractors are engaged through project collaboration, framework agreements and oversight of working conditions, focused on fair agreements, ESG data access and requirements for certifications and the EU Taxonomy.

Targeted stakeholder interviews are conducted annually to assess how the Group's activities impact, or are impacted by, stakeholders across the value chain, and internal input from employees is gathered through open dialogue, satisfaction surveys and employee representative forums. Insights from stakeholder dialogue feed into the double materiality assessment, due diligence and the development of ESG initiatives, targets and strategy, and are communicated to the Executive Board and Board of Directors.

Reference: page 36

The company describes its material impacts, risks and opportunities and their links to strategy and business model. The double materiality assessment shows six of the ten ESRS topics are material: Climate change (E1), Biodiversity and ecosystems (E4), Resource use and circular economy (E5), Own workforce (S1), Workers in the value chain (S2) and Business conduct (G1). Across these six topics, 13 sub-topics were assessed as material, and a total of 23 IROs have been identified as material to the Group.

Compared with the prior year's assessment, Pollution (E2) and Affected communities (S3) are no longer considered material, primarily due to a change in the scoring methodology for impact materiality; the sub-topics Other labour-related human rights under Workers in the value chain (S2) and Protection of whistleblowers under Business conduct (G1) also fell out of scope. Under the European Commission's "Quick Fix" regulation, the Group has chosen to defer reporting on Biodiversity (E4) and Workers in the value chain (S2); both remain material and are included as strategy focus areas, with targets, actions and KPIs to be fully integrated no later than FY2027.

Reference: page 37

The company describes the process used to identify and assess material impacts, risks and opportunities. The double materiality assessment (DMA) is prepared across the Group in accordance with the criteria of ESRS 1 and EFRAG's methodological framework, and follows three steps: mapping and identification (business model and value chain mapping, workshops and interviews with internal and external experts), assessment, and approval. Impacts are assessed on a 1-5 scale based on severity, scope, irremediability and likelihood; risks and opportunities are assessed on a 1-5 scale based on potential financial effect and likelihood, with time horizons of short (up to 1 year), medium (2-5 years) and long term (over 5 years) established for each material IRO.

In 2025 a minor update to the DMA methodology was made: severity is now based on the average, rather than the highest, of the scale/scope/irremediability scores, which meant certain impacts no longer exceeded the materiality threshold. The assessment is reviewed by the Group Executive Board, then the Sustainability Committee, and finally approved by the Board of Directors.

Reference: page 42

The company sets out the ESRS disclosure requirements covered in its sustainability statement, confirming the statement was prepared with reference to 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. Tables on pages 141-142 map each disclosure requirement to its section and page, and cross-reference requirements to other EU legislation (SFDR, the Benchmark Regulation, Climate Law and Pillar 3), noting datapoints treated as not material or subject to phase-in.

A box on page 42 lists disclosures incorporated by reference elsewhere in the management review, including the business model (SBM-1, page 8), headcount by geographical area (SBM-1, page 61), IROs (SBM-3, pages 43, 56, 64), corporate governance (GOV-1, pages 68-70), ESG remuneration (GOV-3, page 66) and due diligence (GOV-4, page 67).

Reference: page 44

MT Hojgaard Holding describes its plan to reduce GHG emissions from own operations (Scopes 1 and 2) and the value chain (Scope 3). In 2025 the Group adjusted its climate targets from being aligned with a 1.5C pathway to instead supporting "well below 2C", so, in the report's own words, "there is no longer a transition plan in line with a 1.5C scenario (cf. ESRS E1-1)"; a reduction plan was developed instead to support the revised Scopes 1 and 2 targets, which the Group states remain eligible for Paris-aligned EU benchmarks. The Group is not committed to the Science Based Targets initiative, though the revised targets are based on the SBTi methodology.

The Scopes 1 and 2 reduction plan focuses on three action areas: energy efficiency and optimisation, electrification and renewable energy, and increased use of low-emission fuels such as HVO biodiesel. The report notes that "it is recognised that parts of the emissions, especially in Scope 1, are locked-in due to existing long-life assets, including large machinery, where emission-free alternatives are still limited." A separate, less quantified reduction plan covers Scope 3, given the Group's limited direct influence over value-chain emissions.

