Assets

Type	Time	Amount	Unit
ifrs-full:Assets	2023-12-31	2343900000	vUSD
ifrs-full:Assets	2022-12-31	2755400000	vUSD

Revenue

Type	Start date	End date	Amount	Unit
ifrs-full:Revenue	2023-01-01	2023-12-31	3691900000	vUSD
ifrs-full:Revenue	2022-01-01	2022-12-31	5312400000	vUSD

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   <mrv:CorporateGovernanceReport contextRef="ctx1" id="fact1000" xml:lang="en">CORPORATE GOVERNANCE For NORDEN, it is important to ensure responsible, long-term governance of the Company aligned with long-term shareholder interests. NORDEN’s governance principles and structure are set out to ensure alignment with long-term shareholder interests to enable prudent management of NORDEN in accordance with relevant national and international regulations, applicable corporate governance recom- mendations as well as to align with the risk framework specified by the Board of Directors. Furthermore, the ongoing management of NORDEN is based on the underlying Company values of flexibility, reliability, empathy and ambition as well as the Company’s guiding purpose of enabling smarter global trade. Governance structure NORDEN has a two-tier governance structure consisting of a Board of Directors and a Executive Management. No individuals are part of both management bodies. The shareholders have the ultimate authority over the Company and exercise their rights by passing resolutions at general meetings. Resolutions are adopted by simple majority of votes, unless otherwise provided by legislation or by NORDEN’s articles of association. The Board of Directors is made up of nine members. Six are elected for a term of one year by the shareholders, while three members are elected for a term of three years by the employees. The Board of Directors determines and approves strategies, policies, overall goals and budgets for the Company. In addition, it sets out the risk management framework and supervises the work, procedures, etc. carried out by the day-to-day management. The Board of Directors appoints the Executive Management and determines on its responsi- bilities and remuneration. To avoid conflicts of interest, there are no transactions between related parties within the Board, and the Board does not operate with any form of incentive-based remuneration. The first level of management comprises the CEO and CFO, who makes up the Executive Management. The Executive Management are responsible for the day-to-day management, organisation and development of NORDEN, for managing assets, liabilities and equity, for accounting and reporting, and for preparing and imple- menting the strategy. The day-to-day contact between the Board of Directors and the Executive Management is primarily handled by the Chair and the CEO. The Executive Management participates in board meetings and is supplemented by other managers in strategic meetings as and when relevant. The second management level include employees with managerial responsiblities and refers directly to the Executive Management team. The Articles of Association are available on the Company’s website. Generally, resolutions to amend the Articles of Association require a quorum of at least two-thirds of the voting share capital represented at a general meeting and a majority of at least two-thirds of the votes cast, as well as of the voting share capital represented at the general meeting. In addition, certain resolutions on changes of the share- holders’ dividend or voting rights or the transferability of shares, as set out in the Danish Companies Act, require a special supermajority of at least 9/10 of the votes and of the capital represented. Board work The Board of Directors sets out an annual work schedule to ensure that all relevant issues are discussed during the year. As part of the annual schedule, regular board meetings and strategy seminars are held to ensure focus on both short and long-term targets for the Company. In line with this focus on short and long-term activities, the Board of Directors is engaged in upholding NORDEN's purpose of enabling smarter global trade. This is, among other areas, reflected in the strategic discussions and priorities set by the Board of Direc- tors and the Executive Management, in the regular updates provided by the Executive Management to the Board, as well as in the remuner- ation targets set forth for Executive Management by the Board. In 2023, the Board of Directors held 13 board meetings. The attend- ance rate was 100%. Board committees As part of the Board of Directors’ work and structure, four subcom- mittees have been established to ensure dedicated focus on recur- ring topics deemed of high importance for the governance of the Company. See overview of committees on p. 39. Board qualifications and evaluation For the Board of Directors to be able to perform its managerial and strategic tasks, and at the same time, act as a sounding board to the Executive Management, the following skills are deemed particularly relevant: • Insight into shipping and trading • Commodity trade • General management • Strategic development • Risk management • Investment, finance and accounting • International experience • ESG competences The Board of Directors and the Executive Management conducted a self-assessment of the composition, qualifications and dynamics of the Board of Directors in 2022. The assessment concluded that the Board of Directors possesses relevant skills and has good working relationships and dynamics. A similar assessment is planned for 2024. Board composition and remuneration At the annual general meeting in March 2023, Klaus Nyborg, Johanne Riegels Østergård, Karsten Knudsen and Robert Hvide Macleod were re-elected as board members. Vibeke Bak Solok and Ian McIntosh were elected for the vacant seats after Helle Østergaard Kristiansen and Stephen John Kunzer, who did not accept re-election. During 2023, the employee representative Stine Maria Gøttrup ended her employment with NORDEN and therefore also resigned from the Board of Directors. Instead, William Boatwright took over as employee representative, joining the two remaining employee representatives Christina Lerchedahl Christensen and Henrik Røjel. The Board of Directors has set a target of 40% underrepresented gender shareholder-elected board members by 2025. Currently, the percentage of female shareholder-elected board members is 33%. Further details on the diversity levels in NORDEN can be found in the ESG section in this report, while NORDEN’s Diversity, Equity &amp; Inclusion policy can be found at https://norden.com/about/ govern- ance/policies-and-charters.</mrv:CorporateGovernanceReport>
   <mrv:StatementOfCorporateSocialResponsibility contextRef="ctx1" id="fact1109" xml:lang="en">ESG IN NORDEN As a global provider of ocean-based freight services, NORDEN plays a decisive and leading role in our industry in creating a sustainable future for global trade, our customers and an organisation built on diversity, engagement and strong compliance. In 2023, we made material progress on the environmental agenda towards our target of achieving net-zero emission by 2050. While NORDEN works proactively with all elements of our ESG strategy, our key strategic focus areas are reducing emissions from our vessels and Diversity, Equity &amp; Inclusion (DE&amp;I). During 2023, we recognised several material successes with an improvement in tonnage-adjusted fleet Energy Efficiency Operating Indicator (EEOI) of 9% Y/Y and reaching our diversity target of 40% for the lowest represented gender in our workforce. In 2024, we will continue the work towards an even more sustainable business model based on existing and new climate and diversity initiatives. Our strategic sustainability priorities Based on our strategy of being a global provider of ocean-based freight services and port logistics solutions, NORDEN has high ambi- tions across the sustainability agenda and has the potential to lead the development and improvements of our industry. Our strategy since 2017 has evolved around data, and by building on the strong foundation that is already in place, NORDEN has the ability to utilise the strong foundation to disclose ESG data in accordance with the adopted reporting and accounting standards. E: Strong execution on the decarbonisation agenda Our commitment and responsibilities for decarbonising our busi- ness and our customers' supply chain continue to be more and more important and they are therefore an integrated and fundamental part of our strategy and our daily operational decisions. The global climate emergency has for a long time stressed the need for accelerating a sustainable future and focus on decarbonisa- tion across industries, not only setting long-term targets, but also committing to initiatives with immediate decarbonisation effect. Today, environmental focus is an enabler for smarter global trade and offering low-carbon emission products to our customers. Being a leading player in the shipping industry that accounts for 90% of the world’s transported goods, but at the same time 3% of the global carbon emissions and a critical part of our customers' scope 3 emis- sions, we have the responsibility to focus on reducing our environ- mental impact and our customers' supply chains. On the environmental agenda, we have already set ambitious targets to reach net-zero emissions by 2050 supported by short-term targets of yearly reductions in our EEOI of a minimum of 2% per year, equivalent to a medium-term target of a reduction in EEOI of minimum 16% by 2030. The targets for reductions in EEOI are part of NORDEN’s strategic scorecard and management’s remuneration scheme. During 2023, NORDEN reduced the EEOI on its entire fleet by 9% Y/Y to 9.0 grammes of CO2 per cargo nautical mile. The reductions are mainly related to fuel efficiency and speed, driven by our deci- sion to operate our vessels at lower speed levels. The reduction in EEOI is mainly a result of our efforts, besides having experienced some tailwind effects from decreased optimal speeds in the industry. In the short term, focus on efficient operation of our operated vessels will be core in our decarbonisation strategy, which includes voluntarily reducing the vessel speeds below what is economically optimal, phasing out the 5% worst polluting vessels from our fleet when chartering in capacity, scheduling consistent hull cleanings to decrease resistance and improve fuel savings to benefit our customers and continue to invest in fuel transparency ensuring fuel quality and better efficiency. In order to measure the fuel efficiency of our operated fleet and be able to support our customers with transparency and reliable data, we utilise our in-house data analytics capabilities. NORDEN is well-positioned to make the most optimal assessments for our business, our customers and the climate by utilising our data model that handles more than nine billion data points every day, combining efficiency data for own vessels with data for chartered vessels. In addition to our operational focus on improving the fuel efficiency, we expect to grow the number of voyages with low-emission biofuel alternatives in the coming years, building on our newly developed and certified book &amp; claim system enabling carbon insetting directly into the shipping logistic supply chain. During the year, we had a commercial breakthrough signing the first low-carbon emission contract with the Canadian mining company Teck and secured the first carbon-insetting transactions. The investment in the biofuel producer MASH Makes is a strategic investment made with the rationale of engaging directly in the development and supply of alternative fuel sources, which will be an important pathway to further reduce our emissions in future and to offer direct decarbonised supply chain solutions to our customers. Currently, the long-term perspectives for what the optimal zero-emission technologies for dry cargo and tanker shipping remain uncertain and therefore, NORDEN prioritises initiatives with a more immediate positive impact. In 2023, we secured our first leased newbuilding with the option of dual-fuel methanol design. To reach our