Novo Nordisk

Governance structure

The shareholders of Novo Nordisk exercise their rights at the Annual General Meeting, which is the supreme governing body of the company. The general meeting, inter alia, adopts the company's Articles of Association, approves the Annual Report and elects the Board of Directors.

Any shareholder has the right to raise questions at general meetings. Resolutions can generally be passed by a simple majority. However, resolutions to amend the Articles of Association require two-thirds of the votes cast and capital represented, unless other adoption requirements are imposed by the Danish Companies Act.

Novo Nordisk has a two-tier management structure consisting of the Board of Directors and Executive Management. The governance structure and rules of Novo Nordisk are further described in our Articles of Association and our Corporate Governance Report, both available at: www.novonordisk.com/about/corporate-governance.html.

Foundation ownership

Novo Holdings A/S, a Danish company wholly owned by the Novo Nordisk Foundation, holds the majority of votes at Novo Nordisk A/S' general meetings. The combination of foundation ownership and stock listing enables Novo Nordisk to embark on long-term sustainable strategies while maintaining short-term transparency on performance. Our foundation ownership supports the overarching imperative to be both commercially successful and responsive to the wider needs of society.

The Novo Nordisk Foundation has two objectives: to provide a stable basis for the commercial and research activities of Novo Nordisk, Novonesis and additional companies in Novo Holdings' investment portfolio; and to support scientific, humanitarian and social causes.

Corporate governance reporting

Novo Nordisk reports in accordance with the Danish Corporate Governance Recommendations, which are implemented by Nasdaq Copenhagen in the Nordic Main Market Rulebook for Issuer of Shares, as well as the Corporate Governance Standards of the New York Stock Exchange applicable to foreign private issuers.

Novo Nordisk complies with the Danish Corporate Governance Recommendations as we account for which recommendations we comply with or deviate from and explain our chosen approach. You can find further information about our corporate governance practices and statement on our approach to each of the Danish Corporate Governance Recommendations as well as the Corporate Governance Standards of the New York Stock Exchange in our Corporate Governance Report, available at: www.novonordisk.com/about/corporate-governance.html.

Remuneration

Executive remuneration is linked to financial performance as well as non-financial performance (e.g. innovation and sustainability). Novo Nordisk has prepared a separate Remuneration Report describing the remuneration awarded or due during 2024 to the Board of Directors and Executive Management members registered with the Danish Business Authority. The Remuneration Report is submitted to the Annual General Meeting for an advisory vote. The Remuneration Policy and the Remuneration Report are available at: www.novonordisk.com/about/corporate-governance.html.

Strategic Aspirations integration

Our commitment to sustainability is reflected in our incentive programmes, which incorporate our Strategic Aspirations 2025 into both individual and corporate performance targets. This highlights our dedication to driving sustainable growth and creating long-term value for all stakeholders.

Purpose and strategy

At Novo Nordisk, our purpose is clear: driving change to defeat serious chronic diseases. Through our life-changing innovations, we are building a healthier future for generations to come.

We are dedicated to reinforcing our leadership in diabetes and obesity, securing a leading position in rare diseases and establishing ourselves as a key player in cardiovascular disease. Additionally, we are actively building our presence in the treatment of metabolic dysfunction-associated steatohepatitis, chronic kidney disease and Alzheimer's disease.

Value chain

Our value chain is similarly comprehensive, encompassing every stage from the initial concept of a new treatment to its final delivery to people living with serious chronic diseases. This includes our own operations in R&D and manufacturing, as well as collaborations with suppliers to source materials and distribute our treatments effectively.

Business model

We create value on multiple fronts. Through the Novo Nordisk Way, we ensure our employees thrive in a supportive and innovative environment. We operate as a responsible business, striving to address environmental and social impacts, to create value for society and fulfil our financial commitments to shareholders, ensuring sustainable growth and success.

Strategic focus areas

• Diabetes: Strengthen leadership by offering innovative medicines and driving patient outcomes
• Obesity: Strengthen leadership through market development and by offering innovative medicines and driving patient outcomes
• Rare Disease: Secure a leading position by leveraging full portfolio and expanding into adjacent areas
• Cardiovascular & Emerging Therapy Areas: Establish position in cardiovascular disease and build a presence in emerging therapy areas

Key metrics

• Reached more than 45.2 million people living with serious chronic diseases
• Added 13,030 employees bringing Novo Nordisk's total workforce to 77,349
• Invested more than DKK 52 billion in R&D
• Invested more than DKK 129 billion in production capacity
• Reached 8.4 million vulnerable people living with diabetes

Stakeholder engagement

We focus on creating lasting value for society and our business with a strong commitment to financial, environmental and social responsibility. Following the Novo Nordisk Way, we are dedicated to delivering long-term value for people living with serious chronic diseases, our employees, partners, shareholders and society at large.

Key stakeholder groups

• People living with serious chronic diseases: Our primary focus is reaching more people with our life-changing medicines
• Employees: We are sustainably scaling our organisation to 77,349 colleagues worldwide
• Shareholders: Paid out more than DKK 64 billion via dividends and share buybacks to shareholders, including Novo Holdings A/S
• Partners and suppliers: We work closely with suppliers and partners across our value chain
• Society: The Novo Nordisk Foundation awards grants in three strategic areas: health, sustainability and the life science ecosystem. In 2024, more than DKK 10 billion were awarded.

Foundation ownership model

Our unique ownership structure, underpinned by the Novo Nordisk Foundation as controlling shareholder, provides us with the stability we need to navigate uncertainties. This model supports our sustainable growth by allowing us to take a long-term view on our investments and strategies; crucial in a volatile world where short-term market pressures can often lead to reactive decision-making.

The Novo Nordisk Foundation holds 77.3% of votes and 28.1% of shares in Novo Nordisk A/S through Novo Holdings A/S. This unique ownership structure supports sustainable growth by allowing us to take a long-term view on our strategies and investments while maintaining short-term transparency on performance.

Material impacts, risks and opportunities

This year, in line with the CSRD, we have conducted a double materiality assessment to identify the sustainability matters that are most important to Novo Nordisk, considering both societal and financial implications. The essential topics identified include patient protection and quality of life, climate change, resource use and circular economy, and own workforce – reflecting our aspirations of progress towards zero environmental impact, being respected for adding value to society and being a sustainable employer.

Strategic Aspirations 2025 integration

The outcomes of this assessment have provided us with key metrics to track our performance across our material sustainability topics. These are integrated into our Strategic Aspirations 2025, which cover our financial and sustainability ambitions.

Key material topics identified:

Environmental

• Climate change: Progress towards zero environmental impact
• Resource use and circular economy: Reducing plastic footprint and waste
• Pollution: Environmental impact management
• Water: Responsible water use
• Biodiversity and ecosystems: Impact on nature and biodiversity

Social

• Patient protection and quality of life: Access to medicines and health equity
• Own workforce: Being recognised as a sustainable employer
• Workers in the value chain: Supply chain responsibility
• Affected communities: Community impact

Governance

• Business conduct: Ethics and compliance

Interaction with strategy and business model

Recognising the magnitude of these challenges, we are aiming to expand the reach and societal impact of our life-changing medicines and preventive health initiatives while striving to reduce our CO2e emissions, plastic footprint and impact on nature.

As our business grows, so does our social responsibility to support vulnerable populations, and this year we were able to reach 8.4 million vulnerable people living with diabetes. The growth of our business has inevitably led to an increase in our environmental footprint, and we are stepping up efforts to mitigate this impact.

This year, in line with the CSRD, we have conducted a double materiality assessment to identify the sustainability matters that are most important to Novo Nordisk, considering both societal and financial implications.

The essential topics identified include patient protection and quality of life, climate change, resource use and circular economy, and own workforce – reflecting our aspirations of progress towards zero environmental impact, being respected for adding value to society and being a sustainable employer.

The outcomes of this assessment have provided us with key metrics to track our performance across our material sustainability topics. You can read more about our progress towards achieving our sustainability ambitions in the Annual review on page 12, while detailed breakdowns of our performance can be found in the Sustainability statement on page 46.

The Annual Report 2024 marks a significant step in the evolution of Novo Nordisk's integrated reporting. This year, our Sustainability statement is for the first time prepared according to the EU Corporate Sustainability Reporting Directive (CSRD) requirements.

We have been committed to integrated reporting since 2004, when we first started evaluating our performance based on social, environmental and financial impact. This commitment was further strengthened in 2019 with the adoption of our Strategic Aspirations 2025, which cover our financial and sustainability ambitions.

The Annual Report 2024 includes:

• Annual review (page 4-45): Strategic progress and performance
• Sustainability statement (page 46-99): CSRD-compliant sustainability reporting
• Financial statements (page 101-147): Consolidated and parent company financials

Together, the Annual review and Sustainability statement make up this year's Management report, providing comprehensive coverage of our material sustainability topics and ESRS disclosure requirements.

Transition plan for climate change mitigation

Scope of the plan

Novo Nordisk is committed to reaching net zero emissions across scope 1, scope 2 (market-based) and scope 3 GHG emissions by 2045 in alignment with the Corporate Net-Zero Standard from the SBTi. The scope 3 target covers nearly 70% of scope 3 emissions, in accordance with the SBTi's provision of postponing up to one third of base year GHG emissions associated with the highest estimation uncertainty and lowest abatement potential. Hence, categories 3, 5, 7, 12, and a part of category 1 and 2 are not included in the scope of the 2033 target.

The transition plan covers:

• Own operations globally: All of Novo Nordisk's global activities including production sites and affiliates
• Upstream value chain: Supply chain globally, including tier 1 suppliers and upstream distribution
• Downstream value chain: Downstream distribution globally

Target years for net zero / carbon neutral

• 2030: Zero scope 1 and 2 (market-based) CO2e emissions
• 2033: 33% absolute reduction of scope 3 CO2e emissions (baseline year 2024)
• 2045: Net zero emissions across scope 1, 2 (market-based) and scope 3 GHG emissions

Scope 1, 2, 3 reduction milestones with baseline years

2024 Performance:

• Scope 1 GHG emissions: 85,000 tCO2e
• Scope 2 GHG emissions (market-based): 16,000 tCO2e
• Scope 1 and 2 (market-based) GHG emissions: 101,000 tCO2e
• Scope 3 GHG emissions: 2,160,000 tCO2e (covering nearly 70% of total scope 3)
• Total GHG emissions (market-based): 2,261,000 tCO2e

Expected reductions: Estimated at 2,200 thousand tonnes of CO2e across scope 3 by 2033. This includes initiatives already identified, estimated at 1,500 thousand tonnes CO2e, and therefore a gap towards the target of an estimated 700 thousand tonnes of CO2. Expected reductions across scope 1 and 2 by 2030 amount to 131 thousand tonnes of CO2e.