Reference: page 41

The Group's climate and environmental policy describes its ambition to reduce direct and indirect climate and environmental impacts in accordance with the Paris Agreement and Denmark's national climate targets. The policy sets the framework for limiting greenhouse gas emissions in own operations and across the value chain through energy-efficient solutions, increased renewable energy use, and resource efficiency and circular economy principles. It also outlines efforts to prevent pollution, minimise air emissions and phase out problematic substances, and supports climate change adaptation.

Policies apply to all Group employees, including subsidiaries where MT Hojgaard Holding holds a controlling interest, and are approved through a four-step model culminating in Board of Directors or Executive Board sign-off; they are reviewed at least once a year. The Group 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 when developing policies.

Reference: page 45

The Group sets out actions supporting its reduction targets across three focus areas. First, energy efficiency and optimisation: many construction sites are energy-intensive, and measures such as reduced idling, energy-optimised site facilities and improved use of machinery aim to lower consumption. Second, electrification and renewable energy: passenger cars, smaller equipment and hand tools are being electrified in line with technology, alongside procurement of renewable electricity and own solar installations. Third, increased use of low-emission fuels: a gradual introduction of certified low-emission fuels such as HVO biodiesel targets diesel-heavy machinery where electrification is not yet realistic.

Concrete 2025 initiatives include Enemaerke & Petersen and Raunstrup transitioning vehicle fleets to electric (around 59% of passenger cars electric in 2025), speed limiters on diesel vehicles, and progress toward ISO 14001 environmental management certification at MT Hojgaard Danmark, Enemaerke & Petersen and Raunstrup. The plan states these efforts must offset the Group's growing activity level as well as deliver actual emissions reductions.

Reference: page 44

The Group discloses its 2028 and 2030 climate targets. For Scopes 1 and 2, the target is a 12.2% reduction by 2028 and 25% by 2030 versus a 2023 base year (11,878 tCO2e); 2025 emissions of 13,001 tCO2e represent a 12.2% reduction against the base year on the chart shown, though the accompanying text notes emissions increased compared with the 2023 baseline, meaning the Group must cut emissions by 31% overall by 2030 to reach the target. For Scope 3, the target is a 12.8% reduction by 2028 and 25% by 2030 versus a 2023 base year of 463,806 tCO2e.

The targets were adjusted in 2025 from alignment with a 1.5C pathway to "well below 2C," reflecting, as the Group states, "a changed business model, with increased focus on emissions-intensive projects within civil engineering & infrastructure," and are not validated by the Science Based Targets initiative, though based on its methodology. The Group states it remains eligible for Paris-aligned EU benchmarks.

Reference: page 54

The Group reports total energy consumption of 58,027 MWh in 2025 (63,457 MWh in 2024), a decrease of 8.6%. Of this, 86.8% came from fossil sources (50,357 MWh; 87.7% in 2024), 11.8% from renewable sources (6,844 MWh, up 2.1% from 7,330 MWh; renewable share up from 11.6%), and 1.4% from nuclear sources embedded in market-based electricity declarations (826 MWh, up from 444 MWh). Crude oil and petroleum products (mainly diesel) account for the largest single fossil category at 77.4% of total consumption (44,897 MWh).

Renewable energy is defined to include wind, solar, geothermal, hydropower, biomass and biogas, covering the Group's biodiesel consumption, the renewable share of market-based electricity and heat declarations, and electricity under contractual renewable energy agreements. Energy intensity for Scopes 1-2 was 5.62 MWh per DKK million turnover, down 3.0% from 5.80 in 2024.