long-term net-zero emission target by 2050, we are committed to investing in net-zero emission technologies, as already included in our target of only ordering zero-emission vessels from 2030. S: NORDEN is a people-driven business NORDEN continuously works to strengthen our position as an attrac- tive employer, offering an inclusive and engaging working environ- ment, in which all employees have equal opportunities for realising their potential - all elements critical for operating a high-performing organisation. We have committed to constantly improving and, while monitoring the impact of organisational development, we exceed targets set for DE&amp;I. We are very satisfied to see a continued positive trend and that NORDEN in 2023 reached our target of 40% of the lowest repre- sented gender across our workforce. A key priority for NORDEN is setting high standards for health and safety for seafarers on board NORDEN-owned vessels. During the year, we saw an increase in the overall Lost Time Incident Rate (LTIR) to 1.0 based on four minor incidents in 3.9 million exposure hours on board NORDEN-owned vessels. We continue the work of improving our health and safety with several campaigns being launched, targeting both the nature of the specific injuries, but also general safety and health awareness across the organisation. NORDEN facilitates the opportunity for its employees and their children as well as children of seafarers on NORDEN-owned vessels to apply for scholarships via Orient’s Fond, primarily funded by portions of NORDEN's generated profits. NORDEN plays an active role in this opportunity, ensuring these scholarships are available to candidates within the maritime community. G: Trust is key for our stakeholders Being a global company that operates in regions where concepts of integrity and good business ethics vary, it is critical for NORDEN to strive to uphold the highest standards for business conduct in our operations and protect our values and heritage to maintain the role as trusted partner by our customers and to the public. NORDEN has an Employee and Supplier Code of Conduct that outlines the ethical, social and environmental standards all employees and suppliers are expected to follow. It serves as a guide for deci- sion-making and maintaining high standards of business conduct. The Code is provided to new hires during onboarding and must be acknowledged annually to ensure comprehension of any updates. During the year, all eligible employees passed an anti-corrup- tion e-learning course, to ensure the organisation is aware of and complies with the programme. To achieve our ambitions of creating a sustainable business model, sustainable procurement is another key priority, which is being anchored in the procurement operating model of NORDEN. In 2023, CASE STORY we were able to assess 55% of our strategic suppliers based on our ESG criteria, surpassing our target of 30%. ESG initiatives for 2024 Looking into 2024, we are planning to accelerate our climate and decarbonisation initiatives based on the commercial and operational breakthrough we experienced this year with the first low-emission contracts and book-and-claim transactions conducted. We foresee an increasing demand for decarbonised solutions from our customers in order for them to reach their scope 3 targets, and NORDEN aims to be the trusted partner in that development. NORDEN will further develop our engaging and inclusive working culture and continue the improvements seen in our priorities of increasing the share of the underrepresented gender in commercial and managerial roles. In 2024, NORDEN will implement a new group HSEQ position to create a strategy and process for existing and new business areas within health, safety and well-being for seafearers working on our vessels. NORDEN will likewise implement steps to further improve measuring the effectiveness of the Anti-Corruption Compliance Programme and our target is that by 2024 60% of our strategic suppliers have been screened for ESG criteria. Reporting standards Over the past year, NORDEN has started the implementation of the European Sustainability Reporting Standards (ESRS) in preparation for the standards becoming mandatory in the reporting year 2025. OPTIMISING FREIGHTS TO DECARBONISE CUSTOMERS' SUPPLY CHAINS The Canadian mining company Teck Resources Ltd. had a goal of reducing the carbon emissions associated with the transportation of its steelmaking and coal, and therefore approached NORDEN for help with the task. As NORDEN and Teck were already in business together, the partnership was a natural extension. The partnership aims to reduce the annual emissions from Teck shipments handled by NORDEN by 25%, or up to 6,700 tonnes of CO2, equivalent to removing over 1,400 passenger vehicles from the road. “With this initiative, we are now able to design customer- tailored freight emission contracts where we leverage our combined expertise to develop unique solutions that support our customers’ ambitions to lower their supply chain emissions,” said NORDEN CEO Jan Rindbo. To achieve the reductions, NORDEN is utilising a range of solutions, including fuel-efficient ships and alternative fuels such as biofuel in combination with an intelligent use of advanced data analytics to optimise vessel speed and routing. By aligning with the ESRS now, we are not only staying ahead of regulatory requirements but also reinforcing our commitment to transparent and accountable sustainability reporting. Our early alignment towards the ESRS not only demonstrates our foresight and readiness for upcoming regulatory changes but also underlines our role as a leader in sustainable practices within the shipping industry. As we transition to these standards, we have made consid- erable efforts to ensure our sustainability disclosures comply with the ESRS framework. This includes a thorough review and analysis of all material aspects of our business operations and their impact, ensuring that our reporting is both comprehensive and meaningful. In line with our commitment to transparency and reliability of our sustainability reporting, NORDEN has obtained limited assurance on all its preliminary asessed material metrics and targets disclosure requirements as outlined by the ESRS index on p. 80. In conformity with the ESRS, NORDEN has performed a double materiality assessment during the reporting period. The assessment allows us to identify sustainability topics, which are material from a sustainability or financial perspective. The full description of our double materiality assessment process can be found on p. 73. In the assessment, NORDEN identified topics within climate change, pollution, DE&amp;I, health &amp; safety and business conduct to be mate- rial for us. In the table below, we provide a condensed overview of selected material topics and monitoring indicators for NORDEN. These highlight our sustainability focus with the monitor indicators we are actively working with. NORDEN’s material topics and monitoring indicators Sustainability priorities ESRS section Material topics Monitoring indicator 2023 2022 Ambitions Environmental E1 Climate Change Short term: 2% improvement per annum Efficient operation Enabling our customers TTW EEOI on all assets (million grammes CO2 per nautical mile) 9.0 9.9 to decarbonise their of our vessels Medium term: 16% by 2030 supply chains Total CO2e emissions from scopes 1 &amp; 2 ('000 tonnes) ¹ 3,835 4,287 Reduce GHG emissions to net zero by 2050 Decreasing value chain emissions Total CO2e emissions from scope 3 ('000 tonnes) 3,693 3,826 Reduce GHG emissions to net zero by 2050 Social S1 Own Workforce Overall Engagement Score (index) 84 83 &gt; Index 80 by 2025 Offering an inclusive, Diversity, Equity engaging, equal and Diversity (share of lowest represented gender) 41% 40% Minimum of 40% share of lowest represented gender safe working and Inclusion environment Retention Rate / Employee Turnover (%) 94% / 15% 94% / 9% &gt; 90% retention rate S2 Workers in Health &amp; Safety LTIR (per one million working hours) 1.0 0.8 &lt; 0.8 at all time value chain Governance G1 Business Conduct Sustainable Galvanising sustainable Procurement Suppliers screened for ESG (%) 55% NA 60% strategic suppliers by 2024 business conduct Staff completed e-learning course (%) 100% 99% 100% e-learning completed Anti-corruption and bribery Number of convictions and the amount of fines for violation of anti-corruption and antibribery laws 0 0 0 all time ¹ Location-based Scope 2 CASE STORY TAPPING INTO THE FUTURE SUPPLY OF RENEWABLE FUELS To assist customers in decarbonising their supply chains and push forward the green transition of the shipping industry, NORDEN has invested in a minority stake in MASH Makes – a Danish-Indian biofuel scale-up that researches, develops and produces renewable fuels from biomass waste. “We cannot rely solely on traditional offtake agreements with fuel suppliers to achieve decarbonisa- tion at the necessary speed that climate change requires. We need to be a greater part of the supply chain to ensure significant volumes and attractive prices that will make NORDEN competitive in offering low emission freight solutions to our customers,” says Jan Rindbo, CEO at NORDEN. “We are humbled that NORDEN has seen a potential in our platform and decided not only to invest, but also enter a strategic partnership with us. Joining forces with a partner like NORDEN is an oppor- tunity for us to accelerate the growth of our scale-up, as well as bring our biooil products to the marine fuel market,” says Jakob Andersen, CEO of MASH Makes. MASH Makes' first biooil product is in a late development stage and expects to conduct the first trial on-board NORDEN vessels in early 2024. Further- more, the expectation is that MASH Makes can gradually ramp up its production and become a significant supplier to NORDEN’s fleet within the next three years in strategically important locations. ENVIRONMENT At NORDEN, we are on the cusp of a monumental shift towards greener shipping – a transformation set to be one of the most significant in our history. With 3% of the world’s carbon emissions originating from the shipping industry, there is an urgent need for a collective push towards more efficient and sustainable freight solutions. NORDEN intends to be on the frontier of change, enabling our customers to decarbonise their supply chains. NORDEN is dedicated to assisting our customers in decarbonising their supply chains. Our commitment extends beyond our opera- tions as we contribute to innovative solutions through collaborations in industry organisations and exploring opportunities within the upstream production of green fuels. To focus our environmental efforts and maintain transparency and progression, we have identified two material topics on our environ- mental agenda: the efficient operation of our vessels and decreasing value chain emissions. The strategies and goals for these topics are an integral part of NORDEN’s six climate commitments. These commitments guide our immediate actions and shape our long-term aspirations: • Carbon Emissions Transparency: At NORDEN, we provide an estimated carbon emission report before every journey and a detailed post-voyage emissions breakdown. This transparency empowers our customers to consider the environmental impact alongside cost and schedule in their freight transport decisions. • Greener Shipping Solutions: We are at the forefront of devel- oping more sustainable shipping options. Our efforts range from utilising advanced analytics for optimising vessel efficiency to offering voyages powered by low emission biofuels. • Improving Operational Efficiency: NORDEN wants to help decar- bonise shipping with our strong emphasis on operational effi- ciency while growing our market share. • Net-zero Office Operations by 2027: With an internal goal set by our employees in 2022, we have focused on three main areas: green building initiatives, sustainable procurement practices and eco-friendly transportation options. • Zero-emission Vessels from 2030: We pledge that by 2030, all new vessels ordered by NORDEN will be equipped with zero-emission