Alignment with 1.5°C / SBTi validation status

The scope 3 target is not 1.5℃ aligned, but is consistent with SBTi's well-below 2.0℃ pathway. The target has been submitted to SBTi for validation. The 2045 net zero target is aligned with climate science and the Corporate Net-Zero Standard from the SBTi.

Key levers / decarbonization pillars

Scope 1 and 2 decarbonization levers:

2024 Progress on Scope 1 and 2:

• Maintained 100% renewable electricity at all production sites
• 99% renewable electricity coverage at affiliates
• Energy consumption from renewable resources: 54% of total energy consumption (excluding steam and heat derived from biomass)
• Energy savings initiatives: 13,740 MWh total energy reduction
• District cooling ring construction progressing (expected energy savings >20,000 MWh/year after 2026 completion)

Scope 3 decarbonization levers:

2024 Progress on Scope 3:

• More than 1,800 suppliers have committed to transitioning to renewable power
• Initiatives identified together with suppliers expected to account for majority of scope 3 emission reductions
• Effectiveness assessed quarterly through tracking estimated GHG emissions
• Procurement of SAF and SMF have helped curb growth in categories 4 and 6

Key decarbonisation measures include switching to low-carbon materials and feedstock across production network, shifting distribution model to low-emissions transportation and supporting suppliers in transitioning to renewable energy.

CapEx / investment commitments

EU Taxonomy alignment:

• In 2024, 6% of CapEx aligned with EU Taxonomy for climate change mitigation (3% including Catalent)
• Two major capacity expansion projects in Hillerød and Kalundborg, Denmark, aligned to EU Taxonomy
• Construction of new buildings: DKK 3,494 million CapEx aligned with Taxonomy in 2024 (3% of total CapEx)
• Total Taxonomy-eligible CapEx: DKK 39,022 million (32% of total CapEx)

Overall capital expenditure:

• Capital expenditure (PP&E) expected around DKK 65 billion in 2025
• Investments are expanding capacity across supply chain, including API manufacturing, aseptic production and packaging capacity
• In the coming years, capital expenditure to sales ratio expected to be low double-digit

Locked-in emissions and stranded asset analysis

Potential locked-in GHG emissions are limited but relevant in relation to partially fossil-fuel-powered production sites, which the company is working to convert to electric and renewable energy.

A forward-looking, high-level assessment of physical and transition climate-related risk was conducted in 2024, considering a 4°C and a 1.5°C scenario. No aspects of the business were identified as incompatible with a transition to a climate-neutral economy.

Use of carbon credits / removals

Beyond 2033, Novo Nordisk expects to use carbon removals to neutralise residual CO2e emissions of up to 10% of the baseline emissions towards the net zero 2045 target, in line with SBTi requirements and guidance from the Intergovernmental Panel on Climate Change (IPCC). The company is exploring opportunities for removing and storing GHG involving both nature- and technology-based solutions. Novo Nordisk does not use biodiversity offsets as part of its nature roadmap.

Biogenic emissions (2024): 110,000 tonnes CO2e, originating primarily from procurement of biogas and bio-based steam, and combustion of bio-based fuels (wood).

Climate adaptation

To address physical climate risks faced by some sites in the medium and long term, all medium- and high-risk sites are covered by mitigation plans, including procedures in cases of temporary production shutdown and safety rooms for employees, as well as leak detection, drainage, and protection against storm surge. The natural hazard exposure of the 400 most critical suppliers is reviewed as part of comprehensive supply chain risk assessment.

Growth projections and decoupling

The roadmap is aligned with Novo Nordisk's overall business strategy, taking into account projected growth. With projected growth and the delayed effect of decarbonisation levers, the company anticipates an overall growth in GHG emissions until 2030 compared to the baseline. The company acknowledges that identified measures will not be enough to meet the target, and will therefore investigate additional levers – including new technologies – to close the gap of an estimated 700 thousand tonnes of CO2. Many scope 3 decarbonisation levers will not materialise until at least 2030.

Plastic footprint reduction

As part of Circular for Zero strategy:

• Target: 30% reduction in plastic used per patient by 2033 (baseline 2024)
• Approach: Reduce, change and avoid across diabetes and obesity portfolio
• Actions: Transitioning from disposable to reusable devices; developing medicines administered less frequently
• ReMed™ device take-back scheme: Active in seven key markets, more than four million returned pens since launch, collaborative industry-wide solution in Denmark, pilot in UK planned for 2025

Nature roadmap integration

In 2024, developed new nature roadmap with overarching ambition to halt nature loss across value chain by 2033 and achieving nature-positive status by 2045. This includes reducing impacts on land, water, and biodiversity while driving positive impacts through restoration and transformative actions.

Policies related to climate change mitigation and adaptation

Novo Nordisk discloses one named policy relevant to climate change mitigation and adaptation.

Environmental Policy

Policy name: Environmental policy

Purpose: Guides action across material environmental topics

Scope: All of Novo Nordisk's global activities

Governance and accountability:

• Most senior level accountable: Executive Management
• The policy has been approved by the Board of Directors and Executive Management

Key content and principles:

• Commitment to ensuring treatment for people living with serious chronic diseases with the lowest possible impact on the environment
• Commitment to reducing GHG emissions in line with the Science Based Targets initiative (SBTi)
• Sets out a key objective of mitigating climate impact through:
  • Energy efficiency measures
  • Deployment of renewable energy
  • Other decarbonisation levers
• Commitment to protecting the business through evaluating climate-related risks and taking measures to adapt to climate change
• Commitment to designing less water-intensive processes by reusing and recycling water
• Special focus on water withdrawal in areas of high water-stress or risk, both at own sites and with suppliers of key commodities
• Support of water stewardship principles and collective actions in water basins that are under pressure
• Addresses water management and treatment of production-related water discharge onsite and/or offsite
• Commitment to avoid water pollution by discharging water in accordance with local regulations, and taking corrective actions in case of any breaches

Public availability: Externally available at: Our environmental policy (URL not provided in excerpts)

Implementation and monitoring:

• Implementation is ensured by management teams across the business and by on-site environmental partners at all production facilities globally, who safeguard compliance and continuous improvements
• All production facilities are ISO 14001 certified for environmental management to ensure continuous improvements and mitigate, control and prevent negative environmental impacts

Applicability across the Sustainability statement:

• Climate change (page 54)
• Resource use and circular economy (page 60)
• Pollution (page 64)
• Water (page 65)
• Biodiversity and ecosystems (page 67)

Actions and resources in relation to climate change policies

Transition plan for climate change mitigation

Novo Nordisk has committed to reaching net zero emissions across scope 1, scope 2 (market-based) and scope 3 GHG emissions by 2045 in alignment with the Corporate Net-Zero Standard from the SBTi.

Targets:

• Zero scope 1 and scope 2 (market-based) CO2e emissions by 2030
• 33% absolute reduction of scope 3 CO2e emissions by 2033 compared to base-year of 2024
• Targets approved by Board of Directors and Executive Management
• Scope 3 target is consistent with SBTi's well-below 2.0℃ pathway

Time horizon:

• Transition plan execution starts in 2025 to achieve scope 3 target by 2033
• Many scope 3 decarbonisation levers will not materialise until at least 2030
• Long-term: net zero by 2045

Key decarbonisation measures

Own operations (Scope 1 and 2 - 4% of total emissions)

Actions:

• Switching to renewable energy sources
• Increased energy efficiency
• Converting partially fossil-fuel-powered production sites to electric and renewable energy

Scope: Own operations

Upstream and downstream value chain (Scope 3 - 96% of total emissions)

Actions:

1. Switching to low-carbon materials and feedstock across production network

   • Scope: Upstream value chain

2. Shifting distribution model to low-emissions transportation

   • Scope: Downstream value chain

3. Supporting suppliers in transitioning to renewable energy

   • Status: More than 1,800 suppliers have already committed to make the switch
   • Scope: Upstream value chain (tier 1 suppliers)

4. Converting to lower carbon materials

   • Scope: Upstream and downstream value chain

5. Lowering emissions from distribution

   • Scope: Downstream value chain

6. Product design initiatives:

   • Shifting from disposable to reusable devices
   • Developing new medicines designed to be administered less frequently
   • Scope: Downstream value chain

ReMed™ device take-back scheme

Action name: ReMed™

Description:

• Device take-back scheme to avoid plastic waste ending up in landfills
• Built on success of local take-back pilot programmes
• Enables pen users to return used devices to give the plastic a new life

Status and scale:

• Four years since launch of first pilot
• More than 4 million returned pens since launch
• Now active in seven key markets including Denmark
• Collaboration with other healthcare companies in Denmark to offer industry-wide solution
• Same collaborative model will be piloted in the UK in 2025

Scope: Downstream value chain

Time horizon: Ongoing expansion (2025 UK pilot mentioned)

Resources: Partnerships with other healthcare companies

Carbon removals (beyond 2033)

Novo Nordisk expects to use carbon removals to neutralise residual CO2e emissions of up to 10% of the baseline emissions towards net zero 2045 target, in line with SBTi requirements and IPCC guidance.