Reference: page 52

MT Hojgaard Holding reports Scope 1 emissions of 12,118 tCO2e in 2025 (13,298 tCO2e in 2024, -8.9%), Scope 2 location-based emissions of 883 tCO2e (975 tCO2e, -9.4%) and Scope 2 market-based emissions of 2,633 tCO2e (2,854 tCO2e, -7.7%). Scope 3 emissions totalled 417,091 tCO2e (462,086 tCO2e, -9.7%), dominated by Category 1 Purchased goods and services at 382,549 tCO2e (91.7% of Scope 3), which itself fell 14.1% on lower subcontractor-related emissions even as purchased building materials rose 15.1%. Total Scopes 1-3 location-based emissions were 430,092 tCO2e (476,359 tCO2e in 2024, -9.7%).

Emissions are calculated under the financial control method per EFRAG's Value Chain Implementation Guide (operational control for joint ventures and associates), using emission factors from the Danish Energy Agency, DEFRA, EXIOBASE, EPA and Climatiq depending on category. Emission intensity (Scopes 1-3, market-based) was 41.94 tonnes per DKK million turnover, down 4.0% year on year. Only 24.0% of Scope 3 is calculated from primary supplier data (13.7% in 2024).

Identification of climate-related risks and scenario analysis

Back-filled from the dedicated "Resilience to climate change" section, where this content is disclosed in the FY2025 report (page 48). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The Group's climate risk analysis classifies material risks into physical and transition categories (page 48). Physical risks, "extreme weather events and climate-related natural phenomena directly derived from climate change," are assessed under the EU Taxonomy Regulation; transition risks and opportunities are assessed using the TCFD recommendations.

Scenarios used (page 48): the analysis applies RCP 2.6, RCP 4.5 and RCP 8.5 across short, medium and long time horizons (to 2050, 2050-2070, 2070-2100). RCP 8.5 is a "business-as-usual" scenario with warming above 4C; RCP 2.6 requires global efforts to stay below 2C; RCP 4.5 is a moderate 2.5-3C scenario. The analysis covers all Group companies and the geographical location of assets, including Denmark, the Maldives and Vietnam, and was updated in 2025. No single scenario is flagged as the "high-emission" or "1.5C-aligned" reference case in the ESRS E1-2 sense; all three RCP scenarios run in parallel.

Related disclosure: the 2028/2030 reduction targets were this year realigned from a 1.5C pathway to "well below 2C" (E1-1, E1-4, page 44).

Resilience in relation to climate change

Back-filled from the dedicated "Resilience to climate change" section, where this content is disclosed in the FY2025 report (page 48). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

The Group's resilience analysis was updated in 2025 (page 48), assessing climate-related risks and opportunities to inform strategic decisions and future competitiveness. Results identify physical risks, flooding, heavy precipitation, sea level rise and landslide, affecting activities in Denmark (long-term building damage risk near water) and particularly the Maldives (medium-term risk to buildings, machinery and site cabins). Transition risks include stricter climate requirements for machinery and construction processes and weakened competitiveness if the Group's transition lags market expectations, mainly affecting newbuild and civil engineering activities. Transition opportunities are identified in climate adaptation projects (cloudburst and coastal protection, port renovation) and energy-efficient renovation of the existing building stock under the EU Energy Efficiency Directive.

A risk or opportunity is treated as material "when there is high vulnerability" (page 48). The Group's transition plan (E1-1, page 44) and reduction plans (E1-3, page 45) are presented as its response, alongside recognition that Scope 1 emissions from long-life machinery are locked-in near term.

Reference: page 41

The Group's climate and environmental policy (page 41) extends to biodiversity: it states the Group "works to protect biodiversity and limit natural resource consumption through responsible procurement and construction practices." Page 36 similarly notes the "Group's Climate and Environmental Policy includes a clear ambition to reduce significant negative biodiversity impacts through responsible resource consumption." No biodiversity-specific standalone policy is presented; this ambition sits within the same Group-wide climate and environmental policy that also covers E1 mitigation and E5 circular economy commitments, approved through the Group's four-step model culminating in Board of Directors or Executive Board sign-off and reviewed annually.

Caveat: the Group's own ESRS disclosure requirements table from other legislation (page 142) marks several E4-2 datapoints, paragraph 24(b), 24(c) and 24(d), as "Phase-in requirement," and the topic itself is deferred under the "Quick Fix" regulation (page 37), so more granular biodiversity policy content (e.g. site- or species-specific commitments) is not yet disclosed.