technology. • Net-zero Emissions by 2050: Achieving net-zero emissions by 2050 requires a paradigm shift towards zero-carbon fuels and innovative maritime technologies. NORDEN is engaging in indus- try-wide partnerships to drive this change. These initiatives and goals are not just about meeting regulatory requirements or industry standards; they reflect NORDEN’s deep- rooted commitment to environmental stewardship and our proactive role in shaping a more sustainable future for global shipping. ESRS E1: Climate Change Impacts, risks and opportunities Governance Our governance model closely aligns executive remuneration with our ESG strategy and initiatives, including climate action, dedicating 15% of Executive Management's compensation to sustainability objectives. This incentive structure is anchored to critical metrics and Tank to Wake EEOI. This KPI supports our strategic commitment to achieving net-zero emissions by 2050, fostering a transition to zero-carbon shipping and delivering on our strategic objective to decarbonise our customers' value chain. In the short term, we are focused on operational efficiency, targeting a 2% annual reduction in EEOI, equivalent to an implied medium- term target of a minimum 16% reduction in EEOI by 2030. This directly ties executive rewards to progress in reducing emissions and increasing efficiency, aligning our leadership's efforts with our ambition to lead in decarbonising our customers' value chain. NORDEN's transition plan is seamlessly integrated into its overall business strategy and financial planning, focusing on enabling customers to meet their decarbonisation commitments. Management is responsible for upholding NORDEN’s risk manage- ment policy and for overseeing and discussing strategic risks and opportunities. NORDEN’s risk profile and exposure are reported to the Board of Directors regularly. Internally, our Risk Committee assists the Board of Directors in its oversight of NORDEN’s overall risk-appetite and management of market, credit and liquidity risks as well as climate-related risks. Our decarbonisation team makes proposals as to how these opportunities and risks can be anchored in the commercial business. Our Audit Committee identifies and manages risks related to financial reporting and auditing, among others. The transition plan has received full approval by NORDEN's Board and is overseen by the ESG board, emphasising strong organ- isational commitment. In the reporting period, NORDEN reported a reduction in CO2 equivalent emissions of 7% and a 9% improvement in fleet-normalised TTW EEOI. Strategy NORDEN has articulated a transition plan aimed at achieving net-zero emissions by 2050 and a short-term reduction in EEOI of 2% per annum, implying a 16% reduction in EEOI by 2030 using 2022 levels as a baseline. The progress of EEOI reduction can be found on p. 54. In 2023, NORDEN has launched several different climate initiatives that enable us to deliver on our environmental ambitions and contin- uously work on implementing new initiatives. This includes volun- tary speed reduction, the elimination of chartering in the 5% worst polluting vessels and scheduling consistent hull cleanings to reduce resistance and enhance fuel efficiency. Additionally, NORDEN offers tailored green freight-solutions for our customers. Depending on the customers' needs, NORDEN can develop freight solutions for customers allowing them to reduce emissions by up to 85% on a well-to-wake (WTW) scope. In the short to medium term, NORDEN considers our carbon inset- ting offering and the investment in Mash Makes as key levers for our ambition to reduce EEOI by 2% per annum. Carbon insetting is a direct reduction of GHG emissions within the industry in which they have been generated. Carbon insets create a demand for low-carbon fuel and thus contribute to financing and accelerating the decarbonisation of the industry. Carbon insetting addresses this challenge by providing a mechanism allowing us to discon- nect the physical burning of biofuel on-board our vessel from the customer purchasing and claiming the associated emissions reduction. Through this mechanism, carriers such as NORDEN can sail on biofuel where possible in the fleet and offer a low-emission solution to all our customers at a competitive price, regardless of their trading routes and other constraints that would prevent them from sailing directly on low-carbon fuels. Currently, the supply of low-carbon fuels such as biofuel is limited both in terms of produc- tion and geographic availability. This means that it is not possible to offer biofuel sailing under the same conditions to all our customers looking to reduce maritime emissions within their supply chain. Therefore, carbon insetting is a vital component of delivering emis- sion reduction in the short and medium term. In the long term, NORDEN will be exploring the production of green fuels like ammonia or methanol to eventually provide CO2e-neutral freight services, highlighting our commitment to pioneering sustain- able shipping solutions. Risks and opportunities NORDEN's process for identifying and assessing climate-related physical and transition risks is conducted by an in-house team of specialists. This team thoroughly evaluates potential transitional and acute risks associated with climate-related scenarios, specifically the RCP 1.9 and RCP 8.5 pathways. These scenarios reflect a spectrum of possible future climate outcomes, from more optimistic low green- house gas concentration trajectories to high-emission scenarios. 2023 achievements &amp; initiatives • Lowered our fleet-adjusted EEOI on all assets by 9% in 2023, thus being well on our way to reach our target of 2% reduc- tion per year and a total reduction of 16% in 2030. • Implemented four climate initiatives with the ambition to demonstrate our proactive approach to environmental responsibility. The impact of our climate initiatives in 2023 resulted in a reduction of emissions by 5% or equivalent to running 25 vessels on green fuels. • Invested in the future supply of renewable fuels at competi- tive prices by investing a minority stake in the Danish-Indian biofuel scale-up, MASH Makes, a company that produces renewables from non-food biomass, enabling 2nd and 3rd generation biofuel. It positions NORDEN at the forefront of renewable fuel research and development, promising future access to innovative biofuels. • Entered into a green freight contract with Teck Resources Limited with the ambition to substantially reduce CO2 emis- sions in their steelmaking coal supply chain. This agreement is set to cut annual emissions from Teck shipments handled by NORDEN by 25%, amounting to a reduction of up to 6,700 tonnes of CO2e. This reduction is comparable to removing over 1,400 passenger vehicles from the road. • Launched our carbon-insetting solution, through a Book &amp; Claim system, to help our customers decarbonise their supply chains by bridging emission reductions made on NORDEN’s biofuel voyages with customers looking to reduce emissions. Based on the risk analysis, the team formulates mitigation actions to manage identified risks and leverages opportunities to enhance the company's resilience. This includes incorporating weather routing systems, diversifying business activities and investing in green technology. The team also explores opportunities arising from the transition to a low-carbon economy, such as the development of new green products or services, or improvements in operational efficiency. The company recognises that while its agile operator model typically shields it from significant impacts of physical climate risks, under the RCP 8.5 scenario, the increased frequency and intensity of extreme weather events could lead to higher risks of damage to ships and cargo, potentially eroding margins. To mitigate these risks, NORDEN is relying on extensive use of weather routing systems for pricing, securing comprehensive insurance coverage and carefully assessing freight contracts for chronic risks. As the maritime industry evolves rapidly with technological inno- vations, particularly in fuel sources and vessel efficiency, there is an inherent risk of our assets declining in value. This devaluation is a direct consequence of the transition towards low-emission tech- nologies and could potentially lead to assets becoming stranded before the end of their useful life. NORDEN operates an asset-light fleet strategy, which mitigates this risk. This approach enhances our agility and flexibility, allowing us to adapt more readily to techno- logical advancements and market shifts without incurring significant losses on asset value. By being an operator of assets, we mitigate the financial risk of declining asset prices that are tied to older, less efficient technologies. Climate mitigation policy As of 2023, NORDEN has not formally adopted a comprehensive climate mitigation policy. The primary reasons for this are twofold: firstly, the rapidly evolving landscape of climate science and policy has necessitated a cautious approach to ensure that any policy adopted is both current and forward-looking. Secondly, NORDEN has been in the process of ensuring extensive stakeholder engage- ment to align our policy with the broad interests and concerns of our customers, investors and regulatory bodies. NORDEN is committed to adopting a climate mitigation policy by the next reporting period. EU Taxonomy The purpose of the EU Taxonomy is to help stakeholders understand whether the economic activity of an undertaking is environmentally sustainable. Taxonomy eligibility and alignment are expressed through three KPIs: turnover, capital expenditure (CapEx) and operating expenditure (OpEx). NORDEN has taxonomy-eligible activities within the 'Sea and Coastal Freight Water Transport, Vessels For Port Operations, and Auxiliary Activities' category, based on the company’s turnover, CapEx and OpEx. NORDEN has aligned activities within turnover and CapEx, but not within the OpEx KPIs. The EU Taxonomy tables for all KPIs are located on p. 82. Please refer to the ESG accounting policies on the EU Taxonomy for the methodology behind our eligibility alignment assessment. Turnover: Taxonomy-eligible revenue is 78% for 2023, while Taxonomy-aligned revenue is 0% (rounded) for 2023. Capital expenditures: Taxonomy-eligible CapEx is calculated to be 100% for 2023, while Taxonomy-aligned CapEx is 4% for 2023. NORDEN does not have any technically aligned CapEx plan, but this is to be considered within the coming years. Operating expenditures: Taxonomy-eligible OpEx is 75% for 2023, while Taxonomy-aligned OpEx is 0% for 2023. Risk matrix In the table overview, we list key transitional and physical risks related to climate for NORDEN alongside mitigation and opportunities arising from these risks based on our analysis: Transitional risks Mitigating actions Opportunities Policy &amp; Legal • Implementation of new regulation which impacts NORDEN • Decreasing residual value risk by shifting exposure to operator • Asset-light operator model and able to quickly shift market more negatively than competitors. activities and being less dependent on the owned fleet. exposure and navigate new legislation. • Failure to comply with reporting and compliance regulations • Monitoring policy, legal and regulatory sustainability • Offering regulatory and carbon tax services to third parties in (ESRS, EU Taxonomy &amp; CII). landscapes. the NORDEN tanker pool. Technology • Accelerated decline in value of existing assets due to • Actively testing and operating zero-emission ships, investing • Agile model allowing NORDEN to perform relatively well technological innovation, e.g. fuel sources and vessel efficiency. in R&amp;D related to low-carbon fuels and, from 2030, only order compared to our peers. ships with zero-emission technology. • Offering innovative and sustainable freight solutions for our • Investing in data analysitcs to keep developing market leading customers. operational systems. Market • Declining demand for seaborne transportation services driven • Diversification of business activities. • Increasing market share through stronger