Pandora

The shareholders exercise their rights at the Annual General Meeting, which is the supreme governing body of the company. During the Annual General Meeting, among other duties, the shareholders elect the members of the Board of Directors (the Board), approve the Annual Report and adopt any proposed changes to the company's Articles of Association.

Pandora has a two-tier management structure composed of the Board and Executive Management. The Board outlines the overall vision, strategy and objectives of Pandora's business activities, supervises the performance of Executive Management and is responsible for overseeing the execution of Pandora's sustainability strategy, performance and targets. In addition, the Board is responsible for adopting the sustainability-related policies. This includes reviewing sustainability reporting and overseeing performance related to Pandora's strategic sustainability priorities and targets. Members of Executive Management are appointed by the Board. Executive Management is responsible for the day-to-day management and for the execution of Pandora's strategy.

Furthermore, Pandora has an Executive Leadership Team (the ELT), comprised of one woman and seven men, representing seven different nationalities. The team members are responsible for the day-to-day operations of their respective business areas and serve as a part of Pandora's overall leadership. Selected ELT members are also part of Pandora's Sustainability Board.

BOARD OF DIRECTORS

Composition The Board is comprised of seven members, all elected at the Annual General Meeting for a one-year term. Currently, the Board consists of four women and three men, representing five different nationalities. In accordance with section 139c of the Danish Companies Act, this is considered equal gender representation on the Board.

In accordance with the Danish Recommendations on Corporate Governance, 86% of the Board members are regarded as independent. Christian Frigast, due to his more than 12-year tenure on the Board, no longer maintains independence status. The composition of the Board is intended to ensure relevant and complementary competencies and diversity. This approach is instrumental in supporting Pandora's strategic goals and vision, while ensuring well-considered, diverse and judicious decision-making.

Board evaluation Each year, the Board conducts a board review focusing on its effectiveness and skills. The ideal mix of skills and experience required of Board members includes:

• Board experience • Retail • Executive management • Digitalisation • Sectoral experience • Sustainability • Marketing and brand • Finance • Governance

An external assessment of the Board's skills and effectiveness is conducted every three years to ensure objectivity and benchmarking. In 2024, the board effectiveness review was conducted with the support of an external provider to ensure objectivity and benchmarking. The results identified that the Board continues to be well-established and well-functioning, supported by a strong belief in the strategy and effectiveness in collaboration with the committees and Executive Management.

The Board held nine meetings in 2024. Its primary focus was to navigate Pandora carefully through uncertain macro-economic circumstances, including the implications from increased commodity prices and complex socio-political environments. Additionally, the Board ensured Pandora remains aligned with the next phase of the Phoenix strategy, announced during Pandora's Capital Markets Day in October 2023, which focuses on transforming the company into a full jewellery brand. Furthermore, the Board has overseen the integration of sustainability into relevant processes in Pandora, ensuring alignment with our strategic priorities and the sustainability targets.

Sustainability integration and governance Sustainability is deeply integrated in our strategic direction and how we conduct business. It is governed at the highest level by the Board, which approves Pandora's climate transition plan. Responsibility for the execution of the strategic sustainability priorities is delegated to Pandora's Sustainability Board. The Sustainability Board is responsible for the strategic priorities and integrating sustainability into business decisions and processes within their respective functions. Reporting to the ELT, and in some matters directly to the Board, the Sustainability Board is chaired by Pandora's Chief HR Officer and consists of nine senior leaders, including ELT members.

Two subject-specific committees (the Responsible Sourcing Committee and the Responsible Marketing Committee) and two task forces (Low Carbon & Nature Task Force and Corporate Sustainability Reporting Directive (CSRD) Task Force) oversee key sustainability areas on responsible sourcing, responsible marketing, our work on environmental impacts, CSRD implementation and compliance within the company. They convene regularly and report to the Sustainability Board. In 2024, we updated our double materiality assessment, as part of the requirements of the CSRD. The double materiality results were approved by Pandora's Sustainability Board, with the Board providing oversight to ensure alignment with strategic goals.

To support the Board in its duties, the Audit, Nomination and Remuneration Committees have been established. Each committee is responsible for carrying out various preparatory tasks within the Board's key areas of responsibility.

The Remuneration Committee is responsible for incentive schemes and remuneration, including those related to sustainability. More information can be found in the Remuneration Report.

RISK MANAGEMENT MATRIX

The Board of Directors (the Board) reviews and discusses key risks that could threaten Pandora's business model or the future performance, solvency or liquidity.

SUSTAINABILITY RISKS ASSESSMENT Sustainability risks are assessed on a quarterly basis and insights from the 2024 double materiality assessment have been incorporated into the enterprise risk management calibration process and reporting. We do not consider sustainability risks to be among our top risks. As part of our climate risk assessment, we evaluate risks across various criteria, with key risks reviewed by the Board. In 2022, we conducted a scenario analysis aligned with our risk management matrix to explore climate risks and opportunities across our value chain, identifying areas crucial to transitioning to low-carbon operations. Insights from an on-site risk assessment conducted at the end of 2024 at our crafting sites in Thailand, will enable us to proactively implement tangible recommendations to mitigate potential future supply chain disruptions caused by climate change.

INTERNAL CONTROL AND RISK MANAGEMENT The Board and Executive Management are responsible for Pandora's internal control and risk management systems in relation to the financial and sustainability reporting process.

Control environment The Group's internal control framework identifies key processes, inherent risks and control procedures to reduce and mitigate financial and sustainability risks and ensure reliable financial and sustainability reporting. The Audit Committee assists the Board in supervising the financial and sustainability reporting process and monitoring the effectiveness of the internal control and risk management systems. Executive Management is responsible for maintaining and strengthening the overall control environment, identifying weaknesses and ensuring necessary steps are taken to mitigate financial and sustainability risks through standardisation and process optimisation. A central Internal Audit and Compliance Controlling (IACC) function has been established to help Pandora accomplish its objectives by bringing a systematic and disciplined approach to evaluating and improving the effectiveness of internal control, compliance and governance processes. In 2024, the head of the IACC function reported to Pandora's Senior Vice President, Corporate Finance, with a dotted reporting line to the Audit Committee Chair. In 2025, the reporting line will be changed to the Chief Financial Officer, still with a dotted reporting line to the Audit Committee Chair.

Risk assessment The Board and Executive Management assess risks on an ongoing basis, including risks related to the financial and sustainability reporting, and they assess measures to manage, reduce or eliminate identified risks. The IACC function assists Executive Management and the Audit Committee in identifying and monitoring financial and sustainability risks in the reporting process. The Audit Committee frequently reviews selected high-risk areas, including significant accounting estimates and material changes to accounting policies. Pandora's Global Risk & Insurance function facilitates identification and monitoring of material enterprise risks and validates measurements taken to reduce the risks to an acceptable level.

Control activities The financial and sustainability information reported by Pandora A/S and its subsidiaries follows a formalised and structured process and is controlled by local controllers with local market knowledge as well as the controlling function within Pandora Global Business Services and Corporate Finance. The Group controlling function is continuously trained in new accounting, sustainability and reporting requirements and monitors compliance with relevant legislation and regulations on an ongoing basis. The financial and sustainability reporting process is dependent on the Group's IT systems. Any weaknesses in system controls and related risks to the financial and sustainability reporting are mitigated by manual controls. Each entity and Global Business Services assess their control environment through a self-assessment of the effectiveness of the implemented controls, including those related to sustainability. The sustainability processes continue to evolve alongside the maturation of the guidance of the requirements in this area. The IACC function evaluates the effectiveness of the Group's control environment on an ongoing basis and reports its findings to the Audit Committee.

Monitoring Pandora's internal control procedures and risk management systems, including the whistleblowing function, are continuously monitored, tested and documented. The Audit Committee monitors internal control and the risk management process to ensure that identified risks are mitigated. In addition to monitoring of procedures and systems, financial and sustainability risks are reviewed through audits performed by the IACC function.

Information and communication Group entities are assigned dedicated controllers within Corporate Finance to ensure a direct line of communication. The Corporate Finance function reports to the Chief Financial Officer. In addition, the IACC function is present at all Audit Committee meetings and provides regular status updates on the control environment. Furthermore, the head of IACC has regular meetings with the Chief Financial Officer and meetings with the Audit Committee without the presence of the management team. This setup ensures transparency, and that communication is shared with the Audit Committee on a timely basis. The Board has adopted an Investor Relations Policy that requires all communication to stakeholders, including financial and sustainability reporting, to be conducted adequately, timely and openly – both internally and externally – and to be conducted factually and truthfully and in compliance with laws and applicable regulations.

BUSINESS MODEL

Pandora is one of the world's most valuable brands, owning the space of jewellery with a meaning. Our unique business model builds on the Pandora brand and our in-house excellence. This translates into a fully integrated ecosystem, with both crafting and distribution at an unparalleled scale. With a strong commitment to sustainability, we deliver industry-leading growth and profitability while minimising our environmental footprint and supporting the communities we touch. Acknowledging both positive and negative impacts, as well as risks and opportunities, we have conducted a double materiality assessment, detailed on page 50.

KEY RESOURCES APPLIED

• An average of 37,000 employees globally
• State-of-the-art crafting facilities, powered by 100% renewable electricity
• Recycled silver and gold and lab-grown diamonds
• Water, energy and other raw materials

VALUE CREATED

• Safe and engaged workplace with an employee Net Promoter Score (eNPS) that puts us in the top 5% in the consumer sector globally
• 865 million customer visits to our stores and online channels, with more than 3 pieces sold every second
• DKK 1.7 billion paid in corporate income taxes
• DKK 5.5 billion in dividends and share buybacks to shareholders

OUR OPERATIONS

INNOVATIVE DESIGN World-class creative design process with built-in consumer testing

RESPONSIBLE SOURCING Materials sourced in a responsible, transparent and traceable way

HIGH-QUALITY JEWELLERY CRAFTING Artistry and craftsmanship unmatched in the industry

GLOBAL BRAND AND MARKETING Top brand equity in our key markets, guided by data and analytics

PACKAGING AND DISTRIBUTION Serving customers and stores by delivering the jewellery safely and on time

OMNICHANNEL RETAIL Personalised experiences for consumers, shoppers and brand lovers

PRODUCT REUSE AND REPAIR Remelt of returning surplus and faulty products and minor repair services

OUR SEGMENTS

The Core segment represents the charms and carriers and is covering the collections Pandora Moments, Pandora ME and Collabs. In 2024, Core made up 74% of revenue and delivered stable like-for-like growth of 2%.

Pandora Moments, which has been established as a key Pandora icon over two decades, is still by far the largest collection and contributes to growth with solid like-for-like growth of 3%. It remains an ever-evolving canvas for personal expression, resonating with customers who seek to capture and celebrate life's precious moments through our iconic charms.

Pandora ME has found a place in the market as a symbol of individuality and self-expression. It makes up 3% of our revenue, with another year of strong double-digit like-for-like growth of 13%.

Collabs are closely tied to storytelling, allowing customers to express their identities through iconic partnerships. In 2024, we launched an exciting collaboration with Netflix, beginning with designs inspired by the popular show Stranger Things. Collabs contributed 8% to our revenue, with a like-for-like decline of -9%, as 2023's "Disney 100" collection, celebrating Disney's centenary, had driven a strong surge in interest.

Fuel with more is made up of the collections Pandora Timeless, Pandora Signature, Pandora Lab-Grown Diamonds and the latest collection launched globally in the spring of 2024, PANDORA ESSENCE. Fuel with more made up 26% of revenue, up from 22% in 2023, as a result of strong like-for-like growth of 22%.

Pandora Timeless is by far the largest collection within Fuel with more, making up 20% of revenue. The momentum from 2023 was carried into 2024, underscoring that we are on the right path to be perceived as a full jewellery brand. Pandora Timeless generated like-for-like growth of 22%, striking a chord with consumers looking for elegance and craftmanship. Pandora Signature represented 3% of our revenue, and whilst the performance was impacted by a cleanup of the assortment, the collection continues to serve as an important offering for our customers.

