The administrative, management and supervisory bodies of Vestas play a pivotal role in sustainability governance and the company's strategic direction. The Board of Directors includes sustainability oversight as part of its responsibilities, with the Audit Committee overseeing sustainability reporting and related risks. The Board regularly reviews sustainability performance and progress against targets through quarterly presentations from management.

The Board has established committees including the Audit Committee which has specific oversight responsibilities for sustainability matters. The Executive Management, led by CEO Henrik Andersen, has integrated sustainability into business strategy and operations.

The governance structure includes the Enterprise Leadership Team (top 80 leaders) and the Vestas Leadership Forum (top 250 leaders) which provide strategic alignment on sustainability initiatives across the organization. Regional Leadership Forums also support the cascading of sustainability priorities throughout the global operations.

Sustainability governance is embedded in the company's decision-making processes with quarterly assessment of sustainability-related goals broken down into key products, services and geographies presented to the Executive Management and the Board. The Board oversees the company's sustainability strategy which has a clear mandate of 'sustainability in everything we do'.

The Board of Directors and Executive Management regularly receive information on sustainability matters through various channels:

• Quarterly reporting: Assessment of sustainability-related goals, broken down into key products, services and geographies, is presented to the Executive Management and the Board on a quarterly basis • Annual reporting: Scope 3 emissions and community engagement metrics are reported annually to leadership • Strategic alignment events: The Vestas Leadership Forum (top 250 leaders) and Enterprise Leadership Team (top 80 leaders) focus on strategic alignment including sustainability matters • Committee oversight: The Audit Committee has specific oversight responsibilities for sustainability reporting and related risks

The sustainability matters addressed include:

• Climate change mitigation (E1)
• Circular economy and resource use (E5)
• Own workforce (S1)
• Affected communities (S3)
• Political engagement (G1)

The Board and management teams regularly evaluate progress against the company's sustainability strategy targets including carbon neutrality by 2030, zero-waste wind turbines by 2040, safety improvements, and increased diversity in leadership positions.

Integration of sustainability-related performance in incentive schemes

Roles covered

The remuneration of the Executive Management team is linked to the results of Vestas' financial and sustainability performance, through incentives.

No board members are included in any incentive or performance-based remuneration.

Sustainability KPIs tied to remuneration

Short-term incentive (STI) components

Long-term incentive (LTI) components

Weighting of sustainability in incentives

For the Executive Management team, 10 percent of the short-term incentive scheme is linked to climate-related KPIs in the form of the KPI 'GHG emissions avoided'.

The long-term incentives are not linked to sustainable targets, nor is the base remuneration.

For the Board, 0 percent of the remuneration is linked to climate-related considerations.

Performance and payout in the reporting period

The bonus targets for 2024 triggered a payout of total DKK 0.7m for the CEO, former CFO, and interim CFO.

During the year, we have not paid any short-term incentives to the Executive Management team linked to climate-related targets as the said targets were not met.

Process for selecting KPIs and setting targets

The annual process for selecting KPIs and setting targets for the incentives is based on Vestas' strategic direction, and the KPIs are approved by the Board in the second quarter of the annual meeting cycle. The process includes input from each business area and leads to consolidated strategic prioritisation from the Executive Management and the Board when deciding KPIs and targets.

Vestas has implemented comprehensive due diligence processes across its operations and value chain:

Human Rights Due Diligence: Vestas updated its Human Rights Policy in 2024 to reflect evolving best practice and was ranked first in the Danish Institute for Human Rights' benchmark of large Danish companies. The company conducts Social Due Diligence on projects, achieving 83% coverage in 2024 compared to 59% in 2023.

Supply Chain Due Diligence: Vestas works closely with suppliers through various mechanisms including the annual Vestas Supplier Forum and enhanced engagement and integration with supply chain partners. The company maintains risk mitigation frameworks taking into account potential disruption of operations.

Value Chain Oversight: The company has established processes for engaging with value chain workers about impacts and maintains channels for workers to raise concerns. Vestas conducts due diligence across its complex supply chain involving both product and project manufacturing models.

Community Engagement: Vestas engages with impacted communities near projects to minimize and address potential grievances, with community grievance mechanisms in place. The company reported 2 community grievances in 2024 and supported 7,919 community beneficiaries.

Business Conduct: The company maintains policies and processes for prevention and detection of corruption and bribery, with 757 EthicsLine cases reported in 2024, of which 147 were substantiated.

Vestas has established comprehensive risk management and internal controls over sustainability reporting:

Governance Structure: The Audit Committee has specific oversight responsibilities for sustainability reporting and related risks. Sustainability risk management is integrated into the company's overall risk management framework.

Reporting Controls: This is Vestas' first integrated Annual Report addressing Corporate Sustainability Reporting Directive requirements. The sustainability statement has been prepared in compliance with ESRS and includes assurance procedures.

Risk Assessment: The company conducts double materiality assessments to identify and evaluate sustainability risks and opportunities. Material topics identified include Climate change, Water and marine resources, Biodiversity and ecosystems, Circular economy and resource use, Own workforce conditions, Workers in the value chain, Affected communities, and Business conduct.

Management Systems: Vestas has implemented management systems across key sustainability areas with regular monitoring and reporting. The company tracks performance against targets with quarterly reporting to Executive Management and the Board.

Assurance: Sustainability key figures for 2020-2023 were subject to limited assurance by previous auditors. The 2024 sustainability statement prepared in compliance with ESRS is subject to assurance procedures.

Data Quality: The company conducts regional validation and clean-up of contract data and has established accounting policies for sustainability metrics to ensure data integrity and reliability.

Business Model

Vision: To become the Global Leader in Sustainable Energy Solutions. By leading across our four business areas, Onshore, Offshore, Service, and Development, we aim to lead the energy transition forward.

Core Business Areas

Onshore: Vestas is the market leader with more than 40 years of experience in Onshore wind. Based on our own onshore wind turbine product design and development, we offer customers wind power solutions, and we take care of everything from siting, manufacturing, construction, and installation to final commissioning in cooperation with our partners.

Offshore: Vestas is becoming a leading player in Offshore wind with almost 30 years of experience. Based on our own offshore wind turbine product design and development, we offer customers wind power solutions, and we take care of all stages from siting through final commissioning.

Service: Vestas is the global market leader in Service within wind power with around 16,000 employees across 67 countries. Our people service 155 GW for our customers on long-term subscription-based contracts, making their assets operate more effectively.

Development: Development helps our customers grow their business, which in turn generates order intake for Vestas. More than 100 employees across 16 countries secure land rights and permits, design sites, ensure grid connection, and secure project offtake agreements to create quality projects for our partners' investments.

Key Inputs (SBM-1-42a)

Viewed through the lens of sustainability and the ESRS, our key inputs are:

• Raw materials
• Capital employed
• Energy
• Employee working hours

We gather these inputs through business relationships in the supply chain and in our own operations spanning from own workforce to contractors. Development and securing of the inputs is primarily through continuous improvement efforts, formal contractual agreements and risk mitigation frameworks taking into account any potential disruption of operations.

Key Outputs and Outcomes (SBM-1-42b)

Viewed through the lens of sustainability and the ESRS, the key outputs and outcomes of our business model are wind turbines installed. The value we create for our employees, investors, customers, and other stakeholders includes:

• Salaries
• EBIT margin before special items
• Total recordable injuries
• GHG emissions avoided

Global Operations

We operate globally with a track record of 189 GW capacity installed in 88+ countries. Our full suite of wind energy solutions ensures we can grow market presence in regions with significant wind potential, serving a wide array of customers across multiple regions, including Europe, North & South America, and Asia Pacific, while expanding our offshore wind capabilities to new markets.

Customer Base

Our main customers are utility companies, which seek to integrate renewable energy into their power grids. We also work with independent power producers that develop and operate wind farms relying on our technology to deliver consistent energy output.

Vestas engages with a diverse range of stakeholders and considers their interests and views in business strategy and operations:

Key Stakeholder Groups

Customers: Our main customers are utility companies seeking to integrate renewable energy into power grids and independent power producers. We maintain a customer-centric approach prioritizing value creation over volume. Priority customers have global account managers and leading access to our siting capabilities and Development projects. In 2024, we achieved a Customer Net Promoter Score of 59 for Onshore.

Employees: With approximately 35,000 employees globally, we prioritize their growth and development through comprehensive training, leadership development, and talent programmes. In 2024, we provided almost four million hours of training globally. Our 'learn and grow' score improved from 73 in 2023 to 76 in 2024 in our Employee Engagement Survey.

Suppliers: We work closely with strategic suppliers through enhanced engagement including the annual Vestas Supplier Forum. Key partnerships include Maersk, ZF and ArcelorMittal. We are shifting our industrial system from push to pull to optimize resource use and supply chain lead time.

Communities: We engage with impacted communities near our projects to minimize and address potential grievances. In 2024, we supported 7,919 community beneficiaries and received 2 community grievances. We conduct Social Due Diligence on 83% of projects in scope.

Investors and Shareholders: We aim to deliver stable profits returned through dividends and/or share buybacks. We issue sustainability-linked bonds and maintain regular communication about financial and sustainability performance.

Value Chain Workers: We have established processes for engaging with value chain workers about impacts and maintain channels for workers to raise concerns through our supply chain oversight.

Government and Regulators: We engage in political advocacy including our 'This is not a wind farm' campaign highlighting the need for redesigned wind farm auctions. We campaign for sustainable scale-up of renewable energy and alignment of public policy with climate commitments.

Stakeholder Engagement Methods

• Regular customer dialogues and partnership meetings
• Employee engagement surveys and leadership forums
• Annual supplier forums and strategic partnerships
• Community engagement programs and grievance mechanisms
• Investor relations and sustainability reporting
• Industry advocacy and policy engagement
• EthicsLine reporting system for raising concerns

Integration of Stakeholder Views

Stakeholder input influences our strategy development, particularly in:

• Sustainability target setting and validation
• Product development and technology priorities
• Supply chain management and partnerships
• Community impact mitigation
• Policy advocacy positions
• Safety and quality improvements

Material Impacts, Risks and Opportunities

Double Materiality Assessment Results

Vestas conducted a comprehensive double materiality assessment to identify material sustainability matters. The assessment identified the following material topics:

Environmental Topics:

• E1 Climate change: Material from both impact and financial materiality perspectives
• E3 Water and marine resources: Material
• E4 Biodiversity and ecosystems: Material
• E5 Circular economy and resource use: Material

Social Topics:

• S1 Own workforce: Material across multiple subtopics including health and safety, secure employment, and equal treatment
• S2 Workers in the value chain: Material
• S3 Affected communities: Material

Governance Topics:

• G1 Business conduct: Material

Key Material Impacts

Positive Impacts:

• Climate Impact: Expected GHG emissions to be avoided over the lifetime of capacity produced and shipped in 2024: 455 million tonnes CO2e
• Energy Transition: Delivered 13 GW of wind turbines in 2024, contributing to global renewable energy capacity
• Economic Development: Supporting local job creation and economic development in communities where we operate

Negative Impacts:

• GHG Emissions: Scope 1 & 2 emissions of 105k tonnes CO2e and Scope 3 emissions of 7.99 million tonnes CO2e in 2024
• Resource Use: Material efficiency rate of 1.0 tonnes of waste per MW produced and shipped
• Safety: 240 total recordable injuries with 2 fatal injuries in 2024

Material Risks

Climate-Related Physical Risks:

• Extreme weather events affecting operations and supply chains
• Sea level rise impacting coastal facilities and offshore installations

Climate-Related Transition Risks:

• Policy and regulatory changes affecting renewable energy incentives
• Technology risks from rapid innovation cycles
• Market risks from changing customer preferences

Supply Chain Risks:

• Disruption of operations due to geopolitical uncertainty
• Raw material price volatility and availability
• Quality issues affecting project execution

Social Risks:

• Workplace safety incidents
• Community opposition to projects
• Human rights risks in value chain

Material Opportunities

Market Opportunities:

• Growing demand for renewable energy driven by energy security concerns
• Expanding addressable market with wind energy expected to grow 7-9% annually for onshore and 20-25% for offshore towards 2030
• Data center and AI boom driving new power demand

Technology Opportunities:

• Development of larger, more efficient turbines
• Digitalization and efficiency improvements
• Circular economy innovations including blade recycling

Partnership Opportunities:

• Strategic partnerships across the value chain
• Customer co-development of sustainable solutions
• Government collaboration on energy policy

Integration with Strategy and Business Model

These material impacts, risks and opportunities are integrated into:

Corporate Strategy: The sustainability strategy with four pillars (Climate, Circularity, Social, Energy transition) addresses key material issues

Business Operations: Risk management and mitigation strategies are embedded across all four business areas (Onshore, Offshore, Service, Development)

Financial Planning: Expected financial effects from climate-related risks and opportunities are considered in strategic planning and capital allocation

Target Setting: Material issues inform sustainability target setting including carbon neutrality by 2030, zero-waste turbines by 2040, and safety improvements

The Board and Executive Management receive quarterly updates on progress against material sustainability issues, with annual reporting on scope 3 emissions and community engagement.

Process for Identifying and Assessing Material Impacts, Risks and Opportunities

Double Materiality Assessment Process

Vestas conducts a comprehensive double materiality assessment to identify and assess material sustainability impacts, risks and opportunities. The process follows ESRS requirements and considers both impact materiality (actual and potential impacts on people and the environment) and financial materiality (financial effects on the company).

Assessment Methodology

The double materiality assessment process includes:

1. Stakeholder Engagement: Input from various stakeholder groups including employees, customers, suppliers, communities, investors, and regulators

2. Impact Identification: Systematic review of potential positive and negative impacts across the value chain

3. Risk and Opportunity Mapping: Assessment of climate-related and other sustainability risks and opportunities

4. Materiality Evaluation: Evaluation of significance from both impact and financial perspectives

5. Validation and Approval: Review and validation by management and Board oversight

Regular Review and Updates

The materiality assessment is regularly updated to reflect:

• Changes in business operations and strategy
• Evolving stakeholder expectations
• New regulatory requirements
• Emerging sustainability issues
• Market developments

Integration with Business Processes

The results of the materiality assessment are integrated into:

• Strategic planning and decision-making
• Risk management processes
• Sustainability target setting
• Reporting and disclosure
• Performance monitoring and management

Key Identified Material Topics

The process identified the following material topics:

• E1 Climate change
• E3 Water and marine resources
• E4 Biodiversity and ecosystems
• E5 Circular economy and resource use
• S1 Own workforce (multiple subtopics)
• S2 Workers in the value chain
• S3 Affected communities
• G1 Business conduct

Governance and Oversight

The materiality assessment process is overseen by:

• Executive Management with quarterly review of sustainability matters
• Board of Directors with oversight of sustainability strategy
• Audit Committee with specific responsibility for sustainability reporting
• Regional and functional leadership teams for implementation

Continuous Improvement

Vestas continuously refines its approach to identifying and assessing material impacts, risks and opportunities through:

• Regular stakeholder feedback
• Industry best practice benchmarking
• Regulatory guidance updates
• Internal capability development
• External assurance and verification

Disclosure Requirements Covered in Vestas' Sustainability Statement

Vestas' sustainability statement covers the following ESRS disclosure requirements based on the materiality assessment:

ESRS 2 General Disclosures

• GOV-1: Role of administrative, management and supervisory bodies
• GOV-2: Information provided to and sustainability matters addressed by bodies
• GOV-4: Statement on due diligence
• GOV-5: Risk management and internal controls over sustainability reporting
• SBM-1: Strategy, business model and value chain
• SBM-2: Interests and views of stakeholders
• SBM-3: Material impacts, risks and opportunities and their interaction with strategy
• IRO-1: Description of processes to identify and assess material impacts, risks and opportunities
• IRO-2: Disclosure requirements covered by the sustainability statement

Environmental Standards

E1 Climate Change:

• E1-2: Policies related to climate change mitigation and adaptation
• E1-3: Actions and resources in relation to climate change policies
• E1-4: Targets related to climate change mitigation and adaptation
• E1-5: Energy consumption and mix
• E1-6: Gross Scopes 1, 2, 3 and Total GHG emissions

E3 Water and Marine Resources:

• E3-1: Policies related to water and marine resources
• E3-4: Water consumption

E4 Biodiversity and Ecosystems:

• E4-2: Policies related to biodiversity and ecosystems

E5 Circular Economy and Resource Use:

• E5-1: Policies related to resource use and circular economy
• E5-2: Actions and resources related to resource use and circular economy
• E5-3: Targets related to resource use and circular economy
• E5-4: Resource inflows
• E5-5: Resource outflows

Social Standards

S1 Own Workforce:

• S1-1: Policies related to own workforce
• S1-4: Taking action on material impacts and effectiveness
• S1-6: Characteristics of employees
• S1-9: Diversity metrics
• S1-14: Health and safety metrics

S2 Workers in the Value Chain:

• S2-1: Policies related to value chain workers
• S2-2: Processes for engaging with value chain workers
• S2-3: Processes to remediate negative impacts
• S2-4: Taking action on material impacts

S3 Affected Communities:

• S3-1: Policies related to affected communities
• S3-2: Processes for engaging with affected communities
• S3-3: Processes to remediate negative impacts
• S3-4: Taking action on material impacts

Governance Standards

G1 Business Conduct:

• G1-1: Business conduct policies and corporate culture
• G1-2: Management of relationships with suppliers
• G1-3: Prevention and detection of corruption and bribery
• G1-4: Incidents of corruption or bribery
• G1-5: Political influence and lobbying activities

Entity-Specific Disclosures

• Transparent tax practices
• Cyber security risks

EU Taxonomy Reporting

Vestas also provides EU Taxonomy disclosures as required under the EU Taxonomy Regulation.