branding and by lower demand for fossil fuel products and higher marginal • Providing green freight options by working with our partners to superior offering. costs (fuel costs, carbon tax, capital costs). co-create greener shipping solutions. • Empowering our customers to reduce their CO2e emissions • Premature investments in green freight products not aligned • Securing long-term alternative fuel supply contracts. by offering greener alternatives competitive with the price of with market demands. carbon. • Increasing funding cost and/or potential lack of funding • Providing logistic solutions supporting a circular economy. availability for activities not aligned with green investment • Book-and-claim offering. demands (e.g. EU Taxonomy, Poseidon principles and SBTi). • Insufficient supply of alternative fuel sources. Reputation • External stakeholders’ perception of NORDEN’s climate • Support industry-wide research within new forms of propulsion, • Delivering net-zero emissions from our operations by 2050. footprint and initiatives. green fuels, and eFuels with Mærsk McKinney Møller Centre for • Becoming an industry leader in helping customers decarbonise • Unable to attract and retain talented employees with high Zero Carbon Shipping. their supply chains. decarbonisation ambitions. • New and ambitious climate strategy. • Improving transparency in emissions reporting. Physical risks Acute • Margin erosion due to more frequent extreme weather events • Extensive use of weather routing systems when pricing and • Leveraging our use of data to improve predictions and decision- (e.g. drought or storm). assessing the risk of freight contracts. making. Chronic • Scarcity of water, impacting trade patterns and volumes. • Including the impact of chronicle risks when evaluating business • Expansion of logistics offerings to non-core activities via Assets • Rising sea levels, impacting port operations and trade patterns. opportunities. &amp; Logistics business unit. Material topics, metrics and targets Decreasing value chain emissions As part of our aspiration to decarbonise our customers’ supply chains, NORDEN aims to be carbon neutral by 2050. This is aligned with the climate ambitions outlined by the Danish government’s climate partnership with the Danish maritime sector of achieving carbon neutrality by 2050. Providing transparency is the first step towards decreasing value chain emissions, mapping the full extent of our GHG emissions and focusing on the ones, where NORDEN has a material impact. We apply a materiality threshold to our scope 3 categories to ensure focus on material sustainability topics. If any category is estimated to contribute less than 1% to the total scope 3 emissions, it falls below our materiality threshold and is deemed non-material for external reporting purposes. In line with this approach, although relevant, the following GHG scope 3 categories have been determined to be ‘material’, ‘relevant, but not material’ and ‘not relevant or material’: GHG scope 3 categories Relevant, Not relevant Material but not material or material • Purchased goods • Waste generated in • Upstream leased and services operations assets (reported in • Capital goods • Business travel scope 1) • Fuel and energy- • Employee • Downstream transpor- related activities commuting tation and distribution • Upstream transporta- • Investments • Processing of sold tion and distribution products • Downstream leased • Use of products sold assets • End-of-life treatment of products sold • Franchises Our total GHG scope 1, 2, and 3 CO2e emissions were 7.5m tonnes – a decrease of 0.6m tonnes compared to 2022. Scope 1 CO2e emissions have decreased by 11% year-on-year, while scope 3 CO2e emissions have decreased by 3% year-on-year. This is mainly driven by lower emissions related to purchased goods and services and upstream emissions on bunker, offset by increasing emissions from TCO vessels. Given our target of net zero by 2050, we must reduce emissions by 3.7% on an annual basis from 2022 levels to realise this ambition. CO2e emissions ('000 tonnes) 2023 2022 % Scope 1 GHG emissions 3,834 4,287 -11% Scope 2 GHG emissions (location-based) 0.4 0.4 19% Scope 3 GHG emissions 3,693 3,826 -3% - GHG 1: purchased goods and services 187 266 -30% - GHG 2: capital goods 18 6 189% - GHG 3: fuel and energy-related activities 823 904 -9% - GHG 13: downstream leased assets 2,665 2,650 1% Total GHG emissions 7,528 8,113 -7% In the short term, NORDEN expects absolute emissions to follow vessel day activity levels and market conditions while being offset by NORDEN’s climate initiatives. Efficient operation of our vessels Efficient operation of vessels is an integral part of NORDEN’s oper- ator business model. We monitor the vessels' fuel efficiency using the EEOI measure. On NORDEN’s owned and operated vessels, we continuously monitor fuel efficiency, determining optimal speeds and route planning. By distinguishing between operated and chartered-out voyages, we can identify the impact of our efforts, while still taking responsibility for all tonnage that we deliver to our customers by providing EEOI based on all assets. During 2023, TTW EEOI on all assets decreased from 9.9 grammes CO2/tonne-mile to 9.0, corresponding to a decrease of 9.9%. Adjusting EEOI for changes in fleet composition has a significant impact on tankers, with a like-for-like change of a negative 1.2% vs a negative 4.7% unadjusted. This is due to an increasing share of MR vessels in the current reporting year with higher fuel efficiency and lower EEOI compared to Handysize T vessels which constituted a larger part of our pool activities in 2022. The development in EEOI is driven by a combination of our climate initiatives and market dynamics making lower speeds more attrac- tive compared to the previous reporting period. Additionally, we have seen higher cargo and laden utilisation, improving the metric. NORDEN’s EEOI framework NORDEN uses the EEOI metric as a performance indicator for operational efficiency. EEOI measures the relationship between CO2 emissions from bunker fuel consumption and transport work (tonne-nautical miles). NORDEN reports three different versions of EEOI: 1. TTW all assets: For the entire fleet including TCO vessels and based on TTW emissions only. 2. TTW operating assets: For the operated fleet excluding TCO vessels and based on TTW emissions only. 3. WTW operating assets: For the operated fleet excluding TCO vessels and on a well-to-wake (WTW) basis, i.e. including upstream emissions related to the extraction, processing and transportation of bunker fuel for our vessels. This measure is presented on a CO2e basis. NORDEN's primary measure is the TTW EEOI all assets presented on a fleet-adjusted basis. NORDEN has divided EEOI into the main drivers that affect the performance, as this allows NORDEN to follow developments in the indicator on a more granular level. CO2e emission drivers are split into speed and bunker type, while transport work drivers are determined by cargo utilisation, laden utilisation, and fleet composition. The relationship between EEOI and the drivers listed is described as: Speed: EEOI is positively correlated with speed.Bunker type: EEOI is impacted by the WTT and TTW CO2eemissions related to the bunker type. Increasing the share of biofuel would decrease emissions and thereby EEOI. Cargo hold utilisation: Measures the utilisation of cargocapacity during a voyage. Cargo utilisation is a number between zero and one. Higher cargo utilisation would increase transport work and fuel consumption as more energy is required for propulsion at a given speed with more cargo. The effect of increasing cargo utilisation is a decreasing EEOI. Laden utilisation: Measures the relationship between ladenand total miles. Laden miles are miles, where the vessel carries cargo. Transport work is calculated as the product of nautical miles and cargo carried. Holding everything else constant, higher laden utilisation would increase transport work and decrease EEOI. Fleet composition: EEOI is highly impacted by fleet compo-sition. To make EEOI more comparable, NORDEN reports performance across vessel types and outlines the fleet-ad- justed EEOI, enabling a more transparent explanation of variations in the performance indicator year-on-year. Energy consumption and mix Perceiving energy consumption as a material sustainability impact, NORDEN reports on development in fuel consumption from crude oil and petroleum products, fuel consumption for renew- able sources and energy intensity in conformity with the ESRS. By monitoring these metrics, NORDEN aims to create transparency on the share of fuel consumption from renewable sources, allowing stakeholders to see progress on a medium and long-term basis. Furthermore, it allows stakeholders to distinguish between reduc- tions being created by operational decisions like reduced speeds and customers being willing to pay for green freight options, which is seen in an increasing share of renewable fuel consumption. Finally, we report on the share of heavy fuel oil (HFO) in our fuel consump- tion to provide transparency on whether reductions in air pollutants Summary of EEOI by vessel and type 2023 2022 WTW Ops TTW Ops TTW WTW Ops TTW Ops TTW TTW Ops Multi Purpose 28.5 23.9 23.9 Handysize 11.6 9.8 9.9 12.7 10.7 11.2 -8.8% Supramax 8.2 6.9 7.1 9.2 7.8 8.3 -11.9% Panamax 8.4 7.1 7.4 9.4 8.0 8.2 -11.3% Capesize 7.3 Dry cargo 9.2 7.8 7.9 10.1 8.5 8.9 -9.2% Fleet-Standardised 9.2 7.8 7.9 10.2 8.7 8.9 -10.6% Handysize T 27.5 23.0 22.9 25.3 20.9 20.8 10.1% MR 17.4 14.6 14.5 18.5 15.1 14.8 -3.3% LR2 6.0 5.1 5.1 Tankers 17.9 15.0 14.8 19.5 15.9 15.5 -6.0% Fleet-Standardised 17.9 15.0 14.8 18.8 15.3 15.0 -2.4% Total 10.7 8.9 9.0 11.8 9.9 9.9 -10.1% Fleet-Standardised 10.7 8.9 9.0 11.6 9.8 9.9 -8.5% are driven by a lower share of HFO, having high emission factors for pollutants like SOx and PM2.5. Share of HFO can be found in the SASB index on p. 79. NORDEN’s fuel consumption from renewable sources increased from 14,470 MWh in 2022 to 19,790 MWh in 2023. This corresponds to 0.1% of NORDEN’s fuel consumption on our operated vessels. Metric 2023 2022 Fuel consumption from crude oil and petroleum products (MWh) 13,861,56515,492,962Fuel consumption for renewable sources (MWh) 19,790 14,470 Energy intensity (USD/MWh) 266 343 In the table below, we have summarised performance from 2022 to 2023 of the key metrics that drive the development in EEOI. Performance summary Key metrics 2023 2022 Chg. Y/Y TTW EEOI (g CO2/tonne-mile) 9.0 9.9 -10% WTW EEOI (g CO2e/tonne-mile) 10.7 11.6 -7% Cargo hold utilisation 81.4% 79.9% 1.5 pps Laden utilisation 78.2% 76.8% 1.4 pps Avg. speed (kts) 11.3 11.7 -3% Avg. fleet DwT 61,316 59,906 2% Renewable fuel share 0.1% 0.1% 78% ESRS E2: Pollution Impacts, risks &amp; opportunities Maritime shipping, while efficient in terms of CO2e emissions rela- tive to the distance and weight of goods transported, presents multifaceted environmental challenges. The varied nature of ships, their cargo, fuels and materials render them complex entities with a broad environmental footprint that spans both air and water ecosystems. In terms of pollutants, vessels, through combustion and energy transformation for propulsion and power, emit a mix of air pollutants. The primary ones include sulphur oxides (SOx), nitrogen oxides (NOx) and particulate matter (PM). In addition, although less prevalent, ships emit non-methane volatile organic compounds (NMVOCs) and heavy metals into the air. These emis- sions are particularly concerning in high-traffic maritime areas and can travel great distances, affecting communities and regions far from the source. Efforts to regulate and reduce such emissions have led to a sustainability trade-off. The implementation of scrubbers to cut SOx emissions, for example, has resulted in an increased release of pollutants into the sea through wash water from scrubbers. These regulatory developments, while striving to curb high-sulphur bunker fuel use without scrubbers, illustrate the complex interplay between reducing atmospheric pollution and protecting water quality. Another complexity is