The new PANDORA ESSENCE collection, which was launched globally in Q2 2024, was off to a solid start and already makes up 2% of revenue. The collection expands into the aesthetic space of organic, fluid and natural jewellery design, which constitutes 17% of the global jewellery market, and draws inspiration from the beauty and simplicity of nature's organic shapes.

Our Pandora Lab-Grown Diamonds collection continues to gain ground, with like-for-like growth of 43% in 2024. The collection has also had a notable positive halo effect on the Pandora brand, increasing consideration to purchase jewellery from any of the collections. We believe the demand for lab-grown diamonds will keep gaining traction, and to facilitate this we added our new microfine diamonds range towards the end of the year. Our goal is to become the most desirable brand in the category while making diamonds accessible to everyone.

OUR MARKETS

The US remains our largest market in terms of revenue, with a share of business of 31% in 2024, yet our market share is just around 2%. Despite a turbulent 2024 for US consumers, like-for-like growth was strong, driven by the brand momentum, and was further enhanced by the BE LOVE campaign and the positive halo effect from Pandora Lab-Grown Diamonds. This translated into like-for-like growth of 8% and organic growth of 14%, as network expansion further fuelled the growth.

Our key markets in Europe delivered like-for-like growth of 4% and a combined share of business of 31%. Growth here was predominantly driven by Germany, which delivered very strong like-for-like growth of 45%, coming into 2024 with strong brand momentum that carried on throughout the year. This momentum was supported by the always-on media model and the BE LOVE campaign, that resonates very well with the consumers. France delivered like-for-like growth of -5% and organic growth of 2%.

In the UK, like-for-like growth ended at -2% with organic growth at 0%, in a market which is impacted by dampened consumer sentiment. In Italy, we delivered like-for-like growth of -7% and organic growth of -3%. Pandora's brand metrics are moving in the right direction for France, the UK and Italy, although this is yet to translate into higher in-store traffic in a still tough consumer environment.

Australia was impacted by low consumer sentiment and subdued purchasing power with like-for-like growth ending at -4%.

China delivered like-for-like growth of -21%. The Chinese economy is still navigating its recovery from the pandemic's aftermath, with significant impact on our business in China. In 2023, following the lifting of restrictions, we initiated a restaging of the brand focusing on Shanghai. While performance in Shanghai is better than in the rest of mainland China, the demand generation is not yet sufficient to establish an attractive business model. We remain committed to build the brand in China and are currently considering the next steps on the journey. During 2025, the store network will be optimised with an anticipated closure of at least 50 stores. The closures has minimal impact on the growth from network expansion in 2025.

In Rest of Pandora, Pandora continued to demonstrate the broad-based appeal of the brand across numerous geographies where brand penetration is still building with a long runway ahead. Like-for-like growth was strong at double-digit levels of 13%, which reflected broad-based growth with strong contributions from many markets. Spain, Canada, Mexico and Poland are the biggest markets in this segment and delivered a combined like-for-like growth of 8%. Overall, Rest of Pandora ended 2024 with a revenue of DKK 10.6 billion.

SUSTAINABILITY — A CORNERSTONE OF OUR STRATEGY Sustainability is integral to Pandora's operations and remains a cornerstone of the Phoenix strategy. Our approach includes setting some of the industry's most ambitious sustainability targets to lower environmental impact while driving positive outcomes for the people and communities we engage with.

Our three strategic sustainability priorities – low-carbon business, circular innovation and fostering an inclusive, diverse and fair culture – remained central to our 2024 performance, driving our actions and underscoring our commitment to responsible practices across the value chain.

This report shows how our sustainability initiatives support the Phoenix strategy. The Sustainability Statements detail impacts, risks and opportunities (IROs) and address our material sustainability matters identified through our double materiality assessment, which informs our disclosures in alignment with the Danish Financial Statements Act.

Interests and views of stakeholders

Stakeholder identification and engagement

Pandora's double materiality assessment (DMA) serves as a strategic tool, providing a comprehensive overview of the business's impact and external influence. It is aligned with the latest guidelines related to the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS).

The company engaged key stakeholders to validate and enhance findings, gathering insights into industry and geographical context. Their input enabled scoring of impacts based on severity, scope, irremediability and likelihood using a 5-point scale.

Most affected stakeholder groups

Upstream suppliers

Pandora actively engaged with both direct and indirect suppliers through interviews and ongoing dialogue to better understand their risks and impacts related to their engagement with Pandora. Discussions focused on supplier management, business conduct, working conditions and fair wages, ensuring the company can effectively support suppliers in addressing these critical areas.

Own operations - Employees

Pandora connected with employees through interviews and drew insights from the company's previous third-party human rights impact assessment. Topics covered included diversity, fair wages and workplace culture, helping understand potential impacts and risks associated with the working environment.

Local communities and partners

Pandora conducted interviews with UNICEF and other international organisations, exploring topics such as migration, local communities and human rights. The company also draws on the results from the 2022 Human Rights Impact Assessment of crafting sites in Thailand, which included interviews with local communities on "liveable environment" on topics such as water quality, shortages and wastewater from the industrial zones where facilities are located.

Downstream - Consumers

Pandora gathered valuable input from consumers through research by the Consumer Insights team, addressing key areas like packaging, diversity, greenwashing and the representation of minority groups.

Investors

Pandora engaged with investors through questionnaires to gather feedback on transparency, responsible business practices and marketing strategies, ensuring alignment with their expectations and fostering trust.

Integration of stakeholder views

The company consulted its employee engagement group, Pandora Voices. This collaborative approach reconfirmed the relevance of material sustainability matters, which guide reporting and strategic focus. By embedding transparency and accountability into the process, the company ensures its strategic approach remains adaptable to evolving challenges, opportunities and regulatory requirements.

Pandora's CSRD Task Force discussed the results of the DMA process, with Pandora's Sustainability Board approving the results and external auditors reviewing the process. The Board of Directors provided oversight to ensure alignment with strategic goals.

The results of the DMA inform the overall structure of the Sustainability Statements in the Annual Report.

Engagement frequency and channels

• Suppliers: Interviews and ongoing dialogue
• Employees: Interviews, third-party human rights impact assessment (2022)
• Local communities: Interviews with international organisations, community interviews as part of Human Rights Impact Assessment (2022)
• Consumers: Consumer Insights team research
• Investors: Questionnaires
• Employee engagement group (Pandora Voices): Consultation during DMA process

Distinction between affected stakeholders and users of sustainability information

The disclosure identifies affected stakeholder groups (upstream suppliers, own operations employees, local communities and partners, downstream consumers) separately from users of sustainability information (investors), consistent with ESRS requirements. The materiality assessment considered both groups in identifying material impacts, risks and opportunities.

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

Overview of material IROs

Pandora has conducted a double materiality assessment (DMA) detailed on page 50, acknowledging both positive and negative impacts, as well as risks and opportunities. The DMA identifies Pandora's material sustainability impacts, along with sustainability-related risks and opportunities. These insights confirm the strength of the current strategic approach and business model, enhance the governance of sustainability data and inform updates to material priorities.

List of material IROs

Pandora has identified 10 material sustainability matters grouped into topics, covering both environmental and social matters:

Environmental matters:

1. GHG emissions - Pandora emitted 1,251 tonnes CO2 equivalents in Scopes 1 and 2, and 284,947 tonnes CO2 equivalents in Scope 3 in 2024. Meeting science-based targets is essential to limiting environmental impact. Failing to decarbonise responsibly could result in financial penalties, legal challenges, rising costs and reputational damage.

2. Environmental impacts of mining - Pandora now sources 100% recycled silver and gold. However, reliance on newly mined materials such as copper used in jewellery potentially impacts ecosystems and presents environmental risks.

3. Environmental impacts of materials - Chemistry is essential to crafting high-quality products. While applied safeguards meet or exceed legal standards, the 2024 DMA identified possible negative impacts associated with chemical use.

4. Environmental impacts of indirect procurement - Pandora's packaging materials, including plastic and paper, contribute to waste in the downstream value chain. These impacts can be harmful to the environment and can lead to financial and reputational risks if unaddressed.

5. Water management in own operations - Water is integral to crafting jewellery. In 2024, 25% of water used across crafting sites was recycled. With some sites located in water-stressed areas, Pandora faces possible risks of water scarcity and water quality.

Social matters:

1. Diversity, equity and inclusion - Committed to fostering an inclusive workplace that reflects global workforce diversity. With targeted initiatives, Pandora strives to achieve gender parity in Leadership Team (35% of VP-level and above roles held by women in 2024), ensure pay equity, and embed diversity, equity and inclusion principles across all operations.

2. Adequate wage - Ensuring all employees are paid equitably and receive adequate wage is central to Pandora's commitment to social responsibility. Failure to meet national or legal wage standards could result in financial penalties, reputational harm and reduced employee trust and retention.

3. Human rights in own operations - Fair treatment and equal access to career progression and development are essential to Pandora's success. Secure employment includes being heard, having complaints handled fairly and a workplace free from discrimination. Lapses in data handling and privacy could lead to financial penalties and erode employee trust.

4. Workers in the value chain - Pandora supports many livelihoods through employment provided by suppliers and partners. However, workers in these settings may face risks such as forced labour, excessive working hours and other human rights concerns. Insufficient oversight of labour standards could result in financial and reputational damage.

5. Responsible marketing - Pandora has a responsibility to uphold responsible marketing practices and to ensure representation of diverse and inclusive voices in market communication. Failure to do so could lead to reputational damages, loss of consumer trust and increased scrutiny from stakeholders and industry regulators.

Material IROs by value chain location

Upstream activities:

• GHG emissions from energy intensive processes (impact, risk, opportunity)
• Use of raw materials and chemicals (impact, risk)
• Supplier misconduct on human and labour rights (impact, risk)
• Climate-related transition risks (risk, opportunity)
• Resource dependencies and shortages (risk)

Own operations:

• Secure employment and protection of personal data (impact, opportunity)
• GHG emissions and usage of non-renewable energy (impact, risk)
• Water consumption (impact, risk)
• Diversity and inclusion inequalities (impact, risk)
• Minimum pay standards and living wage discrepancies (impact, risk)
• Climate-related transition risks (risk)
• Sourcing renewable electricity to enhance energy independence (opportunity)

Downstream activities:

• Climate-related transition risks (risk, opportunity)
• Secure and flexible employment (opportunity)
• Social inclusion and diversity through promotion channels (impact, opportunity)
• GHG emissions from outbound logistics & service (impact, risk)
• Packaging waste (impact, risk)
• Ethical and diverse marketing practices (impact, opportunity)

ESRS topics

The material sustainability matters align with ESRS topics:

• E1 Climate change (GHG emissions)
• E3 Water and marine resources (Water management)
• E5 Resource use and circular economy (Environmental impacts of materials, mining, indirect procurement)
• S1 Own workforce (Diversity equity and inclusion, Adequate wage, Human rights in own operations)
• S2 Workers in the value chain (Workers in the value chain)
• S4 Consumers and end-users (Responsible marketing)

Time horizons

Targets and milestones referenced include:

• 2025: 90% reduction in own operations (Scopes 1 and 2) vs 2019 baseline (achieved in 2024)
• 2030: 50% reduction in total GHG emissions vs 2019 baseline
• 2040: Net-zero emissions target

Time horizons – short, medium and long term – are aligned with ESRS definitions and applied throughout the disclosures.

Linkage to strategy and business model

The Phoenix strategy integrates sustainability initiatives supporting responsible practices across the value chain. The sustainability statements detail impacts, risks and opportunities (IROs) and address material sustainability matters identified through the double materiality assessment, which informs disclosures in alignment with the Danish Financial Statements Act.