Reference: page 41

Circular economy commitments sit within the Group's climate and environmental policy (page 41), which "supports a sustainable transition by promoting the reuse and recycling of materials and reducing reliance on critical and non-renewable raw materials" and outlines efforts across resource efficiency and circular economy principles. Page 49 restates the Group's operating objective: "to reduce use of materials, keep materials in circulation for as long as possible and manage waste in accordance with the waste hierarchy, prioritising reuse, recycling and materials recovery." The policy is reviewed annually and approved via the Group's four-step model culminating in Board of Directors or Executive Board sign-off, and applies across all Group companies alongside company-specific operational policies.

Reference: page 49

The Group describes actions to strengthen circularity across design, execution and completion of projects. In 2025 the waste recirculation target was revised from 75% to 80%, now including demolition waste and excluding hazardous waste, "to provide a more accurate picture of the Group's overall waste streams." A new qualitative target to reduce material losses at construction sites was also introduced, alongside continued focus on responsible material procurement.

Concrete actions in 2025 (pages 49-50) include Enemaerke & Petersen's continued collaboration with Genbyg, which screened around 80% of its construction sites for direct-reuse material removal, and MT Hojgaard Danmark's development and dissemination of practical waste-sorting guides. Case examples include a reused-pantile facade at the Kontorhus BF2.04 project in Nordhavn (approximately 70,000 kg CO2 reduction, 15,000 reused tiles) and reuse of approximately 20,000 m2 of stone wool insulation at the Grantofteparken refurbishment in Ballerup (over 170 tonnes recycled).

Reference: page 49

The Group's 2028 target is to recirculate a minimum of 80% of waste, excluding hazardous waste; 2025 performance reached 77.9% (66.6% in 2024). The target was revised in 2025 to include demolition waste for the first time and to exclude hazardous waste, on the basis that hazardous waste "must largely be landfilled regardless of efforts made and therefore does not reflect the actual potential for influence through measures such as on-site waste sorting."

A complementary qualitative target was introduced in 2025 to reduce material losses at construction sites; the report states "it is not yet possible to quantify the extent of these losses," and work is underway to build the data foundation needed to set a measurable reduction target. No quantitative target has yet been set for resource inflows or the recycled share of materials, which were reported for the first time in 2025 (page 50).

Reference: page 55

Resource inflows were reported for the first time in 2025. The total weight of materials used was 1,164,755 tonnes (up from 1,646,838 tonnes on the prior comparative basis shown, a 29.3% decrease). The assessment covers materials purchased directly and estimated quantities used by subcontractors, calculated from the Scope 3 Category 1 CO2e statements by applying a weight-per-emissions factor. The recycled share of concrete and steel, among the Group's most significant materials, was 1.9% in 2025 (2.9% in 2024, on a comparable definition).

The Group states the purpose of the new resource-inflow reporting is "to create a better overview of the Group's material consumption and identify potentials for increased recycling and resource efficiency" (page 50), and notes that realising higher recycled content depends heavily on client requirements and material availability, since the Group's direct influence over material selection is limited (page 49).

Reference: page 55

Total waste volume in 2025 was 77,122 tonnes (19,310 tonnes in 2024), the increase driven by the inclusion of demolition waste for the first time (60,616 tonnes, 78.6% of the total). Construction waste fell 15% to 15,963 tonnes. Of total waste, 73,876 tonnes (95.8%) was classified non-hazardous. The recirculation rate (reuse, recycling and materials recovery, excluding hazardous waste) rose to 77.9% from 66.6% in 2024; isolating construction waste alone, recirculation rose to 68.9% from 66.5%, driven by MT Hojgaard Danmark's rate climbing to 76.7% from 72.8%, while Enemaerke & Petersen's fell to 58.1% from 60.7% due to a higher share of mixed refurbishment-derived fractions.