Actions:

• Exploring opportunities for removing and storing GHG
• Both nature-based solutions and technology-based solutions under consideration

Time horizon: Beyond 2033, towards 2045 net zero target

Nature and biodiversity ambition

Novo Nordisk has sharpened focus on impact of operations on nature and biodiversity:

Targets:

• Halt nature loss across value chain by 2033
• Achieve nature-positive status by 2045

Scope: Entire value chain

Climate risk assessment and adaptation

Actions:

• Continuous assessment of physical climate risks and their potential impact on operations and value chain
• Natural hazard screening for all relevant physical hazards at production sites and in supply chain (excluding warehouses)
• Annual screening and as part of sourcing due diligence process
• Climate scenario analysis conducted in 2024 (high-level assessment)
  • Considered 4°C and 1.5°C scenarios
  • Physical risks assessed under RCP 8.5 and RCP 2.6 pathways
  • Time horizons: 2030 and 2050
  • Used external meteorological database, asset information and geospatial coordinates
  • Transition risks modelled using Integrated Assessment Model (IAM)

Scope: Own operations and value chain

Resources (non-financial): External meteorological database, IAM scenario analysis tool

Anticipated emissions trajectory

With projected growth and delayed effect of decarbonisation levers, the company anticipates an overall growth in GHG emissions until 2030 compared to the baseline, before decarbonisation measures take effect to achieve 2033 and 2045 targets.

Resources allocated

Non-financial resources:

• More than 1,800 suppliers committed to renewable energy transition
• Partnerships with other healthcare companies (ReMed™ scheme)
• External tools: meteorological database, IAM scenario analysis

Financial resources: Not quantified in the excerpts provided

Linkage to policies and governance

• Actions guided by Environmental Policy (applies to all of Novo Nordisk's global activities)
• Accountable level: Executive Management
• Targets approved by Board of Directors and Executive Management

Net zero emissions target

We have a clear focus on decoupling our environmental impact from our growth as we progress towards our net zero 2045 emissions target.

Scope 3 emissions reduction target

To achieve net zero emissions by 2045, we have a roadmap to reduce scope 3 emissions by 33% by 2033, using 2024 as the baseline. This target – which covers nearly 70% of our scope 3 emissions in accordance with Science Based Targets initiative (SBTi) provisions – is aligned with climate science and has been submitted to the SBTi for validation.

Energy consumption and mix

Novo Nordisk reports total energy consumption from own operations under ESRS E1-5 (now E1-7). The company distinguishes between fossil/other sources and renewable sources, applying a conservative approach where only contractually specified renewable energy is classified as renewable. Steam and heat derived from biomass are not included under renewable sources due to this conservative accounting approach.

Energy consumption by source (MWh)

Energy mix percentages

Energy intensity

Note on nuclear energy: Not applicable to Novo Nordisk.

Scope: Total energy consumption covers all entities under operational control, including fuel consumption in leased vehicles (expanded scope in 2024). Energy consumption from contractual renewable sources – primarily renewable electricity and biogas – is classified as renewable only when specified as renewable in the supplier's contractual agreement. The metric was previously reported as 'Share of renewable power for production sites' and was adjusted in scope to fully reflect ESRS requirements. Biogenic emissions from biogas and bio-based steam totalled 110,000 tonnes CO2e in 2024 (disclosed separately, not in scope 1/2).

All production sites now source 100% renewable electricity, as do the majority of offices and laboratories (99% coverage for affiliates in 2024). The increase in total energy consumption in 2024 (33% year-on-year) is partly due to the inclusion of car fuel in the metric (not previously included) and higher consumption of steam, electricity and natural gas.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1, 2 and 3 GHG emissions (2.1.1)

*2023 figures restated for categories 1, 2, 4 and 6 from previously disclosed values of 2,067; 1,315; 113 and 83 thousand tonnes CO₂e, respectively.

Methodology notes:

• Operational control = financial control approach.
• Scope 1 includes CO₂e emissions from fuels and fugitive emissions of purchased refrigerants. N₂O and CH₄ emissions from consumption of biofuels included; bio-based CO₂ emissions assumed zero and disclosed separately under biogenic emissions. Biogenic emissions from fermentation process not included due to high calculation uncertainty.
• Scope 2 location-based uses national grid average emission factors. Market-based uses contractual instruments (Energy Attribute Certificates, PPAs, Guarantees of Origin); where absent, national average emission factors applied.
• Scope 3 covers nine categories out of fifteen defined by GHG Protocol. Remaining six categories either not applicable or included in other categories. Categories 1 and 2 use combination of supplier-specific data, average-data method and spend-based method. Categories 3, 4, 5, 6, 7, 9, 12 use supplier-specific, distance-based, average-activity, average spend-based and hybrid methods. Major emission factor sources: DEFRA, EXIOBASE, GaBi and other industry databases.
• In 2024, methodology updated to improve reliability, particularly for categories 1 and 2 (transfer of contract manufacturing from spend- to activity-based, adjustment of emission factors, use of supplier-specific data where available). Updates also made to categories 4 and 6 emission factors. Review indicated categories 1 and 2 previously overstated; 2023 scope 3 figures restated accordingly.
• Approximately 12% of scope 3 emissions calculated using primary data in 2024.
• GHG removals, carbon credits and avoided emissions not included.
• Catalent acquisition impact excluded from 2024 figures.

GHG emissions targets (2.1.2)

*Target covers nearly 70% of scope 3 emissions in accordance with SBTi provisions. Categories 3, 5, 7, 12, and parts of categories 1 and 2 excluded from 2033 target scope. **Novo Nordisk estimates residual emissions after decarbonisation levers to be 150 thousand tonnes CO₂e in 2045.

Energy consumption and mix (2.1.3)

Methodology notes:

• Total energy consumption equals energy consumption from activities in high climate impact sectors (all activities assumed in NACE code C21).
• Renewable sources include wood, biogas and externally purchased electricity from wind, solar, hydropower, biomass or biogas as defined in contractual agreements. Due to conservative accounting, steam and heat derived from biomass not included under renewable sources.
• Fossil and other sources include coal, crude oil, petroleum products, natural gas, externally purchased non-renewable electricity/heat/steam/cooling, and non-contractual biomass energy.
• Energy consumption based on meter readings and/or invoices, complemented with renewable energy certificate data.
• In 2024, scope enlarged to include all entities under operational control, including fuel consumption in leased vehicles.
• Energy intensity based on net revenue (total net sales generated by Novo Nordisk).

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

Phase-in exemption applied

Novo Nordisk has opted to use the phase-in provisions for ESRS E1-9 in this first year of CSRD reporting.

Disclosure requirement compliance status

According to Table 2 in the Appendix (Disclosure requirements in ESRS covered by the Sustainability statement), Novo Nordisk has indicated the following for ESRS E1-9:

All disclosure requirements under ESRS E1-9 are marked as "Not applicable to NN" (Novo Nordisk).

Policies related to pollution

Novo Nordisk addresses pollution through its Environmental policy, which covers pollution as one of several environmental topics.

Environmental policy

Scope:

• All of Novo Nordisk's global activities

Governance and oversight:

• Most senior level accountable: Executive Management
• Implementation ensured by management teams across the business and on-site environmental partners at all production facilities globally

Key content and principles:

• Commitment to handling chemicals safely and striving to avoid the use of harmful chemicals when developing or designing new products and processes
• Screening of harmful chemicals applies to both in-house and outsourced product development processes
• For treatments already on the market, minimizing the use of these chemicals and substituting them where possible
• Reusing chemicals where possible and ensuring the best possible handling of hazardous waste and emissions
• Ensuring compliance with the terms of the environmental permit for each production site
• In case of breaches of regulatory terms, registering an environmental non-conformity, investigating, and implementing corrective actions
• Treating production-related water discharge onsite and/or offsite and avoiding water pollution by discharging water in accordance with local regulations

Public availability:

• Externally available at: "Our environmental policy" (specific URL not provided in excerpts)

Monitoring implementation:

• All production facilities are ISO 14001 certified for environmental management to mitigate, control, and prevent negative environmental impacts, including pollution-related incidents and emergency situations
• Annual environmental assessments at all production sites covering air emissions, waste, noise, water withdrawal and water discharge, soil and ground water
• Screening for harmful chemicals during product development process, using the EU Commission's definition of Most Harmful Substances when defining chemicals in scope
• Use of relevant chemicals tracked through environmental assessments at production sites and during product design and development processes
• Registration and tracking of environmental non-conformities with investigation and corrective actions

International standards and frameworks:

• ISO 14001 certification for environmental management at all production facilities
• Compliance with REACH regulations for substances of concern
• Reporting in accordance with the European Pollutant Release and Transfer Register

Pollution of air, water and soil

Chemicals affecting human health or ecosystems

Novo Nordisk conducts annual environmental assessments at all production sites, covering air emissions, waste, noise, water withdrawal and water discharge, soil and ground water. All production facilities are ISO 14001 certified for environmental management to mitigate, control, and prevent negative environmental impacts, including pollution-related incidents and emergency situations.

The company screens for harmful chemicals, including Substances of Concern (SCs) and Substances of Very High Concern (SVHCs) covered by relevant regulations such as REACH during the product development process, using the EU Commission's definition of Most Harmful Substances.

Substances of Concern and Substances of Very High Concern

Table 2.3.1: Substances of concern and substances of very high concern

Emissions to air and water

The remaining substances leaving Novo Nordisk in the form of emissions or as part of products were estimated to be 11 tonnes of SCs and SVHCs during 2024. SCs leaving facilities as part of products make up 5 tonnes, originating primarily from one substance used as an excipient in extremely low concentrations to preserve medicines. The remaining SCs and SVHCs leave facilities as emissions to air and water. In 2024, this amounted to approximately 5 tonnes of SCs and 1 tonne of SVHCs, primarily linked to the production of API. The reported volumes of SCs and SVHCs leaving facilities are within regulatory limits.

European Pollutant Release and Transfer Register

Novo Nordisk reports in accordance with the European Pollutant Release and Transfer Register.

Methodology notes

The figures reported in Table 2.3.1 are manually calculated from available data and are subject to significant uncertainty. The weight of substances is calculated according to their concentration in the material. If information on concentration is not available, the assumption is that 100% of the material consists of substance(s) in scope. Consequently, certain metrics might be overestimated. The scoping of materials included in calculations may not be exhaustive.

Main hazard classes (human health, environmental and physical) are defined by chemical subject matter experts based on specific hazards presented. The estimated volumes of substances leaving as emissions are based on available data for API production and estimated for Chemistry, Manufacturing and Control (CMC) processes. Laboratories were deemed immaterial and are not in scope. Novo Nordisk Pharmatech A/S will be included from 2025.

Substances of concern and substances of very high concern

Policies

Novo Nordisk's environmental policy states our commitment to handling chemicals safely and striving to avoid the use of harmful chemicals, when developing or designing new products and processes. Our screening of harmful chemicals applies to both in-house and outsourced product development processes. For treatments already on the market, we strive to minimise the use of these chemicals and substitute them where possible.