related to our ambition to improve fuel effi- ciency and reduce the EEOI by applying anti-fouling paint. This is a special coating applied to the hull and, in some cases, to the propeller of a vessel to slow the growth and facilitate detachment of subaquatic organisms, commonly known as fouling, which attach to the hull and have a substantial impact on the vessel's hydrody- namic performance. Specifically, it will result in increased resist- ance through the water due to elevated friction resulting from the considerably rougher hull surface caused by the fouling. As a direct consequence, fuel consumption is expected to rise significantly. While improving fuel efficiency and hence reducing the relative CO2e emissions from vessel operation, there is an increased risk of water pollution related to the biocide effect of persistent anti-fouling components. The industry is starting to focus on this topic and new biocide-free coatings are available, but the effectiveness to prevent fouling growth is yet to be proven. Pollution policy NORDEN is following the industry standard enforced by the IMO. This approach ensures that we remain aligned with the best avail- able practices while we await regulation from policymakers. Not complying with the regulation of the IMO may lead to financial penalties, while potentially hurting business relationships by not demonstrating a commitment to environmental compliance. Both are considered material financial risks. Material topics, metrics and targets Pollution to air Perceiving air pollution to be material, NORDEN monitors and reports on emissions of NOx, SOx, PM2.5, NMVOC and HM in the air, which are significant air pollutants associated with maritime transport. These emissions largely originate from the combustion processes within ship engines and are a direct consequence of the fuels used. Having in-house specialists working with fuel efficiency and decarbonisation, NORDEN can apply leading practices to esti- mate air pollution beyond NOx and SOx emissions. A breakdown of development by air pollutant type can be found in the table to the right: Development by air pollutant type Units: Mt 2023 2022 NOx 101,678 115,028 SOx 9,894 10,880 PM2.5 4,546 5,035 NVMOC 4,147 4,636 Heavy Metals in Air 70 76 Pollution to water Based on the preliminary materiality assessment, NORDEN reports the emissions of heavy metals and polycyclic aromatic compounds (PAHs) into the water. These pollutants stem from the operation of vessels having installed and using open-looped scrubbers. Wash- water from this carry pollutants into water. Total pollutants in water have decreased from 39 metric tons in 2022 to 30 metric tons in 2023. Heavy metals in water have decreased from 38 metric tons in 2022 to 29 metric tons in 2023, while PAHs have decreased from 1.2 metric tons in 2022 to 0.9 metric tons in 2023: Development in pollutans in water Units: Mt 2023 2022 Heavy Metals in Water 29 38 PAHs 1 1 In addition to the pollutants above, NORDEN tracks the ecological impact of our operations through the performance indicators from the SASB Marine Transportation Standard including spills, voyage duration in marine-protected areas and share of vessels having implemented BWTS. Development in these performance indicators can be found in the SASB table on p. 79. SOCIAL NORDEN is a people-driven business, and we continuously work to strengthen our position as an attractive employer, offering an inclusive and engaging working environment, in which all employees have equal opportunities to realise their potential - all elements critical to operating a high-performing organisation. At the heart of NORDEN's sustainability framework lies a commit- ment to fostering a working environment built on a strong founda- tion of Diversity, Equity &amp; Inclusion (DE&amp;I) and ensuring the health and safety of seafearers working on our vessels. ESRS S1: Own workforce Impacts, risks and opportunities NORDEN has identified DE&amp;I as the main area of impact on our own workforce. Creating a positive and inclusive working environment is key to employee satisfaction and performance. Working glob- ally and across cultures, teamwork and collaboration are essential, fostering a culture that values open communication, mutual respect and equal opportunities. NORDEN's emphasis on DE&amp;I intends to create an environment where employees feel valued and motivated, ultimately driving innovation and decision-making. The shipping industry's historical male dominance presents both a challenge and an opportunity for NORDEN. Embracing DE&amp;I is not just about fair- ness and ethical responsibility; it is business critical. Diverse teams bring varied perspectives, experiences and ideas, which are critical in a dynamic and globally interconnected industry. By improving diversity figures, NORDEN is not only setting a progressive example but also enhancing our potential performance. On an industry level, NORDEN empowers the diversity agenda through Women In Shipping (WIS), which is a professional network with the aim of strengthening women in shipping and achieving more diversity and equality in the industry. NORDEN is represented in the Advisory Network and on the Board. In 2023, NORDEN co-cre- ated an event with attendance of over 150 participants from the industry. NORDEN conducts ongoing social impact discussions through our ESG Executive Body and through an annual double materiality assessment with in-house topic specialists. The impacts identified through these sessions influence our strategy and initiatives. NORDEN’s workforce is pivotal to our success, creating material risks related to lack of DE&amp;I as these may significantly affect employee satisfaction and the ability to attract new talent. To manage these risks, NORDEN regularly monitors and reviews workforce-related metrics, while fostering open communication channels for employee feedback and implementing policies that promote diversity and inclusion. By investing in DE&amp;I, NORDEN aims not only to mitigate risks but also to create a resilient and agile organisation capable of adapting to changing market demands and sustaining a competitive edge in the maritime industry. By promoting an inclusive culture, NORDEN is likely to maintain the position of an attractive employer for new talent and strengthen our ability to retain employees, reducing the costs of hiring and integrating replacements. NORDEN has articulated several policies to address and mitigate the risks related to the material topics, most which are listed here: https://norden.com/about/governance/policies-and-charters and all of them are described on p. 77. biases that might influence the decision-making process when hiring and promoting. ESRS S2: Workers in the value chain Impacts, risks and opportunities Managing and maintaining excellent working conditions are busi- ness critical to NORDEN – both when it comes to its own workforce and workers in the value chain. Our ambition is not only to ensure compliance with international legislation but also to set higher standards. Having outsourced the technical management of owned vessels, our seafarers are classified as workers in the value chain in conformity with the ESRS, making Health &amp; Safety for workers in the value chain a material topic for us. Operating at sea involves safety and security risks that must always be managed carefully to safeguard the crew and external personnel. Outsourcing technical management and upholding a service that complies with interna- tional law and NORDEN’s standards require a close, continuous dialogue and a comprehensive reporting framework, to ensure trust in the technical manager’s operation. There are consequences associated with outsourcing services such as technical management as physical distances and differences in corporate culture create the risk of incidents being left unreported and an undesirable culture going unnoticed which, in ultimate consequences, may have a negative effect on NORDEN’s reputation. NORDEN's responsibility is to investigate and manage these salient risks. NORDEN regularly monitors and reviews metrics associated with workers in the value chain, while fostering open communica- tion channels for feedback. NORDEN furthermore developed and implemented a Technical Manager Code of Conduct that supports a working environment with a sustainable culture and a strong focus on health and safety. NORDEN believes that enhancing the rights and well-being of seafarers directly correlates with improved performance on vessels and success in both recruiting and keeping talented workers. Furthermore, this commitment to seafarers' well-being aligns NORDEN with stakeholders who share similar values, fostering stronger business relationships. NORDEN's approach to managing the relationship between material risks and opportunities related to impacts on workers in the value chain and dependencies is centred on proactive engagement. NORDEN has articulated several policies to address and mitigate the risks related to the material topics, most which are listed here: https://norden.com/about/governance/policies-and-charters and all of them are described on p. 77. Material topics, metrics &amp; targets Health &amp; Safety In 2023, NORDEN conducted ongoing inspections on board our vessels. In addition, we visited the offices of our technical managers and attended crew seminars to assess their approach to safety. During these visits, we emphasised our focus on safety and the general health of the seafarers and contractors working on board our vessels. On-site visits enable NORDEN to evaluate our technical managers’ approach to safety, as well as the safety culture they are striving to uphold and implement on board the vessels through training of crew and safety campaigns targeting critical work processes on-board. NORDEN aims to set the same high standards for safety and optimal working conditions on board vessels as we do onshore. We continu- ously ensure that our technical managers meet these standards. The number of injuries, owing to which crew members were unable to work the following day (primarily related to shoulders, arms, neck and hand injuries), is measured through the Lost Time Incident Rate (LTIR). LTIR is measured as lost time incidents per one million working hours. Overall, LTIR increased to 1.0 in 2023 based on four incidents in 3.9 million exposure hours. In 2023, there was an increase in LTIR. Following the increase in LTIR over the year, several campaigns have been launched targeted towards the nature of the specific injuries but also general safety awareness campaigns to heighten the focus on routine tasks. During 2024, NORDEN will focus on inspections of owned vessels, conducting office visits and attending crew seminars to support technical managers in developing high health and safety standards and avoiding accidents on board owned vessels. Focus will be on investigating whether new preventive measures should be taken to decrease LTIR and evaluating all technical managers through EcoVadis. NORDEN will implement a new HSEQ position with the purpose of creating a strategy and process for existing and new business areas within health, safety and well-being. Working with human rights As an integrated part of the global supply chain, NORDEN plays an important role in upholding human rights and taking proactive measures to prevent and mitigate human rights violations. NORDEN is dedicated to respecting internationally recognised human and labour rights as stated in the International Bill of Human Rights and the International Labour Organisation's Declaration on Fundamental Principles and Rights at Work. Our policies and practices are in strict compliance with the United Nations Guiding Principles for Business and Human Rights (UNGPs), reflecting our commitment to human rights. NORDEN has a responsibility to consider any human rights violations it may cause, contribute to, or be directly linked to. Therefore, every second year, NORDEN conducts a Human Rights Impact Assessment (HRIA) that forms the basis for controlling the policies and procedures of NORDEN's operations. The scope of the assessment is own