Basis for Omissions

Where specific disclosure requirements are not included, this is based on the materiality assessment results showing these topics are not material for Vestas' business model and impacts. The company applies the ESRS materiality criteria in determining which disclosures to include.

Assurance

Key sustainability metrics have been subject to limited assurance procedures, with the 2024 sustainability statement prepared in compliance with ESRS requirements.

Transition plan for climate change mitigation

Strategic ambitions

Vestas is committed to powering the green transition, with the following strategic ambitions to mitigate climate change:

• Become carbon neutral in our own operations by 2030 without using carbon offsets
• Reduce GHG emissions from our value chain by 45 percent per MWh generated by 2030, from a 2019 baseline

Combating climate change is at the core of our business model. Each day, Vestas wind turbines capture energy from wind, producing a renewable alternative to fossil fuels, a key lever to decarbonise the world's energy systems. The turbines we produced and shipped during 2024 are expected to avoid 455 million tonnes of GHG emissions over their lifetime, equivalent to reducing the GHG emissions from powering 86 million average US homes for one year.

Paris alignment and SBTi validation

Vestas is included in the EU Paris-aligned Benchmarks. Our climate change transition plan starts with the first goal in our sustainability strategy: To become carbon neutral in own operations by 2030 without using carbon offsets. Our 2030 emission reduction targets are validated by the Science Based Targets initiative (SBTi), to ensure our transition plan for climate change mitigation is in line with the Paris Agreement and limiting global warming to 1.5°C.

Current status on targets:

Our current projections tell us that we will not be able to deliver on the 2025 target to reduce GHG emissions by 55 percent by 2025, however we will continue to adapt our strategy and transition plan to stay in alignment with the Paris Agreement. To achieve this, we plan to seek a revalidation of our targets in 2025, considering our new scope of operations, which includes our offshore activities, and complying with the SBTi five-year revalidation requirement.

Vestas is not on track to meet its 2025 mid-term target for scope 1 and market-based scope 2, primarily related to the acquisition of the offshore business and rapid growth of our onshore and offshore service operations and associated fuel consumption. We will continue to adapt our strategy and transition plan to stay in alignment with the Paris Agreement and to ensure our target for scope 1 & 2 emissions remains realistic; to achieve this we plan to seek revalidation of our targets in 2025, following SBTi's requirement to have all targets reviewed five years after the original target was set.

Scope of the transition plan

Entities and geographies: The transition plan covers our entire value chain globally, including:

• Own operations (scope 1 and 2): Manufacturing facilities, construction activities, and service operations across all geographies where Vestas operates
• Upstream value chain (scope 3): Suppliers of steel, iron, blades, transport, and other materials
• Downstream value chain (scope 3): Use phase of sold products

Value chain segments: The plan addresses impacts across manufacturing, construction, service operations, and the full product lifecycle.

Targets and milestones

Scope 1 and 2 targets:

Scope 3 targets:

The scope 3 target covers 70 percent of our scope 3 emissions and addresses categories 1 through 7, and 12. Of these, category 1 (purchased goods) contributes more than 85 percent of Vestas' total scope 3 emissions, largely related to steel required for manufacturing wind turbines.

Decarbonisation levers and actions

We have identified two overarching decarbonisation levers:

1. Transition to renewable energy across our own operations to reduce scope 1 and 2 emissions

Source 100 percent renewable electricity across own operations: Since 2020, we have sourced 100 percent renewable electricity across our own operations globally.

Implement renewable heating: Factories in own operations: We are transitioning to renewable energy for heating in our factories. In 2024, we extended the reach of the biomass boiler at our facility in Daimiel, so it provides renewable heating to more of the factory. We also initiated a project to facilitate the installment of an electrical HVAC system at our facility in Brighton, USA, which will replace the current gas fuelled heating system. At the end of 2024, five of our 15 factory heating systems are renewably fuelled.

Phase out benefit cars powered by fossil fuels: In 2024, Vestas had a total of 732 benefit cars in its fleet, and 523 of these were renewably fuelled. Furthermore, 92 percent of our benefit cars in-use or on order were (PH)EVs. To support the scale-up of (PH)EVs, we have invested in charging infrastructure across our main locations.

Transition all new service vehicles to be renewably fuelled: For our onshore service activities, we are cooperating with industry leaders to transition to electric vehicles. In 2024, Vestas had a total of 6,676 service vehicles in its fleet, and 1,734 of these were renewably fuelled at the end of 2024.

Piloting sustainable fuels for offshore service vessels: To transition to sustainable biofuels for our offshore service vessels, we pioneered the first hydrogen-powered crew transfer vessel (CTV) in the wind industry in July 2022. In 2023, we extended an existing charter of a dual-fuel CTV from five to ten years. The vessel, initially powered by methanol with marine gas oil as a backup, will be operated entirely with methanol. These pilot projects aim to facilitate a complete green transition of the fleet by 2030.

Piloting sustainable aviation fuel for offshore construction: Vestas piloted Sustainable Aviation Fuel (SAF) at the Baltic Eagle wind farm in the Baltic Sea during 2024. SAF is a fuel produced from bio-waste materials such as used cooking oil or tallow, which enables an expected 38 percent CO2e savings per flight compared to using a standard helicopter powered by conventional jet fuel. Helicopters in the project used a 40 percent SAF blend, the highest permitted today, pioneering the use of such a high blend rate during offshore wind farm construction.

2. Work with suppliers to reduce supply chain scope 3 emissions from materials and transport

More than 98 percent of our carbon footprint comes from our value chain scope 3, so we are committed to greening our supply chain. Since 2020, we have worked to reduce emissions with our strategic suppliers of steel, iron, blades, and transport, which account for about 66 percent of Vestas' scope 3 emissions.

Build a sustainability data platform: To support achieving our sustainability goals, we are building a sustainability data platform using digital twin technology to calculate real-time climate footprints and run scenarios for monitoring, forecasting, and optimisation. To reduce scope 3 emissions, we prioritise gathering precise sustainability data from suppliers, focusing on high-emitting sources like steel and blade production. This engagement enables evidence-based target setting with suppliers and supports our overall scope 3 reduction target.

Commercialise low-emission steel: Steel and iron are key raw materials of our wind turbines and account for about 48 percent of Vestas' scope 3 emissions. Decarbonising steel production is crucial to meet our reduction targets. In addition, the EU's Carbon Border Adjustment Mechanism may increase costs for imported conventional steel and thus increase the need for emissions-reduced steel.

Vestas partnered with ArcelorMittal in 2023 to create low-emission steel by melting scrap steel in an electric arc furnace powered entirely by wind energy, reducing GHG emissions by up to 66 percent compared to the conventional steel making route. In 2024, Vestas introduced low-emission steel in its sustainable product portfolio. The first project using this steel is the Baltic Power offshore wind project in Poland, starting construction in 2025, with 52 out of 76 towers using low-emission steel. Additionally, Vestas has received a conditional order to supply 112 turbines for the Nordlicht 1 and 2 projects, with 56 towers using low-emission steel, reducing the towers' carbon footprint by 16 percent.

Piloting wooden tower technology alternative to steel: In 2021, Vestas invested in Modvion™, a company specialising in modular sustainable wind turbine towers made from laminated veneer lumber (LVL). LVL is a low-carbon material sourced sustainably, offering significant carbon emission reductions compared to steel or concrete towers, as wood stores carbon when trees grow. Thus, more carbon emissions are stored in the tower than emitted during the production process.

Vestas aims to support Modvion's™ scale-up strategy and integrate LVL towers into our design and manufacturing processes. This collaboration will help Vestas offer sustainable, cost-competitive solutions, enhancing transportation ease and providing cost-effective tall towers.

Financial resources allocated

CAPEX and OPEX investments:

In 2024, we allocated EUR 0.5m in CAPEX and EUR 23.2m in OPEX to support the implementation of the decarbonisation levers. In 2025 we expect to allocate EUR 1.2m in CAPEX and EUR 27.8m in OPEX to support implementation of the transition plan.

Our OPEX and CAPEX related to the reduction of our GHG emissions are aligned in accordance with the Commission Delegated Regulation 2021/2178. We expect our alignment with the EU Taxonomy to remain high in the foreseeable future.

The transition plan, including its targets and required investment level, has been approved by Executive Management and the Board.

Management and governance

Management reviews the progress towards our emission reduction targets on a quarterly basis. The sustainability matters that relate to our corporate strategy are mainly Climate change mitigation (E1), Circular economy and resource use (E5), Own workforce (S1), Affected communities (S3), and Political engagement (G1). An assessment of our sustainability-related goals, broken down into key products, services and geographies, is presented to the Executive Management and the Board on a quarterly basis, or, in the case of scope 3 and community engagement, on an annual basis.

Locked-in emissions and stranded assets

None of our assets are identified to have locked-in emissions. Our products do not generate emissions during their operating lifetime and the key assets in our own operations can be replaced by sustainably-fuelled alternatives.

Carbon offsets and removals

Vestas has chosen to achieve our targets without using GHG removals. Carbon offsetting means investing in environmental projects that work to reduce future carbon emissions. Carbon offsetting can play a role in accelerating the transition to net-zero emissions at the global level. However, it does not replace the need to reduce value chain emissions in line with scientific methods (SBTi 2020). To ensure we drive direct emission reductions, we have chosen to achieve our targets without using GHG removals.

Policy framework

Our approach to biodiversity and ecosystems protection as well as climate change mitigation is outlined in our SQHE policy and HSE framework. The policy and framework highlight our commitment to manage material impacts, risks, and opportunities related to climate change and biodiversity.

The key content of Vestas' SQHE Policy is our approach to manage environmental, health and safety matters across our organisation. It represents our commitment to proactively assess, identify and mitigate IROs in all activities, at all levels of the organization. Particularly, it outlines our approach to sustainability matters, such as continuous renewable energy deployment, resource efficiency initiatives (i.e., material, energy, waste and water), circular solutions, protection of biodiversity and ecosystems, and creating a safe workplace for employees.

The scope of the policy applies to our own operations and contractors under our operational control. The most senior level accountable for the policy is our Executive Management. For third party standards, the policy follows ISO 14001, 45001 and SBTi.

Scenario analysis and resilience

The 2024 scenario analysis identified climate change mitigation and transition risks, of which two were deemed material to Vestas: Investments in scope 1 and 2 GHG emission reductions, and Carbon taxes and tariffs. It also identified three material climate-related opportunities: Growth rate of the wind industry, Strong ESG profile, and Diversified revenue streams. While physical risks like water stress, heat stress, and extreme rainfall may impact our facilities and suppliers, they are not expected to materially affect our operations. The analysis of the future is based on significant uncertainties and assumptions, also in relation to market developments and evolving climate patterns.

With an ambition to become the global leader in sustainable energy solutions, we are well-positioned to exploit opportunities from the global transition to a sustainable economy. Where our operations are exposed to acute and chronic climate risks, that could disrupt our business activities, we have the organisational and strategic priorities in place to address them. However, aligning our own operations with ambitious climate targets and mitigating financial impacts from carbon taxes requires significant capital investments, and some necessary solutions are still immature.

Our business outlook also depends on political action; without supportive policies, our industry may struggle to meet global climate targets. Despite these risks, we have the strategic priorities in place and are making the necessary investments and mitigating actions to address them.

Policies Related to Climate Change Mitigation and Adaptation

Vestas has established comprehensive policies and commitments related to climate change mitigation and adaptation:

Climate Strategy and Commitments

Carbon Neutrality Target: Vestas has committed to achieve carbon neutrality in our own operations by 2030 – without using carbon offsets. This requires that all our offices, factories, vehicles, vessels, and other operations are fully decarbonised through our own actions.

Science-Based Targets: Our climate targets are aligned with the Science Based Targets initiative (SBTi) and Paris Agreement goals:

• Reduce scope 1 & 2 GHG emissions 55% by 2025 and 100% by 2030 (baseline year 2019)
• Reduce scope 3 GHG emissions per MWh generated 45% by 2030 (baseline year 2019)

Sustainability Strategy Foundation: Climate action is one of four strategic sustainability pillars under our mandate of 'sustainability in everything we do', alongside Circularity, Social responsibility, and Energy transition leadership.

Policy Integration

Corporate Strategy Integration: Climate change mitigation is fully integrated into our corporate strategy, with the sustainability matters relating to climate change mitigation (E1) being one of the main material topics alongside Circular economy and resource use (E5), Own workforce (S1), Affected communities (S3), and Political engagement (G1).

Value Chain Approach: We are working to decarbonise the entire wind energy supply chain by working with strategic suppliers to lower the carbon intensity of energy generated by our turbines (Scope 3 emissions).

Target Revalidation

Vestas recognizes that current projections indicate we will not deliver on the 2025 target to reduce GHG emissions by 55 percent, primarily due to our expanded scope of operations including offshore activities that were not considered when original targets were set. We plan to seek revalidation of our targets in 2025, considering our new scope of operations and complying with the SBTi five-year revalidation requirement, while staying in alignment with the Paris Agreement.

Governance

Climate-related policies are overseen by the Board of Directors and Executive Management, with quarterly assessment of progress presented to leadership. The policies apply across all products, services, geographies, and customer categories as part of our foundational ESG management system.

Actions and Resources in Relation to Climate Change Policies

Decarbonisation Initiatives

Renewable Energy Transition:

• 100% renewable electricity for own activities maintained since previous years
• 33% renewable energy overall in 2024 (including heating and transport)
• Converting benefit vehicle fleet to EV/PHEV
• Testing sustainable aviation fuel for offshore vessels and helicopters

Low-Emission Materials:

• Introduced low-emission steel towers as a new product offering in 2024
• Partnership with ArcelorMittal to enable low-emission steel supply
• Baltic Power project in Poland will be first in the world to utilize low-emission steel for V236-15.0 MW™ turbines
• Expanding range of low-emission materials offerings for 2025 and beyond

Operational Efficiency:

• Decreased Scope 1 and 2 emissions by 44% outside Offshore operations
• Total Scope 1 & 2 emissions: 105k tonnes CO2e in 2024 vs 109k tonnes in 2023
• Improved material efficiency rate to 1.0 tonnes waste per MW in 2024 vs 1.2 in 2023

Supply Chain Decarbonisation

Scope 3 Emissions Reduction:

• Scope 3 GHG emissions intensity improved to 5.66 kg CO2e/MWh generated in 2024 from 6.30 in 2023
• Working with strategic suppliers to reduce carbon intensity of turbine manufacturing
• Enhanced engagement and integration with supply chain partners

Supplier Engagement:

• Annual Vestas Supplier Forum to build relationships and align on sustainability goals
• Formal contractual agreements include sustainability requirements
• Risk mitigation frameworks account for climate-related disruptions

Technology and Innovation

R&D Investment:

• EUR 531m invested in green R&D in 2024 (vs EUR 500m in 2023)
• Continued development of scalable, reliable and sustainable energy solutions
• Focus on larger, more efficient turbines to reduce lifecycle emissions intensity

Product Development:

• V236-15.0 MW™ offshore platform for improved efficiency
• Modular designs for reduced manufacturing emissions
• Circular design principles to enable end-of-life recycling

Climate Impact Metrics

Emissions Avoided:

• Expected GHG emissions avoided over lifetime of 2024 capacity: 455 million tonnes CO2e
• Total expected annual GHG avoided by installed fleet: 239 million tonnes CO2e
• 13 GW of wind turbines delivered in 2024 contributing to global decarbonisation

Resource Allocation

Financial Resources:

• Sustainability-linked bonds issued in 2022 and 2023 were significantly oversubscribed
• Capital allocation priorities include investments supporting long-term decarbonisation goals
• EUR 1.2bn total investments expected in 2025

Organizational Resources:

• Technology & Operations organization with 13,000+ people focused on sustainable industrialization
• Sustainability team with VP level leadership and cross-functional matrix structure
• Regional and functional teams implementing climate initiatives globally

Monitoring and Reporting

Progress Tracking:

• Quarterly assessment of climate-related goals presented to Executive Management and Board
• Annual sustainability key figures subject to assurance
• Regular stakeholder reporting through integrated annual report and sustainability disclosures

Continuous Improvement:

• Regular review and updating of climate action plans
• Benchmarking against industry best practices
• Integration of stakeholder feedback into climate strategy evolution

Targets Related to Climate Change Mitigation and Adaptation

GHG Emissions Reduction Targets

Scope 1 & 2 Emissions Targets:

• 2025 Target: Reduce scope 1 & 2 emissions by 55% from 2019 baseline
• 2030 Target: Achieve 100% reduction in scope 1 & 2 emissions (carbon neutrality without offsets)
• Current Status: 105k tonnes CO2e in 2024, showing improvement from 109k tonnes in 2023

Scope 3 Emissions Targets:

• 2030 Target: Reduce scope 3 GHG emissions per MWh generated by 45% from 2019 baseline
• Current Performance: 5.66 kg CO2e/MWh generated in 2024, improved from 6.30 in 2023

Energy and Resource Efficiency Targets

Renewable Energy Usage:

• Target: 100% renewable electricity for own activities (achieved and maintained)
• Performance: 33% renewable energy overall in 2024, with 214 GWh renewable energy consumed

Material Efficiency:

• 2025 Target: Improve material efficiency rate to 1.2 tonnes waste per MW produced and shipped
• 2030 Target: Improve material efficiency rate to 0.2 tonnes waste per MW produced and shipped
• 2024 Performance: 1.0 tonnes waste per MW, showing improvement from 1.2 in 2023

Target Revalidation and Challenges

2025 Target Status: Vestas acknowledges that current projections indicate we will not deliver on the 2025 target to reduce GHG emissions by 55%. This is primarily due to:

• Expanded scope of operations including offshore activities
• Original targets set before re-entering offshore wind market
• Increased overall business activities and manufacturing capacity

Planned Actions:

• Seek revalidation of targets in 2025 considering new scope of operations
• Comply with SBTi five-year revalidation requirement
• Maintain alignment with Paris Agreement goals
• Continue adaptation of strategy and transition plan

Positive Impact Targets

Climate Impact:

• Achievement: 455 million tonnes CO2e expected to be avoided over lifetime of capacity produced and shipped in 2024
• Fleet Impact: 239 million tonnes CO2e expected annual avoided emissions from total installed fleet
• Capacity Growth: 13 GW of wind turbines delivered in 2024

Integration with Business Strategy

Financial Targets Alignment: Climate targets are integrated with long-term financial ambitions including:

• At least 10% EBIT margin before special items
• 20% ROCE over the cycle
• Market leadership in revenue growth

Technology Targets:

• Continued R&D investment (EUR 531m in 2024) to advance sustainable energy solutions
• Development of larger, more efficient turbines
• Innovation in low-emission materials and manufacturing processes

Governance and Monitoring

Oversight: Climate targets are monitored through:

• Quarterly assessment by Executive Management and Board
• Annual sustainability reporting with external assurance
• Integration into strategic planning and capital allocation

Accountability: Progress against climate targets influences:

• Strategic decision-making
• Resource allocation
• Performance evaluation
• Stakeholder communications

Energy consumption and mix

E1-5: Energy consumption and mix (2024)

Scope: Energy consumption covers Vestas' factories, construction, and service operations. All activities are linked to NACE codes C27, C28, F42, and F43, which are all considered high climate-impact sectors.

Contractual instruments: The share of contractual instruments for scope 2 is 84%, of which 94% is bundled and 6% is unbundled. These contractual instruments include purchased electricity from renewable energy suppliers, green energy certificates, guarantees of origin, and renewable energy certificates.

Renewable electricity: Since 2020, Vestas has sourced 100% renewable electricity across its own operations globally.

Energy intensity

Energy production

Note on energy production: Renewable energy production refers to the self-generation of electricity from Vestas' wind turbines, supplied to local grid and not directly used by the company.

Gross Scopes 1, 2, 3 and Total GHG emissions

Scope 1 and 2 GHG emissions

Note: Scope 1 emissions primarily driven by fossil fuels in service operations. Scope 2 emissions primarily driven by electricity and district heating. Vestas tracks performance based on market-based scope 2 emissions, purchasing renewable electricity credits to cover energy consumption.

Scope 1 and 2 emissions by region (2024):

Target: 55% reduction by 2025 and 100% reduction by 2030 (from 2019 baseline of 114,000 t CO₂e), without using carbon offsets. Validated by Science Based Targets initiative (SBTi).

Scope 2 location-based emissions

Vestas sources 100% renewable electricity across own operations globally. Location-based scope 2 emissions are not explicitly disclosed separately but are incorporated in total GHG emissions calculations (8.14m tonnes using location-based method vs 8.09m tonnes using market-based method for total emissions).

Scope 3 GHG emissions

Scope 3 emissions represent 98.8% of Vestas' total GHG emissions.

Scope 3 emissions by GHG Protocol category (2024):

Steel and iron materials account for approximately 48% of scope 3 emissions. Target covers 70% of scope 3 emissions in alignment with SBTi requirements (categories 1-7 and 12).

Target: 45% reduction in intensity (kg CO₂e/MWh) by 2030 from 2019 baseline (6.82 kg CO₂e/MWh to 3.74 kg CO₂e/MWh). Validated by SBTi.

Total GHG emissions

GHG intensity

Scope 3 intensity metric is reported as 5.66 kg CO₂e per MWh generated in 2024, down from 6.30 in 2023 (17.0% reduction from 2019 baseline of 6.82 kg CO₂e/MWh).

Expected GHG emissions avoided (entity-specific metric)

Wind turbines produced and shipped in 2024 are expected to avoid approximately 50x the GHG emitted during their production over their lifetime.

Energy consumption

Energy consumption breakdown (2024):

Energy intensity: 0.037 GWh per million EUR net revenue. All activities linked to NACE codes C27, C28, F42, and F43 (high climate-impact sectors).

Methodology notes

• GHG accounting follows the GHG Protocol and SBTi methodology.
• Scope 1 includes direct emissions from owned/controlled sources.
• Scope 2 market-based uses contractual instruments (renewable electricity credits).
• Scope 3 covers categories 1-7 and 12, representing 70% of total value chain emissions.
• Baseline year is 2019 for both scope 1+2 and scope 3 targets.
• One restatement in 2024: refurbished component utilisation methodology updated (not GHG-related).
• No significant changes to GHG accounting methodology or definitions in 2024.
• LCA calculations involve uncertainty related to turbine lifetime estimates.
• Scope 3 uses actual data where available, combined with emission factors and sector-average data where direct data is unavailable.

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

Assessment Status

ESRS E1-9 is assessed as not material by Vestas.

According to the list of disclosure requirements, the following E1-9 data points are specifically identified as not material:

• ESRS E1-9 Exposure of the benchmark portfolio to climate-related physical risks paragraph 66: Not material
• ESRS E1-9 Disaggregation of monetary amounts by acute and chronic physical risk paragraph 66 (a): Not material
• ESRS E1-9 Location of significant assets at material physical risk paragraph 66 (c): Not material
• ESRS E1-9 Breakdown of the carrying value of its real estate assets by energy-efficiency classes paragraph 67 (c): Not material
• ESRS E1-9 Degree of exposure of the portfolio to climate-related opportunities paragraph 69: Not material

Phase-in Provisions

Vestas has disclosed its approach to phase-in provisions: "Vestas has in 2024, with a few exceptions, chosen to exercise all phase-in provisions dedicated to companies with more than 750 employees. We have also chosen to omit all voluntary metrics, except those which could impact a fair review of the relevant sustainability topic."

Cross-reference

For current financial effects of Vestas' material impacts, risks, and opportunities, the company refers to SBM-3 48d on page 188 in the Financial statements.

Policies Related to Water and Marine Resources

Vestas recognizes water and marine resources as a material sustainability topic, particularly given our operations in coastal areas for offshore wind development and our global manufacturing footprint.

Water Management Policies

Resource Efficiency: Vestas is committed to responsible water management across our operations, with policies focused on:

• Efficient water use in manufacturing processes
• Water conservation measures in facilities
• Responsible withdrawal from freshwater sources
• Protection of local water resources

Operational Water Use: Our water consumption primarily relates to:

• Manufacturing processes for turbine components
• Facility cooling and heating systems
• Employee facilities and office operations
• Cleaning and maintenance activities

Marine Resource Considerations

Offshore Wind Development: As we expand our offshore wind capabilities, we consider marine resource impacts including:

• Marine ecosystem protection during construction and operation
• Sustainable installation practices
• Responsible decommissioning planning
• Collaboration with marine conservation stakeholders

Coastal Operations: Our offshore manufacturing and service facilities are designed with consideration for:

• Coastal water quality protection
• Marine habitat preservation
• Sustainable port and harbor usage
• Integration with local marine resource management

Integration with Sustainability Strategy

Circular Economy Connection: Water management connects to our circular economy goals through:

• Waste water treatment and reuse where possible
• Minimizing water-intensive processes
• Closed-loop manufacturing systems where feasible

Supply Chain Requirements: We engage with suppliers on responsible water management practices as part of our overall supply chain sustainability requirements.

Governance and Management

Oversight: Water and marine resource management is overseen as part of our comprehensive environmental management system, with regular monitoring and reporting of water consumption metrics.

Continuous Improvement: We continuously evaluate opportunities to improve water efficiency and reduce environmental impact on marine resources through operational improvements and technology upgrades.

Regulatory Compliance

Vestas maintains compliance with local water management regulations across all operational jurisdictions and works proactively with authorities on marine resource protection in offshore wind development projects.

Actions and resources related to water

Vestas has initiated actions during 2024 to address water consumption impacts. The company states that "CAPEX and OPEX invested in implementing these actions are not considered significantly material to justify disclosure."

Water management systems

Description: Released a water management procedure in 2024. A water management system will be implemented at all Vestas locations where Vestas is responsible for water management.

Scope: Own operations (all Vestas locations)

Time horizon: 2024-2025 (short-term)

Expected outcomes:

• Support sustainable water usage
• Systems to be evaluated and revised with significant changes in water consumption or wastewater generation
• Requirements detailed in the water and wastewater management procedure

Link to policy: Implements commitments from SQHE policy and HSE framework

Resources allocated: Financial resources not disclosed (stated as not significantly material)

Water leakage management

Description: Focus on water leakage management to reduce wastage and overall consumption through regular site inspections.

Scope: Own operations (manufacturing sites)

Expected outcomes:

• Reduce water wastage and overall consumption
• Continuously reduce water use, especially in water stressed areas
• Minimize impact on people and nature

Note: The company states "Because our impact is hard to quantify, and our overall water consumption is low, we do not directly remediate local populations or nature in these areas."

Awareness of water conservation

Description: SQHE policy applied at all manufacturing facilities promotes water conservation with emphasis on responsible water use, especially in water-scarce areas.

Scope: Own operations (all manufacturing facilities)

Three principles:

• Minimise irrigation through landscaping with low water requirements
• [Additional principles mentioned but not fully detailed in excerpt]

Link to policy: SQHE policy

Targets related to water

Vestas has not set water-related targets nor a base year to measure progress from. The company states it has no plan to do so, as water use is mainly for domestic purposes, and employees need access to water. However, Vestas continues to measure, monitor, and work towards reducing freshwater consumption.

Monitoring and reporting (not targets)

While not formal targets, Vestas monitors and reports on:

• Total water consumption: 73 thousand m³ in 2024
• Water consumption in areas exposed to water stress: 86.3% of total water consumption in 2024
• Water intensity ratio: 0.4 thousand m³ per mEUR revenue in 2024
• No water recycled or reused in 2024

Water consumption

Vestas' primary water consumption is for domestic purposes in connection with manufacturing. In 2024, total water consumption was 73 thousand m³.

Water consumption metrics (2024)

Water stress context

86.3 percent of total water consumption occurred in areas with high or extreme water stress. Vestas has 8 manufacturing facilities located in regions facing high or extreme immediate water stress, and 18 sites with water consumption in countries exposed to high or extreme immediate water stress.

Methodology

Water consumption: Measurements follow ESRS definitions of total water withdrawal and water not discharged back to water environment or a third party in the reporting period. Information comes from direct measurements such as meter readings or purchase bills, and supplier statements with minimal assumptions made.

Total water consumption in areas at water risk: Vestas utilises the WRI Water Risk Atlas to map sites' geolocations with areas at "Overall Water Risk" and includes those sites with High or Extremely High Overall Water Risk.

Water intensity: Total water consumption in own operations expressed in cubic meters (1,000 m³) per million EUR net revenue.

Total water withdrawals: Water withdrawals from surface water sources, ground water, rain water collected and supplied water from municipal or other water utilities.

No water was recycled or reused in 2024.

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

Overall approach

Wind farms can have a negative impact on biodiversity, but ultimately play a positive role in protecting global biodiversity and ecosystems, as replacing traditional energy sources with renewables supports GHG emissions avoidance. By utilising nature-based solutions, mitigating harm with technology and focusing on ecosystem restoration, wind farms might even have a nature-positive biodiversity impact.

Resilience of strategy and business model

Vestas has assessed and mapped its biodiversity impacts, risks, opportunities (IROs) and dependencies. The analysis is conducted in line with TNFD recommendations, using the LEAP-approach and third-party solutions, and supports understanding of the resilience of the strategy and business model to biodiversity and ecosystem-related physical, transition, and systemic risks.

Multiple risks are assessed using internationally recognised scenarios (SSP126, SSP245, SSP585, IEA NZE, IEA STEPS) and time horizons (Physical: 2030, 2050, 2070, Transition: one-five years, five-10 years, 10-30 years) for manufacturing facilities, warehouses and critical suppliers. The assumptions of the analysis are in line with the scenarios used, and include e.g. future GHG emissions in the atmosphere. Dependencies are assessed at the sector level (Electric energy production and Metals & mining). The impact and opportunity assessments are conducted with internal and external experts covering the entire value chain. Vestas has not yet engaged with local or indigenous people during the assessment.

Integration into strategy and business model

Wind power plays an important role in mitigating climate change and thereby in stemming global biodiversity loss. Through strategic focus on reducing scope 1, 2, and 3 GHG emissions and producing zero waste wind turbines, Vestas is concentrating on the areas with the biggest influence on biodiversity impact.

As the resilience analysis did not identify any material biodiversity risks, opportunities, or dependencies, and the strategic focus caters for material impact, Vestas believes its business currently is resilient to changing ecosystem conditions. However, as the company accelerates the transition to a world powered by renewable energy, it must do so in balance with local ecosystems and species.

Consideration of biodiversity and ecosystems in operations

By conducting Environmental Impact Assessments (EIAs) and ensuring optimal site locations during development, collaborating with customers and stakeholders throughout construction and operations and continuously improving product sustainability, consideration for biodiversity and ecosystems is already an integrated part of how Vestas operates.

Vestas continues to develop its approach to biodiversity with consideration of the Kunming-Montreal Global Biodiversity Framework and the EU Biodiversity Strategy for 2030.

Policies Related to Biodiversity and Ecosystems

Vestas recognizes biodiversity and ecosystems as a material sustainability topic, particularly considering the environmental impact of wind energy infrastructure on natural habitats and wildlife.

Biodiversity Protection Framework

Environmental Impact Assessment: Vestas implements comprehensive environmental impact assessments for wind energy projects, including:

• Pre-construction biodiversity surveys
• Wildlife migration pattern analysis
• Habitat impact evaluation
• Species protection measures
• Long-term monitoring protocols

Project Development Integration: Our Development business incorporates biodiversity considerations throughout the project lifecycle:

• Site selection criteria include biodiversity impact assessment
• Permitting processes address environmental protection requirements
• Grid connection planning considers ecosystem connectivity
• Community engagement includes environmental stakeholders

Marine Biodiversity Focus

Offshore Wind Considerations: As we expand offshore wind capabilities, we specifically address:

• Marine ecosystem protection during construction and operation
• Seabird and marine mammal impact mitigation
• Benthic habitat preservation
• Sustainable installation practices that minimize ecosystem disruption

Collaborative Approach: Working with marine conservation organizations, research institutions, and regulatory authorities to:

• Develop best practice guidelines for offshore installations
• Support marine biodiversity research
• Implement adaptive management strategies
• Share learnings across the industry

Supply Chain and Manufacturing

Sustainable Materials: Consideration of biodiversity impacts in material sourcing including:

• Responsible sourcing of raw materials
• Supply chain requirements for environmental protection
• Partnership with suppliers on sustainability practices
• Life cycle assessment including biodiversity considerations

Land Use Management: At manufacturing and service facilities:

• Responsible land use planning
• Native vegetation preservation where possible
• Sustainable facility design and construction
• Local ecosystem integration

Policy Integration

Regulatory Compliance: Full compliance with biodiversity protection regulations across all operational jurisdictions

Best Practice Implementation: Adoption of international best practices for biodiversity protection in renewable energy development

Stakeholder Engagement: Active engagement with environmental organizations, local communities, and regulatory bodies on biodiversity protection

Continuous Improvement

Research and Innovation: Support for research into:

• Wildlife-friendly wind energy technologies
• Ecosystem impact mitigation measures
• Biodiversity monitoring technologies
• Habitat restoration techniques

Knowledge Sharing: Participation in industry initiatives to share knowledge and best practices for biodiversity protection in renewable energy development.

Governance

Environmental Management: Biodiversity protection is integrated into Vestas' environmental management system with regular review and improvement of policies and practices.

Community Engagement: Our community engagement processes specifically address environmental concerns and biodiversity protection measures with local stakeholders.