All of Novo Nordisk's production facilities are ISO 14001 certified for environmental management and thus mitigate, control, and prevent negative environmental impacts, including pollution-related incidents and emergency situations. We reuse chemicals where possible and ensure the best possible handling of hazardous waste and emissions. We also ensure compliance with the terms of the environmental permit for each production site. In case of breaches of regulatory terms, we register an environmental non-conformity, investigate, and implement corrective actions.

Actions

We work with several innovation projects in both our own and outsourced production processes to reduce the environmental impacts of our products on an ongoing basis.

Key action: Reducing chemicals in production and medicines - Recurring action to minimise the use of specific chemicals in production processes through substitution or purification for reuse, and to optimise efficacy of medicines with lower chemical use. Scope: In-house and outsourced production processes. The use of relevant chemicals is tracked through environmental assessments at production sites and during product design and development processes to monitor effectiveness.

Performance

We continuously track our use of chemicals through various internal KPIs and environmental assessments to ensure that we mitigate negative impacts on the environment or human health.

A total of 2,304 tonnes of SCs and SVHCs were procured in 2024. Most of their use is linked to solvents used in the production of our API. We are seeking to reduce the use of these chemicals through substitution initiatives or purification for reuse. During the production process, almost all of SCs and SVHCs are collected as waste and handled safely in accordance with our policies and any relevant regulations.

The remaining substances, leaving Novo Nordisk in the form of emissions or as part of products, were estimated to be 11 tonnes of SCs and SVHCs during 2024. SCs leaving our facilities as part of our products make up 5 tonnes, and originate primarily from one substance used as an excipient in extremely low concentrations to preserve our medicines. The remaining SCs and SVHCs leave our facilities as emissions to air and water. In 2024, this amounted to approximately 5 tonnes of SCs and 1 tonne of SVHCs, primarily linked to the production of API. The reported volumes of SCs and SVHCs leaving our facilities are within regulatory limits.

In addition to the disclosures above, we also report in accordance with the European Pollutant Release and Transfer Register.

Quantitative disclosure

Note: If a material belongs to more than one main hazard class, the weight of the substance is reported in both hazard classes. Consequently, the sum of the sub-categories exceeds the total.

Accounting policies

The figures reported are manually calculated from the available data and are subject to significant uncertainty. The weight of substances is calculated according to their concentration in the material. If information on concentration is not available, the assumption is that 100% of the material consists of substance(s) in scope. Consequently, certain metrics might be overestimated. The scoping of the materials included in the calculations may not be exhaustive.

Main hazard classes: Defined by chemical subject matter experts, based on the specific hazards they present and includes following hazard class codes: Human health hazard (hazard class code H3xx or EUH3xx), environmental hazard (hazard class code H4xx or EUH4xx or EUH059) and physical hazard (hazard class code H2xx or EUH2xx). If a material belongs to more than one main hazard class (human health and environmental hazard) the weight of the substance is reported in both hazard classes. Consequently, the sum of the sub-categories exceeds the total. Main hazard classes are not applicable to SVHCs.

Total weight of substances of concern/substances of very high concern: Comprise the total weight of substances procured into production, categorised into main hazard classes. Data sources include receipts of materials and purchase orders mapped against a chemical database indicating hazard class.

Amount of substances of concern and substances of very high concern that leave facilities as emissions: Total weight of SCs and SVHCs that leave production sites as emissions to air or water, split into main hazard classes. The estimated volumes of substances are based on available data for our API production and estimated for Chemistry, Manufacturing and Control (CMC) processes. Laboratories were deemed immaterial and are not in scope. Novo Nordisk Pharmatech A/S will be included from 2025.

Amount of substances of concern that leave facilities as products or part of products: Total weight of SCs and SVHCs that leave Novo Nordisk as products or part of products split into main hazard classes. Products or parts of products are defined as either excipients or devices. Data sources include production data (with final product quantities), bills of materials and purchase orders mapped against a chemical database indicating hazard class.

Policies related to water and marine resources

Environmental Policy

Novo Nordisk's environmental policy addresses water management and related impacts.

Key content and principles:

• Sets out the ambition to design less water-intensive processes by reusing and recycling water
• Addresses treatment of production-related water discharge onsite and/or offsite
• Commits to avoiding water pollution by discharging water in accordance with local regulations
• Requires corrective actions in case of any breaches
• Addresses special focus on water withdrawal in areas of high water-stress or risk, both at own sites and with suppliers of key commodities
• Covers water withdrawal savings programme and planned efforts to engage priority suppliers
• Addresses support of water stewardship principles and collective actions in water basins that are under pressure
• Includes efforts to establish district cooling in Kalundborg and planned efforts to enhance water quantity and quality

Scope:

• Own production sites and operations
• Suppliers of key commodities
• Water basins under pressure

Monitoring and implementation:

• Water withdrawal savings programme with sites in scope forecasting expected water withdrawals and implementing water savings initiatives
• Water savings are registered per initiative via an internal dashboard
• Total water savings in 2024 amounted to 105,600 m³, of which 51,000 m³ was in areas of high water-stress and/or water risk
• Systematic tracking of water withdrawals and water savings

No information is disclosed regarding who approves and oversees the environmental policy, public availability or links to international standards and guidelines.

Water consumption

Material impacts, risks and opportunities

Identified IRO: Availability and deterioration of water resources (Upstream, Own operations, Downstream)

Negative impacts on water availability occur when we source water for production purposes, especially in water-stressed areas, and at the end-stage impact water quality. Resilience is assessed as part of our nature and biodiversity efforts.

Processes to identify impacts, risks and opportunities

To assess water-related impacts, risks, and opportunities, we conduct screenings of our production sites for areas of water stress and risk using the tool Aqueduct 4.0 from the World Resource Institute (WRI). In 2024 we conducted stakeholder engagements with water management authorities and other industrial water users at our sites in Montes Claros, Brazil, and Hillerød, Denmark, and at our largest API production sites: Clayton, US, and Kalundborg, Denmark.

Policies

Novo Nordisk's environmental policy addresses water management and sets out our ambition to design less water-intensive processes by reusing and recycling water. We treat production-related water discharge onsite and/or offsite and avoid water pollution by discharging water in accordance with local regulations, and in case of any breaches, we take corrective actions.

Our environmental policy also addresses our special focus on water withdrawal in areas of high water-stress or risk, both at our own sites and with suppliers of key commodities, for example through our water withdrawal savings programme and planned efforts to engage priority suppliers. The policy also addresses our support of water stewardship principles and collective actions in water basins that are under pressure.

Actions

We implemented and planned several actions in 2024 to mitigate our impacts on water, as part of our Circular for Zero strategy and our new nature roadmap.

Performance

We have not set external targets on water, but systematically track water withdrawals and water savings as part of our water withdrawal savings programme. In 2024, we experienced an increase in water withdrawal of 26% compared to 2023 due to our growth. Most of the increase is due to increased API production, as well as water used in expansion and construction projects. In 2024, the organisational scope of water withdrawal expanded to also include water withdrawals for offices and research facilities outside of Denmark, which increased the total water withdrawal by further 3%.

Most of water drawn into the boundaries of Novo Nordisk is used for cooling and the fermentation process, and is subsequently discharged, making the actual water consumption relatively low. The largest share of water consumed comes from evaporation, water waste (sludge) and water in our products. We estimate that, in 2024, over 400 thousand m³ of water were reused or recycled at our production facilities.

Production sites in China (Tianjin), US (Clayton and Durham), Iran (Tehran) and Algeria (Blida) are located in areas with high or extremely high water-stress and/or water risk. These sites account for approximately 23% of the total water withdrawal, with the biggest withdrawal occurring in the US and China.

2.4.1 Water consumption

¹ Water withdrawal was previously reported as 'Water consumption'.

Accounting policies

Water withdrawal: Includes all types of water such as drinking water, industrial water, steam, rain water and water from remediation wells and rainwater. Data is based on meter readings and invoices. Data for offices and affiliates outside Denmark are extrapolated based on data available for their Danish counterparts (approximately 97% of the total is based on primary data).

Water discharge: Includes discharge of process- and sanitary water and discharge from storm water to outside Novo Nordisk's boundaries, and water discharge used for irrigation. For offices where discharge data are not available, it has been assumed that water discharge equals water withdrawal.

Water consumption: Water drawn into Novo Nordisk's boundaries but not discharged, calculated as the balance between total water withdrawal and total water discharge.

Total water consumed in areas at water risk, including areas of high-water stress: Total water consumed by sites located in areas at water risk, including areas of high water stress. The identification of production sites in scope is performed using the Aqueduct 4.0 Water Risk Atlas tool provided by the World Resource Institute using two indicators: baseline water stress and overall water risk. 'High' means high or extremely high ratings in Aqueduct 4.0. The data reported are based on primary data.

Total water recycled and reused: Total quantity of water and water discharge (treated or untreated) that has been used more than once at the production sites before being discharged. The volume is estimated based on key indicators for specific water treatment equipment and technologies available at the sites. This includes steam condensate returned to steam generator, reverse osmosis water treatment, and water discharge from water treatment for irrigation. The metric is estimated with a conservative approach.

Water intensity ratio: Total water consumption (as outlined above) per DKK million in net revenue, defined as total net sales generated by Novo Nordisk.

Transition plan and consideration of biodiversity and ecosystems in strategy and business model

Integration in corporate strategy and business model

Novo Nordisk has an aspiration to halt the loss of nature in the value chain by 2033, and become nature positive by 2045. This will be achieved by reducing impact on land, water, and biodiversity, while driving positive impacts through restoration and transformative actions. In pursuing this ambition, the company seeks to mitigate the risks nature loss poses to business and drive action for nature in line with global policy frameworks, including the Kunming-Montreal Biodiversity Framework and the EU Biodiversity Strategy for 2030. The nature roadmap has been approved by Executive Management and Board of Directors.

Local and indigenous knowledge will be incorporated into the development of restoration projects where appropriate, and biodiversity offsets are not used as part of the nature roadmap.