workforce, tier 1 and significant tier 2 suppliers. For NORDEN, tier 1 suppliers are technical managers, and significant tier 2 suppliers are suppliers linked to vessel operation through technical management services. NORDEN utilises a mixed-method approach combining qualitative and quantitative data, including surveys, interviews with stakeholders, employees, managers and partners and on-site inspections, ensuring an in-depth understanding of the potential risks and that diverse perspectives are considered and respected. NORDEN takes a systematic identification approach to potential human rights risks, followed by a prioritisation process based on severity and likelihood of impact. When conducting HRIAs, NORDEN follows best-practice recommendations set forth by the UNGPs, Danish Shipping and the Danish Institute for Human Rights. The findings from the HRIA assessment, along with proposed preventive and mitigating actions, were thoroughly reviewed and approved by the responsible ESG Executive Body representative. The HRIA serves as a foundational tool for continuously refining and improving our human rights policies and procedures and maintaining an ongoing active dialogue with all stakeholders. NORDEN is committed to transparently communicating the findings of our HRIAs. NORDEN has established easily accessible channels for employees and external stakeholders to report human rights grievances and ensuring timely and effective responses to grievances, with clear accountability and remediation processes, ensuring responsiveness to any concerns raised either internally or in the value chain. To enforce the policies commitment, employees are trained in the respective requirements of the policies through our Employee Code of Conduct and are required annual acknowledgement to ensure aware- ness and understanding of any revisions as part of their conditions for employment. 2023 milestones • Developed and implemented a Technical Manager Code of Conduct, outlining common principles for how to adhere to social, ethical and environmental standards. This has been signed by all technical managers. Launched an annual Speak Up campaign to ensure awareness of the different reporting channels and processes, for breaches of human rights and other kinds of misconduct. NORDEN reports on the number and nature of whistleblower reports received in the Governance section on p. 62. Introduced screening of strategic suppliers using EcoVadis to assess their ESG performance, including human rights observance. Looking ahead In 2024, NORDEN will continue to define and prioritise areas for actions. A new human rights impact assessment will be carried out, and its findings will be compared with those of 2022, to assess areas requiring further attention. GOVERNANCE Our governance framework is designed to align with the enduring interests of our stakeholders and to manage NORDEN's operations in adherence to all pertinent local and global regulations. We are committed to maintaining the highest ethical standards within our business practices. Operating internationally, NORDEN is mindful that standards of integrity and proper business conduct may differ across regions, presenting unique challenges. Recognising the severe consequences of non-compliance, including legal action and damage to our reputa- tion, we prioritise robust governance to prevent corruption and define clear expectations for ethical behaviour in all our markets. Our unwa- vering commitment to combatting corruption underpins our goal of enabling smarter global trade. ESRS G1: Business conduct Impacts, risks and opportunities NORDEN's governance structure is designed to integrate sustaina- bility targets seamlessly with strategic business objectives. The Board of Directors oversees ESG governance, while the ESG Executive Body, comprising Senior Management and specialists from core operational areas, formalises strategy and policies. ESG accountability resides at board level, with ESG owners within business functions driving initia- tives to meet our targets. Performance measured against performance indicators is reported quarterly to the Board, ensuring continuous alignment with our ESG goals. Our Board members possess collective expertise in global shipping management, strategy, financial oversight and risk manage- ment, ensuring informed guidance in business conduct matters. This expertise underpins our commitment to ethical business practices and supports our ability to navigate the complexities of international trade and sustainability. NORDEN actively establishes, develops and promotes a corporate culture rooted in compliance and ethical integrity. Our culture is designed to mitigate reputational risks and clarify behavioural expec- tations for all employees, including the Board of Directors. The Head of Asset Management oversees the ownership and enforcement of our Anti-Corruption Compliance Programme, and our CFO oversees overall governance of the Company. Our corporate values and expectations are outlined in the Employee Code of Conduct, accessible on the Intranet and disseminated to new hires during onboarding. We require annual acknowledgement of the Code to ensure awareness and understanding of any revisions, thereby maintaining a culture of compliance and integrity. Whistleblower scheme NORDEN upholds an environment that encourages and protects best practices. Since 2011, we have maintained an independent whis- tleblower scheme to empower employees and external partners to report any operational or workplace concerns, ensuring the confiden- tiality and anonymity of the reporting party. Concerns can be raised directly with direct managers, the HR department or through the whistleblower scheme. Reports received are handled by the Chair and Vice Chair of the Board of Directors, along with the Head of Group Legal, ensuring a thorough and impartial investigation. In 2023, a total of six whistleblower reports were received. The majority of the cases concerned working conditions for seafarers, whereas others related to GDPR. All cases were investigated and actions to address the complaints were carried out when required. NORDEN has a strict non-retaliation policy vital to ensuring that employees feel safe speaking up. Responsible tax As a company with global reach, NORDEN operates in multiple juris- dictions with different tax rules and regulations. NORDEN complies with the current tax legislation in the countries in which we operate, and we comply with all applicable transparency rules, including coun- try-by-country reporting. NORDEN does not use so-called tax havens according to the European Union tax haven blacklist. Sanctions Due to the global nature of the shipping industry and the constantly evolving geopolitical landscape, navigating sanctions requires an agile and comprehensive approach to compliance, continuously assessing risks and adapting strategies to align with evolving inter- national laws and regulations. In NORDEN, sanctions compliance is embedded in all parts of our organisation, as it is part of our daily operations, conducting business in almost all countries in the world. It is implemented by having a robust sanctions compliance framework, a specialist sanctions team and formal processes and procedures in place to handle sanctions. Impacts and risk Following the double materiality assessment conducted during the reporting period, NORDEN has identified sustainable procurement, anti-corruption and bribery as our material impacts when it comes to governance. The maritime industry is inherently international, which makes anti-corruption and bribery measures critically important. For a company like NORDEN, with a vast operational reach, the ability to ensure transparent and ethical business practices across various legal and cultural landscapes is not just a regulatory requirement but a fundamental aspect of maintaining our licence to operate and safeguarde our reputation. Therefore, the risk of non-compliance in this area is considered material, as it may have significant legal conse- quences and undermine stakeholder trust. Sustainable procurement is another topic of material significance. Our procurement practices directly impact our environmental footprint and social responsibility. It also influences our resilience against supply chain disruptions, which have become increasingly relevant in the face of global challenges. The material risks here include potential environmental damage and 2023 achievements &amp; initiatives • Successfully renewed our EcoVadis certification and has been recognised by EcoVadis as being in the world’s top 5% sustainable companies within the shipping industry, achieving a gold score for the first time. The framework ensures NORDEN is measured against the latest sustaina- bility criteria. • Embedded sustainable procurement into the organisation and managed to screen 55% of our strategic suppliers for ESG criteria. • NORDEN actively contributed to the elimination of all forms of maritime corruption on a more systemic level through our active engagement with MACN, which serves as a strong collective voice against corruption. • In 2023, we renewed our TRACE certification. To achieve a TRACE certification, companies must undergo a heavily benchmarked and comprehensive due diligence review, analysis and approval process. This certification ensures that a company has been thoroughly vetted and trained. the repercussions of associating with suppliers who may not adhere to our sustainability criteria, which could have far-reaching conse- quences for our business and the communities we engage in. Material topics, metrics and targets Sustainable procurement As a globally operating company, we interact with numerous suppliers around the world, and it is a priority for NORDEN to ensure sustainable procurement in collaboration with our external stake- holders. NORDEN seeks to enable sustainable procurement by inte- grating ESG matters into our procurement processes and decisions. During 2023, NORDEN began assessing and working with our stra- tegic suppliers, i.e. suppliers that are critical to business operations, to become more sustainable. Working through a partnership with EcoVadis, we have begun to identify areas of potential risks and work with our suppliers to reduce it. As we gain more knowledge of our suppliers’ activities, we are better equipped to make decisions in relation to our sourcing strategy. Looking ahead, we will continue our focus on securing ESG score- cards on strategic suppliers and establish a baseline for improve- ment plans. Sustainable procurement continues to be anchored in the procure- ment operating model. NORDEN's progression towards fully anchoring sustainable procurement consists of five steps, outlined in the illustration on the right. This is the process that will continue to apply as we map and grow to understand our suppliers’ value chains. In 2023, we were able to assess 55% of our strategic suppliers for ESG criteria, and based on that, we have been able to identify suppliers we want to follow more closely. The KPI set out for 2024 is to ensure that 60% of our strategic suppliers have been screened for ESG criteria by 2025. During 2024, NORDEN will work on increasing the focus on iden- tifying risks among strategic suppliers, getting scorecards and corrective action plans, while improving due diligence and auditing. We will work on further embedding sustainable procurement across the business and conduct at least one on-site supplier visit. Lastly, we will continue our focus on preparing for legislation on sustainable procurement following the ESRS. Material topics, metrics and targets Anti-corruption and bribery NORDEN calls numerous ports all over the world every single day. Occasionally, NORDEN faces challenges, particularly in countries where corruption presents a higher risk. In this business context, making the right choice becomes more complex, yet increasingly important, as non-compliance may entail legal and reputational risks and damage our licence to operate. Corruption is one of NORDEN’s material topics, as it impedes access to global markets and constitutes economic and social