By treatment method, the Group reports 12,847 tonnes reused, 41,596 tonnes recycled, 3,247 tonnes materials-recovered, 15,316 tonnes energy-recovered and 3,004 tonnes landfilled (2025 figures). A 2025 focus area was reducing mixed, unsortable waste through practical sorting guides developed by MT Hojgaard Danmark.

Reference: page 55

The waste table on page 55 breaks total 2025 waste of 77,122 tonnes down by type: construction waste 15,963 tonnes (20.7%), demolition waste 60,616 tonnes (78.6%, reported for the first time in 2025 with no adjusted comparative), and household waste 543 tonnes (0.7%). By management method: reuse 12,847 tonnes, recycling 41,596 tonnes, materials recovery 3,247 tonnes, energy recovery (combustion) 15,316 tonnes and landfill 3,004 tonnes. Hazardous waste was 3,247 tonnes (4.2% of the total), including 2,632 tonnes recirculated; no radioactive waste was recorded.

Total recirculated waste (excluding hazardous waste and demolition waste, for comparability with prior years) reached a rate of 68.9%, up from 66.5% in 2024. Accounting policy notes that waste reporting follows the financial control approach and includes only activities the Group is directly invoiced for.

Reference: page 41

Own-workforce policies form part of the Group's broader policy suite (page 41). The Employee Code of Conduct sets the overall framework for behaviour, ethical standards and culture, covering climate and environment, accident prevention, labour rights, human rights, inclusion and anti-discrimination; it is integral to employment contracts and reviewed at onboarding. The human rights policy "commits the Group to respecting human and labour rights in its own operations and throughout the value chain," including a zero-tolerance approach to forced and child labour and requirements for fair wages. The gender equality and diversity policy "promotes an inclusive culture with a focus on equal opportunities, gender balance in management, equal pay, flexibility and respectful workplace interactions."

Policies are prepared by responsible functions and approved through a four-step model culminating in Board of Directors or Executive Board sign-off, reviewed at least annually, and informed by stakeholder dialogue, due diligence findings and employee surveys. The Group follows the UN Guiding Principles on Business and Human Rights, OECD Guidelines and the ILO Declaration on Fundamental Principles and Rights at Work.

Reference: page 40

Internal input from employees is collected through open dialogue processes and regular evaluations, adapted in frequency and format to company size. Health and safety representatives and employee representatives provide a formal forum for ongoing dialogue, supplemented by employee development reviews and periodic satisfaction surveys; operational responsibility for engagement and follow-up sits with local company management (page 40). The employees stakeholder row in the Group's stakeholder table lists satisfaction surveys, employee development dialogues, training and skills development, and working groups as the main engagement channels, with key topics of career development, well-being/safety and diversity and inclusion.

Insights from employee engagement feed into the double materiality assessment and the adjustment of ESG initiatives, targets and strategy, and are communicated to the Executive Board and Board of Directors (page 40).

Reference: page 59

Under "Human rights and labour rights," the Group states it "does not accept discriminatory treatment and has well-defined complaint processes that ensure quick follow-up." Complaints and concerns can be raised through established internal channels; they are "registered centrally, handled quickly and followed up systematically," with efficiency monitored via KPIs, reporting and employee satisfaction measures, and low scores addressed with concrete improvement plans. In 2025, three complaints were submitted via internal employee channels (three in 2024), of which two were categorised as discriminatory treatment; none were classified as serious human rights incidents.

The whistleblower scheme (page 66), established under the EU Whistleblower Directive, is also available to employees for reporting fraud, bribery, social dumping, serious health and safety or environmental breaches, and offers anonymity and protection against retaliation, with reports handled by an external law firm working alongside the Group's legal department.

Reference: page 58

The Group describes 2025 own-workforce actions across three areas. Health and safety: MT Hojgaard Danmark added health and safety coordinator resources on projects and launched the monthly AM FOKUS safety campaign; Enemaerke & Petersen reorganised to bring health and safety work closer to projects and implemented the 4S psychosocial working-environment tool. Inclusion: initiatives include inviting all female apprenticeship applicants at Enemaerke & Petersen to interview, participation in school construction weeks aimed at girls, and the multilingual MitMTH app to reduce communication barriers for a diverse workforce.