Actions and resources related to biodiversity

Decarbonising our value chain

Description: Reducing the environmental and carbon footprint of our supply chain is our most significant contribution to biodiversity. The primary actions we are taking to reduce our scope 3 GHG emissions include working with our suppliers on setting decarbonisation targets and developing partnerships for low-emission materials such as steel.

Scope: Upstream value chain (supply chain)

Time horizon: Target to reduce scope 3 GHG emissions by 45 percent per MWh generated by 2030

Resources allocated: Refer to pages 75-76 for CAPEX and OPEX allocated to the action plan (specific amounts not provided in excerpt)

Link to targets: The target of reducing scope 3 GHG emissions by 45 percent per MWh generated by 2030 directly contributes to minimise our negative impact on biodiversity. The target is not informed by the Kunming-Montreal Global Biodiversity Framework, but indirectly supports target 8 of the frameworks. The target was not developed following specific ecological thresholds, but is in line with the 1.5°C threshold of the Paris Agreement.

Note: While decarbonisation is our most impactful measure to protect global biodiversity, we also continuously work to further minimise our impact during our development, construction, and operational activities. Similar to Vestas' decarbonization efforts, we do not use biodiversity offsets.

Location-specific impact assessment and siting

Description: We can lower our impact on local biodiversity and ecosystems through spatial planning of wind energy development zones. By conducting wind resource and biodiversity impact assessments, we can optimise locations to minimise or negate negative impacts on habitats and species.

Scope: Own operations (project development), downstream value chain (customer projects)

Key activities:

• Working with local agencies, experts, and regulation to carry out EIAs
• Developing environmental management plans
• Implementing nature-based solutions when developing new projects
• Sometimes engaging indigenous knowledge
• Mitigating or compensating for any adverse impacts of projects
• Careful siting of wind farms to avoid migratory corridors and sensitive areas, reducing risks to aerofauna
• Operational curtailment based on local bird and bat activity peaks
• Using radar systems to further reduce impacts on aerofauna

Responsibility: Unless we develop the project ourselves, our customers have the primary responsibility for undertaking EIAs and develop environmental management plans for the wind power plant. During construction, we collaborate with customers to implement measures highlighted in the environmental management plan.

Resources allocated: Not quantified

Link to policy: Actions are in line with SQHE policy and HSE framework commitment to develop projects on land and at sea according to local legislation and the recommendations of environmental impact assessments.

Targets related to biodiversity and ecosystems

Scope 3 GHG emissions reduction target (biodiversity-related)

Target metric: Scope 3 GHG emissions per MWh generated

Target value: 45 percent reduction

Target year: 2030

Baseline year and value: Not disclosed

Scope: Value chain (scope 3)

Type: Intensity-based (per MWh generated)

Validation: In line with the 1.5°C threshold of the Paris Agreement. Not developed following specific ecological thresholds. Not informed by the Kunming-Montreal Global Biodiversity Framework, but indirectly supports target 8 of the framework.

Progress to date: Not disclosed

Statement on biodiversity-specific targets

The company states: "Although we do have facilities located near biodiversity sensitive areas, we have concluded that none of them have a material negative impact on the areas. Therefore, we have no biodiversity specific metrics nor have we set a base year from which progress is measured."

The company notes: "In 2025, we plan to further develop the assessment of our biodiversity impact."

Impact metrics related to biodiversity and ecosystems change

Disclosure Statement

Although Vestas has facilities located near biodiversity-sensitive areas, the company has concluded that none of them have a material negative impact on the areas. Therefore, Vestas has no biodiversity specific metrics nor have they set a base year from which progress is measured.

Assessment of Facilities Near Protected Areas

Vestas has several facilities located near Natura 2000 or other biodiversity-sensitive areas. Through geospatial coordinates, Vestas maps the proximity of its factories to biodiversity-sensitive areas. However, none of these facilities have been assessed to:

• Lead to material deterioration or disturbance of natural habitats or the habitats of species
• Have material negative impact on the local habitat in terms of land degradation, desertification, or soil sealing
• Have negative effects on threatened species

Methodological Approach

Vestas determines the proximity of its facilities to Natura 2000 and Key Biodiversity Areas by mapping the location of sites in the respective platforms' map viewers. For all facilities located near sensitive areas, Vestas assesses:

• The characteristics of the location and surrounding environment
• The characteristics of activities and how they might harm or influence the immediate environment and the sensitive ecosystem

The assessment is conducted by internal experts with knowledge of ecosystem conditions and manufacturing activities.

Primary Biodiversity Impact

Vestas' material biodiversity impact is GHG emissions stemming from the supply chain, with 99 percent of combined negative impact on biodiversity originating from the supply chain (extraction, production, and transportation of raw materials and products). The highest emitting sub-sectors relate to:

• Ferrous metals including steel and iron
• Rubber and plastics
• Machinery and equipment
• Sea and land transportation

Additional Context

When building new factories or procuring/leasing existing ones, Vestas ensures that an environmental impact assessment is in place following local legislation and meeting standards of Directive 2011/92/EU or equivalent.

For project-level impacts, Environmental Impact Assessments (EIAs) are conducted during development to ensure optimal site locations and minimize impacts on aerofauna (birds and bats) and other species during construction and operation.

Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunities

The company has assessed biodiversity-related financial risks and opportunities as immaterial.

As stated in the double materiality assessment:

No quantified financial effects from biodiversity-related impacts, risks and opportunities are disclosed.

Policies Related to Resource Use and Circular Economy

Vestas has established comprehensive policies focused on circular economy principles and efficient resource utilization as part of our sustainability strategy pillar "Circularity - We want to produce zero-waste wind turbines by 2040."

Circular Economy Strategy

Zero-Waste Vision: Our ultimate goal is to produce zero-waste wind turbines by 2040, supported by our industry-leading Circularity Roadmap which outlines our pathway and interim targets.

Material Efficiency: We have set specific targets to improve material efficiency:

• 2025 Target: Improve material efficiency rate to 1.2 tonnes waste per MW produced and shipped
• 2030 Target: Improve material efficiency rate to 0.2 tonnes waste per MW produced and shipped (90% improvement)
• 2024 Performance: 1.0 tonnes waste per MW, showing improvement from 1.2 in 2023

Waste Management and Recycling Policies

Waste Hierarchy: Following the waste management hierarchy of reduce, reuse, recycle:

• Reduce: Minimizing waste generation through design optimization and manufacturing efficiency
• Reuse: Extending component life through refurbishment and repurposing
• Recycle: Maximizing recycling rates for materials and components

Recycling Performance:

• 68% of materials recycled in 2024 (maintained from 2023)
• 30k tonnes of waste collected for recycling in 2024
• Focus on increasing recyclability rates across product portfolio

Product Design and Innovation

Circular Design Principles: Integration of circular economy principles into product development:

• Design for disassembly and end-of-life recycling
• Material selection prioritizing recyclable and sustainable materials
• Modular design approaches for component reuse
• Life cycle assessment integration in design decisions

Blade Recycling Innovation: Advanced development of circular recycling methods for epoxy-infused blades while continuing traditional recycling routes for repowering projects

Component Life Extension

Refurbishment Programs:

• 34.5% refurbished component utilization in 2024 (vs 33.5% in 2023)
• 2030 Target: Increase refurbished component utilization to 55%
• Focus on extending useful life of components through repair and refurbishment

Repowering Services: Supporting customers in:

• Lifetime extensions of existing turbines
• Technology upgrades for improved efficiency
• Component replacement with refurbished alternatives
• End-of-life planning and material recovery

Supply Chain Integration

Supplier Requirements: Integration of circular economy principles into supply chain management:

• Supplier sustainability requirements
• Collaborative development of circular solutions
• Material traceability and lifecycle tracking
• Waste reduction initiatives across the value chain

Material Sourcing:

• Prioritizing recycled and sustainable materials where possible
• Working with suppliers on circular material flows
• Developing closed-loop material systems

Resource Efficiency Measures

Manufacturing Efficiency:

• Waste reduction in production processes
• Material optimization and yield improvement
• Energy efficiency in manufacturing operations
• Water conservation and reuse initiatives

Packaging and Transport:

• Sustainable packaging solutions
• Transport optimization to reduce material use
• Returnable and reusable packaging systems
• Logistics efficiency improvements

Governance and Implementation

Strategic Integration: Circular economy policies are integrated into:

• Corporate strategy and business planning
• Product development processes
• Supply chain management
• Customer engagement and solutions

Performance Monitoring: Regular tracking and reporting of:

• Material efficiency metrics
• Waste generation and recycling rates
• Component refurbishment utilization
• Circular economy target progress

Stakeholder Engagement

Customer Partnerships: Working with customers on:

• Circular economy solutions
• End-of-life planning for turbines
• Sustainable upgrade and repowering options
• Shared value creation through circularity

Industry Collaboration: Participation in industry initiatives to:

• Develop circular economy standards
• Share best practices
• Advance recycling technologies
• Create circular material markets

Actions and Resources Related to Resource Use and Circular Economy

Blade Recycling Innovation

Advanced Recycling Technology: In 2024, we advanced the development of a new circular recycling method for epoxy-infused blades, representing a significant breakthrough in addressing one of the wind industry's most challenging recycling problems.

Traditional Recycling Continuation: While developing new technologies, we continue to recycle blades through traditional recycling routes, particularly for repowering projects in the USA and other markets.

Research and Development: Significant investment in R&D for circular solutions as part of our EUR 531m green R&D investment in 2024.

Component Refurbishment Programs

Refurbishment Utilization: Achieved 34.5% refurbished component utilization in 2024, up from 33.5% in 2023, demonstrating progress toward our 2030 target of 55%.

Service Integration: Refurbishment programs are integrated into our Service business operations:

• Component repair and restoration
• Performance testing and certification
• Quality assurance processes
• Customer integration and acceptance

Life Extension Services: Supporting customers through:

• Lifetime extension programs for existing turbines
• Technology upgrade solutions
• Component replacement with refurbished alternatives
• Performance optimization services

Manufacturing Efficiency Improvements

Waste Reduction: Achieved material efficiency rate improvement to 1.0 tonnes waste per MW produced and shipped in 2024, down from 1.2 in 2023.

Production Optimization:

• Streamlined manufacturing processes to minimize waste
• Improved material yield and utilization
• Enhanced quality control to reduce defects and rework
• Technology & Operations organization focusing on industrial efficiency

Recycling Performance:

• 68% materials recycling rate maintained in 2024
• 30k tonnes of waste collected for recycling
• 44k tonnes total waste from operations

Circular Product Development

Design Integration: Integration of circular economy principles into product development:

• V236-15.0 MW™ offshore platform designed with end-of-life considerations
• Modular design approaches for improved component reuse
• Material selection prioritizing recyclability
• Life cycle assessment integration

Turbine Recyclability:

• Hub and blade recyclability rate: 88% in 2024 (down from 90% in 2023 due to material mix changes)
• Total turbine recyclability rate: 97% reported for first time in 2024
• Continuous improvement in recyclable design features

Repowering Market Development

Market Leadership: Vestas is positioned as a leader in the growing repowering market, particularly in the USA where significant capacity installed 15-20 years ago is reaching end of design life.

Three Repowering Options:

1. Lifetime Extension: Continue safe operation beyond design life
2. Partial Repowering: Replace select components for improved performance
3. Full Repowering: Complete replacement with modern technology

Customer Support: Comprehensive repowering services including:

• Site assessment and feasibility studies
• Technology selection and optimization
• Project management and execution
• Material recovery and recycling coordination

Supply Chain Circular Initiatives

Supplier Engagement: Working with strategic suppliers on circular economy initiatives:

• Annual Vestas Supplier Forum includes sustainability and circularity discussions
• Contractual requirements for sustainable practices
• Collaborative development of circular solutions
• Material traceability and lifecycle management

Material Innovation:

• Low-emission steel towers introduced as new product offering
• Partnership with ArcelorMittal for sustainable steel supply
• Expansion of sustainable material options planned for 2025

Resource Allocation

Financial Investment:

• Circular economy initiatives integrated into EUR 531m green R&D investment
• Capital allocation for recycling technology development
• Investment in refurbishment capabilities and facilities

Organizational Resources:

• Dedicated teams working on circular economy solutions
• Cross-functional collaboration on circular design
• Integration with Technology & Operations organization
• Service business capabilities supporting circularity

Performance Monitoring

Metrics Tracking: Regular monitoring of:

• Material efficiency rates
• Waste generation and recycling performance
• Refurbished component utilization
• Product recyclability rates

Continuous Improvement:

• Regular assessment of circular economy initiatives
• Integration of learnings into business processes
• Stakeholder feedback integration
• Best practice sharing across operations

Customer and Market Engagement

Customer Solutions: Providing customers with circular economy options:

• Repowering and lifetime extension services
• Sustainable upgrade pathways
• End-of-life planning and material recovery
• Performance optimization through circular approaches

Market Development: Active participation in developing circular economy markets:

• Industry collaboration on standards and best practices
• Policy engagement on circular economy regulations
• Knowledge sharing and thought leadership
• Market education on circular economy benefits

Targets Related to Resource Use and Circular Economy

Material Efficiency Targets

2025 Target: Improve material efficiency rate to 1.2 tonnes of waste per MW produced and shipped

• Current Performance: 1.0 tonnes per MW in 2024
• Status: Target achieved ahead of schedule, showing 17% improvement from 2023 baseline of 1.2

2030 Target: Improve material efficiency rate to 0.2 tonnes of waste per MW produced and shipped

• Improvement Required: 90% improvement from current baseline
• Progress: On track with significant improvement already achieved

Long-term Circular Economy Vision

2040 Target: Produce zero-waste wind turbines

• Strategic Framework: Industry-leading Circularity Roadmap outlines pathway and interim targets
• Integration: Aligned with overall sustainability strategy pillar of "Circularity"

Component Refurbishment Targets

2030 Target: Increase refurbished component utilization to 55%

• 2024 Performance: 34.5% refurbished component utilization
• 2023 Baseline: 33.5%
• Progress: Positive year-over-year improvement toward target

Product Recyclability Targets

Turbine Recyclability: Maintain and improve high recyclability rates

• 2024 Performance: 97% total turbine recyclability rate
• Hub and Blade Performance: 88% recyclability rate in 2024
• Continuous Improvement: Ongoing design optimization for recyclability

Waste Management Targets

Recycling Rate: Maintain high materials recycling performance

• 2024 Performance: 68% of materials recycled
• Volume: 30k tonnes of waste collected for recycling out of 44k tonnes total
• Target: Continue improvement in recycling rates and waste reduction

Innovation and Development Targets

Blade Recycling Technology: Develop and commercialize circular recycling methods for epoxy-infused blades

• 2024 Progress: Advanced development of new circular recycling method
• Implementation: Continue traditional recycling while scaling new technologies

Circular Design Integration: Embed circular economy principles in all new product development

• Modular Design: Develop products for easier disassembly and component reuse
• Material Selection: Prioritize recyclable and sustainable materials
• Life Cycle Assessment: Integrate circular considerations in design decisions

Business Integration Targets

Repowering Market Leadership: Maintain leadership position in growing repowering market

• Service Integration: Leverage 155 GW under service for repowering opportunities
• Technology Solutions: Offer comprehensive repowering options (lifetime extension, partial, full)
• Market Development: Support market growth through education and best practices

Supply Chain Circularity: Integrate circular economy requirements across supply chain

• Supplier Engagement: Work with strategic suppliers on circular initiatives
• Material Traceability: Develop systems for lifecycle material tracking
• Collaborative Innovation: Partner with suppliers on circular solutions

Performance Measurement

Quarterly Monitoring: Progress against circular economy targets included in quarterly sustainability assessments to Executive Management and Board

Annual Reporting: Comprehensive reporting on circular economy metrics and target progress

Stakeholder Communication: Regular updates to stakeholders on circular economy achievements and challenges

Target Integration

Strategic Alignment: Circular economy targets integrated with:

• Overall sustainability strategy
• Business area strategies (Onshore, Offshore, Service, Development)
• Financial performance targets
• Customer value proposition

Risk Management: Targets support risk mitigation related to:

• Resource availability and costs
• Regulatory requirements
• Customer sustainability expectations
• End-of-life product responsibilities

Success Metrics

Quantitative Measures:

• Material efficiency rate (tonnes waste per MW)
• Refurbished component utilization percentage
• Product recyclability rates
• Waste recycling percentages

Qualitative Measures:

• Customer satisfaction with circular solutions
• Industry recognition and benchmarking
• Innovation pipeline development
• Stakeholder engagement effectiveness

E5-4 Resource Inflows

Vestas uses ISO-compliant Life Cycle Assessments (LCAs) to evaluate the environmental performance of wind turbines from raw material extraction to end-of-life. The assessments cover the entire plant until grid connection, including the turbine, foundation, site cabling, and transformer station, using Sphera LCA for Experts software.