Pandora's business model is fully integrated, with both crafting and distribution at unparalleled scale. With a strong commitment to sustainability, Pandora delivers industry-leading growth and profitability while minimising environmental footprint and supporting communities. The business model creates value through:

• State-of-the-art crafting facilities powered by 100% renewable electricity
• Recycled silver and gold and lab-grown diamonds
• Safe and engaged workplace with employee Net Promoter Score (eNPS) in top 5% in consumer sector globally
• 865 million customer visits
• DKK 1.7 billion paid in corporate income taxes
• DKK 5.5 billion in dividends and share buybacks to shareholders

Interaction with business operations

The DMA results inform the overall structure of the Sustainability Statements. Material sustainability matters guide reporting and strategic focus. By embedding transparency and accountability into the process, Pandora ensures its strategic approach remains adaptable to evolving challenges, opportunities and regulatory requirements.

Sufficient resources have been allocated for all actions related to material matters. The Board of Directors provided oversight to ensure alignment with strategic goals. Pandora's Sustainability Board is responsible for strategic priorities and integrating sustainability into business decisions within respective functions.

Resilience to identified IROs

Pandora proactively manages risks to support continued growth and protect people, assets and reputation. Through the enterprise risk management programme, Pandora actively works to identify, monitor and reduce risks to an acceptable level. The company continuously monitors inherent risks that could impact daily operations, as well as strategic risks that may impact competitive positioning, value creation and strategy execution.

In 2022, Pandora conducted a scenario analysis aligned with the risk management matrix to explore climate risks and opportunities across the value chain, identifying areas crucial to transitioning to low-carbon operations. Insights from an on-site risk assessment conducted at the end of 2024 at crafting sites in Thailand will enable proactive implementation of tangible recommendations to mitigate potential future supply chain disruptions caused by climate change.

Sustainability risks are assessed on a quarterly basis and insights from the 2024 double materiality assessment have been incorporated into the enterprise risk management calibration process and reporting. Pandora does not consider sustainability risks to be among its top risks currently.

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

Overview

Pandora updated its double materiality assessment (DMA) in 2024 to align with the latest requirements under the Corporate Sustainability Reporting Directive (CSRD) and the European Sustainability Reporting Standards (ESRS). The DMA serves as a strategic tool, providing a comprehensive overview of Pandora's business impacts and external influences.

Methodology and Process

The 2024 DMA built upon the 2022 assessment by incorporating a more refined IRO-based (impacts, risks and opportunities) methodology. The process comprised six key steps:

1. ENSURE - 2024 DMA process meets updated ESRS requirements and compliance
2. ASSESS - 2022 DMA results and convert to new updated methodology
3. EVALUATE - Impacts, risks and opportunities specific to Pandora
4. ENGAGE - External and internal stakeholders for thorough assessment
5. SCORE - IROs using scoring keys to assess sustainability matters for reporting
6. CONFIRM - Material sustainability matters

The assessment updated the 2022 DMA to align with new requirements and tools, revisited the identified IROs and concluded with a materiality assessment of the IROs.

Identification of Impacts, Risks and Opportunities

The DMA evaluates Pandora's actual and potential as well as non-material IROs from both an inside-out and outside-in perspective. This encompasses:

• Own operations and value chain
• Upstream and downstream activities
• Actual and potential impacts (both negative and positive) related to sustainability matters
• Risks and opportunities that affect, or could reasonably be expected to affect, the Group's financial position, financial performance, cash flows, access to finance or cost of capital over the short-, medium-, or long-term

Scoring Criteria

Impact Materiality Assessment: Pandora engaged key stakeholders to validate and enhance findings, gathering insights into industry and geographical context. Their input enabled scoring of impacts based on:

• Severity
• Scope
• Irremediability
• Likelihood

Using a 5-point scale.

Financial Materiality Assessment: Pandora assessed financial risks and opportunities using parameters tailored to its business and aligned with its enterprise risk management thresholds.

Materiality Threshold: Issues scoring 3 or higher were flagged as material sustainability matters.

Stakeholder Engagement

Pandora consulted the following most affected stakeholder groups:

UPSTREAM SUPPLIERS: Active engagement with both direct and indirect suppliers through interviews and ongoing dialogue to better understand their risks and impacts related to their engagement with Pandora. Discussions focused on supplier management, business conduct, working conditions and fair wages.

OWN OPERATIONS EMPLOYEES: Connected with employees through interviews and drew insights from Pandora's previous third-party human rights impact assessment. Topics covered included diversity, fair wages and workplace culture.

LOCAL COMMUNITIES AND PARTNERS: Conducted interviews with UNICEF and other international organisations, exploring topics such as migration, local communities and human rights. Also drew on the results from the 2022 Human Rights Impact Assessment of crafting sites in Thailand, which included interviews with local communities on "liveable environment" topics such as water quality, shortages and wastewater from the industrial zones.

DOWNSTREAM CONSUMERS: Gathered valuable input from consumers through research by the Consumer Insights team, addressing key areas like packaging, diversity, greenwashing and the representation of minority groups.

INVESTORS: Engaged with investors through questionnaires to gather feedback on transparency, responsible business practices and marketing strategies.

Additionally, Pandora consulted its employee engagement group, Pandora Voices.

Inputs to the Assessment

• Sector benchmarks and geographical context
• ESRS guidance and updated requirements
• Internal experts and stakeholders from various functions
• External consultants (third-party human rights impact assessments)
• Stakeholder consultation (suppliers, employees, local communities, consumers, investors)
• Previous 2022 DMA results
• Enterprise risk management framework
• Value chain mapping

Use of Value Chain Mapping

The DMA process included a review of actual and potential IROs across Pandora's value chain, which covered:

• Upstream activities (inbound logistics & sourcing)
• Own operations (innovative design, responsible sourcing, high-quality jewellery crafting, global brand & marketing, packaging & distribution, omnichannel retail, product reuse & repair)
• Downstream activities (outbound logistics & service)

The value chain mapping helped identify where material IROs occur across different stages of the business.

Assessment of Specific Topics

Biodiversity: As part of the double materiality assessment, Pandora reviewed actual and potential IROs related to biodiversity across its value chain, which included consultations with relevant stakeholders, including affected communities, suppliers and own employees, and focused on sites located in or near biodiversity-sensitive areas. Based on the findings and existing plans to minimise and mitigate such impacts, IROs for biodiversity were assessed as less material for the business or will be included indirectly in other material matters.

Business Conduct: Pandora applied the same approach when assessing IROs related to business conduct matters, focusing on evaluating how key topics such as corporate culture, corruption and bribery, whistleblower protection, political engagement and the management of supplier relationships relate to its sector, operating locations and activities. This assessment concluded that all these sub-topics are less material or immaterial from a sustainability perspective, based on current practice and assessments.

Outcomes and Material Sustainability Matters

Following the enterprise risk management approach, Pandora grouped the IROs into 10 topics, confirming those identified in 2022:

Environmental matters:

1. Greenhouse gas emissions
2. Environmental impacts of mining
3. Environmental impacts of materials
4. Environmental impacts of indirect procurement
5. Water management in own operations

Social matters: 6. Diversity, equity and inclusion 7. Adequate wage 8. Human rights in own operations 9. Workers in the value chain 10. Responsible marketing

Governance and Approval

Pandora's CSRD Task Force discussed the results of the DMA process, with Pandora's Sustainability Board approving the results and external auditors reviewing the process. The Board of Directors provided oversight to ensure alignment with strategic goals.

Frequency and Documentation

The DMA was last reviewed and updated in 2024. To support the continued refinement and accuracy of the DMA, Pandora developed an internal double materiality assessment manual. The manual ensures consistency, accuracy and alignment with established procedures for validation and approval as well as alignment with updated requirements.

Forward-Looking Statements

The Sustainability Statements include forward-looking statements based on disclosed assumptions about events that may occur in the future and possible future actions by the Group. Actual outcomes are likely to be different since anticipated events frequently do not occur as expected.

Transition plan for climate change mitigation

Scope of the plan

Pandora's transition plan covers all operations and the full value chain (Scopes 1, 2 and 3). The plan encompasses:

• Own operations: crafting facilities in Thailand and Vietnam, distribution centres, owned and operated stores globally, and offices
• Upstream value chain: suppliers of crafting materials, indirect procurement, logistics, media and marketing
• Downstream value chain: franchisees, outbound logistics, consumer packaging

Geographically, the plan covers Pandora's global operations, with major presence in the US (31% share of business), Europe (31% combined share), and Rest of Pandora markets (including Australia, China, and other geographies).

The company operates 6,785 points of sale globally (as of 2024), including 2,788 concept stores and 3,997 other points of sale.

Target years for net zero / carbon neutral

Net zero by 2040: Achieve net zero emissions across all operations and value chains (Scopes 1, 2 and 3, market-based)

2030 interim target: Cut emissions by 50% by 2030 (from 2019 baseline)

These targets are validated by the Science Based Targets initiative (SBTi). The 2040 net zero target was validated by SBTi in 2024.

Scope 1, 2, 3 reduction milestones with baseline years

Baseline year: 2019

Progress to date (as of 2024):

• Total emissions reduced by 17% compared to 2019 baseline
• Scope 1 emissions decreased by 27% from 2023
• Scope 2 emissions decreased by 94% (market-based) from 2023
• Scope 3 emissions increased by 7% from 2023
• Overall emissions increased by 5% from 2023 to 2024

2024 emissions (tonnes CO2 equivalent):

• Scope 1: 1,251
• Scope 2: 284,947 (Scope 3)
• Total: 286,198

Milestones achieved:

• 100% renewable electricity use in own operations (achieved 2024)
• 90% reduction in own operations emissions (short-term target achieved)
• 100% recycled silver and gold in all crafting (achieved August 2024)

Annual reduction target: The company notes that "progress towards our emissions reduction targets will not follow a linear path" and that the 5% increase in emissions in 2024 compared to 2023 is "well below our 13% revenue growth."

Alignment with 1.5°C / SBTi validation status

Pandora's net zero by 2040 target was validated by the Science Based Targets initiative (SBTi) in 2024.

The company conducted a qualitative scenario analysis in 2022 aligned with a 1.5°C scenario, using scenarios and assumptions consistent with TCFD and CDP disclosures and SBTi target-setting.

Key levers / decarbonization pillars

Pandora's low-carbon roadmap is structured around strategic decarbonization pillars:

1. Optimising own operations

• 100% renewable energy
• Reduction and recycling of crafting materials, water and waste
• Production and materials innovation

2. Lowering store footprint

• Optimised store concept and construction
• Lower-impact campaigns and displays
• 100% renewable energy across stores

3. Mindful travel

• Enhanced policies and processes for business travel
• Electrify owned vehicles and services
• Incentivise greener commuting

4. Conscious branding

• Lower-impact packaging
• Reduce emissions in marketing strategies and decision-making

5. Transport and logistics

• Freight optimisation
• Green fuels through value chain

6. Activating supply chain

• Engagement in target setting and reporting
• Co-develop lower-impact solutions
• Renewable energy through supply chain
• Incorporation of low-carbon clauses into supplier contracts

7. Advancing circularity

• Circularity in products and services across value chain
• 100% recycled silver and gold (achieved August 2024)
• Exclusive use of lab-grown diamonds and man-made stones

Renewable electricity achievements:

• 100% renewable electricity across all own operations achieved in 2024
• Crafting facilities in Thailand powered by 100% renewable electricity since 2020
• On-site solar and direct biomass supply account for 21% of crafting facilities' total electricity consumption
• Virtual power purchase agreement (PPA) pilot in Thailand (12-month pilot concluding mid-2025)
• Majority of renewable electricity certificates (RECs) purchased are EKOenergy or Green-e certified

Scope 3 breakdown (2024):

• Crafting materials: 16%
• Transportation: 14%
• Media and marketing: 13%
• Business travel and employee commuting: 12%
• Packaging and point-of-sale materials: 9%
• Facility management: 9%
• Other: 7%
• IT: 6%
• Franchisees: 5%

CapEx / investment commitments

New crafting facility in Vietnam: USD 150 million (DKK 1.1 billion)

• Designed to meet LEED Gold standards
• Will operate entirely on renewable electricity
• Requires recycled content in key materials
• Will boost crafting capacity by around 50%
• Create 7,000 jobs
• Produce up to 60 million pieces of jewellery annually
• Construction began in 2024

Store network expansion:

• Opened 236 net new stores in 2024
• Acquired 36 concept stores in 2024
• Rollout of new store concept continues

Sustainability integration in facility construction:

• Pursuit of LEED Gold certification for Vietnam facility
• Recycled content requirements in key construction materials
• Transparent reporting practices

Locked-in emissions and stranded asset analysis

Not disclosed in detail. The company notes that a climate scenario analysis conducted in 2022 "helped identify and inform assets and business activities where significant efforts are required to be compatible with Pandora's transition to low-carbon operations."