Biodiversity targets and scope

Linkage to nature-related risk assessment

To inform the development of the nature roadmap in 2024, Novo Nordisk conducted a high-level resilience analysis of the exposure of the current business model to ecosystem-related risks. The analysis considered one scenario where the company meets its nature roadmap ambitions and one in which it does not. The results indicated that implementation of the roadmap could decrease Novo Nordisk's exposure to nature-related risks related to raw material shortage and emerging deforestation regulation and highlighted the need for continued focus on water management.

In conducting the analysis, it was assumed that high nature degradation would continue along the current trajectory towards 2030 and 2050. The scope included the upstream value chain of strategically significant raw materials in selected geographies, water withdrawal at key sites in own operations, and chemicals in water discharge in the downstream value chain. External stakeholders were not involved in the analysis.

Performance and effectiveness tracking

As part of the nature roadmap, the company is continuously working to understand and measure impacts and dependencies, and will continue this effort as it begins implementing the roadmap in 2025, also establishing processes to track the effectiveness of actions.

Policies related to biodiversity and ecosystems

The sustainability statement includes ESRS E4-2 disclosure requirements. According to the reference table on page 67, the company addresses data point 24 (d) under ESRS E4-2 in the Sustainability statement on page 67.

However, the excerpts provided do not contain the actual policy content from page 67. The cross-reference table indicates that:

• ESRS E4-2 data point 24 (b) is covered on page 67 (SFDR reference: x)
• ESRS E4-2 data point 24 (c) is marked as "Not applicable to NN" (Not applicable to Novo Nordisk)
• ESRS E4-2 data point 24 (d) is covered on page 67 (SFDR reference: x)

The excerpts show that E4-2 (Policies) is listed in the disclosure requirements table but the actual policy details are not included in the provided excerpts. Without access to page 67 of the Sustainability statement, the specific policy names, scope, governance, and other required elements under ESRS E4-2 cannot be confirmed.

Based solely on the excerpts provided, the biodiversity policies content is not available for extraction.

We have sharpened our focus on the impact of our operations on nature and biodiversity, setting an ambition to halt nature loss across our value chain by 2033 and achieving nature-positive status by 2045.

Impact metrics related to biodiversity and ecosystems change

Species impact metrics

Novo Nordisk has disclosed actions related to vulnerable and endangered species:

Horseshoe crab materials phase-out:

• Phase-out of TAL (Tachypleus amebocyte lysate from endangered Chinese horseshoe crab) has been completed as of 2023
• Use of LAL (Limulus amebocyte lysate from vulnerable American horseshoe crab) in research areas was discontinued in 2024
• Remaining phase-out of LAL for testing samples is tentatively expected between 2025 and 2035, with the majority of testing expected to be phased out by 2027
• Complete discontinuation depends on regulatory approvals of alternative testing methods

Land use footprint

The company references transformation approaches to "optimise and replace glucose in API production to bring our glucose land footprint close to zero by 2045" in own operations, but does not disclose the current quantified land use footprint in hectares.

Nature-related risk analysis scope

The scenario analysis scope included:

• Upstream value chain of strategically significant raw materials in selected geographies
• Water withdrawal at key sites in own operations
• Chemicals in water discharge in the downstream value chain

No quantified metrics for land use (hectares), deforestation footprint, operations in protected areas/KBAs, or ecosystem restoration are disclosed.

Policies related to resource use and circular economy

The excerpts provided do not contain specific information about policies related to resource use and circular economy (ESRS E5-1). The document index shows that E5-1 is disclosed on page 60, but the actual policy content from that page is not included in the excerpts provided.

The excerpts only contain cross-reference tables and navigation information showing where various ESRS disclosures can be found in the full report, but do not include the substantive policy disclosures themselves for E5-1.

Plastic footprint reduction target

We are targeting a 30% reduction in the amount of plastic used per patient by 2033, underpinned by the adoption of a reduce, change and avoid approach across our diabetes and obesity portfolio.

ESRS E5-4 Resource Inflows

Novo Nordisk discloses resource inflows as part of its Circular for Zero strategy and efforts to decouple resource use and waste from growth in patient volumes.

Overall Resource Inflows

In 2024, the overall total weight of products and technical and biological materials used for the manufacture of medicines amounted to 226 thousand tonnes, with approximately two thirds being technical materials and one third biological components.

Resource Inflows Table

Material Composition

The main products and materials sourced that relate to resource inflows include:

• Biological materials: Agricultural commodities (e.g., glucose) and printed packaging
• Technical materials: Acids and bases, solvents, plastic components and plastic raw materials
• Critical raw materials: While not directly purchased, some purchased items include magnesium, manganese, and phosphorus

Sustainably Sourced Materials

Novo Nordisk does not currently procure certified sustainably sourced biological materials, leading to a reported share of 0% for sustainably sourced biological materials.

Recycled and Reused Materials

In 2024, the total weight of reused or recycled materials was 3 tonnes (representing 1% of total materials), primarily from:

• Sourcing of gowning
• Recycled pallet shippers and shipper boxes

Context

The company notes that while it strives to source reused, recycled, and renewable biological materials, patient safety and stringent regulatory requirements applicable to the pharmaceutical sector are paramount considerations. The pharmaceutical industry faces restrictions on the use of recycled materials in medicines and devices due to regulatory standards.

Resource outflows

Product durability

Prefilled devices:

• Expected durability of unopened prefilled devices: 24-36 months (shelf-life)
• Prefilled devices for single use: 1 use
• Prefilled devices for multiple use: 7 uses
• Industry range: 12-36 months (unopened); 7 uses (multiple use)

Reusable devices:

• Expected durability: 60 months
• Industry range: 12-72 months

Recyclability

Products:

• Recyclable content in products: 0%
• Rationale: While many components of devices can be recycled individually, there is no established recycling infrastructure for pharmaceutical waste in many markets. Novo Nordisk conservatively assumes zero recyclable content in products.

Packaging:

• Recyclable content in products packaging: 28% (conservative estimate reflecting the lowest share according to product lifecycle assessments)
• Full range across markets: 28-88%, with variation due to differing packaging compositions across core products and three key geographies (Europe, US and Japan)
• Note: Data on total packaging weights by geography have not been available for 2024, but establishing this data foundation is a priority for 2025.

Design for circularity

Novo Nordisk applies circular design guidelines to every design process for devices and packaging, considering:

1. Design for expected lifetime
2. Design for sustainable materials
3. No unnecessary waste in production
4. Recyclability after use

The company is developing a cost-efficient reusable pen with a competitive environmental profile across its injection pen portfolio, with launch planned for 2026. Future plans include delivering the majority of daily insulins in reusable devices.

ReMed™ take-back programme

ReMed™ is a device take-back scheme launched in 2020 to enable pen users to return used devices for recycling, preventing plastic from ending up in landfills. The scheme is now active in seven key markets including Denmark, Brazil, France, Italy, UK, Japan, and Germany.

• Return rate: 32% achieved for all injection devices in Danish industry scheme (2024)
• Recycling rate for returned pens: Increased from 50% in early 2024 to 70% by end of 2024
• Total pens returned since first pilot: Over 4 million
• Denmark operates a unique industry-wide collaboration with other healthcare companies
• UK pilot planned for 2025

Waste

Total waste and composition

In 2024, Novo Nordisk's total waste increased by 21% compared to 2023, primarily due to:

• Increased production volumes (19% increase in waste generated in production)
• Inclusion of non-production entities in the total waste metric (2%)

The company's largest waste streams by volume are:

• Organic residue (e.g., yeast slurry)
• Water waste (waste fraction with high water content treated as waste)
• Ethanol waste

The majority of organic residues is diverted from disposal through recycling and other recovery operations.

Waste by type and destination

Waste composition:

• 15% of total waste was directed to disposal (non-recycled)
• 85% was recycled, recovered or prepared for reuse
• Hazardous waste accounted for 23% of total, with equal split between further recycling/recovery operations and waste directed to disposal through incineration

Detailed breakdown (from visual representation in report):

Non-hazardous waste (176,708 tonnes):

• Waste diverted from disposal: 149,853 tonnes
  • Preparation for reuse: minimal
  • Recycling: 26,022 tonnes
  • Other recovery operations: 14,099 tonnes
  • (Remainder unlabelled in breakdown)
• Waste directed to disposal: 7,743 tonnes
  • Incineration: 247 tonnes
  • Landfill: 120 tonnes
  • Other disposal operations: 40 tonnes
  • (Remainder unlabelled)

Hazardous waste (52,982 tonnes):

• Waste diverted from disposal: 26,713 tonnes
  • (Breakdown not fully detailed)
• Waste directed to disposal: 26,269 tonnes
  • Incineration: 12,614 tonnes
  • (Remainder unlabelled)

Radioactive waste:

• 20kg Isotope 125-I solid
• 15kg Isotope 125-I Liquid
• 15kg Isotope 3-H, solid
• 37kg Isotope 3-H, solid

Waste management approach and policies

Novo Nordisk's environmental policy prioritises the waste hierarchy, addressing all levels from prevention and reuse to recycling, energy recovery and disposal. The company works systematically to avoid and reduce waste over waste treatment where possible.

Key principles:

• All production facilities are ISO 14001 certified for environmental management
• Waste is measured by weight receipts or other data from certified waste management companies
• December data is estimated
• Waste data for offices and affiliates outside Denmark are extrapolated based on headcount data
• All waste categories are split between hazardous and non-hazardous according to the EU's Waste Framework Directive
• Radioactive waste is reported separately and handled in compliance with applicable regulations

Targets and progress

Zero landfill target:

• Target: Zero waste to landfill from production sites by 2030
• Baseline: 2019
• 2024 progress: 94 tonnes waste to landfill from production
• Achievement: 92% reduction compared to baseline (2019)

Plastic footprint target:

• Target: 30% reduction in plastic footprint per patient by 2033
• Baseline: 0.35 kg/patient in 2024
• 2024 absolute plastic footprint: 15,654 tonnes

Circular production processes

Novo Nordisk implements circular production processes including:

• Internal reuse of ethanol at the two largest API production sites, reducing use of new ethanol by almost 90%
• At site Kalundborg, Denmark, remaining ethanol waste together with yeast slurry is turned into energy and fertiliser for local farmers as part of the Kalundborg Symbiosis

The Novo Nordisk Way Essentials

1. We create value by having a patient-centred business approach.
2. We set ambitious goals and are empowered to achieve them.
3. We are accountable for our financial, environmental and social performance.
4. We are curious and innovate for the benefit of patients and society at large.
5. We build and maintain good relations with our stakeholders.
6. We value diversity and treat everyone with respect.
7. We focus on performance and personal development.
8. We have a healthy and engaging working environment.
9. We strive for agility and simplicity in everything we do.
10. We never compromise on quality and ethics.