These detailed studies account for approximately 25,000 parts, typically covering over 99.5 percent of the turbine mass and 99.9 percent of the complete wind plant. Each component's material type, weight, and manufacturing processes are described. The LCA models form the basis for Vestas' global Resource inflow mass balance. Double counting is avoided as reused and recycled inflows are considered separately. The LCA reports account partially for packaging in the bills-of-materials of the product. Based on our estimated data, packaging accounts for below 1 percent of material flows in total, being relatively negligible.

Wind turbines are typically composed of 85-90 percent steel, iron, and metals, 10-15 percent composites and polymers, and the rest electronics, lubricants, and fluids. Recycled content is accounted for using industry datasets, such as Worldsteel or Eurofer.

Resource Inflows Metrics (2024)

The scope of Resource inflows includes materials in Vestas' wind turbines produced and shipped and components for service operations for the reporting period. The metric excludes property, plant and equipment, which are deemed negligible.

The data for resource inflows is sourced from Vestas LCAs and the corresponding bill-of-materials, supplier certification scheme information and global Service transaction data.

In 2024, Vestas used an estimated 430 thousand tonnes of secondary raw materials in its turbines. This figure is based on estimations from standard database data and is not Vestas supplier-specific.

Critical raw materials, including rare earth elements, are detailed in the 'Social information' section of the Sustainability statement under 'S2 Workers in the value chain'. These materials are also modelled in the LCA and managed by Global Procurement through cross-functional activities.

Resource outflows

Recyclability of products

Recyclability rate of hub and blade: 41% (2024)

• 2023: 42%
• 2022: 42%
• 2021: 90%
• 2020: 88%

Recyclability rate of total turbine: Not disclosed for 2024 (97% reported for 2020, then discontinued)

Product durability and lifetime

Expected lifetime of wind turbines: 25-30 years (standard design life)

The expected annual GHG avoided by the total aggregated installed fleet at the end of 2024: 186 million tonnes CO₂e. The turbines produced and shipped during 2024 are expected to avoid 455 million tonnes of GHG emissions over their lifetime.

Circular design initiatives

Vestas is developing circular blade solutions. In 2024, the company advanced development of a new circular recycling method for epoxy-infused blades in collaboration with Aarhus University, Danish Technological Institute and Olin. This solution allows for the separation and recovery of raw materials in epoxy-infused blades.

The blade circularity solution was developed to an industrially relevant scale in close collaboration with recycling partner Stena Recycling during 2024.

Material efficiency

Material efficiency rate: 2.5 tonnes of waste (excluding recycled) per MW produced and shipped (2024)

• 2023: 2.0
• 2022: 1.6
• 2021: 1.2
• 2020: 1.0

Vestas has a target to improve material efficiency rate to 0.2 tonnes of waste per MW produced and shipped by 2030.

Repowering and lifetime extensions

Vestas offers repowering solutions that extend the productive life of wind farms. The company has a dedicated focus on the growing repowering market, allowing customers to replace aging turbines with more efficient modern technology.

Waste

Total waste generation

Volume of waste from own operations: 89,000 tonnes (2024)

• 2023: 70,000 tonnes
• 2022: 47,000 tonnes
• 2021: 44,000 tonnes
• 2020: 44,000 tonnes

Waste collected for recycling: 46,000 tonnes (2024)

• 2023: 35,000 tonnes
• 2022: 26,000 tonnes
• 2021: 30,000 tonnes
• 2020: 30,000 tonnes

Waste management approach

Vestas focuses on reducing waste from own manufacturing and key suppliers, repairing and refurbishing components to extend their useful life, and ensuring that waste generated is managed responsibly.

The company's Circularity Roadmap guides efforts towards a fully circular value chain that avoids waste, reuses materials and creates a circular economy for turbine components and materials.

Circular economy targets

Vestas has set a target to produce zero-waste wind turbines by 2040. The company aims to improve its material efficiency rate to 0.2 tonnes of waste per MW produced and shipped by 2030 (from 2.5 in 2024).

The company also targets to increase the rate of refurbished component utilisation to 55% by 2030.

Non-recyclable materials impact

Non-recyclable materials in turbines have a negative impact on the environment (identified as a material impact in the double materiality assessment). Design with greater proportion of recyclable materials, such as the blade circularity solution, is identified as a financial opportunity.

Anticipated financial effects from resource use and circular economy-related impacts, risks and opportunities

Financial opportunities and risks identified

The double materiality assessment identifies the following circular economy-related financial effects:

Recyclable materials (Downstream opportunity)

• Design with greater proportion of recyclable materials, e.g. the blade circularity solution, is a financial opportunity.
• Non-recyclable materials in turbines create actual negative environmental impact downstream.

Resource inflows-related financial risks and opportunities

• Assessed as immaterial (N/A value chain).
• Extraction of base metals and rare-earth metals for turbines has actual negative environmental impact upstream.

Waste-related financial risks and opportunities

• Assessed as immaterial (N/A value chain).
• Waste generation in own operations has actual negative environmental impact.

Circularity targets with financial implications

In October 2021, Vestas launched the Circularity Roadmap, a comprehensive set of commitments to reach zero-waste turbines by 2040, setting targets in three main areas: Design for circularity, Operational circularity and Material recovery.

Design for circularity:

• Material efficiency target: Increase material efficiency by 90 percent by 2030, to 0.2 tonnes of waste per MW produced and shipped, compared to baseline of 2.0 tonnes per MW in 2021.
• 2024 performance: 1.0 tonnes of non-recycled waste per MW produced and shipped (2023: 1.2 tonnes), representing a 17 percent decrease.
• Blade rotor recyclability target: 100 percent recyclable rotor by 2030.
• 2024 performance: 88 percent recyclability rate (2023: 90 percent).

Operational circularity:

• Refurbish 55 percent of turbine components by 2030 and 75 percent by 2040.
• 2024 performance: 34.5 percent refurbished component utilisation rate (2023: 33.5 percent).

Material recovery:

• Recycling rate of at least 94 percent by 2030, and zero-waste by 2040.
• 2024 performance: 88.6 percent of waste was non-hazardous and 11.4 percent hazardous. Landfilled 11.4 percent, incinerated 2.3 percent, incinerated with energy recovery 18.2 percent, reused 0 percent, and recycled 68.2 percent.

EU Taxonomy alignment and financial scale

Vestas' circular economy activities are substantially aligned with EU Taxonomy:

Non-aligned activities:

• 1 percent of revenue is non-eligible, related to 'over the counter' sale of spare parts.
• 1 percent of CAPEX is non-eligible, related to 'over the counter' sale of spare parts and supporting administrative functions.
• 8 percent of OPEX is non-eligible, related to 'over the counter' sale of spare parts and supporting administrative functions.

Product lifetime and durability

• Average lifetime of turbines: 24.63 years (based on 2024 sales documentation), compared to industry average of approximately 20-25 years.
• Average lifetime is determined according to project-specific sales documentation indicating wind turbine lifetime for specific wind power projects in the reporting year.

Quantified financial effects

No specific quantified financial effects (e.g., amounts in EUR/currency, expected cost savings, revenue impacts) are disclosed for circular economy-related impacts, risks and opportunities beyond the Taxonomy alignment percentages.

Characteristics of the undertaking's employees

Total headcount and FTE

Gender distribution of Executive Management team

Age distribution of Executive Management team

Board of Directors composition

Women in leadership

Employment contracts and types

Vestas reports that 97.3% of the workforce held a standard employment contract in 2024 (2023: 97.7%). Temporary employees are brought on primarily for project-based roles with specific end dates or to cover absences such as parental leave.

Employee turnover

Geographic/Regional split

Vestas operates globally with a presence in 88+ countries. The company reports operations across regions including Europe (EMEA), Americas, and Asia Pacific (APAC), though detailed headcount breakdowns by region are not provided in the S1-6 disclosure.

Registered shareholders (stakeholder engagement metric)

Note: This represents an increase of approximately 30,000 shareholders during the year.

Methodology notes

The workforce figures cover employees with Vestas employment contracts (FTEs). The scope includes own employees but excludes contractors and subcontractors unless specifically noted. Top management definition for gender diversity is detailed in Accounting policies on page 110 (not extracted).

Health and safety metrics

Coverage

100% of Vestas' own workforce is covered by the Health and Safety Management System, which is based on legal requirements and recognised ISO 45001 standards and certified by third-party auditors.

Health and safety performance metrics

Multi-year trends (from sustainability highlights and key figures)

Scope and definitions

Vestas' 'Own workforce' is defined as own employees plus other workers (contractors and sub-contractors) working under Vestas' supervision and control. The TRIR includes restricted work injuries and medical treatment injuries in addition to Lost Time Injuries (LTIs).

Work-related injuries are based on incidents reported in Vestas' Incident Management System (IMS). Fatal injuries include deaths occurring after the incident if they are a direct result of the incident.

In 2024, five fatalities occurred in total: two involved Vestas' own workforce (under operational control), and three involved contractors not under Vestas' operational control.

Days lost

Number of days lost to work-related injuries is not disclosed in the S1-14 metrics section.

Compensation metrics

Pay gap

Vestas reports a gender pay gap of 2.2% for 2024.

Remuneration ratio

Vestas discloses an annual total remuneration ratio of 96.4 for 2024, representing the ratio of the highest paid individual to the median annual total remuneration for all employees, excluding the highest paid individual.

Methodology

Gender pay gap: The gender pay gap is the difference of average pay levels between female and male employees, expressed as percentage of the average pay level of male employees. The number includes the salary, cash allowances (variable payments), benefits, insurances, bonus, and long-term incentives. The calculated figure depends on factors such as health insurance costs, employee benefits, the nature of work, and regional differences. As a global company, these variables vary significantly across countries, influencing the final value.

Annual total remuneration ratio: The annual total remuneration ratio of the highest paid individual to the median annual total remuneration for all employees, excluding the highest paid individual. Pay data is collected quarterly from local payrolls in Vestas and compiled into one validated report. The pay data includes base salary, cash allowances (variable payments), pension, benefits, and other fixed recurring payments.

Adequate wages

Vestas does not disclose a living wage benchmark or assessment against ESRS S1-10 requirements.

Benchmark used

No living wage benchmark is disclosed. The company references:

• "Fair wages" as a foundational element of business practices
• Monitoring "updates to legislation and labour market requirements to ensure we are compliant through company policies applied globally and locally"
• Compensation decisions based on "the candidate's qualifications and experience, internal pay equity, and any local specific legal requirements"

Coverage and scope

No coverage percentage or assessment scope is disclosed for adequate/living wage evaluation.

Methodology

No methodology is disclosed for living wage calculation or assessment. The company mentions:

• "Training and education for relevant P&C employees and fair pay guidelines included into relevant P&C processes and guidelines"
• A global bonus programme that "encompasses all Vestas employees, as well as some non-employees in certain locations in accordance with the relevant legal and contractual obligations"
• Offering "various components including healthcare benefits, retirement and pension plans, paid leave, income protection, workplace safety, physical well-being, as well as training and development aligned to local market standards and practices"

Targets

No targets or commitments relating to adequate wages or living wage coverage are disclosed.

Policies related to own workforce

Vestas has established several policies governing its own workforce, addressing working conditions, health and safety, equal treatment and opportunities, and other work-related rights.

Safety, Quality, Health, and Environmental (SQHE) Policy

Scope: All Vestas entities, employees, activities, products and services globally, and includes expectations for external parties.

Governance:

• Approved by the Executive Management
• Most senior level accountable: Group President & CEO
• Leaders are responsible for implementing the HSE Policy
• Reports on injury rate performance shared with the Board quarterly and Executive Management monthly
• Reviewed annually and aligned with ESRS and Vestas' HSE framework in 2024

Key content/principles:

• Based on principles of ISO 45001
• Outlines procedures for identifying, mitigating, and reporting health and safety related negative impacts and risks for own workforce
• Commitment to set, measure, monitor, and review health and safety targets
• Safety First principle

Public availability: Not specified in the excerpts

International standards: Based on ISO 45001 principles

Monitoring:

• Quarterly reporting to Board on injury rate performance
• Monthly reporting to Executive Management
• HSE management system based on ISO 45001
• Annual policy review

Human Rights Policy

Scope: All employees globally, covering all members of the workforce. Applies to own operations and business partners across the whole value chain.

Governance:

• Introduced in 2010, revisited in 2015 and 2019, updated in 2024
• Signed by the Board Chair
• Executive Management holds the highest level of accountability for implementation

Key content/principles:

• Commitment to respect human rights, including labour rights
• Addresses working conditions and equal treatment and opportunities for all
• Includes respecting labour rights and engaging with own workforce
• Applies international best practice standards where local laws set lower standards
• Covers freedom of expression, peaceful assembly and protest
• Zero tolerance of modern slavery, child and forced labour or human trafficking
• Outlines how employees are expected to prevent discrimination and harassment
• Promotes equal opportunities and treatment

Public availability: Available at corporate website

International standards:

• UN Guiding Principles on Business and Human Rights
• Universal Declaration of Human Rights
• ILO Declaration of Fundamental Principles and Rights at Work
• UN Declaration on the Rights of Indigenous Peoples (UNDRIP)
• ILO Convention No. 169 on Indigenous and Tribal Peoples

Monitoring:

• Through due diligence framework in value chain
• Corporate-Wide Human Rights Assessment conducted every three years
• Grievance mechanisms including EthicsLine

Employee Code of Conduct

Scope: Binding for all employees with a Vestas employment contract globally. Includes groups at particular risk of vulnerability related to gender, ethnicity, age, and seniority.

Governance:

• CEO is most senior level accountable for implementation
• Drafted in consultation with external and internal stakeholders representing different regions and functions
• Managers responsible for ensuring the Code is followed

Key content/principles:

• Sets behavioural expectations for members of workforce
• Ensures safe and ethical workplace
• Respects human rights of all stakeholders
• Creates workplace free from discrimination
• Respects labour rights
• Governs approach to working conditions, health and safety, equal opportunities
• Zero tolerance approach to workplace harassment, violence, bullying, and disrespectful behaviour
• Commitment to providing safe and secure workplace with training and information needed

Public availability: Available to all employees via intranet

International standards:

• UN Guiding Principles on Business and Human Rights
• Universal Declaration of Human Rights
• ILO Declaration of Fundamental Principles and Rights at Work
• UN Global Compact principles
• International labour standards (Freedom of Association and Protection of the Right to Organise Convention C.87; Right to Organise and Collective Bargaining Convention C.98)

Monitoring:

• Through whistleblower platform EthicsLine
• Mandatory familiarisation and signing when joining Vestas
• Regular training sessions and awareness campaigns
• Breaches mitigated and acted upon once detected

Diversity, Equity, Inclusion & Belonging (DEIB) Policy

Scope: All employees globally, including groups at particular risk of vulnerability related to gender, ethnicity, age, and seniority.

Governance:

• Global Head of Talent Management (part of top management team) accountable for implementation and effectiveness, with support from Head of DEIB
• Nomination and Compensation Committee reviews DEIB status and strategy annually
• Board discusses overarching diversity principles
• Global DEIB Team meets monthly
• Executive Management receives periodic diversity reporting

Key content/principles:

• DEIB mission statement
• Commitment to equal opportunities and fair treatment regardless of background
• Prioritises diversity, equitable opportunities, inclusive culture, inclusive leadership, and respectful, discrimination-free workplace
• Focuses on people from groups at particular risk of vulnerability
• Details DEIB initiatives
• Principles: contextualised, evidence-based, preceded by awareness-raising, embedded in core people processes

Public availability: Available at corporate website and communicated through various channels (intranet, internal communication, training sessions, P&C function)

International standards: Not explicitly specified

Monitoring:

• Monitoring and improving female representation in leadership
• Periodic diversity reporting to Executive Management
• Monthly Global DEIB Team meetings
• Annual review by Nomination and Compensation Committee
• Input from regional DEIB networks, employees, customers, and community partners

Learning and Development Policy

Scope: All employees, all functions, and all units at Vestas globally.

Governance:

• Global Head of Talent Management (who oversees Global Talent Management Function) accountable for implementation and effectiveness, with support from Head of Global Learning & Development

Key content/principles:

• Intent to empower business performance by driving inclusive working culture
• Allows all employees to grow and develop skills
• Clarifies roles and responsibilities related to L&D
• Outlines expectations for people managers, employees, and all L&D functions
• Commitment to providing training and information needed to manage tasks safely

Public availability: Available on Vestas intranet and communicated through various channels (intranet, internal communication, training sessions, P&C function)

International standards: Not explicitly specified

Monitoring: Not explicitly detailed in excerpts

Contractors' HSE Terms and Conditions

Scope: All workers performing work on behalf of Vestas. Covers contractors in own operations within transport, construction and service for both offshore and onshore. Includes sub-contractors.

Governance:

• Functional heads are the most senior level responsible
• Implemented 1 September 2024
• Will effectively replace Global Minimum Requirements document on 1 September 2025

Key content/principles:

• Objective of raising expectations for contractor health and safety standards
• Advancement of health and safety maturity of contractors
• Step-wise approach to facilitating collaboration with business partners
• New consequence management approach designed to be just and fair
• Handles infractions to ensure requirements are met effectively

Public availability: Not specified

International standards:

• Aligned with ILO standards
• Aligned with European Bank for Reconstruction and Development (EBRD) standards

Monitoring:

• Post service evaluation conducted by Vestas project management
• Scores form basis for future engagement
• Action plans developed where scores are lower than expected

Global Minimum Requirements for Contractors

Scope: All workers performing work on behalf of Vestas, including contractors and sub-contractors.