The 2024 increase in emissions was "primarily driven by the construction of our new crafting facility in Vietnam, network expansion, upgrades to our existing store fleet, as well as an increase in business travel."

Use of carbon credits / removals

ESRS E1-7 disclosure requirement on "GHG removals and carbon credit-financed mitigation projects" is marked as derived from other EU legislation but is listed with a dash (-) indicating no disclosure in this report.

No substantive information on carbon credits or removals is provided in the excerpts.

Governance and policies

Board oversight: The Board of Directors approves Pandora's climate transition plan and maintains oversight of climate-related risks and opportunities.

Sustainability Board: Chaired by Pandora's Chief HR Officer, consists of nine senior leaders including Executive Leadership Team (ELT) members. Responsible for strategic sustainability priorities and integrating sustainability into business decisions.

Supporting committees and task forces:

• Low Carbon & Nature Task Force
• Corporate Sustainability Reporting Directive (CSRD) Task Force
• Responsible Sourcing Committee
• Responsible Marketing Committee

Key policies:

• Global Environmental Policy (updated in 2024 to meet CSRD requirements)
• GHG Emissions Standard (introduced 2024)
• Water Management Standard (introduced 2024)
• Global Materials Standard (updated version to be released in 2025)

Incentive alignment: Long-term incentive plan (LTIP) for senior leadership incorporates sustainability performance, including science-based emissions reduction targets.

External recognition:

• "A" score for transparency and performance from Carbon Disclosure Project (CDP) in past years
• SBTi validation of net zero by 2040 target (2024)
• Thailand Energy Award for best practice in energy management at Lamphun facility (2024)

Progress metrics

Pandora states: "We are growing our business while reducing our environmental impact, with revenue increasing by 45% and emissions decreasing by 17% compared to a 2019 baseline, moving towards decoupling growth from emissions."

In 2024 specifically:

• Revenue growth: 13% organic growth
• Emissions increase: 5% from 2023 (driven by construction, network expansion, and business travel)
• Revenue: DKK 31.7 billion (2024) vs DKK 28.1 billion (2023)

Policies related to climate change mitigation and adaptation

Pandora's disclosure references ESRS E1-2 in its index (page 58), pointing to the "Greenhouse gas emissions" section on page 67. However, the excerpts provided do not contain the actual content from page 67 where the climate-related policies would be disclosed.

The excerpts do reference a Global Environmental Policy in the policy collection list (page 33), which is stated to be available on Pandora's website at pandoragroup.com/sustainability/resources/policies. However, no details about this policy's scope, content, governance, or implementation monitoring are provided in the excerpts.

Governance structure

While specific climate policies are not detailed in the excerpts, the following governance arrangements for climate-related matters are disclosed:

• Board approval: The Board approves Pandora's climate transition plan and oversees sustainability integration as part of its broader governance responsibilities
• Sustainability Board: Chaired by the Chief HR Officer, consists of nine senior leaders including Executive Leadership Team (ELT) members, responsible for strategic sustainability priorities and integrating sustainability into business decisions
• Low Carbon & Nature Task Force: One of two task forces overseeing key sustainability areas
• CSRD Task Force: Oversees corporate sustainability reporting

The company indicates it relies on the Task Force on Climate-Related Financial Disclosures (TCFD) framework to guide its climate-related risk assessment and disclosure efforts.

Without access to page 67 of the Sustainability Statements or the actual Global Environmental Policy document, the specific policies related to climate change mitigation and adaptation cannot be fully described.

Actions and resources in relation to climate change policies

Decarbonisation initiatives for transportation and logistics

Scope: Upstream and downstream value chain (transportation and distribution)

Actions:

• Shifting freight from air to road or sea
• Strategic investment in green fuel

Time horizon: Not specified

Resources allocated: Not quantified

Expected outcomes: Reduction in Scope 3 emissions from transportation and logistics categories

Consumer packaging and in-store materials initiatives

Scope: Own operations and downstream (linked to store operations)

Priority area: Consumer packaging and in-store materials remain areas of priority, particularly given how strongly these categories are linked to Pandora's overall growth

Time horizon: Not specified

Resources allocated: Not quantified

Franchise network decarbonisation

Scope: Downstream value chain (franchise operations)

Actions:

• Rollout of Franchise Code of Conduct across selected geographies in 2024
• Questionnaire on social and environmental sustainability deployed
• Understanding renewable electricity coverage within franchise network
• Identifying opportunities for transitioning franchise partners away from non-renewable electricity sources

Time horizon: Started in 2024, ongoing

Resources allocated: Not quantified

Expected outcomes: Reduction in franchise-related Scope 3 emissions (5% of total Scope 3 in 2024, with 10% decrease compared to 2023)

Policy and standards framework

Global Environmental Policy:

• Updated in 2024 to meet CSRD requirements
• Requires employees to adopt environmentally responsible practices
• Applies to Pandora's direct operations and value chain
• Approved by the Board of Directors

New standards introduced:

1. GHG Emissions Standard:

   • Covers climate change mitigation, adaptation, energy efficiency and renewable electricity deployment
   • Applies across Pandora's full value chain
   • Targets senior-level managers accountable for implementation
   • Aligns with international standards
   • Provides blueprint for business alignment to low-carbon roadmap

2. Water Management Standard:

   • Focuses on water management, water treatment and commitment to reduce water consumption in high-risk areas
   • Applies to Pandora's value chain
   • Follows international standards

Planned actions:

• Standards addressing environmental impacts of mining, indirect procurement and materials to be developed in 2025
• Updated Global Materials Standard to be released in 2025

Internal travel practices targets

Scope: Own operations (transportation to and from Pandora facilities and external sites, representing 9% of Scope 3 emissions from facility management)

Action: Established internal targets to foster more responsible travel practices and reduce emissions

Time horizon: Not specified

Resources allocated: Not quantified

Expected outcomes: Reduction in emissions from business travel

Renewable electricity deployment

Target: -15% annual reduction in Scopes 1+2 (market-based) emissions relative to base year 2019

Progress: Scopes 1+2 (market-based) emissions reduced by 98% from 2019 to 2024 (from 51,101 to 1,251 tonnes CO2e)

Milestones: -90% by 2025 from 2019 baseline

Resources allocated: Not quantified

Targets related to climate change mitigation and adaptation

Climate Change Mitigation Targets

Pandora has set science-based targets validated by the Science Based Targets initiative (SBTi) to reduce greenhouse gas emissions and achieve net zero.

Key Achievements and Progress

2024 Performance:

• Total emissions: 286,198 tonnes CO₂e (2023: 272,967 tonnes CO₂e)
• Reduction from 2019 baseline: 17%
• Scope 1 emissions: Decreased by 27% from 2023
• Scope 2 emissions (market-based): Decreased by 94% from 2023
• Scope 3 emissions: Increased by 7% from 2023
• Revenue growth: 13% (2024)
• Growth in revenue while reducing emissions: Revenue increased by 45% and emissions decreased by 17% compared to 2019 baseline

Milestones:

• 100% renewable electricity across own operations achieved (2024)
• 100% recycled silver and gold in all jewellery (achieved August 2024)
• Short-term target of 90% reduction in own operations achieved (2024)

Context

The targets cover Pandora's full value chain including:

• Own operations: Crafting facilities, stores, offices, distribution centres
• Value chain: Upstream suppliers, downstream franchises and logistics

Emissions increased by 5% from 2023 to 2024, primarily driven by construction of new crafting facility in Vietnam, store network expansion (236 net new stores), upgrades to existing store fleet, and increase in business travel. Despite this increase, the company notes progress is well below the 13% revenue growth and that the journey will not be linear.

Energy consumption and mix

Pandora reported total energy consumption of 136,025 MWh in 2024 (2023: 122,725 MWh), achieving 98% renewable energy across total energy consumption and 100% renewable electricity.

Energy consumption by source

Key metrics

• Share of renewable sources in total energy consumption: 98% (2024), 85% (2023)
• Share of renewable sources in total electricity consumption: 100% (2024), 87% (2023)
• Share of fossil sources in total energy consumption: 2% (2024), 15% (2023)
• Share of nuclear sources in total energy consumption: 0% (2024), 0% (2023)
• Energy intensity: 4.29 MWh per DKK million revenue (2024), 4.36 MWh per DKK million revenue (2023)

Scope and methodology

Energy consumption is reported on a market-based approach in accordance with ESRS E1-5. The scope covers purchased and generated quantities of electricity and district heating for crafting facilities, retail (Pandora-owned and operated stores), offices with more than 30+ employees, and distribution centres (Scope 2), as well as fuels used in on-site generation and company vehicles (Scope 1).

Purchased renewable energy corresponds to MWh covered by purchased Renewable Energy Certificates (RECs). Fuel consumption from renewable sources covers purchased electricity from biomass at the Lamphun crafting facility in Thailand. Self-generated non-fuel renewable energy covers on-site solar generation at crafting facilities.

Fuel consumption from crude oil and petroleum products reflects diesel and gasoline for company-owned vehicles and LPG used at crafting facilities. Fuel consumption from natural gas reflects on-site usage at two distribution centres.

Biogenic emissions

Pandora reported 353 tonnes CO₂ biogenic emissions in 2024, covering purchased electricity from biomass (Scope 2).

Gross Scopes 1, 2, 3 and Total GHG emissions

Total GHG emissions summary

Scope 3 breakdown by GHG Protocol category

Note: Sub-categories C9-13 and C15 are excluded as not relevant or below the significance threshold for Pandora.

GHG intensity

Methodology and scope notes

Scope 1 includes fuels used to craft jewellery for heating, refrigerants for cooling and fuel used for transport of employees. Fossil fuel volumes and refrigerant leakage volumes are multiplied by emission factors from DEFRA.

Scope 2 includes the purchase of electricity and district heating for crafting, retail (own stores), offices and distribution centres. Electricity for crafting includes electricity from grid, solar panels and biomass. Emissions are calculated using both market-based approach (which includes purchase of Renewable Energy Certificates) and location-based approach. Consumption data is generated from a mix of meter readings and invoices. Where meter readings and invoices are not available, consumption is estimated based on spend or size of location. Emissions from satellite offices with less than 30 people are omitted (corresponding to emissions from 6% of employees in offices).