development barriers. For NORDEN, corruption escalates costs and endangers the safety and well-being of the workers in our value chain, while posing legal and reputational risks. Therefore, NORDEN takes firm measures to prevent any form of corruption as part of our ambition to enable smarter global trade. In 2023, NORDEN had 9,496 port calls across 136 countries. Following the SASB Marine Transportation standard, NORDEN reports on the number of port calls in the world's 20 most corrupt countries, applying the Corruption Perception Index. The result indicates an increase in port calls with a high risk of corruption from 2022 to 2023. The recent increase in high-risk port calls has been analysed to understand the underlying factors and potential risks. No changes to the current set-up were deemed necessary due to the increase. NORDEN conducts risk assessments at country level and job func- tion level. The assessment makes it possible for us to conduct an integrity risk assessment resulting in a corruption risk map from which we can devise a possible action plan. In order to address the appropriate compliance training requirements for employees, identification of specific risks linked to departments and job func- tions have been undertaken and resulted in a categorisation where different roles are required different training. This assessment enables NORDEN to identify risks, trends and finan- cial impact on the business and ensure necessary training. Based on these analysis, NORDEN reviews the Anti-Corruption Compliance programme at least every second year. NORDEN has set up an anti-corruption working group consisting of representatives from Senior Management and anti-corruption specialists. The group meets monthly to analyse and discuss risks and actions. NORDEN takes a systematic approach to assess corrup- tion and bribery risks, particularly in countried deemed high-risk. Furthermore, specialist are dedicating time to conducts country risk assessments and engage with masters guiding on the specific challenges for the port of call. UN Global Compact NORDEN’s CEO, Jan Rindbo, comments: "NORDEN remains committed to upholding the principles of the UN Global Compact and supports the worldwide movement to accelerate and scale the collective impact of responsible and sustainable business. In May 2023, NORDEN submitted its 2023 Communication on Progress (COP) in line with new requirements.” NORDEN adheres to the following UN Sustainable Devel- opment Goals (SDGs), which are mapped to each of the E, S and G-related activities that we consider relevant to our core business: Environment: • 13.1: Strengthen resilience and adaptive capacity to climate-related hazards and natural disasters in all countries. • 17.16: Enhance the global partnership for sustainable devel- opment, complemented by multi-stakeholder partnerships that mobilise and share knowledge, expertise, technology and financial resources, to support the achievement of the sustainable development goals in all countries, in particular developing countries. Social: • 5.5: Ensure women’s full and effective participation and equal opportunities for leadership at all levels of deci- sion-making in political, economic and public life. • 5.C: Adopt and strengthen sound policies and enforceable legislation for the promotion of gender equality and the empowerment of all women and girls at all levels. • 8.5: By 2030, achieve full and productive employment and decent work for all women and men, including for young people and persons with disabilities, and equal pay for work of equal value. • 8.7: Take immediate and effective measures to eradicate forced labour, end modern slavery and human trafficking and secure the prohibition and elimination of the worst forms of child labour, including recruitment and use of child soldiers and by 2025 end child labour in all its forms. • 8.8: Protect labour rights and promote safe and secure working environments for all workers. • 10.2: By 2030, empower and promote the social, economic and political inclusion of all, irrespective of age, sex, disa- bility, race, ethnicity, origin, religion or economic or other status. • 10.3: Ensure equal opportunity and reduce inequalities of outcome, including by eliminating discriminatory laws, poli- cies and practices and promoting appropriate legislation, policies and action in this regard. Governance: • 16.5: Substantially reduce corruption and bribery in all their forms. Furthermore, NORDEN conduct due diligence of business relations as an integrated part of NORDEN's business conduct, ensuring compli- ance with legal requirements, stakeholders’ expectations, improving internal decision-making, raising risk awareness and protecting NORDEN’s reputation. NORDEN has a complex third-party landscape and currently has different due diligence procedures in place for various third-party groups. The main third-party groups in NORDEN are Agents, Brokers and Suppliers. All NORDEN’s third-party contacts are screened daily on a number of potential risk factor issues, including sanctions lists, global law enforcement lists, vessel information and politically exposed persons. NORDEN has zero tolerance towards bribery and our Anti-Corruption Policy clearly outlines the refusal of all types of facilitation payments. To ensure a culture of exemplary conduct with strong procedures, NORDEN has an Anti-Corruption Compliance Programme in place. The programme helps ensure that corruption and bribery risks are identified, that concerns are reported and that measures are taken to mitigate any identified risks throughout the organisation. Further, this programme covers third-party responsibility, gift and entertainment, commissions, conflicts of interest, sponsorships and political and charitable contributions as topics within the broader compliance agenda. The purpose is to mitigate corruption by monitoring the effectiveness of the programme, any mitigation plans and ensure the prevention of future corruption. In 2023 the focus was how to best encourage continuous improvement of internal reporting mechanisms, conducting awareness campaigns and internal training. NORDEN’s Anti-Corruption Programme is incorporated into NORDEN’s Employee Code of Conduct which is provided to new hires during onboarding and must be acknowledged annually by all employees to ensure comprehension of any updates. To ensure compliance with the programme, a Compliance Manager has been appointed. The role of the Compliance Manager is to ensure that relevant policies and procedures are followed and that risk assessment, due diligence and monitoring are conducted regularly. NORDEN’s Compliance Manager reports to the CEO if issues arise, which must be addressed immediately or discussed. The Compliance Manager provides regular updates to the ESG Executive Body. NORDEN has articulated several policies to address and mitigate the risks related to the material topics, some of which are listed here: https://norden.com/about/governance/policies-and-charters and all of them are described on p. 77. NORDEN continues to be an active member of the Maritime Anti-Corruption Network (MACN), a network working to eliminate all forms of corruption in the maritime industry and enables fair trade to the benefit of society at large. MACN’s members represent more than 50% of total global tonnage. MACN and its members work with raising awareness of the challenges faced, implementing anti-cor- ruption principles, co-developing and sharing best practices, colla- borating with governments, non-governmental organisations and civil society to identify and mitigate the root causes of corruption and creating a culture of integrity within the maritime community. In high-risk areas where MACN has introduced collective actions, the reported corruption requests have dropped. On behalf of NORDEN, our external technical managers carry out anti-corruption training for the workers in our value chain to ensure alignment with legislation and NORDEN’s Anti-Corruption Compli- ance Programme. NORDEN requires its technical managers to be members of MACN and promotes awareness internally and exter- nally regarding MACN tools and helpdesks. For chartered vessels, an anti-corruption instruction is sent to captains and agents. NORDEN tracks performance through two indicators: Eligible employees trained in NORDEN’s anti-corruption course in the current year, as well as number of confirmed bribery cases. NORDEN requires all employees to take an e-learning course annu- ally on anti-corruption. All eligible employees (excluding employees on leave, long-time sickness, etc.) passed the course in 2023. The anti-corruption course focuses on the complexity of corrup- tion and trains employees to identify and assess situations in which corruption can occur. Additionally, employees are trained in the severity of corruption and potential consequences. The course covers topics such as anti-corruption practices, bribery and facili- tation payments, gift and entertainment, conflicts of interest, indi- rect bribery via commissions, fraud, third-party procedures and NORDEN’s whistleblower scheme. In 2023, NORDEN had zero bribery cases in line with our ambitions. In 2024, NORDEN will implement steps to further improve the measuring of the effectiveness of the Anti-Corruption Compliance Programme and engage further with MACN on systematic chal- lenges and risks. ESG ACCOUNTING POLICIES The reporting boundaries The ESG report comprises activities in the parent company and all subsidiaries. The accounting policies are applicable for the reporting period: 1 January – 31 December 2023. ESG metrics follow the below boundaries unless otherwise specified: • Owned and leased vessels (excl. time chartered-out ('TCO') and third-party pool-managed vessels). Employees on shore (scoped as own workforce).Crew on board vessels (scoped as workers in the value chain).All NORDEN offices across the world.In our preparation for the European Sustainability Reporting Standards (‘ESRS’), NORDEN has adjusted some accounting poli- cies compared to the previous year to align reporting to material disclosure requirements. In most cases, the conformity to ESRS has required a change of reporting format, but not changes to accounting policies. Statement on carbon insetting The greenhouse gas emission intensity information presented in the report reflects calculations that account for allocation of low emis- sion transport activity to selected customers. The emission intensity presented is therefore not appropriate for use in customer-specific greenhouse gas emission calculations. Changes to accounting policy and previously reported metrics Following the Group's double materiality assessment, emissions related to GHG 5: Waste from operations, 6: Business Travel and 7: Employee Commuting are no longer part of NORDEN’s exter- nally reported emissions data and are therefore removed from the accounting policies. GHG 2: Capital Goods have been added to our scope 3 reporting framework. In conformity with the material topics and related disclosure require- ments identified in the double materiality assessment of topics in the ESRS, we have added the following accounting policies: - ESRS E1-5: Fuel consumption from crude oil and petroleum products. - ESRS E1-5: Total energy consumption from renewable sources. - ESRS E1-5: Energy intensity based on net revenue. - ESRS E1-6: GHG intensity based on net revenue. - ESRS E1-7: GHG removals and storage projects in the value chain - ESRS E1-7: GHG emission reductions or removals by the purchase of carbon credits. - ESRS E2-4: Particulate matter 2.5 (‘PM2.5’). - ESRS E2-4: Non-methane volatile organic compound (‘NMVOC’). - ESRS E2-4: Heavy metals (‘HM’). - ESRS E2-4: Polycyclic aromatic compounds (‘PAH’). - ESRS S1-6: Total number, employee turnover. - ESRS G1-4: The number of convictions. Additionally, we have made the following adjustments to accounting policies and previously reported metrics: - Change in global warming potential (‘GWP’) values: Aligning to the ESRS, GWP values changed to values from the IPCC Assess- ment Report 6 (‘AR6’). Change in GWP values increases the CO2e emissions by