Governance:

• Functional heads are most senior level responsible
• Integrated part includes Disciplinary Policy with three-step warning process for infractions

Key content/principles:

• All-encompassing framework for managing health and safety
• Objective to manage and coordinate jobsite safety with contractors and sub-contractors
• Establishes principles and procedures to follow same health and safety standards as Vestas globally
• Includes responsibilities and minimum requirements for practices and procedures

Public availability: Not specified

International standards:

• Aligned with ILO standards
• Aligned with European Bank for Reconstruction and Development (EBRD) standards

Monitoring:

• Three-step warning process for infractions
• Actions taken if contractor does not comply

Taking action on material impacts on own workforce

Safest Place to Work - Health and Safety Actions

Scope: Own operations (applies to all Vestas entities, employees, activities, products and services globally)

Time Horizon: Ongoing (short, medium and long-term financial benefits recognized)

Actions are dedicated to building a strong HSE system, creating safety awareness, reporting, and analysing root causes to prevent incidents. These actions are already in place, of ongoing nature, and serve to prevent fatalities and health and safety incidents of our employees. In addition, Vestas enables remedy to its materially affected members of its workforce in line with local regulation.

Awareness Raising

• Safety training: Mandatory part of the onboarding process for all employees
• Periodic safety campaigns: Launched so employees feel more secure in seeking advice and raising concerns
• Five safety principles and eight LIFE saving rules: Established with the aim of saving lives and preventing serious injuries
• 'Walk and Talk' programme: Long-standing programme where leadership engages one-on-one to reinforce good safety behaviours and how to prevent risks

HSE Management System

• Continue to evolve and improve HSE management system covering all sites and all workers in value chain
• Rooted in risk-based approach designed to build capacity within operations to manage and adapt to potential safety risks
• Based on principles of ISO 45001
• Emphasizing critical control checks and strong assurance process

Expected Outcomes:

• TRIR (Total Recordable Injury Rate) reduction targets:
  • 2025 target: 2.4 (updated from 1.5)
  • 2030 target: below 1 (updated from 0.6)
• Monthly reviews and dashboards for tracking injuries
• Quarterly performance reports

Links to Policy: Safety, Quality, Health, and Environmental (SQHE) Policy and HSE framework based on ISO 45001

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Workforce Planning

Scope: Own operations

Time Horizon: Implemented during 2024; extending to white-collar employees during 2025

Description: Implemented a workforce planning process during 2024. The process currently covers all blue-collar employees in the functions Service and Manufacturing, with the aim of extending it to white-collar employees during 2025 to cover the entire workforce.

Expected Outcomes:

• Transparency into resourcing, cost and planning
• Strategic monitoring of workforce forecasts
• Plan according to business needs
• Support a secure workforce

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Reward Structures

Scope: Own operations, all recruitment and retention activities, all employees

Time Horizon: Ongoing

Description: Vestas provides salary structures and guidance on compensation offers to ensure a consistent and objective approach to setting salaries both at hire and change of positions. Decision on individual's pay is guided by:

• External market benchmark
• Candidate's qualifications and experience
• Internal pay equity
• Local specific legal requirements

Actions:

• Constantly monitors updates to legislation and labour market requirements
• Training and education for relevant P&C employees
• Fair pay guidelines included into relevant P&C processes and guidelines
• Global bonus programme encompasses all Vestas employees, as well as some non-employees in certain locations
• Programme rewards individuals based on annual company performance using bonus scorecards

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Reducing Turnover and Managing Employee Exits

Scope: Own operations, all internal recruitment activities

Time Horizon: Ongoing

Description: Support employees to build long and successful careers within Vestas and offer ongoing opportunities for continued growth and development at all levels. This action covers all internal recruitment activities.

Actions:

• Resourcing tool which enables all employees to apply for new roles within Vestas
• Smooth offboarding process for departing employees (retirement, resignation, or other reasons)
• Exit survey to collect feedback from departing employees to learn from every departure and improve work environment

Expected Outcomes:

• Employee turnover monitoring (see S1-6)
• Feedback from annual Employee Engagement Survey
• Exit interview insights

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Diversity, Equity, Inclusion & Belonging (DEIB) Actions

Scope: Own operations across all Vestas operations

Time Horizon: Ongoing

Resources: Supported by a dedicated budget for diversity and inclusion-related training, awareness raising sessions, and region-specific initiatives

Inclusive Recruitment

• Ongoing measures:
  • Tools to ensure job applications use gender and identity-neutral language
  • Mandatory psychometric assessments for all leadership roles
  • Include DEIB statement in job advertisements
• Employer Branding and Acquisition teams have diversity-focused KPIs to motivate exploration of innovative ways of attracting diverse talent

Championing Diverse and Inclusive Leadership

• Inclusive Leadership Programme (ongoing since 2022):
  • Comprises trainings focused on embedding inclusivity into daily interactions and decision-making
  • Promotes speak-up culture that safeguards physical and psychological safety
  • In 2024, partnered with external vendor and made training available to all employees
  • By end of 2024: 66% of employees in corporate leadership positions completed Foundations of Inclusive Leadership (2023: 50%)
  • 18% completed Inclusive Interactions (second module introduced in 2024)
  • Mandatory for leadership positions (managers, specialists, project managers and above)
• Quarterly monitoring of gender ratio of selected candidates
• Track female representation in leadership positions

Expected Outcomes:

• 25% female leadership by 2025 (achieved in 2024)
• 30% female leadership by 2030

Links to Policy: Diversity, Equity, Inclusion & Belonging Policy (DEIB Policy)

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Training and Skills Development Actions

Scope: Own operations (all employees except temporary staff)

Time Horizon: Ongoing

Continuous Performance and Development (CPD) Framework

• Applies to all employees except temporary staff
• Provides ongoing individualised development plans featuring clear, annual performance objectives (individual, team-shared, or manager-cascaded)
• All employees develop performance objectives together with their leader within first three months of tenure
• Year-end performance & potential assessment capturing ongoing and development-oriented inputs from key stakeholders
• In 2024, 100% of employees completed their year-end performance assessment (2023: 98%)

Talent Development Programmes

• Aim: Fill 65% of positions with internal employees (see S1-5)
• Programmes support development of internal talent
• CPD process forms integral part of building succession pipeline by identifying employees with potential for advancement

Programmes include:

1. Vestas Graduate Programme:

   • Two-year international programme
   • Aimed at attracting and developing talented young professionals who aspire to hold future key positions
   • 2024 cohort: 56% women, 44% men

2. Regional Talent Programme:

   • 10-month programme
   • Serves mid-and short-term business needs of regional business units
   • 2024: 48% women

3. Rising Executives Programme:

   • 10-month programme
   • Focuses on developing global leaders with executive potential
   • 2024: 24% women

Training for Existing Employees

• All employees can access range of Learning & Development (L&D) opportunities
• Enables development of core skills and competences at own pace
• Opportunities either targeted to specific roles, leadership levels, or functions, or generic to all employees across Vestas
• Various formats: classrooms and virtual courses, webinars, gamified and non-gamified e-learnings, e-books and podcasts
• Accessible through The Vestas Academy
• In 2024, average of 111 training hours per employee

Performance Monitoring:

• Leadership Team receives quarterly dashboard with development-related KPIs including:
  • Vestas' internal fill rate
  • Succession pipeline metrics
  • Insights from Employee Engagement Survey

Links to Policy: Learning and Development Policy, Code of Conduct

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Effectiveness Assessment

Health and Safety:

• Monthly reviews and dashboards for tracking injuries
• Quarterly performance reports
• Reports on injury rate performance shared with Board quarterly and Executive Management monthly

Working Conditions - Secure Employment:

• Monitored through employee turnover, engagement, and satisfaction indicators
• Reported to key internal stakeholders as part of quarterly functional dashboards
• Key contextual information including market trends provided
• Workforce engaged in identifying lessons for improvement as part of Employee Engagement Survey process

DEIB:

• Network of Employee Resource Groups (ERGs) and Regional DEIB Networks support employee engagement
• Quantitative metrics: percentage of women in leadership positions
• Qualitative feedback from employee engagement surveys
• Regular reporting to Executive Management Team

Training and Skills Development:

• Tracked and assessed by P&C leadership team and relevant functional teams
• Leadership Team receives quarterly dashboard with development-related KPIs

Targets related to own workforce

Health and Safety Target (TRIR)

Target metric: Total Recordable Injury Rate (TRIR)

Target values and years:

• 2025 target: 2.4 (updated from previous target of 1.5)
• 2030 target: below 1 (updated from previous target of 0.6)

Baseline: Not disclosed

Type: Absolute

Scope: Vestas employees and contractors working under operational control, globally

Validation: Internal

Target update rationale: The targets were updated to reflect a shift in Vestas' risk profile, the inclusion of growing offshore activities as well as an overall increase in work activities across various areas. The aim is to implement more realistic short-term ambitions across different regions and functions which can lead to more consistency and focus.

Effective date: The new targets are valid as of 1 January 2025

Monitoring: Monthly reviews and dashboards for tracking injuries, along with quarterly performance reports in the interim reports

Note: TRIR includes 'restricted work injuries' and 'medical treatment injuries' in addition to Lost Time Injuries (LTIs)

Diversity Target - Female Leadership

Target metric: Women in leadership positions (percentage)

Target values and years:

• 2025 target: 25% female leadership
• 2030 target: 30% female leadership

Baseline: Not disclosed

Type: Not specified (appears to be absolute percentage)

Scope: Corporate leadership positions (roles with job titles of managers, specialists, project managers and above), globally

Validation: Internal

Progress to date:

• 2023: 24% women in corporate leadership
• 2024: 25% women in corporate leadership (2025 target achieved)

Monitoring: Integrated into broader strategic KPI reviews, with regular progress reviewed by the Executive Management team on a quarterly basis

Note: Vestas-American Wind Technology, Inc. ("VAWT"), Vestas-Canadian Wind Technology, Inc. ("VCWT"), and all other Vestas subsidiaries in North America (collectively, "VAME") are committed to abiding by all state, federal, and provincial laws, including Title VII of the Civil Rights Act of 1964. The aspirational goal of increasing the number of women in leadership positions will not be a factor considered in hiring decisions.

Training and Development Target - Internal Fill Rate

Target metric: Internal fill rate (percentage of positions filled with internal talent)

Target value: 65%

Target year: Ongoing target (no specific end year)

Baseline: Not disclosed

Type: Not specified

Scope: Corporate leadership positions across Vestas, globally

Validation: Internal

Progress to date:

• 2024: 69% of corporate leadership positions were filled with internal talent

Monitoring: Quarterly P&C dashboard reviewed by P&C leadership team

Secure Employment

Targets: Vestas has not identified measurable targets relating to secure employment, and has not set a base year from which progress is measured.

Monitoring instead: Vestas tracks the effectiveness of policies and actions to support secure employment by monitoring employee turnover, engagement, and satisfaction. These indicators are reported to key internal stakeholders as part of quarterly functional dashboards.

Training and skills development metrics

Training hours

Overall training provision:

• Almost 4 million hours of training provided globally in 2024
• Average training hours per employee: 111 hours (2024)

Performance and career development reviews

Scope: All employees covered by the Continuous Performance and Development (CPD) framework are included. This applies to all employees except temporary staff. Performance objectives are developed within the first three months of tenure, and year-end performance and potential assessments are completed annually.

2024 completion rate: 100% of employees with standard employment contracts completed their year-end performance assessment (2023: 98%), with exceptions being extended leave or long-term illness.

Breakdown by demographic categories

No breakdown of average training hours by gender (male/female) or employee category (executive/management/non-management) was disclosed.

Training investment

Total financial investment in training (€) was not disclosed.

Supporting infrastructure

Vestas Academy Portal: Launched in 2024, the portal attracted 60,000 visitors in its first year.

Talent development programmes:

• Regional Talent Programme (10-month duration)
• Rising Executives Programme (10-month duration, for executives with global potential)
• Graduate Programme (2-year international programme)
• Frontline Leadership Programme (piloted in 2024 for Manufacturing, Service, and Construction, planned global rollout in 2025 impacting over 20,000 colleagues)

Programme diversity (2024 cohorts):

• Graduate Programme: 56% women, 44% men
• Regional Talent Programme: 48% women
• Rising Executives Programme: 24% women

Incidents, complaints and severe human rights impacts

Summary of complaints and incidents (2024)

In 2024, Vestas received 78 substantiated complaints related to social and human rights from our own workforce, of which 147 were received through our whistleblower platform EthicsLine, and 0 via the National Contact Points for OECD Multinational Enterprises. EUR 0m in fines, penalties and compensation were paid in 2024 as a result of these incidents and complaints.

The number of severe human rights incidents reported in 2024 was 0. Severe human rights incidents are defined as confirmed cases of modern slavery, human trafficking or child labour. Based on information from EthicsLine, legal disputes, and media allegations in the Business & Human Rights Resource Centre, we have found no cases of the aforementioned issues in our own workforce in 2024. Therefore, no fines, penalties or compensation were paid.

As a result, no cases of non-respect to the UN Guiding Principles on Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work or OECD Guidelines for Multinational Enterprises were reported in 2024.

Detailed metrics table

*Entity-specific ESRS metric

Complaints handling and channels

Requests, concerns, and complaints raised through any of the channels that Vestas offers its employees are handled on an ad hoc basis by the People & Culture organisation or other stakeholders, when relevant.

Definition of substantiated complaints

'Number of complaints filed through channels for people in own workforce to raise concerns': These are defined as total and substantiated number of EthicsLine cases in the categories of Labour Rights & Working Conditions, Discrimination, Harassment, Sexual Harassment, and Health & Safety.

'Number of complaints filed to National Contact Points for OECD Multinational Enterprises': These are defined as Number of complaints registered at local OECD National contact point.

'Amount of material fines, penalties, and compensation for damages as result of violations regarding social and human rights factors': Vestas includes all monetary amounts proceeding from of severe human rights issues and incidents connected to own workforce.

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

Scope and definition

Vestas' own workforce comprises own employees plus other workers, i.e. contractors and sub-contractors, working under Vestas' supervision and control.

100 percent of Vestas' own workforce (including non-employees) is covered by the Health and Safety Management System, which is based on legal requirements and recognised ISO 45001 standards and certified by third-party auditors.

Health and safety metrics for own workforce (including non-employees)

Vestas tracks Total Recordable Injuries and Lost Time Injuries across its entire own workforce, including contractors and sub-contractors under operational control:

Working hours methodology

The number of working hours is measured on the basis of hours registered in system for hourly-paid employees, and prescribed working hours for salaried employees excluding e.g. holidays, absence due to illness and parental leave. The working hours for Vestas' employees and workers under Vestas' supervision are registered and measured on the same basis as the Total Recordable Injuries.

Contractor management framework

Vestas has implemented Contractors' HSE terms and conditions (effective 1 September 2024) covering the advancement of health and safety maturity of contractors, including sub-contractors. The scope covers contractor health and safety incidents occurring in Vestas' own operations within transport, construction and service for both offshore and onshore.

The Global Minimum Requirements (GMR) document establishes principles and procedures to ensure contractors and sub-contractors follow the same health and safety standards as Vestas at a global level. The scope includes all workers performing work on behalf of Vestas.

Target

Vestas has updated TRIR targets from 1.5 to 2.4 by 2025 and from 0.6 to below 1 by 2030, reflecting a shift in Vestas' risk profile, the inclusion of growing offshore activities, and an overall increase in work activities across various areas. The new targets are valid as of 1 January 2025.

Specific disclosures on non-employee characteristics

Vestas discloses that more than half of its workforce is comprised of blue-collar employees working in a high-risk environment. The company operates with around 16,000 employees across 67 countries (Service business unit) and references contractors throughout its operations in manufacturing, construction, and service activities.

However, Vestas does not provide:

• A specific headcount or FTE number for non-employee workers separately from employees
• Breakdown by type (contractor vs agency vs self-employed)
• Multi-year comparison of non-employee numbers

Collective bargaining coverage and social dialogue

Vestas acknowledges the right to freedom of association and collective bargaining as established in the Freedom of Association and Protection of the Right to Organise Convention (C.87) and the Right to Organise and Collective Bargaining Convention (C.98) in line with Principle 3 of the United Nations Global Compact and international labour standards.

In applicable countries, employees can raise concerns and grievances through works councils which meet on a regular basis to discuss employee issues and suggestions. The councils collaborate with management to find solutions and play a crucial role in resolving workplace problems.

Workers' representatives are made aware of reporting channels via email.

Note: No quantitative data on collective bargaining coverage percentages is disclosed in the provided excerpts.

Diversity metrics

Gender distribution in leadership and governance

Women in leadership positions

Women in leadership positions (number)

Board composition

Board committees (number of members women/men)

Executive Management team

Age band distribution

Board of Directors

Executive Management team

Total workforce

Methodology notes

Women in leadership positions: Calculated based on headcounts at the end of the reporting period. Leadership positions comprise managers, specialists, project managers, and above. Employee information is from the company's HRIS with specification of gender and leadership level.