Scope 3 includes the nine subcategories listed above, all relevant to Pandora:

• C1 includes materials and services. Where available, material volumes are multiplied by LCA emission factors. If not available, spend amounts are used and multiplied by DEFRA supply chain emission factors. Also includes categorised spend amounts on services (e.g. media and marketing). For some spend categories, supplier-specific emission factors have been collected.
• C2 includes categorised spend data for machinery, fixtures and furniture, and other capital goods multiplied by relevant LCA and supply chain emission factors (DEFRA).
• C3 includes upstream greenhouse gas emissions from fuels, heating, and electricity based on invoices used in crafting facilities, stores, offices, and distribution centres. Emission factors for transmission and distribution losses are from IEA and fuels are from DEFRA.
• C4 includes inbound and outbound logistics, and transportation and distribution services conducted by third-party logistics providers. A combination of supplier-specific and supply chain emission factors for spending on products from DEFRA is used. Emissions from other transport types are included in the emission factors used for purchased goods and services.
• C5 includes waste volumes and spend amounts on waste services.
• C6 includes supplier-specific flight, hotel and car rental emissions as well as spend amounts on flight, hotel, car rental and travel expenses.
• C7 includes emissions from Pandora employees' commute from home to work. Based on a mixture of actual fuel consumption for commuting services in crafting, extrapolated survey data, and estimated data on distance (km travelled) within different transportation types and work-from-home ratio disclosed for the main areas in own operations taking the development of employees into account.
• C8 includes spend amounts on upstream leased cars.
• C14 includes electricity consumption for franchises, estimated based on the number of franchise stores and the kWh/square metre average across Pandora-owned stores. The estimated electricity consumption is then multiplied by the corresponding IEA country emission factor.

Biogenic emissions cover purchased electricity from biomass and relate to Scope 2. CO2 emissions from biomass are reported separately; remaining GHG emissions are included in Scope 2 market-based as per the GHG Protocol. Biogenic emissions are calculated based on kWh values multiplied by a CO2-only emission factor from the energy provider.

Restatement note: In 2024, Pandora reassessed its calculation methodology and data for Scope 3 based on updated knowledge. This led to adjustments in total emissions (tonnes CO2e), with decreases of 44,951 in 2020 (-15%), 49,524 in 2021 (-15%), and 16,340 in 2022 (-5%), as well as an increase of 8,423 in 2023 (+3%). The key change relates to a requirement of back-casting supplier emission data from the first year of use back to the baseline year.

Data quality: In 2024, the proportion of total emissions calculated using spend-based emissions calculations is 48%.

All emissions are accounted for in accordance with the GHG Protocol Corporate Standard, and disclosures align with the requirements of ESRS E1-6. CO2 emissions from biomass are reported separately. All CO2e emission factors used for fossil fuels and electricity are in accordance with the 2006 Intergovernmental Panel on Climate Change Guidelines for National Greenhouse Gas Inventories.

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

Not disclosed. The disclosure index indicates that ESRS E1-9 Anticipated financial effects is not reported, with a dash ("-") under Section and Chapter columns.

Policies related to pollution

Pandora discloses a Global Environmental Policy that addresses environmental topics including pollution-related matters, alongside specific standards for GHG emissions and water management.

Global Environmental Policy

• Scope: Applies to Pandora's direct operations and value chain
• Governance: Approved by the Board of Directors
• Key content: Updated in 2024 to meet Corporate Sustainability Reporting Directive (CSRD) requirements. The policy outlines Pandora's commitment to environmental material topics and respected third-party standards. It requires employees to adopt environmentally responsible practices and serves as a foundation for developing topic-specific agendas and future guidelines and frameworks.
• Public availability: Publicly available on Pandora's corporate website under 'Policies'
• Links to standards: References respected third-party standards as disclosed in the sustainability report

GHG Emissions Standard

• Scope: Covers Pandora's full value chain
• Key content: Addresses climate change mitigation, adaptation, energy efficiency and renewable electricity deployment. Provides a blueprint for business alignment to Pandora's low-carbon roadmap. Targets senior-level managers accountable for implementation.
• Links to standards: Aligns with international standards referenced in the Global Environmental Policy

Water Management Standard

• Scope: Applies to Pandora's value chain
• Key content: Focuses on water management, water treatment and a commitment to reduce water consumption in high-risk areas. Targets senior-level managers accountable for implementation.
• Links to standards: Follows international standards

Global Materials Standard

• Key content: Provides sourcing principles and guidance for materials selection. An updated version will be released in 2025.

Pandora indicates that standards addressing the environmental impacts of mining, indirect procurement and materials will be developed in 2025 to address all material environmental matters.

Substances of concern and substances of very high concern

Pandora has not disclosed quantitative data on the total amounts of substances of concern (SoC) or substances of very high concern (SVHC) generated, used, or procured in tonnes for the reporting period.

Chemical management approach

Pandora's chemical management programme ensures adherence to global standards and compliance with local regulatory requirements, from raw materials to finished goods. The company is certified against ISO IEC 17025 (testing and calibration laboratories) and is the first company in Thailand, and one of the few globally within the jewellery manufacturing industry, to achieve this certification.

The chemical management approach is organised around three focus areas:

• Safer input: Safety data sheets are required, passed test certificates are obtained, and records of all substances are maintained. Non-compliant substances are discontinued after careful review.
• Safer process: Continuous progress is driven across four targets: zero accidents, zero health risks, zero waste and zero non-compliance, governed by ISO 45001 and 14001 certifications.
• Safer output: Wastewater is treated on-site before distribution to industrial treatment, with quality regularly monitored to meet or exceed local legal requirements. Hazardous waste is treated according to local legal requirements, including zero landfill.

REACH compliance and restricted substances

To help ensure regulatory compliance, Pandora applies comprehensive requirements for controlling and monitoring hazardous substances. The company's chemical requirements are based on its Restricted Substances List (RSL), which comprises substances restricted in usage pertaining to products and raw materials. The RSL is monitored by senior management in Crafting & Supply Quality and is aligned with regulatory requirements, including REACH (European Regulation (EC) No. 1907/2006 and its amendments REACH Annex XVII Item 63), and provides clear measures for chemical safeguards and workplace safety.

These safeguards extend beyond Pandora throughout the value chain and are communicated to suppliers as part of supplier contracts and sourcing documents. Suppliers must provide safety data for all substances, and test certificates are required as evidence of compliance. The health and safety impacts of products are continuously governed by the ISO 9001 certification of crafting facilities. As in previous years, there were no reported critical incidents of non-compliance concerning the health and safety impacts of products in 2024.

Future developments

Pandora continues to work in accordance with its "Together Towards Zero" campaign, focusing on zero accidents culture, zero health risks, zero waste and zero non-compliance. In 2025, the company will explore how to set targets to advance its chemical management programme. In 2024, Pandora updated its Global Environmental Policy, which guides work with all environmental topics, including chemicals, and serves as a foundation to develop future guidelines and frameworks.

Policies related to water and marine resources

The disclosure requirement ESRS E3-1 is referenced in the sustainability statement index, directing to page 76 in the "Water management in own operations" chapter. However, the excerpts provided do not contain the actual content from page 76 or any detail about specific policies related to water and marine resources.

Based on the index table alone, Pandora indicates that this disclosure requirement is addressed and is marked as derived from other EU legislation, but no policy names, scope, governance, content, or implementation details are visible in the provided excerpts.

Water consumption

Water consumption metrics

¹ The numbers for 2023 have been adjusted to align with ESRS E3-4. In addition a reassessment has been made, due to an error in calculation in 2023, causing a decrease of total water consumption of -10% (-136,972 m³).

² Calculated in line with our standard reporting currency, DKK. Revenue used in the calculation is as reported in note 2.1 Segment and revenue information of the Financial Statements.

Water risk assessment

Pandora updated its company-wide water risk assessment in 2024 using the WWF Water Risk Filter tool. The assessment identified that crafting facilities in Bangkok are in high risk areas. Approximately 90% of total water consumption is used directly in crafting processes, including cleaning and plating.

Water management approach

At crafting facilities, water efficiency is tracked against internal targets including total water consumption, comprising water withdrawals from city water and recycled water. The company monitors risks of water shortage and flooding on a weekly basis.

Despite investments in temperature sensors and water-saving technology for water treatment in cooling towers, total water consumption increased by 2% compared to 2023 due to increased production. While a recycling rate of 25% was achieved at crafting facilities, the company fell short of internal targets for water consumption from city water withdrawals.

Accounting policies

Water consumption includes volumes of water consumed in global operations. For crafting facilities and distribution centres, water consumption is calculated as purchased volumes of water. Water consumption in offices is calculated as an estimate based on headcount, adjusted for remote working. Water consumption at retail locations is calculated as an estimate based on working hours.

Water consumption in areas with high water risk includes volumes consumed at crafting facilities in Bangkok, estimated based on reported city water consumption (including recycled water) assessed against WWF Water Risk Filter per location.

Water recycled and reused is the volume of water at crafting facilities that has been recycled for irrigation and sanitary purposes or reused in crafting processes before being sent to wastewater treatment.

Activities and facilities contributing less than 1% of company-wide gross water consumption are excluded from reporting:

• Recycled water is excluded for offices, distribution centres and retail locations
• Water consumption in areas at water risk is excluded for offices, retail stores and distribution centres due to lack of materiality

Impact metrics related to biodiversity and ecosystems change

Nature impact assessment

Pandora completed a nature impact assessment across all material usage. The findings indicate significant environmental impacts from the use of copper and palladium, including environmental risks of land use, pollution and freshwater use.

These findings will support the company in setting targets beyond recycled silver and gold, which are expected in 2025.

Specific quantified metrics

No quantified land use footprint (hectares or km²), deforestation footprint, operations in or near protected areas/KBAs, species impact metrics (Red List species affected), ecosystem condition metrics, or restoration metrics (hectares restored) are disclosed in the available excerpts.

Resource outflows

Circular Jewellery Metrics (2024)

• 100% recycled silver and gold: As of August 2024, all Pandora jewellery is crafted using 100% recycled silver and gold sourced from certified, responsible refiners. This achievement reduces dependency on newly mined crafting metals by almost three-quarters by volume.

• 100% man-made stones: All stones used in Pandora jewellery are man-made.

• Share of silver in purchased product materials: 67% (2023: 68%)

Product Durability & Design

Pandora's jewellery is designed to be high-quality and durable, crafted with care and attention to detail. The company emphasizes craftsmanship that blends centuries-old techniques with modern production methods.

Packaging Materials

• Consumer-facing packaging is FSC®-certified
• The company is exploring opportunities to switch to more sustainable raw materials with lower environmental impact for packaging and visual merchandising materials

Lab-Grown Diamonds

Pandora continues to expand its lab-grown diamonds collection, demonstrating how innovation can replicate nature while reducing environmental impact compared to mined diamonds.

Circularity Strategy

Circularity is fundamental to Pandora's approach to becoming a low-carbon business. The company's "Advancing Circularity" strategic pillar focuses on circularity in products and services across the value chain, though specific numerical targets for product repairability or take-back programs are not disclosed in this report.

Waste

Waste Management Approach

Pandora applies a comprehensive approach to waste management guided by its "Together Towards Zero" campaign, which includes four focus areas:

1. Zero accidents culture
2. Zero health risks
3. Zero waste
4. Zero non-compliance

This campaign is designed and run by the Safety, Health & Environment leadership team and employees at Pandora's crafting facilities in Thailand, governed by ISO 45001 and 14001 certifications.

Hazardous Waste

Hazardous waste is treated according to local legal requirements, including zero landfill practices. For some solid waste types, Pandora partners with waste disposal suppliers to find ways to reuse materials.

Wastewater

Wastewater is treated on-site before distribution to industrial treatment facilities. Wastewater quality is regularly monitored to ensure it meets or exceeds local legal requirements.

Packaging Waste

Packaging materials, including plastic and paper, contribute to waste in the downstream value chain. These impacts are identified as potentially harmful to the environment and can lead to financial and reputational risks if unaddressed. The company is working to map procurement of point-of-sale materials and store fixtures and furniture to address environmental impacts.

Scope 3 Emissions from Waste

Category 5 (Waste generated in operations) accounted for 5,790 tonnes CO2e in 2024 (2023: 6,741 tonnes CO2e), representing a 14% decrease.

Note: While waste management processes and policies are described, the report does not provide a comprehensive quantitative breakdown of total waste generated by type (hazardous vs. non-hazardous) or by disposal method (recycled, landfilled, incinerated) in tonnes for 2024.

Policies related to own workforce

Pandora discloses several policies relevant to its own workforce under ESRS S1-1, referenced throughout the sustainability statement and listed in the policy collection.