Training: a new course portal was implemented to strengthen learning structure Group-wide, and Enemaerke & Petersen was nominated for Apprenticeship of the Year for the fourth consecutive year. Local anchoring initiatives, such as the collaboration with Almen Virke under KAB-Faellesskabet, created flexible job entry points for people outside the labour market.

Reference: page 57

Towards 2028 the Group updated its workforce targets. The rate-of-accidents target was adjusted from 8 to 12 per million working hours "in order to set a more realistic and achievable level," while the ambition remains that no employee should be injured at work. A new employee turnover target of a maximum of 15% among salaried employees was introduced, alongside a new qualitative target to expand employment initiatives for people outside the labour market. Other targets carried forward unchanged include a maximum 3.5% absence due to illness, minimum 5% women in hourly-paid positions and 30% in salaried positions, and a minimum 10% training positions.

2025 performance against these targets: rate of accidents 17.6 (target 12), absence due to illness 3.6% (target 3.5%), employee turnover 17.9% among salaried employees (target 15%), women in salaried positions 25.3% (target 30%), women in hourly-paid positions 3.1% (target 5%), and training positions 7.9% (target 10%).

Reference: page 61

The Group reports an average of 3,172 FTEs in 2025 (3,298 in 2024) and 3,425 employees on a headcount basis (3,465 in 2024), of which 39% salaried and 61% hourly-paid. By country: Denmark 3,110 (2,967 in 2024), Greenland 107 (249), the Maldives 154 (190) and Vietnam 54 (58). By type of contract in 2025: 3,121 permanent employees, 203 temporary employees and 90 non-guaranteed-hours employees, out of 3,324 total, of which 414 female, 2,909 male and 1 other gender.

Age structure was 21% under 30, 48% aged 30-50 and 31% over 50 by headcount (21/47/32 in 2024). Employees include discontinued operations, so the figures differ from note 1.2 in the consolidated financial statements.

Reference: page 62

The share of women across the Group rose to 12.2% in 2025 (11.3% in 2024). Among management (excluding the Executive Board), women represented 29.2% (29.6% in 2024, 19 of 66 managers). The Executive Board had 0.0% women in 2025 (5.2% in 2024, reflecting a change in composition). Among other salaried employees, 25.3% were women (24.4% in 2024); among hourly-paid employees, 3.1% (2.9% in 2024). One employee was registered as "other gender" at year-end.

The Group states it "wants to create a more balanced gender distribution" and is "moving in the right direction towards the targets of 5% hourly paid women and 30% salaried women" (page 59), with Enemaerke & Petersen driving hourly-paid gains (5.5% women in 2025, up from 4.5%).

Reference: page 60-61

The Group reports 7.9% of employees in training positions in 2025 (8.1% in 2024), split between apprentices (4.7%), interns (0.9%) and other training positions such as trainees, student assistants and industrial PhDs (2.3%). MT Hojgaard Danmark's training-position share fell to 4.7% (5.1% in 2024), while Enemaerke & Petersen's rose to 12.2% (11.9% in 2024), supported by a strengthened training manager role and more structured apprentice follow-up. Enemaerke & Petersen was nominated for Apprenticeship of the Year for the fourth consecutive year.

The Group's 2028 target is 10% training positions Group-wide. Regular apprentice days are organised across the Group's companies to support professional development, community and retention, covering introductions to key functions, working-environment dialogue and corporate values.

Reference: page 63

The rate of workplace accidents with absence was 17.6 per million hours worked in 2025 (18.9 in 2024), against a 2028 target of 12; the number of accidents with absence fell to 97 (111 in 2024), a 12.6% decrease. There were zero fatal accidents among employees, contract workers and subcontractors in 2025. Absence due to illness was 3.6% (3.5% in 2024), against a 3.5% target. The percentage of employees covered by an occupational health and safety management system (ISO 45001) was 73.7% (69.8% in 2024).