The foundation of our commitment to supporting the wellbeing and development of our employees is the Novo Nordisk Way; a set of guiding principles constituting the core of our identity and operations. It bridges our company's past, present and future, steering our strategy, decisions and behaviours. By familiarising new employees with the 10 Essentials that direct the decisions and actions of every Novo Nordisk colleague, we uphold our dedication to the company's core values of openness, accountability and respect.

Taking action on material impacts on own workforce

Training and Development Programmes

Scope: Own operations (global)

Description: Employees have access to not only role-related training but also development options through global talent and development programmes, virtual and face-to-face skill courses, and online learning content.

Outcomes/KPIs (2024):

• Employees engaged in development programmes
• About 2,000 employees completed global strategic capability development programmes
• More than 40,000 times employees and leaders have completed a learning item online to help develop specific skills
• Progress of training programmes are monitored through voluntary surveys following course completion

Resources allocated: Not quantified

Gender Diversity in Leadership

Scope: Own operations (global)

Time horizon: Target set in 2021 for achievement by end of 2025

Description: Target to achieve balanced gender representation across all managerial levels, and a minimum of 45% women and 45% men in senior leadership roles by the end of 2025. The target was developed in collaboration with leaders and People & Organisation representatives and approved by the Board of Directors.

Link to policy: Target is applicable across operations and was set based on various benchmarks, including pharmaceutical peers, other global Danish companies, industry-leaders and research.

Performance (2024):

• 46% of all leadership positions filled by women (same as 2023)
• 42% of senior leadership positions filled by women (vs. 41% in 2023)
• Board of Directors: equal gender representation (6 female, 6 male members)

Resources allocated: Not quantified

Equal Pay Reviews

Scope: Own operations (global)

Description: Active work with equal pay through equal pay reviews. In 2024, 0.13% of positions were identified to have an equal pay gap when taking into account various parameters beyond gender.

Outcomes/KPIs (2024):

• Aggregated gender pay gap: 3% in favour of women

Resources allocated: Not quantified

Diversity and Inclusion Monitoring

Scope: Own operations (global)

Description: Across all D&I efforts, monitoring of global Inclusion Index. Tracking of age distribution among employees to ensure equal treatment and opportunities for all.

Performance (2024):

• Under 30 years old: 16%
• Between 30 and 50 years old: 65%
• Over 50 years old: 19%

Resources allocated: Not quantified

We are carefully monitoring workplace stress levels, targeting a 10% annual reduction in the number of employees reporting symptoms of stress. Although we did not meet this target in 2024, when overall stress levels remained unchanged year-on-year at 13.8%, we will continue to implement new measures to address symptoms of stress at the earliest opportunity.

Characteristics of the undertaking's employees

Total headcount and FTE

Note: Total headcount of 77,349 as per note 2.4 in the Consolidated financial statements. The variance of 3,193 employees is due to Catalent employees not being included. On 18 December 2024, Novo Nordisk acquired three fill-finish sites from Catalent Inc. The impact has been deemed immaterial for sustainability reporting and Catalent employees are not included in the Sustainability statement.

Headcount by region

Headcount by employment contract type and gender

Note: Prior year comparatives (2023, 2022) not disclosed for these breakdowns.

Employee turnover

Accounting policy: Employee turnover measured as the number of leavers during the financial year (excluding temporary employees), divided by the average number of employees (excluding temporary employees). Employees working for Group companies that have been sold are not counted as having left the Group.

Gender representation in leadership

The company discloses gender in senior leadership positions with a target of balanced gender representation (minimum 45% women and 45% men in senior leadership roles by end of 2025).

Management levels breakdown:

Collective bargaining coverage

Note: All employees covered by collective bargaining agreements in Denmark are also covered by workers' representatives, resulting in a 32% representation. Novo Nordisk began reporting on collective bargaining coverage for Denmark in 2024.

Additional workforce characteristics

The company increased its workforce by 9,837 employees since 2023, ending 2024 with 74,156 employees (excluding Catalent). The most significant increase was at production sites, particularly within manufacturing and quality, as well as professionals within Digital & IT. The company reports providing pay above the living wage in each country.

Scope note: For policies, actions and targets related to 'Own workforce', NNE (a subsidiary) is excluded, as the subsidiary has its own processes in place. Employee data is based on registrations in Novo Nordisk's HR systems. Employees are attributed to geographical regions according to their primary workplace.

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

Disclosure

Novo Nordisk's disclosure indicates that non-employee workers are included in the scope of certain policies and reporting processes, but does not provide detailed quantitative breakdowns of non-employee workforce characteristics.

Scope and Coverage

Policy Coverage:

• The Health and Safety policy applies across all operations, including contractors
• Cases reported to the Compliance Hotline cover internal employees, consultants and other externally hired individual workers

Accounting Policy - Employees (headcount): Measured as the headcount of all employees at year-end, excluding:

• Externals
• Employees on unpaid leave
• Interns
• Bachelor's and Master's thesis employees
• Substitutes

Employee data is based on registrations in Novo Nordisk's HR system.

Work-related accidents: Contractors, visitors, employees on unpaid leave, interns, and Bachelor's and Master's thesis students are not included in the rate of recordable work-related accidents metric.

Quantitative Data

No specific headcount or FTE data for non-employee workers (contractors, agency workers, self-employed) is disclosed in the sustainability statement.

Collective bargaining coverage and social dialogue

Policy and dialogue mechanisms

Novo Nordisk respects employees' right to associate freely and to join or refrain from joining labour unions and workers' councils without fear of discrimination or retaliation. Where the right of freedom of association and collective bargaining is restricted or prohibited under law, the company does not hinder employees from developing alternative mechanisms to express their grievances and protect their rights regarding working conditions.

To encourage social dialogue, Novo Nordisk engages with workers' representatives, for example, through Novo Nordisk's European Works Council (EWC). Dialogue meetings between management and workers' representatives are scheduled at least every quarter. Dialogue with the European Works Council (EWC) secretariat takes place on an ongoing basis, and includes an annual meeting with all EWC representatives. Negotiations on topics such as salary and collective bargaining agreements depend on the agreed time frame.

In Denmark, worker's representatives are also represented at the Board of Directors, further enhancing dialogue and representation.

Collective bargaining coverage metrics

Novo Nordisk began reporting on the number and percentage of collective bargaining coverage for Denmark in 2024. All employees covered by collective bargaining agreements in Denmark are also covered by workers' representatives.

Table 3.2.4: Collective bargaining agreements and workers' representatives coverage

Methodology note: Percentage of employees covered by collective bargaining agreements and workers' representatives are calculated as headcount covered in Denmark at year-end divided by total headcount in Denmark at year-end. There are five collective bargaining agreements currently in effect, covering 32% of the workforce in Denmark, based on specific employee sub-groups (administrative, technicians, operators, skilled workers, etc.).

Value chain standards

Novo Nordisk's Responsible Sourcing Standards require suppliers to respect labour rights principles, enabling workers to associate freely, join or not join labour unions, seek representation, and join workers' councils in support of social dialogue.

Our focus is on ensuring new hires receive the support and resources they need to fully integrate into our global workforce and connect with the Novo Nordisk Way. This approach also safeguards our focus on diversity and inclusion, fostering an environment where every employee feels valued and included.

Share of women in senior leadership positions has increased by 0.7 percentage point to 42% compared to 2023.

Adequate wages

Benchmark used

Novo Nordisk states in its Labour Code of Conduct that:

"All employees are required to receive secure employment and adequate income in a standard working week to meet their basic needs, along with discretionary income. This is achieved by maintaining employee salaries and benefits above the living wage of a given country, the statutory minimum wage given by law, prevailing industry benchmarks, or the wage negotiated in collective agreements, whichever is the highest."

The company explicitly references living wage as one of the benchmarks applied (alongside minimum wage, industry benchmarks, and collective bargaining agreements). However, the specific methodology or external living wage benchmark used (e.g., Fair Wage Network, WageIndicator, Anker Methodology) is not disclosed.

Coverage

In section 3.2.4, Novo Nordisk states:

"With respect to adequate wages, we provide employees with pay that is above the living wage in the given country."

No specific percentage of workforce assessed or verified as earning above living wage is disclosed. The statement appears to apply to all own employees globally.

Geographic scope

The policy scope is listed as "All Novo Nordisk employees" globally. No geographic exclusions are mentioned.

Targets and commitments

No forward-looking targets or commitments related to adequate wages are disclosed.

Methodology details

The company states that "periodic assessments and adjustments are made to account for changes in the cost of living and economic conditions," but does not disclose:

• The specific living wage calculation methodology used
• Frequency of reassessment
• Whether contractors or non-employees are included
• How living wage thresholds are determined for different countries

Additional context

In Denmark, 32% of the workforce is covered by collective bargaining agreements (5 agreements in effect as of 2024). The company emphasizes paying whichever is highest among living wage, minimum wage, industry benchmarks, or collectively bargained wages.

Social protection

Novo Nordisk states that employees are covered by social protection through public programmes or benefits offered by Novo Nordisk.

The company does not provide quantitative disclosure of the percentage of employees covered by social protection against loss of income due to sickness, maternity, paternity, disability, unemployment, or retirement. No breakdown by country, employee category, or type of scheme (public vs. private) is provided.

Related policy commitments

The company's Labour Code of Conduct applies to all Novo Nordisk employees globally and is aligned with international labour standards including the UN Guiding Principles on Business and Human Rights and the International Labour Organization's Declaration on Fundamental Principles and Rights at Work.

Enhanced parental leave benefits

As part of working conditions improvements, Novo Nordisk introduced enhanced global minimum standards for paid leave effective January 2025:

• Parental leave for non-birthing parents extended from 8 to 14 weeks globally
• Introduction of 2 weeks of paid leave annually for employees to handle serious health conditions of dependents

These enhancements apply across global operations.