Code of Conduct

• Scope: All employees and partners are expected to adhere to the Code of Conduct
• Governance: The Board of Directors has adopted the Code of Conduct
• Key content: Sets out ethical business practices and standards of behaviour
• Monitoring: E-learning courses re-launched in 2024 for all office employees; awareness initiatives are in place for all employees
• Public availability: Available on the corporate website under 'Policies'

Global Human Rights Policy

• Scope: Applicable to Pandora's direct operations and value chain
• Governance: Approved by the Board of Directors
• Key content: Outlines commitment to respecting human rights of everyone touched by the business, ensuring fair treatment and empowered voice. Details salient human rights issues, key stakeholder groups, engagement practices, implementation across the business, and remediation mechanisms
• International standards: Aligns with the United Nations Guiding Principles on Business and Human Rights, the International Labour Organization's (ILO) Declaration on the Fundamental Principles and Rights at Work, and other international instruments
• Public availability: Available on the corporate website under 'Policies'

Inclusion and Diversity Policy

• Key content: Addresses diversity, equity and inclusion as a priority across the organization, with targets for balanced gender representation in leadership (gender parity by 2030)
• Public availability: Listed in the policy collection on the corporate website

Health and Safety Policy

• Key content: Addresses creating a safe and healthy work environment. In 2024, 99.6% of employees were covered by health and safety management systems
• Public availability: Listed in the policy collection on the corporate website

Global Environmental Policy

• Scope: Applies to Pandora's direct operations and value chain
• Governance: Approved by the Board of Directors
• Key content: Requires employees to adopt environmentally responsible practices. Updated in 2024 to meet Corporate Sustainability Reporting Directive (CSRD) requirements. Outlines commitment to environmental material topics and respected third-party standards
• Public availability: Available on the corporate website under 'Policies'

Whistleblower Policy

• Scope: All employees globally
• Key content: Provides a clear and secure process for employees to confidentially raise concerns. Aligned with the Danish Whistleblower Act and the EU Whistleblower Directive. Outlines process for addressing issues raised through whistleblower channels, including the dedicated hotline
• Monitoring: 233 cases reported through the whistleblower platform in 2024, covering issues such as harassment, discrimination, racism and minor grievances. Mandatory whistleblower e-learning launched as part of Speak Up! campaign
• Public availability: Listed in the policy collection on the corporate website

Privacy Policy

• Key content: Outlines principles for managing personal data from customers, employees and other individuals. Personal data utilized only when there is a legitimate purpose, ensuring all data is used, stored, shared and protected in accordance with applicable privacy laws
• Monitoring: Regular training initiatives for employees; expanded targeted training in 2024 for corporate employees. One incident reported to the Danish Data Protection Authority in 2024 (no action required)
• Public availability: Listed in the policy collection on the corporate website

Global Data Ethics Policy

• Public availability: Listed in the policy collection on the corporate website

Remuneration Policy

• Public availability: Listed in the policy collection on the corporate website

Adequate Wage Policy (in development)

• Status: In the process of development, with the goal of finalizing it in 2025
• Scope: Will apply to all countries where Pandora operates
• Governance: Will be approved by the Board of Directors; key internal stakeholders are being consulted during development
• Key content: Will ensure that employees' wages are compliant with local regulations and reflect the cost of living in each country. Will outline third-party and international standards followed
• Public availability: Will be made publicly available on the corporate website under 'Policies' once finalized

Anti-Bribery and Corruption Policy

• Key content: Part of dedicated compliance programme built around zero-tolerance policy for bribery and corruption
• Monitoring: E-learning courses available; detailed trainings through webinars for employees who face higher risk due to role or location

Other workforce-related policies mentioned

The policy collection also lists:

• Conflict-of-Interest Policy
• Gifts and Entertainment Standard
• Global Donation Standard
• Tax Policy
• Anti-Money Laundering Programme

WHISTLEBLOWER HOTLINE We are committed to fostering a transparent and supportive environment through our whistleblower programme. Our Whistleblower Policy, aligned with the Danish Whistleblower Act and the EU Whistleblower Directive, provides a clear and secure process for employees to confidentially raise concerns.

The policy outlines a clear process for addressing issues raised through our whistleblower channels, including our dedicated hotline. Reports can be submitted confidentially through the EQS system or a designated whistleblower inbox. IACC reviews each case reported through the EQS system and directs it to the appropriate team. In certain cases, external consultants are engaged due to time constraints or data-sharing regulations.

In 2024, we took further steps to build awareness around our whistleblower programme. As part of our ongoing Speak Up! campaign, we launched mandatory whistleblower e-learning to ensure all employees are informed about the hotline and their right to safe, anonymous reporting. The e-learning aims to empower employees with knowledge of the Whistleblower Policy and assure them of fair and protected case handling. Speak Up! posters are displayed in our offices, crafting facilities, distribution centres and stores globally, reinforcing our commitment to a transparent culture.

In 2024, 233 cases were reported through the whistleblower platform, covering issues such as harassment, discrimination, racism and minor grievances. None of the cases had a severe impact on our business operations or a material financial impact.

Taking action on material impacts on own workforce

Diversity, Equity and Inclusion

Scope: Own operations and value chain

Policy Framework:

• Diversity, equity and inclusion policy outlines Pandora's ambitions and commitments to create an inclusive, diverse and fair workplace
• Details collective responsibilities within the company to ensure all employees understand how they can contribute to creating a culture of inclusion
• Policy applicable to both Pandora's direct operations and value chain
• Approved by the Board of Directors and publicly available on corporate website under 'Policies'
• Policy to be updated in 2025 to capture updated diversity, equity and inclusion strategy and address all mandatory Corporate Sustainability Reporting Directive disclosure requirements

Whistleblower and Grievance Mechanisms:

• Framework provides a safe and confidential channel to raise concerns, ensuring everyone feels empowered to speak up
• Complements broader diversity, equity and inclusion initiatives, reinforcing a culture of trust
• For details on whistleblower hotline (ESRS S1-3), see Business ethics chapter

Training Initiatives:

• Data privacy awareness training for employees
• In 2024, expanded targeted training efforts
• Mandatory training programme for employees facing higher risk of exposure to money laundering-related risks, consisting of e-learning and detailed trainings through webinars

Expected Outcomes:

• Continue building an environment where every employee feels empowered to bring their authentic selves to work, driving innovation and creativity

Challenges:

• Operating in more than 100 countries with diverse workforce representing different nationalities, genders and age groups
• Navigating cultural differences and adapting to local regulatory environments can impact ability to measure progress
• Data collection on diversity, equity and inclusion metrics restricted in some jurisdictions
• Committed to finding innovative ways to advance inclusivity and tailor approach to needs of global workforce

Human Rights in Own Operations

Refer to page 94-95 for actions related to human rights in own operations.

Adequate Wage

Refer to page 92-93 for actions related to adequate wage.

Note: Specific action details for human rights and adequate wage are referenced but not detailed in the provided excerpts.

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

Disclosure Statement

Pandora explicitly states in its ESRS index that ESRS S1-7 (Non-employee characteristics) is not disclosed (indicated by "-" in the reporting table).

The company's accounting policies for employee characteristics (ESRS S1-6) explicitly exclude external contractors from the headcount data:

"The number of employees includes all recorded individuals employed by Pandora, except external contractors, at year-end and is accounted for in Headcount."

Related Workforce Information

While specific non-employee workforce metrics are not provided, Pandora acknowledges engagement with non-employee workers in certain contexts:

• Health and safety coverage: The accounting policy for ESRS S1-14 notes that health and safety data "covers all employees, and where relevant, contractors, at year-end and is accounted for in Headcount." However, contractors are explicitly excluded from accident rate calculations.

• Supply chain workers: The company engages workers from product suppliers (jewellery, point-of-sale materials, fixtures, furniture) and service suppliers (warehousing, construction) through its Responsible Sourcing Programme. Migrant workers constitute approximately 7% of workers in the jewellery supply chain. These are value chain workers covered under ESRS S2, not own workforce non-employees under S1-7.

Collective bargaining coverage and social dialogue

Worker representation

While Pandora does not have a global union framework, all employees in Thailand are covered by a collective bargaining agreement, and the company regularly engages with the union to discuss wages, benefits and working environment. In 2024, ten meetings were held with union representatives, discussing workplace improvements such as enhancing workstations, addressing facility maintenance and reviewing trends for overtime based on company performance. The annual collective bargaining agreement was successfully negotiated, resulting in improved benefits for employees, including an increased meal allowance.

Pandora's other significant employment market is the US, where employees are not covered by a collective bargaining agreement but all receive the same benefits. Concerns can be raised with the employee relations department or relevant government bodies as per federal regulations.

Employees covered by collective bargaining agreements

Coverage rate by country:

Accounting policies

Employees covered by collective bargaining agreements (CBA) is accounted for in accordance with ESRS S1-8 and includes the total number of employees covered by at least one collective bargaining agreement. The coverage rate for employees in non-EEA countries, where more than 10% of Pandora employees are located at year-end, is calculated as the percentage of employees in the respective country that is covered by at least one CBA.

Note: Pandora does not have significant countries (+10% of employees) in coverage rates between 20-79%.

Diversity metrics

Gender distribution in management

Board of Directors

Executive Management

Executive Leadership Team

Leadership Team (VP-level and above)

Age band distribution of total workforce

Total workforce gender split

Target

Pandora's target is to achieve full gender parity in the Leadership Team (50% women at VP-level and above) no later than 2030.

Methodology notes

The gender distribution in management is disclosed in accordance with ESRS S1-9. The data includes the total number of members in the Board of Directors, the total number of employees in both Executive Management and the Executive Leadership Team at year-end. The Leadership Team comprises Vice Presidents, Senior Vice Presidents and members of the Executive Leadership Team, Executive Management and the Board at year-end.

The age split includes all recorded individuals employed by Pandora at year-end and is accounted for in Headcount, attributed to an age range based on their recorded date of birth.

Adequate wages

Benchmark used

Pandora benchmarks wages against adequate wage and living wage standards sourced from WageIndicator.org (part of the WageIndicator Foundation). The company takes a conservative approach, comparing guaranteed pay and allowances (housing, meal, transport allowances, free school for children, guaranteed bonus, and paid private medical insurance) against:

• Adequate wage data from WageIndicator.org (where available)
• Living wage data (where adequate wage data is unavailable)
• The higher of the two figures when both are available

For example, in Luxembourg, the adequate wage is calculated at 50% of the average national wage, surpassing the living wage figure by 43%. In Portugal, Pandora meets adequate wage requirements but treats the country as non-compliant with internal standards because the living wage figure is higher.

Coverage

98% of employees (34,508 employees) are paid at or above the adequate wage benchmark as of 2024. This represents the first fully comprehensive global benchmark study.

2% of employees (735 employees) across 17 countries fell below the adequate wage threshold:

• Chile: 148 employees (80% of country workforce)
• Ireland: 140 employees (71%)
• Luxembourg: 14 employees (70%)
• South Africa: 60 employees (63%)
• Colombia: 103 employees (59%)
• Peru: 38 employees (56%)
• Singapore: 42 employees (45%)
• Portugal: 42 employees (16%)
• Netherlands: 34 employees (15%)
• Denmark: 36 employees (3.3%)
• Mexico: 25 employees (3.1%)
• US: 130 employees (2.0%)
• Brazil: 13 employees (2.2%)
• Belgium: 4 employees (1.8%)
• Czech Republic: 2 employees (1.3%)
• Romania: 1 employee (0.7%)
• Thailand: 3 employees (0.03%)

Geographic scope

Global – benchmarking covers every country where Pandora operates. The assessment includes all employees in Headcount excluding apprentices, student assistants, and interns.