The Danish Working Environment Authority issued 79 notices in 2025 (60 in 2024) across 248 visits, with 21.0% of visits resulting in a notice (19.4% in 2024); notices included 3 administrative fines and 1 police report. The rate of improvement was driven by MT Hojgaard Danmark (accident rate down from 16.8 to 15.2) and NemByg (down from 37.7 to 15.7).

Reference: page 61

The gender pay gap was 4% in 2025 (-5% in 2024, meaning men earned more than women on average this year, a reversal from 2024), calculated across all employees including management and the Executive Board as a percentage of average male salary. The ratio between the highest-paid individual's total remuneration and the median of the rest of the workforce was 20 (14 in 2024). The report attributes both movements mainly to variations in salary and bonus payments year on year, alongside a lower average salary for women than men among hourly-paid staff linked to differences in the mix of hourly-paid functions across genders.

Reference: page 62

The Group reports 2 incidents of discriminatory treatment in 2025 (2 in 2024) and 3 complaints via employee channels (3 in 2024); DKK 0 in fines resulted from employee complaints in 2025 (DKK 20,000 in 2024). No complaints were submitted via the National OECD Contact Point in either year. No severe human rights incidents among employees, and no incidents in violation of the UN Guiding Principles or OECD Guidelines, were recorded in 2025 or 2024, and no related fines were paid.

Discriminatory treatment is defined in the accounting policies (page 62) as "unwanted conduct related to a protected ground of discrimination, such as gender, race, religion, disability, age or sexual orientation, occurring with the purpose or effect of violating a person's dignity" and includes harassment. Complaints are recorded whether raised verbally, in writing to HR or a manager, via an external complaints email, or through the whistleblower scheme.

Reference: page 41

The Supplier Code of Conduct (CoCE) "sets out the Group's expectations for suppliers and other business partners," requiring compliance with ILO labour standards, respect for human rights, freedom from child and forced labour, safe working conditions and adherence to environmental and climate requirements; suppliers "must ensure workers' rights to organise, provide training in safety and supply appropriate personal protective equipment." All strategic partners must adhere to the CoCE upon contract signing. The Group's human rights policy also extends "throughout the value chain," with a zero-tolerance approach to forced and child labour and requirements for fair wages and employment conditions.

Under the 2025 ESG strategy, the governance pillar "focuses on strengthening the Group's collaboration with subcontractors and suppliers to promote responsible working conditions and respect for human rights throughout the value chain" (page 33), supported by increased monitoring, site inspections and stricter contractual requirements.

Reference: page 40

Suppliers and subcontractors are one of the Group's nine prioritised stakeholder groups (page 40), engaged through project collaboration, framework agreements and negotiations, and oversight of working conditions. Key topics for this group include fair framework agreements, access to ESG data and product documentation, requirements for certifications and the EU Taxonomy, and working conditions, safety, chemistry and climate. Group initiatives in response include dialogue on ESG expectations and requirements, strengthened oversight of working conditions among subcontractors, and risk mitigation action plans.

Supplier inspections themselves (page 65) also serve as an engagement mechanism: inspections are conducted both through proactive checks based on risk assessment and through client-driven audits carried out as part of contractual requirements, giving the Group direct visibility into conditions among inspected suppliers.

Reference: page 66

The Group's whistleblower scheme, established under the EU Whistleblower Directive, is available "both to employees and external parties," which includes value chain workers, and "ensures anonymity and protection against retaliation." Reports are handled by an external law firm in collaboration with the Group's legal department. The scheme covers complaints including "social dumping" explicitly, alongside fraud, bribery, forgery, serious health and safety or environmental breaches, and violence or threats. In 2025 the Group received four reports through the whistleblower scheme (one in 2024), an increase the report attributes partly to awareness campaigns run in 2024 and 2025.

Supplier violations identified through inspection (page 65) feed a separate violation-management process, where "corrective actions are defined and remediation is ensured through documentation, back payments or other corrective measures depending on the severity of the violation," with authorities notified for serious or deliberate violations.