Health and safety metrics

Coverage of health and safety management system

100% of Novo Nordisk employees (own workforce) are covered by the health and safety management system. The system applies to all employees globally and is based on legal requirements and/or recognised standards or guidelines. All production facilities are certified by ISO 45001.

Health and safety performance metrics (own workforce)

Methodology notes

The calculation method for the rate of recordable work-related accidents was changed as of January 2024 to follow international standard definitions, harmonising the FTE equivalent working hours to 2,000 hours per year (previously 1,600 hours) and using average FTE numbers instead of year-end figures. Comparative figures for 2022 and 2023 have been restated from 1.5 accidents per million hours worked to 1.3.

Recordable work-related accidents are defined as total number of work-related injuries causing at least one day of absence in addition to the day of the accident. Contractors, visitors, employees on unpaid leave, interns, and Bachelor's and Master's thesis students are not included in the metrics.

The percentage of employees covered is calculated as the number of employees covered by health and safety management systems (headcount) divided by all employees (headcount).

Moreover, it is crucial that we maintain a sustainable work-life balance for all our employees. As our business grows, we are carefully monitoring workplace stress levels, targeting a 10% annual reduction in the number of employees reporting symptoms of stress. Although we did not meet this target in 2024, when overall stress levels remained unchanged year-on-year at 13.8%, we will continue to implement new measures to address symptoms of stress at the earliest opportunity.

Compensation metrics

Pay gap

In 2024, Novo Nordisk reported a gender pay gap of 3% in favour of women (aggregated across all job levels and countries). This represents the unadjusted headline figure.

The company conducts quarterly equal pay reviews that go beyond gender, considering various parameters including job level, job family, tenure, and country to identify pay gaps. In 2024, out of approximately 62,000 positions covered in the pay review, 0.13% were identified with an equal pay gap (compared to 0.6% in 2023), with corrective actions being taken.

Remuneration ratio

The annual total remuneration ratio between the highest-paid individual and the median employee is 63:1 (ratio: 63).

Methodology

Gender pay gap: Calculated as the difference between the average annualised salary for men and women divided by the average annualised salary for men, expressed as a percentage. All employees at all job levels and in all countries have been included in this metric. Calculations were performed for the full consolidation, regardless of job level and country. A negative gender pay gap shows a pay gap in favour of women.

Annual total remuneration ratio: Calculated as the ratio between the annual remuneration of the highest paid individual (typically CEO) and the annual total remuneration for all employees (median).

Scope: The metrics cover global operations across Novo Nordisk's consolidated entities.

Incidents, complaints and severe human rights impacts

Summary

In 2024, Novo Nordisk had 167 substantiated people-related cases, which is based on people who have filed a complaint or concern of different levels of severity and which have been confirmed. Of these, 139 cases related to harassment, including discrimination. None were deemed as severe cases of human rights incidents.

Various activities took place during the year to ensure awareness of speak-up channels and completeness of data. In 2024, the architecture of grievance mechanisms has been improved and the internal governance has been strengthened, to support registration of incidents reported and investigated locally. The company acknowledges that there may be cases which are not being reported to the Compliance Hotline.

Metrics

Accounting policies

Substantiated people-related cases: Cases that, through a formal process, have been reported to or filed with the Compliance Hotline and have been substantiated or partially substantiated based on an investigation during the year. Cases are within the overarching categories of the global anti-harassment framework, the Novo Nordisk Way and Ombudsman, as well as other potential human rights breaches for internal employees, consultants and other externally hired individual workers.

Substantiated cases of harassment, including discrimination: Cases that have been closed as substantiated or partially substantiated based on an investigation under the Novo Nordisk Way and the global anti-harassment framework for own workforce.

Severe human rights incidents: Any substantiated case of severe adverse human rights impacts (child labour or forced labour) reported via Novo Nordisk's Compliance Hotline for own workforce, that has been closed during the year based on an investigation.

Breaches of the UNGPs: Incidents presenting a breach to the United Nations Guiding Principles on Business and Human Rights.

Complaints filed with OECD Multinational Enterprise Contact Points: Cases filed against a Novo Nordisk legal entity (parent or affiliate) under the OECD's database of specific instances.

Amount of material fines, penalties and compensation related to the above-mentioned incidents: Damages resulting from violations of social or human rights laws, including discrimination and severe human rights incidents, where a Novo Nordisk legal entity (parent or affiliate) has been found in violation by a court of law and been condemned to pay material fines, penalties or compensation.

Sustainable supply chain

Acquisition of Catalent by Novo Holdings and the related acquisition by Novo Nordisk of three manufacturing sites from Novo Holdings completed.

Key decarbonisation measures include switching to low-carbon materials and feedstock across our production network, shifting our distribution model to low-emissions transportation and supporting our suppliers in transitioning to renewable energy. To date, more than 1,800 suppliers have already committed to make the switch.

Taking action on material impacts on value chain workers

Responsible Sourcing Programme

The Responsible Sourcing Programme is being implemented across global procurement teams responsible for various sourcing categories to ensure identification and mitigation of negative impacts and risks by engaging with suppliers, conducting supplier audits, developing corrective action plans and monitoring progress.

Scope: Global suppliers

Governance: Senior Vice President of Global Solutions (most senior level accountable)

Process:

• Direct and indirect engagement with supplier representatives through ongoing engagements across sourcing units and supplier audits
• Procurement functions responsible for ensuring engagement is conducted in accordance with the Responsible Sourcing Programme
• Audits may be extended if indicators from pre-audit survey show heightened human rights risks

Monitoring:

• Regular supplier audits conducted, including re-visits
• Corrective action plans developed in event of breach
• Follow-up to ensure resolution of issues
• Right to terminate contract if supplier fails to comply with corrective action plan

Performance 2024:

• 429 supplier audits conducted (increased from 382 in 2023)
• 3 critical findings issued:
  • 2 related to responsible sourcing (management of contract labour) - remediation ongoing
  • 1 related to quality audits (protection against cross contamination) - agreements made with affected supplier

Specific Actions

Strengthened the Responsible Sourcing Standard

Description: Update of policy from October 2024, making it mandatory for all new contracts going forward. Policy requirements aligned with external legal firm and CSDDD.

Scope: Global suppliers

Timeline: Phased approach initiated October 2024, aiming to complete by 2027

Target in place: No

Overall progress in 2024:

• Focus on larger contracts and strategic suppliers
• Working in phased approach to ensure all suppliers globally adopt Responsible Sourcing Standards in new or renegotiated contracts
• Effectiveness and progress assessed continuously

Key Policy Requirements for Suppliers

Health and Safety:

• Regular review of health and safety policies, regulations and processes
• Provide necessary worker protection and safety equipment
• Implement emergency plans and train workers accordingly
• Global minimum construction safety standards for capacity expansion projects
• Safe working conditions (physical and mental health, workplace free from harassment)

Human Rights:

• Zero tolerance for forced labour or human trafficking
• Protection of vulnerable groups
• Protection, security, and lawful use of personal data
• Minimum compliance with all applicable privacy and data protection laws

Resources (non-financial):

• Various procurement functions managing supplier relationships
• Corporate Quality & Inspections function conducting audits
• External legal firm support for policy alignment with CSDDD

Related Programmes (mentioned as engagement mechanisms)

• Renewable electricity commitments in supply chain
• Informed supplier and third-party representative selection
• Human rights due diligence through established contracting and engagement processes

Prevention initiatives

Our pioneering urban health programme, Cities for Better Health (CBH), sits at the forefront of our prevention efforts. Now with a broadened scope that aligns with our expansion into new therapy areas, this public-private partnership drives action to prevent serious chronic diseases across a global network of 51 large cities.

The Childhood Obesity Prevention Initiative (COPI) is the latest initiative to come out of CBH. Taking aim at childhood overweight and obesity, it seeks to deliver measurable, community-driven interventions promoting healthy eating and physical activity among children living in underprivileged urban communities.

Patient access and protection

As the global prevalence of serious chronic diseases continues to increase, overburdened healthcare systems face growing pressure to deliver cost-effective, quality care, while millions of people lack access to essential treatments. In 2024, we reached more than 45.2 million people with our life-changing medicines – an increase of 3.6 million compared to 2023.

Access initiatives for vulnerable populations

As our business grows, so does our social responsibility to support vulnerable populations, and this year we were able to reach 8.4 million vulnerable people living with diabetes – a slight decrease compared to 2023.

Changing Diabetes® in Children programme

Key initiatives include Changing Diabetes® in Children (CDiC), which has reached over 64,000 children with type 1 diabetes in low- and middle-income countries since 2009. Support can include free life-saving medicine, blood glucose monitoring equipment and medical supplies for young people under 25.

Other access programmes

• Partnering for Change: collaboration with the Danish Red Cross to address health issues in humanitarian crises
• iCARE: integrated business model aimed at breaking down barriers to diabetes care in Middle Africa and Indonesia
• Access to Insulin Commitment: providing access to affordable care for vulnerable populations

Taking action on material impacts on consumers

PRODUCT SAFETY AND QUALITY

Mitigating risks related to product safety and quality signals

Description: Monitoring and using safety information from patients to take timely and appropriate action to improve product quality and safety. Outcomes are monitored in our risk management system and a risk management plan is prepared in accordance with regulatory requirements.

Scope: All Novo Nordisk products with marketing authorisation and products in Novo Nordisk sponsored clinical trials

Target in place: No

Progress in 2024:

• A safety committee with members from all relevant functional areas is established prior to any clinical investigation of a new pharmaceutical product or medical device, providing assessments of safety data throughout the product or device's life cycle
• Number of product recalls and failed inspections are reported to track effectiveness. In 2024, we tracked three product recalls and 0 failed inspections

Performance:

• Product recalls: 3 (2024), 2 (2023), 3 (2022)
  • Three product recalls in 2024 due to cracked cartridges of insulin products in South Africa, underfilled vials in the Czech Republic and incorrect labelling of products in clinical trials. None of the recalls had serious adverse health consequences.
• Failed inspections: 0 (2024), 0 (2023), 0 (2022)
  • 180 inspections conducted in 2024; 144 inspections passed and 36 were in-progress at year-end

Mitigating safety risks in clinical trials

Description: Detailed protocol for each clinical research activity based on scientific methodology and ethical considerations, to be approved by an Independent Ethics Committee, Institutional Review Board or other appropriate bodies, as well as by regulatory authorities prior to study start.