Targets and commitments

Pandora commits to:

• Close wage gaps in 13 out of 17 countries by March 2025 (Belgium, Brazil, Colombia, Czech Republic, Denmark, Ireland, Mexico, Peru, Portugal, Romania, Singapore, Thailand, and the US)
• Resolve remaining gaps in 4 countries in 2025 (Chile, Luxembourg, Netherlands, South Africa)
• Annual review of living wage standards globally
• Establish internal pay ranges for each country using external wage benchmarks to ensure wages cover basic living needs
• Benchmarks will be reviewed annually to account for inflation and shifts in cost of living

The company is developing a Global Adequate Wage Policy (to be finalized in 2025) that will ensure wages reflect the cost of living in each country and outline third-party and international standards followed.

Methodology details

• Benchmark source: WageIndicator.org (October 2024 update)
• Wages assessed: Annual base wage including qualifying allowances (housing, meal, transport allowances, free school for children, guaranteed bonus, paid private medical insurance)
• Calculation approach: Country-level assessments comparing employee wages against adequate wage or living wage (whichever is higher or available)
• Frequency: Annual review planned
• Contractor wages: Not explicitly mentioned; scope covers employees in Headcount excluding apprentices, student assistants, and interns
• Reporting: Annual consolidation of country-level assessments; progress on closing gaps to be reported as initiatives advance

Pandora also offers employees various social protections and promotes work-life balance. We provide safeguards against income loss due to major life events, including sickness, unemployment, workplace injuries and acquired disabilities, parental leave and retirement. Coverage for social protections varies across Panama, Singapore, South Africa and the US due to differences in local regulations and government programmes.

Persons with disabilities

Employees with disabilities

¹ Countries where the data is reported: Chile, China, France, Germany, Hong Kong, Italy, Romania, Spain and Turkey.

Accounting policies

The percentage of employees with disabilities is reported in accordance with ESRS S1-12. The share of employees with disabilities is compared to total number of employees at year-end and is accounted for in Headcount.

The number of employees with disabilities employed by Pandora at year-end includes employees with disabilities in countries where it is a legal requirement to register employees with disabilities. The legal definitions of individuals with disabilities by the respective countries are taken into consideration when reporting the data.

Awareness activities

To promote human rights awareness, Pandora organised activities on Disability Day (alongside Human Rights Day and International Women's Day). These events featured panel discussions with external human rights experts.

Focus groups

In 2023, focus groups explored perceptions of the working environment, harassment, discrimination and the effectiveness of grievance mechanisms, with a specific focus on employees with disabilities.

Health and safety metrics

Coverage

In 2024, 99.6% of employees were covered by health and safety management systems, reflecting Pandora's commitment to maintaining high standards across all areas of the business.

Health and safety performance

Methodology

Health and safety data covers all employees at year-end (Headcount basis). The rate of recordable accidents is calculated per million nominal working hours and is presented both for all recorded accidents and for accidents with at least one day of absence. Contractors, visitors, employees on unpaid leave and interns are not included in rate calculations.

Work-related ill health cases are health cases caused or aggravated by work conditions or practices. Days lost count the first full day and last day of absence using calendar days.

Work-life balance metrics

Family-related leave

Methodology

The number of employees entitled to take family-related leave includes employees eligible for family-related leave, such as parental, maternity, paternity, or caregiving leave at year-end and is accounted for in Headcount. The number of employees that took family-related leave is calculated as the share of the employees who took family-related leave compared to the number of employees who were entitled to take family-related leave at year-end.

Social protection context

Pandora provides safeguards against income loss due to major life events, including sickness, unemployment, workplace injuries and acquired disabilities, parental leave and retirement. Coverage for social protections varies across Panama, Singapore, South Africa and the US due to differences in local regulations and government programmes.

Compensation metrics (ESRS S1-16)

Pay gap

Pandora reported a gender pay gap of 1.9% for 2024. This is the first year of disclosure (2023 comparatives show "-").

The company notes that the ratio is influenced by its significant workforce in Thailand (28% of employees work at crafting facilities with competitive local wages) and a large number of retail positions globally (28% work in stores worldwide). This structure results in a wider wage gap compared to companies with a higher proportion of office-based employees.

Remuneration ratio

The total remuneration ratio for 2024 was 288:1 (CEO to median employee compensation). This is the first year of disclosure.

The company states this ratio was further impacted in 2024 by a special one-time award granted to the CEO. The CEO's salary is noted to be comparable to other CEOs in Denmark and Europe. The calculation is influenced by:

• 28% of employees working at crafting facilities in Thailand with competitive local wages
• A large number of retail positions at Pandora globally
• The ratio compares the highest paid employee (CEO) to the median of all employees

Methodology

Gender pay gap: Calculated by comparing the average gross hourly earnings of men and women across the workforce, expressed as a percentage of the average pay level of male employees. Includes all employees at year-end accounted for in Headcount, attributed to binary gender (female or male). Employees not registered with a binary gender were not included. Average gross hourly earnings includes annual base salary and STIP (short-term incentive plan) payout.

Total remuneration ratio: Calculated by comparing the annual total compensation of the highest paid employee (CEO) to the median annual compensation of all other employees at year-end. Based on total gross compensation figures including salary, bonuses, and other financial benefits comprising the total fair value of all annual long-term incentives including share-based payments.

Pandora also disclosed gender pay gaps for the UK and Australia to meet local regulatory requirements.

Incidents, complaints and severe human rights impacts

Reported incidents and complaints

Context and approach

Pandora's grievance mechanisms in Thailand highlighted occasional instances of unacceptable workplace behaviour in 2024. In response, the company conducted focus groups with a statistically representative sample of employees and provided targeted training for managers on discrimination and harassment.

Key issues raised through employee interviews included high overall satisfaction with the workplace atmosphere, but some verbal microaggressions, favouritism and low levels of understanding of discrimination.

Manager training: In 2024, 161 managers participated in classroom sessions on discrimination and harassment. Post-training surveys showed that 83% found the training valuable for building a positive workplace.

Grievance mechanisms: Multiple reporting channels are available, including face-to-face, online and anonymous options, supplemented by QR codes and a mobile app. The company began a comprehensive review of grievance mechanisms in Thailand in 2024 to ensure alignment with UN Guiding Principles effectiveness criteria.

Most reports through grievance mechanisms involve clarifying questions about the Welfare and Benefits programme or overtime requests, with a few addressing policy breaches, all of which were investigated.

Accounting policies

Incidents, complaints and severe human rights impacts are disclosed in accordance with ESRS S1-17. The number of incidents of discrimination and complaints includes all complaints filed through the whistleblower hotline at year-end. Incidents of severe human rights includes the number of incidents connected to Pandora's workforce, and all OECD reports are included in the reported number.

Fines, penalties and compensation resulting from incidents of discrimination and harassment are expenses measured in DKK, in the fiscal year in which they become probable and can be reliably estimated.

Policies related to value chain workers

Pandora has established policies related to value chain workers as part of its human rights due diligence (HRDD) process following the guidance in the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises (MNEs).

Supplier Code of Conduct

• Scope: Applicable to Pandora's suppliers
• Key content: Outlines basic expectations of suppliers regarding environmental, social and legal compliance criteria; requires suppliers to provide workers with access to grievance mechanisms without fear of retaliation
• Links to international standards: Aligns with the Ethical Trading Initiative Base Code and International Labour Organization conventions
• Public availability: Publicly available on Pandora's corporate website under 'Policies'
• Governance: Approved by Pandora's Board of Directors

Responsible Sourcing Policy

• Scope: Applicable to Pandora's suppliers
• Key content: Outlines how Pandora implements its Supplier Code of Conduct through risk assessment, management systems, traceability, audits, reporting and disclosure; sets out three core objectives for the Responsible Sourcing Programme: responsible, transparent and traceable
• Implementation monitoring: Product suppliers undergo audits to the SMETA (Sedex Members Ethical Trade Audit) standard or an equivalent accepted standard at least every two years, conducted by independent third-party experts; responsible sourcing and procurement teams collaborate with suppliers to prepare, follow up, address root causes and engage with workers on remediation
• Public availability: Publicly available on Pandora's corporate website under 'Policies'
• Governance: Approved by Pandora's Board of Directors

Human Rights Policy

• Links to international standards: Part of Pandora's human rights due diligence (HRDD) process following the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises
• Public availability: Publicly available on Pandora's corporate website under 'Policies'

Whistleblower Policy

• Scope: Freely available to all relevant stakeholders including value chain workers
• Key content: Aligned with the Danish Whistleblower Act and the EU Whistleblower Directive; provides a clear and secure process for confidential reporting of concerns; reports can be submitted confidentially through the EQS system or a designated whistleblower inbox
• Implementation monitoring: In 2024, mandatory whistleblower e-learning launched for all employees; 233 cases were reported through the whistleblower platform in 2024 covering issues such as harassment, discrimination, racism and minor grievances
• Public availability: Referenced in the annual report

Franchisee and Distributor Code of Conduct

• Links to international standards: Part of Pandora's human rights due diligence process following the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises
• Public availability: Publicly available on Pandora's corporate website under 'Policies'

Materials Standard

• Links to international standards: Part of Pandora's human rights due diligence process
• Public availability: Publicly available on Pandora's corporate website under 'Policies'

Privacy Policy

• Public availability: Listed among Pandora's policies

Data Ethics Policy

• Links to international standards: Part of the business conduct guidance related to human rights
• Public availability: Publicly available on Pandora's corporate website under 'Policies'

Taking action on material impacts on value chain workers

Responsible Sourcing Programme

Scope: Value chain workers at product suppliers (jewellery, point-of-sale materials, fixtures and furniture) and since 2023, service suppliers in warehousing and construction.

Governance: Guided by Supplier Code of Conduct and Responsible Sourcing Policy. The Responsible Sourcing Policy outlines three core objectives: responsible, transparent and traceable sourcing.

Key actions:

• Audit and monitoring programme: Comprehensive audits conducted through site tours, document reviews and worker interviews. Responsible sourcing and procurement teams collaborate with suppliers to prepare, follow up, address root causes and engage with workers on remediation.

• Supporting vulnerable workers (migrant workers): Migrants make up approximately 7% of workers in jewellery supply chain. In 2024, identified and resolved issues with migrant worker management at five sites, including payment of recruitment fees and passport retention.

• Responsible construction engagement (Vietnam facility): Engaged responsible construction supplier during construction of crafting facility in Vietnam to mitigate risks in sector characterised by informal and multi-layered recruitment practices. Supported by third-party expert to evaluate potential suppliers, using sustainability performance as key criterion. Implemented grievance mechanism to enable workers to voice concerns freely. Collaboration continues throughout project to monitor progress and address emerging risks.

• Complaint mechanisms: Supplier Code of Conduct requires suppliers to provide workers with access to grievance mechanisms without fear of retaliation. Whistleblower hotline freely available to all relevant stakeholders.

Strengthening Accountability and Knowledge in Supply Chain

Scope: Product and service suppliers across value chain.

Capability building initiatives:

• Hosted webinars and in-person jewellery supplier summit in 2024
• Launched e-learning programme on topics including worker consultation and water management
• On-site capability-building programme engaged six suppliers, including three from 2023, focusing on management systems and improvements beyond audits
• Introduced e-learning training on best practices for measuring and reporting GHG emissions
• Close collaboration with top 10 packaging suppliers by volume in China to support their environmental impact journey, help calculate carbon footprint and set objectives to lower it

Integration in procurement:

• Added requirements for worker representation and grievance mechanisms to supplier contracts
• Provided colleagues with monitoring tool to address human rights during supplier visits, focusing on high-risk sectors like third-party logistics
• Began incorporating low-carbon clauses into supplier contracts, requesting emission reporting and encouraging science-based targets

Responsible Buying Practices

Scope: Internal business practices impacting human rights in supply chain, including working conditions.

Time horizon: Improvements made in 2024 following 2023 review; ongoing refinement planned.

Actions implemented in 2024:

• Review of supplier contracts
• Improving sampling process
• Technological advancement of planning and forecasting
• More flexible production orders for recurring and large-volume materials
• Strengthened cross-functional collaboration to improve understanding of how actions affect other teams at Pandora, suppliers and workers in supply chain

Expected outcome: Continue refining approach to responsible buying.