Women in top management: Includes women in Executive Management team and women people leaders who report directly to Executive Management team.

Board of Directors: Six members elected by shareholders and four members elected by employees. Shareholder-elected members serve one-year terms; employee-elected members serve four-year terms.

Policies related to value chain workers

Vestas has established three primary policies that relate to workers in the value chain:

Human Rights Policy

Scope:

• All stakeholders impacted, including women, migrants, indigenous people and vulnerable groups
• Value chain workers
• Covers both suppliers' own workers and their supply chains

Governance and approval:

• For MDR-P disclosures related to this policy, see S1 page 103

Key content/principles:

• General commitment to respect human rights
• Commitment to engage with affected rightsholders including value chain workers
• Commitment to make grievance mechanisms available to value chain workers
• Commitment to remedy any adverse impacts Vestas may cause or contribute to

International standards:

• Endorses the International Bill of Rights
• UN Declaration on the Rights of Indigenous and Tribal Peoples (UNDRIP)
• International Labour Organisation's Convention concerning Indigenous and Tribal Peoples (ILO No. 169)

Public availability:

• Available at corporate website

Supplier Code of Conduct

Scope:

• All suppliers, sub-contractors, agents, consultants, and their respective affiliates who provide goods and/or services to Vestas
• Covers all value chain workers
• Suppliers' own workers and their supply chains

Governance and approval:

• Most senior level accountable: Head of Global Procurement

Key content/principles:

• Four main areas: Human Rights, Working with Integrity, Respecting the Environment, and Fair Business Practices
• Starting point for supplier due diligence framework
• Integrated part of purchase agreements
• Human Rights chapter addresses modern slavery, child and juvenile labour, and specific labour rights
• Covers health and safety of supply chain workers
• Requests suppliers to take diligent and reasonable steps to prevent human and labour rights violations within their own supply chains
• Takes into account all stakeholders impacted including women, migrants, indigenous people and vulnerable groups

International standards:

• Aligns with UN Global Compact principles
• International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work
• UN Guiding Principles on Business and Human Rights

Public availability:

• Communicated through purchasing agreements and at corporate website

Monitoring:

• Integrated into supplier onboarding and assessment processes
• Part of supplier due diligence framework

Conflict Minerals Policy

Scope:

• All eligible direct suppliers
• Focuses on minerals and metals, particularly tin, tantalum, tungsten, and gold (3TGs)
• Addresses value chain workers by mitigating risks associated with conflict-affected or high-risk areas

Governance and approval:

• Signed by the Head of Global Procurement

Key content/principles:

• Commitment to responsible sourcing practices
• Ensures minerals and metals sourced for products do not originate from conflict-affected or high-risk areas
• Conflict-affected and high-risk areas are characterised by the presence of armed conflict, widespread violence, or other risks of harm to people
• Leverages influence and requires suppliers to conduct additional due diligence in their supply chains upon identifying risks

International standards:

• Aligned with OECD Due Diligence Guidance

Public availability:

• Available at corporate website

Monitoring:

• Annual survey of first-tier suppliers in component categories where conflict minerals are expected
• Third-party supply chain data management solution
• Conflict Minerals Programme tracks supplier compliance

Additional policy frameworks for contractors:

Contractors' HSE Terms and Conditions:

• Implemented 1 September 2024
• Phase-in stage for contractors
• Will effectively replace Global Minimum Requirements document on 1 September 2025
• Covers advancement of health and safety maturity of contractors, including sub-contractors
• Scope: contractor health and safety incidents in own operations within transport, construction and service (offshore and onshore)
• Includes consequence management approach designed to be just and fair
• Most senior level responsible: functional heads
• Aligned with International Labour Organisation (ILO) and European Bank for Reconstruction and Development (EBRD)
• Includes integrated Disciplinary Policy with three-step warning process

Global Minimum Requirements for contractors:

• All-encompassing framework for managing health and safety related to contractors and sub-contractors
• Scope: all workers performing work on behalf of Vestas
• Key content: responsibilities, minimum requirements for practices and procedures
• Includes Disciplinary Policy with three-step warning process
• Most senior level responsible: functional heads
• Aligned with International Labour Organisation (ILO) and European Bank for Reconstruction and Development (EBRD)

Taking action on material impacts on value chain workers

Overview

Management of material social impacts in a global supply chain is a complex matter. Vestas' Sustainable Procurement team and Global HSE team possess their own expertise in human rights and health and safety, but also work cross-functionally across the organisation to ensure that human rights and health and safety are embedded into and aligned within the business.

In order to address impacts and risks of health and safety incidents of value chain workers, key actions in 2024 included:

• Management of contractor performance
• Defining low-to-high risk contractors

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1. Managing contractor performance

Action description: The implementation of the Contractors' HSE terms and conditions will enable Vestas to take a more proactive approach to the way it manages contractor performance. Contractors who develop and implement their HSE approach to align with industry standards will be identified as having done so through the completion of a post service evaluation conducted by Vestas project management, the results of which form the basis for future engagement. Where post service scores are considered lower than expected, specific action plans are then developed.

Scope: Contractors in own operations within transportation, construction, operations and maintenance.

Time horizon: This activity is considered continuous improvement and will thereby be ongoing for as long as we work with contractors.

Expected outcomes: The outcome of the Contractors HSE Terms and Conditions will show an improvement in the post service evaluation scores.

Resources allocated: Not specified.

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2. Defining low-to-high risk contractors

Action description: To enhance business decision-making, Vestas has established a process for assigning risk profiles to contractors, which undergoes continuous review. The criteria used for contractor assessments ensure sufficient oversight, facilitating effective decision-making. Data is collected at the operational level through various metrics, such as hazardous observations, near-miss cases and incidents, and now also includes consequence management information.

Scope: Value chain workers (contractors).

Resources allocated: Not specified.

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3. Supplier due diligence framework

Action description: To address potential adverse impacts and risks within the value chain, Vestas focuses on both direct and indirect suppliers with whom we have a contractual relationship through a supplier due diligence framework. Central to this framework is the Supplier Code of Conduct, which outlines clear requirements for suppliers and their subcontractors regarding labour practices and human rights. Additionally, the Supplier Quality Manual (SQM) provides separate quality guidelines.

Process components:

• Onboarding: Screening for sanctions and ethical risks, followed by a Supplier Registration Questionnaire where suppliers acknowledge SQM and the Supplier Code of Conduct. This step is a prerequisite to proceed with the Supplier Business Assessment (SBA) tailored to the specific scope of supply.

• Verification: For indirect suppliers, Vestas uses a matrix that considers onboarding questionnaire results and high-risk criteria to determine which suppliers undergo onsite assessments. All direct suppliers undergo onsite assessments as a standard procedure. Assessments include verification of policies and management systems related to human and labour rights aiming to uncover potential risks in addition to technical and quality aspects.

• Corrective action: Any identified improvement areas prompt the development of corrective action plans.

Scope: Upstream value chain (direct and indirect suppliers).

Resources allocated: Assessments conducted by Vestas' own team (non-financial resource: internal personnel).

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4. Wind Energy Initiative and EcoVadis implementation

Action description: In 2024, Vestas has joined the Wind Energy Initiative, a multi-stakeholder collaborative effort between EcoVadis, WindEurope, other OEMs and customers. Recognising the importance of supply chain sustainability, the initiative aims to enhance transparency and elevate performance standards across ESG topics. As part of this commitment, Vestas will implement EcoVadis. Through this third-party assessment process, suppliers will receive scorecards and improvement plans validated by professionals, empowering them to enhance their ESG performance and contribute to a more responsible and resilient supply chain. Based on these scorecards, Vestas will work with suppliers to implement suggested corrective action and improvement plans to address any identified sustainability gaps.

Scope: Upstream value chain (suppliers).

Resources allocated: Partnership with EcoVadis, WindEurope and other OEMs (non-financial resource: multi-stakeholder collaboration).

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5. Monitoring and assessment activities (2024 performance)

In 2024, Vestas assessed suppliers in the following ways:

• 2,110 due diligence screenings of potential suppliers, prior to the supplier onboarding process.
• 141 onsite supplier assessments for both direct and indirect suppliers.
• 114 suppliers scored above 70 percent, meeting the acceptable risk threshold based on Vestas' methodology.
• 27 suppliers scoring below 70 percent received corrective action plans developed and agreed upon by Vestas and the supplier. Of these, six suppliers were rejected.

Scope: Upstream value chain (suppliers).

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6. Improvement areas from supplier assessments

Every supplier found to have improvement areas in their operations will have a corrective action plan prepared and discussed with them. This plan is collaboratively agreed upon with Vestas' Supplier Quality & Development teams and the supplier.

Scope: Upstream value chain (suppliers).

Link to policy: Linked to Supplier Code of Conduct and Supplier Quality Manual (SQM).

Policies related to affected communities

Vestas has committed to engaging communities in a meaningful and timely manner to understand how its activities might affect individuals and/or various groups, mitigate any potential negative impacts, and increase community acceptance of wind farms. The company's policies related to affected communities are aligned with international responsible business principles, the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines for Multinational Enterprises.

Human Rights Policy

Scope:

• Applies globally to all individuals, workers, communities, and suppliers in a contractual relation with Vestas
• Addresses specific salient human rights issues for the wind industry including community engagement, indigenous and tribal peoples, land acquisition and resettlement

Governance:

• Signed by the Chair of the Board at the most senior level

Key content:

• Embeds commitment to respecting human rights, including the particular rights of indigenous and tribal peoples
• States that Vestas does not tolerate threats, intimidation, physical or legal attacks against individuals or groups lawfully exercising their rights to freedom of expression, association, peaceful protest or assembly in relation to Vestas' business or operations
• Elaborates on how Vestas meets its obligation to respect human rights by conducting due diligence and remediating negative impacts on affected communities

International standards:

• Endorses the International Bill of Rights
• Endorses the UN Declaration on the Rights of Indigenous and Tribal Peoples (UNDRIP)
• Endorses the International Labour Organisation's Convention concerning Indigenous and Tribal Peoples (ILO No. 169)

Public availability:

• Available at the corporate website

Update:

• Updated in 2024 to reflect increased expectations from investors, clients, and civil society organisations

Employee Code of Conduct

Scope:

• Applies to all employees

Key content:

• Includes a section titled 'Our Responsibilities Towards Communities' which states expectations towards employees in terms of community engagement
• Requires employees to engage with and listen to local communities in an inclusive, equitable, culturally appropriate, gender-sensitive way, particularly indigenous communities (where relevant)
• Requires treating communities' views with respect and considering them without discrimination
• Commits employees to strive to respect the principles of Free, Prior, and Informed Consent within the scope of responsibility in cases where indigenous and tribal peoples may be impacted by a project

Governance:

• Senior accountability detailed on page 103 (referenced but not detailed in excerpts)

Supplier Code of Conduct

Scope:

• Applicable to all suppliers
• Integrated part of purchase agreements

Key content:

• Outlines expectations to suppliers in four main areas: Human Rights, Working with Integrity, Respecting the Environment, and Fair Business Practices
• Expects suppliers to avoid causing, or contributing to, adverse human rights impacts across their own operations and supply chains, and within the local communities where they operate
• Expects suppliers to consider the human rights of all stakeholders impacted, paying specific attention to women, migrants, indigenous people, and vulnerable groups
• Expects suppliers to have adequate management systems in place to ensure compliance
• Suppliers are responsible for conducting due diligence to identify and manage potential risks related to human rights

Process:

• Vestas conducts due diligence on suppliers as part of the supplier selection process to identify and manage potential risks

Social Management System

Scope:

• Applicable to communities around:
  • Engineering, Procurement and Construction (EPC) projects outside high income OECD countries
  • Supply-and-Installation projects of 100 MW or above outside high-income OECD countries
  • Projects in OECD countries where there is a risk for impacting Indigenous and Tribal Peoples' lands, territories or livelihoods

Governance:

• Head of Global Compliance & CSR is the most senior level in the organisation accountable for the Social Management System

Key content:

• Outlines how Vestas has operationalised its human rights methodology in its market approach supporting customers in creating bankable projects
• Addresses how Vestas manages adverse social risks including land-related impacts, and adverse impacts on Indigenous and Tribal Peoples' rights to Free, Prior, and Informed Consent
• Includes information on Social Due Diligence Process, Grievance Mechanism, main social risks addressed, key mitigation measures, and stakeholder engagement
• Outlines key human rights due diligence steps applicable for affected communities

International standards:

• Helps operationalise commitment to the UN Guiding Principles on Businesses and Human Rights
• Helps operationalise commitment to the OECD Guidelines for Multinational Enterprises

Public availability:

• Publicly available on the corporate website

Monitoring

Vestas monitors compliance with these commitments through:

• Internal tracking and monitoring of progress against several salient human rights issues, including community-related impacts identified in the latest Corporate-Wide Human Rights Assessment
• Monitoring access to grievance and remedy mechanisms available for affected communities to raise concerns or misconducts, with communication of this information internally and externally
• Regular monitoring of the Human Rights Resource Centre for Business and Human Rights
• Monitoring several external human rights benchmarks that assess commitments to the UN Guiding Principles on Business and Human Rights and the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work
• Addressing adverse impacts through customer engagement as outlined in the Social Management System in the downstream value chain
• Social Due Diligence tool that facilitates review of customers' Environmental and Social Impact Assessments (ESIAs) and Stakeholder Engagement Plans, evaluated based on the IFC Performance Standards, ILO standards, and UNGPs
• Grievance mechanism to assess effectiveness of engagement during construction

Taking action on material impacts on affected communities

Overview

Vestas is committed to building resilient relationships with communities impacted by operations, prioritizing stakeholder engagement to ensure views, interests, and rights of potentially affected communities are discussed and considered in wind farm projects, particularly those with potential high social risks.

Key actions are driven by the Corporate-Wide Human Rights Assessment which identifies communities as a key rightsholder group, with recommendations for improving processes in due diligence and general practices.

Key Actions Implemented

1. Social Due Diligence (SDD) Process

Scope: Construction projects (EPC and Supply-and-Installation projects)

Applicability:

• EPC projects outside high-income OECD countries
• Supply-and-Installation projects ≥100 MW outside high-income OECD countries
• Projects in OECD countries with risks to Indigenous and Tribal Peoples' lands, territories, and livelihoods

Process:

• Identify and assess social risks to understand potential negative impacts
• Use customers' Environmental Impact Assessments and associated studies (e.g., Stakeholder Engagement Plans) as base for due diligence
• Collaborate with customers to determine necessary actions to address impacts and promote positive outcomes
• Assign roles and responsibilities among project stakeholders

Resources allocated:

• Budgets for community initiatives (specific amounts not disclosed)
• Community Liaison Officers
• Expert consultants for addressing community-related impacts
• Project or Construction Managers acting as primary representatives to communities

Expected outcomes:

• Prevention or mitigation of adverse impacts on communities
• Building social license to operate
• Sound relationships with affected communities

Performance in 2024: 83% of qualifying projects underwent the SDD process across 3 regions

Target: 100% of qualifying projects to undergo SDD by 2025

2. Feasibility Studies and Community Profile Mapping

Scope: Wind farm development (own operations)

Activities:

• Conduct feasibility studies including Environmental & Social Impact Assessments (ESIAs)
• Map community profiles to better understand local context
• Identify actions needed to prevent or mitigate adverse impacts on communities
• Take steps to prevent adverse impacts related to land acquisition

Resources:

• Environmental and social specialists
• Expert consultants

Outcomes:

• Inform site layout preparation taking into consideration measures that prevent potential risks to affected communities
• Identify mitigation measures where prevention is not possible
• Build good relationships and demonstrate social commitment

Example: Lotus Creek Wind Farm, Australia - worked with Traditional Owners to protect cultural heritage sites, developing a Cultural Heritage Management Plan and Indigenous Land Use Agreements

3. Community Engagement Initiatives

Scope: Construction and service projects where Vestas is a supplier (downstream)

Time horizon: Ongoing, with target to reach 35,000 cumulative beneficiaries by 2025 (achieved in 2022)

Activities:

• Initiatives to uplift communities socially and economically
• Improvement of overall quality of life in aspects such as:
  • Education
  • Skills training for local employment
  • Social infrastructure development support (healthcare, drinking water)
  • Local cultural activities for community bonding

Resources:

• Budgets for community initiatives (specific amounts not disclosed)
• Partnerships with local stakeholders and authorities

Performance 2024:

• 7,919 direct beneficiaries reached across Latin America, Asia Pacific, Africa and Mediterranean regions
• 54,359 cumulative beneficiaries since 2019 (baseline)

Outcome metrics:

• Number of community beneficiaries tracked annually
• Contribution to structural, cultural, and intellectual gains

4. Promoting Employability Through Training and Capacity Building

Scope: Communities near wind farm projects (downstream)

Objective: Improve socio-economic impacts and foster project ownership amongst affected communities by promoting employability and preventing economic displacement

Activities:

Latin America - Technical Training:

• Mexico (Tamaulipas project): Technical training in wind turbine maintenance - 22 beneficiaries in 2024
• Brazil (Keep it Local initiative with EDPR): 121 participants in 2024
• Partnership with Engie: Training course for 53 students (2024-2025)

Africa - Capacity Building:

• Senegal (2024): Trained 200 community members in:
  • Organic fertilising
  • Market-oriented agriculture
  • Poultry farming
  • Processing of vegetables

Outcomes:

• Prevention of economic displacement
• Promotion of more sustainable farming practices
• Enhanced local employment opportunities

5. Operational-Level Grievance Mechanism (OGM)

Scope: All wind farm construction and service operations (own operations and downstream)

Process:

• Multiple communication channels: project websites, email, phone, community engagement activities
• Anonymous submissions allowed for individuals or groups
• Neutral handling without discrimination
• Documentation of all grievances and remedies
• Integration with Vestas Incident Management System (IMS)

Resources:

• Community Liaison Officers
• Project/Construction Managers
• Grievance tracking and management systems
• Awareness-raising through intranet, onboarding training, site meetings

Effectiveness measures:

• Remedy discussed equally with affected stakeholders
• Stakeholders can accept or reject solutions
• All remedy agreements documented

Performance 2024: 2 community grievances received (related to community health & safety concerns)

Links to policies:

• Human Rights Policy
• Social Management System
• UN Guiding Principles on Business and Human Rights
• OECD Guidelines for Multinational Enterprises

6. Engagement with Indigenous and Tribal Peoples

Scope: Projects potentially impacting Indigenous and Tribal Peoples' lands, territories, or livelihoods

Commitment: Respect for Free, Prior, and Informed Consent (FPIC)

Activities:

• Early identification and involvement of indigenous communities or representatives
• Information provision in relevant languages
• Use of culturally appropriate procedures
• Consultation on mode and parameters of engagement
• Explicit agreement evidencing consent
• Identification of land ownership or traditional user rights
• Protection of sites of cultural heritage
• Assessment of physical or economic displacement risks

Resources:

• Consultants with specific expertise in Indigenous and Tribal Peoples' rights
• Cultural Heritage Management Plans
• Indigenous Land Use Agreements

Outcomes:

• Prevention of adverse impacts on FPIC rights
• Consideration of perspectives in project development
• FPIC considerations guide project viability and feasibility decisions

Cross-Cutting Elements

Policy framework:

• Human Rights Policy (endorses International Bill of Rights, UNDRIP, ILO Convention No. 169)
• Social Management System
• Supplier Code of Conduct

Monitoring and tracking:

• Internal tracking of progress against salient human rights issues
• Quarterly presentation to Executive Management and Board on sustainability goals
• Annual reporting on scope 3 and community engagement
• Monitoring of Human Rights Resource Centre for Business and Human Rights
• Tracking of external human rights benchmarks

Organizational accountability:

• Head of Global Compliance & CSR is most senior level accountable for Social Management System
• Development Execution teams in each region ensure community engagement under Regional Development Directors
• Risk Officers and Action Owners responsible for developing and implementing action plans

Targets related to affected communities

Vestas discloses three metrics and associated targets related to affected communities, which have been tracked since 2019. The targets were designed internally and are not science-based or externally validated.

Target 1: Social Due Diligence Process Coverage

Target metric: Share of in-scope projects having undergone the Social Due Diligence Process

Target value: 100%

Target year: Yearly basis by 2025

Baseline year: Not disclosed

Baseline value: Not disclosed

Scope:

• Engineering, Procurement and Construction (EPC) projects outside high-income OECD countries
• Supply & Installation projects of 100 MW or above outside high-income OECD countries
• Projects in OECD countries where there is a risk for impacting Indigenous and Tribal Peoples' lands, territories or livelihoods

Type: Absolute (percentage coverage)

External validation: Internal target (internal stakeholders involved in target setting)

Progress to date (2024): 83% of qualifying projects underwent the Social Due Diligence Process across 3 regions

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Target 2: Community Beneficiaries Reached

Target metric: Number of community beneficiaries reached through community initiatives

Target value: 35,000 beneficiaries

Target year: 2025

Baseline year: 2019 (tracking started)

Baseline value: Not disclosed

Scope: Initiatives implemented in relation to construction or service projects where Vestas has been a supplier, across Latin American, Asia Pacific, Africa and Mediterranean regions

Type: Absolute (number of beneficiaries)

External validation: Internal target (only internal stakeholders involved in setting this target)

Progress to date:

• 2022: Target of 35,000 beneficiaries achieved ahead of schedule
• 2024: 7,919 direct beneficiaries reached during the year
• Cumulative since 2019: 54,359 beneficiaries reached

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Metric 3: Community Grievances Received

Metric: Number of community grievances received through the Operational-level Grievance Mechanism (OGM)

Note: Vestas does not have a target for the number of grievances received as this indicator is dependent on levels of activities and types of construction projects. This metric is tracked to assess the effectiveness of the grievance mechanism.

Progress to date (2024): 2 community grievances received (related to community health & safety concerns)

Incidents of corruption or bribery

Confirmed incidents

Vestas reported zero confirmed incidents of corruption or bribery in 2024. The company explicitly states: "In 2024, Vestas had no convictions or fines for violating anti-­corruption or anti-bribery laws" and "Vestas had 0 public legal cases regarding corruption and bribery brought against the enterprise or own workers."

Convictions and fines

Disciplinary actions

Vestas did not report any employees dismissed or disciplined specifically due to corruption or bribery in 2024.

Contracts terminated

The company did not disclose any contracts with business partners terminated or not renewed due to corruption or bribery incidents in 2024.

Investigation procedures and speak-up mechanisms

Vestas maintains EthicsLine, a whistleblower platform managed through an independent third party that is accessible to all employees and external stakeholders globally. The platform allows anonymous reporting and is available via the corporate website, a dedicated Compliance app, the company intranet, and by phone.

In 2024, 757 EthicsLine cases were raised in total, with 147 substantiated and 500 unsubstantiated. The remainder were still under investigation at year-end. Of the substantiated cases, 78 related to social or human rights areas.

The company operates under a comprehensive EthicsLine Policy that:

• Protects whistleblowers from retaliation
• Ensures independent and objective investigations
• Provides multiple reporting channels
• Is aligned with the EU Whistleblowing Directive (EU) 2019/1937

Vestas' anti-corruption framework includes:

• Global and Regional Anti-Bribery and Corruption Compliance Programmes with five pillars: Programme Governance, Learning & Awareness, Culture & Behaviour, Monitoring & Auditing, and EthicsLine
• Business Ethics Policy covering bribery, facilitation payments, gifts and hospitality, donations, and conflicts of interest
• Mandatory training for 100% of functions-at-risk (office employees and service technicians)
• Annual Global Anti-Bribery and Corruption Survey
• Quarterly reporting to the Audit Committee and Board of Directors

The company commits that "if any breaches were to be identified, Vestas is committed to taking appropriate action, including amending standards or processes and implementing disciplinary measures such as warnings or dismissals."

Public legal cases

Vestas confirmed that during 2024, "we have not registered any final court convictions on violations of labour law and human rights, tax laws, corruption laws, or fair competition laws against the Vestas Group or its senior management."

Political influence and lobbying activities

Political engagement approach

At Vestas, our political advocacy is aimed at accelerating the clean energy transition in alignment with the Paris Agreement's goal of limiting global warming to 1.5°C. Our lobbying and advocacy activities focus on supporting policies, driving for example:

1. The acceleration of wind energy build-out.
2. The removal of permitting bottlenecks that delay renewable energy deployment.
3. The scaling up of grid capacity to accommodate renewable energy.
4. The establishment of auction frameworks that ensure sustainable supply chains while delivering affordable, clean electricity.
5. The upholding of established trade rules supporting a level playing field in the wind industry.

Vestas' contribution to the green transition by supporting policies and regulations aligned with the Paris Agreement's goal of limiting global warming to 1.5°C, has been identified as a positive material impact of our political engagement. Through our political engagement, Vestas contributes to policies that accelerate wind energy buildout, which enables a clean energy system that mitigates climate change, protects ecosystems, and improves air quality, thus impacting the natural environment positively in the short, medium and long term.

This impact occurs across the entire value chain and originates from our business model, which is improved by expanding the role of wind energy in the global energy mix. For example, by launching global information campaigns and participating in international forums like COP29 and the World Economic Forum, we actively shape the discourse around renewable energy policies. We also engage with policy makers both directly and through our industry associations, most notably WindEurope, the American Clean Power Association (ACP), and the Global Wind Energy Council (GWEC).

Ethical standards and guidelines

Our Employee Code of Conduct outlines the direction of our political engagement. It states that we seek to engage with politicians to promote Vestas' interests in renewable energy in a legal, ethical, and transparent manner. It also confirms that we do not use corporate funds for donations that support political parties or individual politicians.

The Business Ethics Policy sets the framework for responsible political engagement at Vestas. It establishes key principles, such as the prohibition of corporate donations to politicians, and provides clear guidance on appropriate gifts, including precautions to take when giving or receiving gifts to political stakeholders.

Governance and oversight

Our Public Affairs department is responsible for the oversight of political influence and lobbying activities, and the Head of Public Affairs controls the activities and ensures Executive Management and Board oversight through quarterly reporting on these activities. This management system and monitoring process ensures that our policy engagement is aligned with the Paris Agreement, both for our direct lobbying activities and our trade associations. It covers all jurisdictions where we have operations.

The Head of Public Affairs is directly accountable to the Group Senior Vice President of Marketing, Communication, Sustainability, and Public Affairs, who in turn reports to the Chief Sales Officer and ultimately to the Chief Executive Officer. No one in our administrative, management, or supervisory bodies held comparable positions within public administration within the last two years of the reporting period.

EU Transparency Register

Vestas is registered in the EU Transparency Register under REG number 769186224869-06.

Political contributions

Direct political contributions: Vestas made no direct financial or in-kind political contributions in 2024, as prohibited by our Employee Code of Conduct.

Indirect political contributions: While Vestas made no direct political contributions in 2024, we did make indirect contributions to intermediary organisations, such as lobbyists, think tanks, and trade associations, that advocate the acceleration of wind energy deployment. This also included payments for external assistance from embassies and political consultancies.

The Public Affairs department estimates in-kind political contributions by recording all spending aligned with the principle of "non-financial support provided directly or indirectly to political parties or individual politicians."

Political contributions 2024

Targets and metrics

In line with our policies we are committed to conduct business with integrity and we seek to engage with governments and politicians to promote Vestas' interests in renewables in a legal, ethical and transparent manner.

No overarching targets are set related to incidents of corruption and bribery or political engagement as it is context dependent. In this regard, we have not set a baseline year from which we measure our progress. However, metrics are continuously evaluated to assess how we can improve our positive impact year on year.

Prevention and detection of corruption and bribery

Vestas has established several policies to address the identification, assessment, management, and remediation of material impacts, risks, and opportunities related to business conduct matters, specifically corruption and bribery. The policy framework aligns with the United Nations Convention against Corruption.

Employee Code of Conduct and Supplier Code of Conduct

• Scope: Employees and suppliers globally
• Key content: Outline expectations for employees and suppliers regarding business conduct matters
• International alignment: United Nations Convention against Corruption
• Public availability: Details provided on pages 103 and 114 in accordance with MDR-P disclosure requirement

EthicsLine Policy

• Scope: All employees and third parties globally across the value chain
• Governance:
  • Implemented by the EthicsLine function with assistance from Regional and Group Level Ethics Committees
  • Accountability at highest level lies with the Executive Vice President & CFO
  • Ethics Committees support and monitor the EthicsLine function at both global and regional levels, determining appropriate outcomes of investigations on a case-by-case basis, including disciplinary steps and other remediation actions
  • Audit Committee oversees the EthicsLine function as part of its mandate, including being informed of high-level metrics
  • Investigators assigned to work on EthicsLine cases operate independently from management
• Key content:
  • Sets framework for whistleblower system designed to investigate suspected violations of laws and Vestas' policies and procedures
  • Emphasizes safe reporting environment and details protections for individuals reporting misconduct or cooperating with investigations
  • Details anti-retaliation measures
  • Relates to material impact on protection of whistleblowers
• Public availability: Accessible through internal channels, the EthicsLine platform, the Vestas Compliance app, and publicly at corporate website and by phone
• Compliance: Vestas complies with EU Whistleblower Directive (EU) 2019/1937, ensuring whistleblower protection in every investigation
• Monitoring:
  • In 2024, 757 EthicsLine cases were raised, with 147 substantiated and 500 unsubstantiated
  • 78 substantiated cases related to social or human rights areas, including termination of employment
  • Training conducted for employees managing cases in 2024

Business Ethics Policy

• Scope: All Vestas employees globally and covers all Vestas activities, including engagement with business partners
• Governance:
  • Owned by Group Compliance function, responsible for maintaining it
  • Anchored under the CFO who is ultimately accountable for implementation
  • Head of Legal is the most senior level accountable for implementation of the Global Compliance Programme
  • Regional Compliance programme is signed by Regional Presidents
• Key content:
  • Outlines standards and expectations regarding bribery, facilitation payments, gifts and hospitality, donations, and conflicts of interest
  • Standards further clarified through supplementary guidelines for each topic
  • Sets framework for responsible political engagement
  • Establishes key principles including prohibition of corporate donations to politicians
  • Provides clear guidance on appropriate gifts, including precautions when giving or receiving gifts to political stakeholders
• Legal requirements: Vestas is subject to legal requirements under national law transposing Directive (EU) 2019/1937, or equivalent requirements regarding protection of whistleblowers
• Public availability: Made available to employees on internal platforms (Vestas Process Portal and intranet)
• Monitoring: Relates to management of corruption and bribery risks and helps establish ethical corporate culture

Global and Regional Compliance Programmes

• Scope:
  • Global and regional in nature covering all of Vestas' own workforce
  • Target audience defined through risk-based approach linked to global compliance survey and EthicsLine cases
  • Functions most at risk identified as office employees and service technicians due to nature of their functions
• Governance:
  • Governed by Codes of Conduct and global policies
  • Executed by Group Compliance and Regional Legal & Compliance functions
  • Compliance addressed in quarterly meetings between Regional teams and Executive Management to monitor progress by each region
  • Addressed as quarterly item in Audit Committee meetings
  • Programme delineates role of Executive & Regional Management in promoting culture of compliance, establishing 'Tone at the Top' and providing oversight
  • Outlines Audit Committee's role in evaluating effectiveness of Compliance Programmes
• Key content:
  • Established to mitigate corruption and bribery risks
  • Outline how Vestas works with Anti-Bribery & Corruption (ABC) inspired by the six principles in the UK Bribery Act 2010
  • Comprised of five pillars: 'Programme Governance', 'Learning & Awareness', 'Culture & Behaviour' (aimed at preventing misconduct), 'Monitoring & Auditing', and 'EthicsLine' (used to prevent, detect and manage misconduct)
  • Serve as training policy for business conduct relating to impact on corruption and bribery
  • Updated annually
  • Describe training strategy, channels to deliver training, and training content
  • Describe how Group Compliance function must support Regions including who should receive training, which material should be used, and in what way
• International alignment: Inspired by UK Bribery Act 2010 six principles
• Public availability: Made available to employees on internal platforms
• Training and monitoring:
  • Fundamental training conducted as part of onboarding process
  • Additional training performed on yearly basis covering areas relevant for Vestas
  • 100% of at-risk employees (office employees and service technicians) assigned to business conduct training in 2024
  • All Vestas office employees and service technicians required to complete mandatory e-learnings on business conduct topics (6-25 minutes each)
  • In 2024, quarterly in-person and online training sessions (typically 30 minutes per topic) provided to various employee groups covering Code of Conduct requirements and policies on business ethics topics like Gifts & Hospitality
  • Training materials translated into several languages and available on intranet, including anonymised EthicsLine cases
  • Regional initiatives conducted (e.g., Latin American Region focused on on-site training for service technicians in Argentina, Brazil, and Mexico)
  • Regional leadership and CFO actively promoted campaigns and involved in establishing 'Tone at the Top'
  • Communication through various channels: in-person, online, hybrid trainings, e-mails, videos from senior management

Performance in 2024

• No convictions for violation of anti-corruption and anti-bribery laws
• No fines for violation of anti-corruption and anti-bribery laws
• Zero public legal cases regarding corruption and bribery brought against the enterprise or own workers
• 100% of functions-at-risk assigned to training programmes

Payment practices

Supplier finance arrangements

Vestas has 7 local or regional supplier financing programs with 3 different banks. Supplier finance arrangements provide selected suppliers with optional early payment terms, compared to the invoice payment date.

Supplier finance liabilities (mEUR)

Payment terms by supplier finance program

The following information has been disaggregated by Vestas' three largest supplier finance programs covering North America, EMEA and APAC regions and Other local programs. This only covers suppliers with annual spend in excess of EUR 1m.

Standard payment terms

For standard trade receivables and contract assets, payment terms are typically one month from the invoice date.

Legal proceedings for late payment

Not disclosed.