Scope: All Novo Nordisk sponsored clinical trials

Target in place: No

Progress in 2024:

• Relevant safety information is continuously assessed during Novo Nordisk-sponsored clinical research activities and appropriate actions taken if risks outweigh potential benefits
• In the event of any clinical research-related injury, participants are compensated according to domestic laws

FALSIFIED MEDICINES

Product protection end-to-end solutions

Description: Applying relevant security features based on risk assessment and regulatory requirements, including reinforcing supply chain integrity through security specifications in distribution and warehouse contracts.

Scope: Global operations and downstream value chain

Target in place: No

Progress in 2024:

• Continued to review the security of our supply chain including agile testing solutions and rapid testing devices to support swift identification of falsified medicines
• Continuously review our approach to the protective features of products, from overt to covert solutions

Awareness campaigns and training

Description: Awareness campaigns and onboarding programme to prevent patients from buying medicines outside legitimate channels, including more information for healthcare professionals.

Scope: Global operations and downstream value chain

Target in place: No

Progress in 2024:

• Rolled out a dedicated, onboarding programme to over 1,600 employees in relevant functions
• Launch of awareness programme for law enforcement agencies enabling an increase in seizures of falsified medicines
• Launch of other external awareness campaigns for patients via social media and our website

Operational approach:

• Novo Nordisk detects falsified medicines through reported product complaints from patients, healthcare professionals and authorities, as well as through field- and online surveillance by investigative firms
• Specialised security services are used to conduct investigations, test purchases and for decommissioning
• Perform market searches to help health authorities locate and seize falsified products
• Collaborate with authorities in over 20 countries, including Europol and Interpol

Ethics and compliance

In Novo Nordisk, we have an ethics and compliance programme which comprises of a code of conduct (OneCode), requirements (The Ethics Navigator), processes and awareness and capability building as stipulated in the seven elements of an effective compliance programme.

Data privacy is a key component in our ethical principles, ensuring guardrails are in place to manage and mitigate risks, thus safeguarding our patients and society at large.

We have also adopted a set of principles for data and artificial intelligence (AI) ethics to support ethical decision-making. We have initiated building our AI Ethics & Compliance framework, incorporating elements such as principles, requirements and risk assessments, as well as building AI literacy training and capabilities.

You can read more about these principles, in accordance with the Danish Financial Statements Act Section 99d, at: www.novonordisk.com/data-privacy-and-user-rights/data-ethics.html.

Corporate culture foundation

We employ a distinctive, systematic approach known as facilitation – value audits – to ensure that all employees adhere to these Essentials. The foundation of our commitment to supporting the wellbeing and development of our employees is the Novo Nordisk Way; a set of guiding principles constituting the core of our identity and operations.

Supply chain management

Key decarbonisation measures include switching to low-carbon materials and feedstock across our production network, shifting our distribution model to low-emissions transportation and supporting our suppliers in transitioning to renewable energy. To date, more than 1,800 suppliers have already committed to make the switch.

Catalent acquisition

Acquisition of Catalent by Novo Holdings and the related acquisition by Novo Nordisk of three manufacturing sites from Novo Holdings completed. A significant milestone in 2024 was the acquisition of three fill-finish sites previously run by the global contract manufacturing and development organisation Catalent Inc. This move will enable us to expand our manufacturing capacity and provide future optionality and flexibility for our existing supply network.

In Novo Nordisk, we have an ethics and compliance programme which comprises of a code of conduct (OneCode), requirements (The Ethics Navigator), processes and awareness and capability building as stipulated in the seven elements of an effective compliance programme.

We have also adopted a set of principles for data and artificial intelligence (AI) ethics to support ethical decision-making. We have initiated building our AI Ethics & Compliance framework, incorporating elements such as principles, requirements and risk assessments, as well as building AI literacy training and capabilities.

Incidents of corruption or bribery

Confirmed incidents and convictions

Novo Nordisk reports zero convictions for violations of anti-corruption and anti-bribery laws in 2024. The company continues to have no convictions for breaches of anti-corruption and anti-bribery laws, consistent with 2023 results.

The company explicitly states: "As in 2023, we continue to report zero convictions for breaches of anti-corruption and anti-bribery laws. The amount of fines for violation of anti-corruption and anti-bribery laws, an additional metric introduced in 2024, also amounted to zero."

Fines and penalties

No fines were paid for violations of anti-corruption or anti-bribery laws in 2024. The company reports:

Substantiated cases of misconduct

In 2024, Novo Nordisk reported 242 substantiated cases related to accounting issues, fraud and business ethics matters via the Compliance Hotline. This represents a 9% increase compared to 2023 (221 cases), driven by business growth and increased number of employees.

Note: The numbers for 2022 and 2023 have been restated, as cases involving Novo Nordisk Way violations have been moved to separate reporting on people-related cases to avoid double-counting.

Investigation procedures and speak-up mechanisms

Novo Nordisk operates a Compliance Hotline available to all employees and external stakeholders for reporting concerns of misconduct in a secure and confidential manner, with the option of anonymity. The hotline can be used to report:

• Business ethics misconduct
• Accounting issues
• Fraud, bribery and corruption
• Quality misconduct
• Breaches of antitrust laws
• Environmental legislation and data privacy
• Departures from the Novo Nordisk Way
• Other serious offences

Investigation process:

• For each report in scope, an internal lead investigator is appointed working objectively and independently under confidentiality obligations
• The company replies to all complaints within a few days and confirms closure when investigations are finalized
• Results and significant ongoing investigations are reported quarterly to the Audit Committee and Executive Management, including updates on severe cases, general trends, and corrective actions

Protection of whistleblowers: Novo Nordisk has zero tolerance for discrimination or retaliation against whistleblowers. Anyone who retaliates against an employee reporting misconduct will be subject to disciplinary action, up to and including termination. The company's measures are aligned with the EU Whistleblowing Directive (EU Directive 2019/1937).

Disciplinary actions: Novo Nordisk has established a global Disciplinary Sanction Guideline based on two severity factors: intent and frequency. The guideline ensures alignment of disciplinary sanctions across the organization while respecting local employment laws and collective agreements.

Effectiveness assessment: The company continually assesses the effectiveness of the Compliance Hotline, including an assessment every two years conducted by a third party to ensure trust in the channel and processes.

Anti-corruption programme

Novo Nordisk maintains a robust anti-corruption programme comprising:

• Internal audits
• Training for employees and business partners (99% of employees trained in ethics and compliance in 2024)
• Due diligence around third-party representatives
• Strict prohibition of bribery and corruption
• Adherence to relevant laws and industry codes

Political influence and lobbying activities

Political engagement approach

Novo Nordisk actively engages with various stakeholders, including public officials, to advocate for important issues affecting patients, our business, our partners and the communities in which we operate globally. Our OneCode policy sets out the objectives of having patients' interests as our first priority, acting with professionalism and integrity and adhering to local regulation on public engagement. It also outlines our zero-tolerance of giving or offering anything of value to a politician, public official or decision-maker to seek undue influence. This is essential for us and guides our interactions.

Our advocacy is grounded in realising the potential that innovation in our industry can bring to patients, healthcare systems and society, while ensuring transparency and adherence to business ethics in our interactions. We strive to achieve this by advocating for industry-level initiatives and regulation that promote the following:

• Evidence-based chronic disease prevention, public health and improvement of care for people living with serious chronic diseases.
• Innovation and provision of optimal conditions for making new discoveries to benefit patients.
• Improvements of resilience of healthcare systems.
• A more environmentally sustainable way of operating in the pharma industry.

We are a member of various industry and trade associations representing the pharmaceutical industry, to bring about consensus on broad policy issues that affect the patients we serve and our business. Our membership of these organisations is evaluated on an ongoing basis, considering their expertise in policy, advocacy and ability to drive the agenda on issues important to us.

We engage in a dialogue with stakeholders globally with a deep understanding of the local systems to advance the healthcare agenda, working directly with governments, payers, healthcare providers, advocacy organisations and patients. We also interact with industry organisations as their legitimate representatives, in compliance with relevant laws and regulation.

EU Transparency Register

To ensure transparency around our activities, we are registered in the EU Transparency Register under ID 29570313329-11. No members of our Board of Directors have held a comparable position in public administration in the two years preceding their appointment.

Political contributions and in-kind contributions

A zero-tolerance policy applies at Novo Nordisk with regards to in-kind political contributions.

Trade association memberships

Accounting policies: The total monetary value of trade association membership fees during the financial year reported in DKK millions. Data is collected at country level for Brazil, Canada, China, Denmark, France, Germany, India, Italy, Japan, the United Kingdom and the US, where Novo Nordisk focuses its public affairs activities.

In-kind contributions can include advertising, use of facilities, design and printing, donation of equipment, provision of board membership, employment or consultancy work for elected politicians or candidates for office.

Key advocacy actions

Payment practices

Overview

Novo Nordisk's procurement policy defines guidelines for contracting, including fair and transparent payment practices. The standard payment terms are 60 days, though other terms may be agreed during contract negotiations. The company is committed to preventing late payments to suppliers, particularly small enterprises. During the COVID-19 pandemic, a payment guideline was implemented to ensure payment to small suppliers as soon as possible upon receipt and approval of invoices, which was made permanent and continues to apply.

Payment performance metrics (2024)

Accounting policies

Average number of days to pay invoice: Average number of days it takes Novo Nordisk to settle an invoice from the invoice date (when contractual or statutory term of payment starts to be calculated) until the invoice has been cleared.

Percentage of payments aligned with standard payment terms: Includes all transactions where the invoice cycle time is equal to or less than the specified payment terms, divided by the total number of transactions. Small suppliers (with less than DKK 1 million in spend over the last twelve months) are measured based on 30-day payment terms, whereas other suppliers are assessed using payment terms from the invoice document recorded in internal systems.

Number of outstanding legal proceedings for late payments: Number of all outstanding legal proceedings (litigation or arbitration) for late payment.

Standard payment terms

• Standard payment terms: 60 days
• Small suppliers payment terms: 30 days (for measurement purposes)
• Other terms may be agreed as part of contract negotiations