Reference: page 65

The Group is "committed to upholding business conduct grounded in integrity, accountability and transparency" (page 65). Corporate culture is identified as a material risk: "an inappropriate culture can lead to low employee well-being, high employee turnover and challenges in attracting new talent," with consequences including knowledge loss and reputational damage. The Group's Employee Code of Conduct is "communicated at onboarding and is accessible on both internal and external platforms," while the Supplier Code of Conduct "clarifies expectations for responsible behaviour across the value chain" (page 65, cross-referring to page 41).

The Board of Directors and Executive Board "set the overall direction and regularly follow up on themes such as diversity, inclusion and responsible conduct, ensuring that the culture supports the Group's objectives" (page 65). The most important Group policies underpinning business conduct, including the anti-corruption policy, whistleblower policy, tax policy and data ethics policy, are set out on page 41.

Reference: page 65-66

Although "management of relationships with suppliers" is not named among the Group's material G1 sub-topics in the DMA summary, the Group discloses substantive supplier-oversight content explicitly under the Business conduct chapter: "In 2025, the Group strengthened its inspection of wages and working conditions among suppliers, particularly subcontractors." 65 suppliers were inspected in 2025 (43 in 2024, +51.2%), the proportion with an identified violation rose to 56.9% (51.2% in 2024), and the share of violations resulting in sanctions rose to 91.9% (90.9% in 2024). A new 2028 target commits the Group to annual inspections of wage and working conditions at a minimum of 100 suppliers.

Inspections combine proactive, risk-based checks with client-driven audits, examining documentation such as payslips, timesheets, employment contracts, and, for foreign labour, registration in the Danish Register for Foreign Service Providers and valid work/residence permits. The Group also plans a more risk-based, preventive approach to supplier pre-screening and participates in a cross-industry initiative on standardised risk screening.

Reference: page 66

The Group has procedures for preventing and managing corruption and bribery, including "two-factor approval of invoices and clear procurement guidelines." Suspicions and incidents are handled by a control unit anchored in MT Hojgaard Holding, which reports directly to the Executive Board and Board of Directors and "receives enquiries via secure channels" ensuring documentation, follow-up and organisational learning. In 2025, 71.2% of employees in risk functions (those with procurement mandate) completed anti-corruption training, up from 57.7% in 2024.

The whistleblower scheme, aligned with the EU Whistleblower Directive, ensures anonymity and protection against retaliation for internal and external reporters and is administered by an external law firm alongside the Group's legal department. In 2025 the Group received 4 reports through the whistleblower scheme (1 in 2024) and 1 through the external complaints procedure (0 in 2024).

Reference: page 75

No violations of anti-corruption legislation were reported in 2025, and the Group received no judgments or fines as a result of corruption or bribery-related incidents (0 incidents, 0 employment-law consequences, 0 judgments/decisions, DKK 0 in fines). This is an improvement on 2024, when the accounting-policy table shows 1 incident of corruption or bribery with employment-law consequences recorded, though also with 0 judgments, decisions or fines in that year. The Group's incidents-of-corruption metric is defined to include "violations of anti-corruption and bribery legislation during the financial year in which the Group or its employees have been involved," including value-chain incidents with the Group's direct involvement, with the number of employees dismissed as a result separately tracked.

Targets related to business conduct

Back-filled from the Business conduct chapter, where targets are addressed directly under the "2028 targets" heading rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS.

The Group discloses three new business conduct targets introduced for 2028 (page 65): first, a quantitative target to "conduct annual inspections of wage and working conditions at a minimum of 100 suppliers," to "ensure systematic monitoring, prevent social dumping and minimise the risk of unacceptable practices"; 65 suppliers were inspected in 2025, up from 43 in 2024. Second, a qualitative target to "implement preventive, risk-based processes in supplier management." Third, a qualitative target to "enhance training in responsible business conduct."

These targets sit within the 2028 ESG Strategy Framework governance pillar (page 34), alongside the priorities "a strong management system with supporting processes" and "ensure fair working conditions and prevent social dumping in the supply chain." The report does not describe how effectiveness will be tracked beyond the inspection count, and no separate anti-corruption target is disclosed.