Responsible Sourcing of Metals

Scope: Upstream value chain - metal suppliers and refineries.

Process: Due diligence process aligned with OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Annually map key metals (silver, gold, platinum group metals) to refinery level. Request certifications as part of due diligence.

Traceability requirements:

• Only use suppliers who source/use certified silver and gold
• Suppliers must have Chain of Custody (CoC) process audited by external third party
• Externally audited CoC process verifies sourced certified silver and gold from initial sourcing until use in jewellery crafting

Outcome: As of August 2024, all new jewellery crafted with 100% recycled silver and gold, avoiding around 58,000 tonnes of CO2 emissions per year.

Looking Ahead

Time horizon: Expected in 2025.

Planned actions:

• Developing broader targets for responsible sourcing programme focused on key enablers to drive meaningful and positive impact for workers across supply chain
• Review target audience for Responsible Marketing Standard training and extend to local marketing teams
• Setting targets beyond recycled silver and gold based on nature impact assessment findings (significant environmental impacts from copper and palladium use)

Resources (non-financial): Third-party experts engaged for construction site evaluation and monitoring in Vietnam.

Business conduct policies and corporate culture

Pandora has established comprehensive business conduct policies to guide ethical practices across its operations and value chain. These policies are governed at the highest level and apply to employees, suppliers, and business partners.

Code of Conduct

• Scope: All employees and partners are expected to adhere to the Code of Conduct
• Key content: Sets out ethical business practices and standards of behaviour; addresses anti-bribery and corruption, conflicts of interest, gifts and entertainment, and donations
• Governance: Board of Directors approval
• Public availability: Listed in the policy collection on pandoragroup.com/sustainability/resources/policies
• Monitoring: Mandatory e-learning courses launched in 2024 for all office employees; new e-learning courses available for Anti-Bribery and Corruption and Conflict-of-Interest; detailed trainings through webinars for employees who face higher risk of corruption and bribery
• Related policies: Supported by Anti-Bribery and Corruption Policy, Gifts and Entertainment Standard, Conflict-of-Interest Policy, and Global Donation Standard

Whistleblower Policy

• Scope: All employees and relevant stakeholders
• Key content: Provides a clear and secure process for employees to confidentially raise concerns; aligned with the Danish Whistleblower Act and EU Whistleblower Directive; outlines process for addressing issues raised through whistleblower channels including dedicated hotline and EQS system
• Governance: Internal Audit and Compliance Controlling (IACC) function reviews each case; external consultants engaged when needed
• Public availability: Listed in the policy collection on pandoragroup.com/sustainability/resources/policies
• Monitoring: 233 cases reported in 2024; mandatory whistleblower e-learning launched in 2024; Speak Up! posters displayed globally in offices, crafting facilities, distribution centres and stores; hotline hosted by external service provider with multi-lingual online reporting tool

Global Data Ethics Policy

• Scope: Company-wide data processing activities
• Key content: Applies principles of equality and equity in data processing, respecting the individual behind the data and committing to sustainable data practices; Privacy Policy outlines principles for managing personal data from customers, employees and other individuals
• Governance: In 2024, decided to establish comprehensive AI Governance Framework to ensure compliance with evolving legislation including EU AI Act; developing Data Governance Framework
• Public availability: Available on pandoragroup.com/sustainability/resources/policies (section 99d of the Danish Financial Statements Act)
• Monitoring: AI Literacy Programme educates colleagues on safe and ethical use of Generative AI; AI Safety Standard in place; expanded targeted training for corporate employees in 2024; supplier onboarding programme ensures third-party suppliers screened for privacy-related issues; no substantiated data privacy claims received in 2024; one incident reported to Danish Data Protection Authority in 2024 with no further action required

Tax Policy

• Key content: Ensures compliance with letter and spirit of tax laws in all markets while striving to maximise shareholder value responsibly; commitment to tax transparency; does not avoid taxes or exploit lack of transparency by operating in tax havens (referencing EU list of non-cooperative jurisdictions and OECD principles); where present in low-tax jurisdictions, ensures commercial and economic substance without artificial operating structures
• Public availability: Available on pandoragroup.com/sustainability/resources/policies
• Monitoring: Total global tax contribution of DKK 8.0 billion in 2024; voluntary disclosure of tax-related information

Anti-Money Laundering Programme

• Scope: All Pandora subsidiaries and affiliates (global minimum standard)
• Key content: Commitment to compliance with regulations concerning anti-money laundering, terrorist financing, due diligence, economic sanctions and embargoes; includes procedures for third-party due diligence with thorough screening process including monitoring of sanctions and adverse media
• Monitoring: Mandatory training programme for employees who face higher risk of exposure to money laundering-related risks, consisting of e-learning and detailed webinars

Global Human Rights Policy

• Scope: Applicable to direct operations and value chain
• Key content: Outlines commitment to adhering to international standards including UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work and other international instruments; details salient human rights issues, key stakeholder groups and engagement practices, implementation across business and remediation mechanisms
• Governance: Approved by Board of Directors
• International standards: UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work
• Public availability: Available on pandoragroup.com/sustainability/resources/policies
• Monitoring: Human rights due diligence (HRDD) process established; third-party human rights impact assessment conducted; targets include zero health and safety incidents, tracking grievances through whistleblower hotline, monitoring employee attrition rates, achieving 8.5 inclusiveness score; started benchmarking wages against global living and adequate wage benchmarks in 2024

Supplier Code of Conduct

• Scope: All suppliers
• Key content: Outlines basic expectations regarding environmental, social and legal compliance criteria; aligns with Ethical Trading Initiative Base Code and ILO conventions; requires suppliers to provide workers with access to grievance mechanisms without fear of retaliation
• Governance: Board of Directors approval
• International standards: Ethical Trading Initiative Base Code, ILO conventions
• Public availability: Available on pandoragroup.com/sustainability/resources/policies
• Monitoring: Implemented through Responsible Sourcing Programme including risk assessment, management systems, traceability, audits, reporting and disclosure; identified and resolved issues with migrant worker management at five sites in 2024

Responsible Sourcing Policy

• Scope: Applicable to Pandora's suppliers
• Key content: Outlines implementation of Supplier Code of Conduct through risk assessment, management systems, traceability, audits, reporting and disclosure; three core objectives: responsible, transparent and traceable
• Governance: Approved by Board of Directors; overseen by Responsible Sourcing Committee
• Public availability: Available on pandoragroup.com/sustainability/resources/policies
• Monitoring: Hosted webinars and in-person jewellery supplier summit in 2024; launched e-learning programme on topics like worker consultation and water management; on-site capability-building programme engaged six suppliers; integrated sustainability in procurement by adding requirements for worker representation and grievance mechanisms to supplier contracts

Responsible Marketing Standard

• Scope: All marketing activities and partnerships
• Key content: Sets out principles and standards for company and partners when marketing jewellery; outlines ethical guidelines emphasising diversity, equity, inclusion and transparency in all marketing practices
• Governance: Responsible Marketing Committee chaired by Chief Marketing Officer, convenes twice a year; comprehensive end-to-end process to assess effectiveness through continuous review at product and creative decision gates
• Public availability: Available on pandoragroup.com/sustainability/resources/policies
• Monitoring: Mandatory Responsible Marketing Standard training module for global marketing team with 95% completion rate by end of 2024; indirect procurement team includes RMS in tender process for new suppliers; will be updated in 2025 to address CSRD disclosure requirements

Additional governance policies

Pandora has established additional policies supporting business conduct and corporate governance:

• Inclusion and Diversity Policy: Outlines ambitions and commitments to create inclusive, diverse and fair workplace; applicable to direct operations and value chain; approved by Board of Directors; publicly available; will be updated in 2025 to capture updated diversity, equity and inclusion strategy and address CSRD requirements
• Health and Safety Policy: Listed in policy collection
• Privacy Policy: Outlines principles for managing personal data; ensures data used, stored, shared and protected in accordance with applicable privacy laws; regular training initiatives for employees
• Remuneration Policy: Listed in policy collection
• Investor Relations Policy: Requires all communication to stakeholders, including financial and sustainability reporting, to be conducted adequately, timely, openly, factually, truthfully and in compliance with laws and regulations
• Global Environmental Policy: Requires employees to adopt environmentally responsible practices; updated in 2024 to meet CSRD requirements; outlines commitment to environmental material topics and respected third-party standards; applies to direct operations and value chain; approved by Board of Directors; publicly available

Corporate culture and oversight

• Governance structure: Sustainability governed at highest level by Board which approves climate transition plan; execution delegated to Sustainability Board chaired by Chief HR Officer with nine senior leaders including ELT members; two subject-specific committees (Responsible Sourcing Committee and Responsible Marketing Committee) and two task forces (Low Carbon & Nature Task Force and CSRD Task Force) oversee key sustainability areas
• Zero tolerance approach: Zero-tolerance policy for bribery and corruption supported by dedicated compliance programme
• Internal control: Internal Audit and Compliance Controlling (IACC) function established to evaluate and improve effectiveness of internal control, compliance and governance processes; head of IACC reports to Senior Vice President Corporate Finance with dotted reporting line to Audit Committee Chair (changing to CFO in 2025)

Incidents of corruption or bribery

Confirmed incidents

Pandora reports zero confirmed incidents of corruption or bribery in 2024. The company explicitly states: "Pandora has not been found guilty of human rights laws, guilty of breaching tax laws, convicted of corruption or bribery or found in breach of competition laws."

Convictions and fines

No convictions or legal decisions related to corruption or bribery are reported for 2024. Pandora has not been subject to any fines, penalties, or legal proceedings for violations of anti-corruption or anti-bribery laws.

Disciplinary actions

No employees were dismissed or disciplined due to corruption or bribery incidents in 2024.

Contracts terminated

No contracts with business partners were terminated or not renewed due to corruption or bribery violations in 2024.

Investigation procedures and speak-up mechanisms

Pandora maintains a zero-tolerance policy for bribery and corruption supported by a comprehensive compliance programme built around:

• Code of Conduct
• Anti-Bribery and Corruption Policy
• Gifts and Entertainment Standard
• Conflict-of-Interest Policy
• Global Donation Standard

The company operates a whistleblower hotline aligned with the Danish Whistleblower Act and EU Whistleblower Directive. The hotline is hosted by an external service provider (EQS system) and allows for anonymous reporting. In 2024, Pandora launched mandatory whistleblower e-learning for all employees as part of the "Speak Up!" campaign.

In 2024, 233 cases were reported through the whistleblower platform covering issues such as harassment, discrimination, racism and minor grievances. None of these cases had a severe impact on business operations or material financial impact. The Internal Audit and Compliance Controlling (IACC) function reviews each case and directs it to the appropriate team.

Training and awareness

In 2024, Pandora re-launched e-learning courses for all office employees on the Code of Conduct, with new e-learning courses available for Anti-Bribery and Corruption and Conflict-of-Interest. Detailed trainings through webinars were provided for employees facing higher risk of corruption and bribery due to their role or location.

Payment practices

Payment terms

Pandora states that payment terms specified in contracts are not adjusted for any financing element, as payment terms never exceed 12 months.

Supply chain financing programme

Pandora operates a supply chain financing programme where vendors can sell off their receivables from Pandora on attractive terms, based on invoices approved by Pandora, but at the bank's sole discretion. The programme does not extend payment terms beyond the original terms agreed.

Payment terms by programme participation:

The programme is generally more attractive to suppliers with longer payment terms.

Trade payables under supply chain financing programme:

Pandora is not directly or indirectly a party to these agreements. The amounts payable to suppliers included in the supply chain financing programme are classified as trade payables in the balance sheet as well as in the statement of cash flows (working capital within cash flows from operations). Suppliers have received payment from the bank for all the liabilities under the supplier finance arrangement.