approximately 0.5%. - Change in CO2equivalents (CO2e): CO2e was in previous years calculated by applying the emission factors from ICCT (2021a), which included black carbon (‘BC’) in the estimation of CO2e. The ESRS states that CO2e should include emissions of CO2, CH4, N2O, HFCs, PFCs, SF6 and NF3, while additional GHG may be consid- ered when significant. Since BC is not a GHG, it is no longer part of our CO2e. BC is estimated as part of PM10 and PM2.5. The impact of removing BC from the CO2e is more than 5%, which results in a restatement of previously reported figures. Since we are already required to restate reported figures, NORDEN has applied new emission factors from FUEL EU aligning with industry consensus and practice within the organisation. The change requires a restatement of scope 1 GHG emissions, GHG 3: Fuel and ener- gy-related activities and GHG 13: Downstream leased assets. - Change in NOX and PM10: Updated measures for air pollution now consider the different levels of specific fuel oil consumption (SFOC) on the main vs. auxiliary engine. NORDEN assumes SFOC of respectively 175 and 195 g/kwh. This change impacts the air pollution metrics NOx and PM10. NORDEN has not restated previ- ously reported figures since the changes to historically reported figures are below our threshold of 5%. Data quality and data collection The reporting principles of balance, clarity, accuracy, reliability, timeliness and comparability are applied when collecting informa- tion and data that form the basis for NORDEN’s ESG performance. NORDEN has built and implemented models for reporting environ- mental KPIs based on data from our Integrated Maritime Operations System (IMOS) and Spinergie for logistic operations in Gabon. Besides providing more insights into the development of key indica- tors for fuel efficiency, the models allow for checking and reporting extreme observations and enable NORDEN to identify potential errors on an ongoing basis. This ensures the accuracy and reliability of data points reported for internal and external stakeholders. The HR department enters HR data into our HR system, Fairsail. Post data entry, HR personnel can immediately review, analyse, and visualise the impact of their data entry in our HR visualisation tool. This tool allows for an instantaneous check, ensuring that the data aligns with actual HR metrics and facilitating any necessary correc- tions or updates in real time. Subsequently, numbers are checked and validated by our finance department before being shared with internal and external stakeholders. Other social KPIs stem from our technical managers. Numbers are reported monthly and validated by our internal technical department and finance department. Having implemented the SASB Marine Transportation standard in 2022, NORDEN reports values for the previous two years allowing for comparability. All accounting policies following the accounting standards from the SASB Marine Transportation reporting standard are mrked by “TR-MT”. The SASB reporting standard can be found at https://www.sasb.org/standards/download/?lang=en-us During the reporting year, NORDEN initiated the process of complying with the upcoming ESRS requirements. All metrics calcu- lated in conformity with the ESRS are listed in the ESRS Index table, which can be found on p. 80. The development of company-specific material ESG performance indicators can be found in the ESG Materiality Matrix in the introduc- tion section while supporting indicators are disclosed in the rele- vant sections of the ESG report. Accounting metrics from the SASB Marine Transportation standard can be found on p. 79. NORDEN applies a 5% threshold for changes to previously reported emission figures in the ESG statements. Differences below the selected threshold will be accounted for in the current reporting period. Changes to previously reported figures are monitored continuously in our internal controls and reporting tools. For inclusion of GHG categories, NORDEN applies a 1% materiality threshold of total scope 3 emissions to ensure focus on our main impacts. Although not part of external reporting, NORDEN esti- mates and tracks development in all relevant GHG categories and will include GHGs, when they exceed the 1% materiality threshold. Environmental performance Energy consumption Total energy consumed (TJ): Calculated by adding up tonnes of fuel and electricity usage, applying their higher heating values (HHV) of 40.2MJ/kg for heavy fuel oil, 42.7MJ/kg for distillate fuel oil, 41.7MJ/ kg for very low sulphur residuals, 37 MJ/kg for biofuel, and 0.0036 MWh/TJ for electricity. Following TR-MT-110a.3., but NORDEN reports on total energy consumed in TJ instead of GJ. Total energy consumption from fossil sources (MWh): Following ESRS E1-5. Since NORDEN is in one of the high climate impact sectors as defined in the ESRS, we must disaggregate into fossil sources. However, only the fuel consumption from crude oil and petroleum products is relevant to NORDEN. Calculated by adding up tonnes of fuel and electricity usage, applying their higher heating values (HHV) of 40.2MJ/kg for heavy fuel oil, 42.7MJ/kg for distillate fuel oil, 41.7MJ/kg for very low sulphur residuals. Total energy consumption from renewable sources (MWh): Following ESRS E1-5. Includes fuel consumption on operated voyages for renewable sources including biomass (also comprising industrial and municipal waste of biological origin), biofuels, biogas, and hydrogen from renewable sources. Calculated by adding up tonnes of fuel and electricity usage, applying the higher heating values of 37 MJ/kg for biofuel. Energy intensity (MWh/USD): Following ESRS E1-5. Calculated as the total energy consumption (MWh) per net revenue (USD). Heavy fuel oil as a % of total energy consumed: Following TR-MT- 110a.3. Calculated as the heavy fuel oil consumption multiplied by 40.2MJ/kg and divided by the total energy consumed from bunker consumption on owned or operated voyages. Renewables as a % of total energy consumed: Following TR-MT- 110a.3. Calculated as the biofuel consumption multiplied by 37MJ/ kg and divided by the total energy consumed from bunker consump- tion on owned or operated voyages. Energy efficiency operational indicator (gCO2 /cargo-nauti- cal-mile): The energy efficiency operational indicator (EEOI) is a measurement of energy efficiency and is defined as the amount of CO2 emitted per tonne of cargo transported 1 nautical mile. Trans- port work expresses the mass of cargo transported over distance, as registered in the Integrated Maritime Operations System (IMOS). The relative relationship between CO2 emitted and transport work measures the fleet’s operational efficiency. NORDEN provides EEOI with different boundaries: 1.EEOI TTW on operating assets: vessels operated by NORDEN,based on tank-to-wake (TTW) emissions, and only including CO2 emissions using factors from FUEL EU. 2. EEOI WTW on operating assets: vessels operated by NORDEN but based on well-to-wake (WTW) emissions and reported in CO2 equivalent emissions using the 100-year horizon GWP values from AR6 and FUEL EU. 3. EEOI TTW on all assets: including TCO vessels, based on TTW emissions, and only including CO2 emissions using factors from AR6 and FUEL EU. All metrics are reported per vessel type. Logistics operation is not included in EEOI. Greenhouse gas emissions CO2 equivalent emissions (1,000 tonnes): All emissions are reported as CO2 equivalents calculated by the 100-year time horizon GWP values from IPCC (6th assessment report) in conformity with the ESRS E1-6 and using emission factors from FUEL EU. Gross Scope 1 GHG Emissions: Direct emissions from NORDEN’s consumption of fuel from owned and chartered-in vessels. Consumption is periodised across reporting periods based on contract service performance criteria. The pool's allocation of emis- sions is based on the pool’s distribution model. Including bunker consumption on ballast leg prior to voyage operation by NORDEN, which could be considered part of GHG #4: Upstream transportation and distribution. NORDEN includes these emissions in our Gross Scope 1 GHG Emissions as we consider the emissions to be part of our own operation. Gross Scope 2 GHG Emissions: Indirect emissions from purchased electricity and district heating. Actual or estimated usage is converted into emissions using national averages and location/ market-based conversion factors and a third party is used to convert spend/consumption into emissions: Location-based: Not considering renewable energy certificates(RECs) or power purchase agreements (PPAs). Simply using loca- tion-based grid average emission factors. Market-based: Reflects the GHG emissions from the electricitythat NORDEN has purposefully chosen (or the lack of a choice). Gross Scope 3 GHG Emissions: Indirect upstream and downstream emissions from third-party activities and operational management services. Based on our materiality threshold of 1%, below the GHG recommendation of 5%, NORDEN includes the following scope 3 GHG categories in our external reporting framework: Purchased goods and services (GHG #1): Overhead, administra-tion and port costs as classified in the NORDEN chart of accounts are converted into emissions based on CEDA Group categorisa- tion of costs. A third party have been used to convert spend into emissions. Capital goods (GHG #2): Capital expenditures (CapEx) such asinvestments in vessel newbuildings, scrubbers or dry docking of vessels are converted into emissions based on costs using the U.S. EPA emissions factors for Ship Building and Repairing. The USD aligns with the ‘transferred from prepayments during the year’ in the financial statement notes related to tangible assets and addi- tional CapEx investments related to dry docking, scrubbers and similar. Thus, the emissions related to investments in newbuildings are accounted for at the vessel's delivery. Follows cash usage and is not periodised over the depreciation schedule of the asset or upgrade. Fuel and energy-related activities (GHG #3): Upstream emis-sions related to direct bunker consumption using CO2 equivalent emission factors from FUEL EU based on fuel types on owned or operated voyages using data from IMOS and Spinergie. The upstream emission factor on biofuel is based on actual emission factors provided by the supplier. Upstream transportation &amp; distribution (GHG #4): Upstreamtransportation emissions on our purchased goods and services based on CEDA Group categorisation of costs. Since upstream transportation and distribution are part of the emission factors applied by a third-party provider, GHG #4 is included despite being below our 1% threshold and reported as part of purchased goods and services in the reported figures. Downstream leased assets (GHG #13):- Emissions from TCO voyages are included based on contract service performance in the reporting period. NORDEN’s share of TCO emissions in the NORDEN Tanker Pool is allocated based on the distribution model. The residual between total emissions generated by TCO voyages in the NORDEN Tanker Pool and NORDEN’s share of these is not part of NORDEN’s scope of emissions. - Emissions related to operating third-party vessels generating management fees in the NORDEN Tanker Pool. Estimated as the difference between the total emissions from operated vessels and the NORDEN share of these based on the distribution model. The residual is accounted for as emissions related to the operational management of pool vessels. GHG categories 5, 6, 7 and 15 are considered relevant for NORDEN but fall below our materiality threshold of 1% of total scope 3 emis- sions. NORDEN continues to monitor development in the GHG categories internally, but these will not be part of our externally reported ESG metrics subject to the emissions exceeding our selected threshold. GHG emissions intensity: Following ESRS E1-6. Calculated as total GHG emissions (CO2e) per net revenue (USD). EEDI (gCO2 /cargo-capacity-mile): Following TR-MT-110a.4. The calculations follow methodologies outlined in IMO MEPC 66/21/ Add.1, Annex 5, 2014. The average EEDI is a simple average of the EEDI value of all new ships added to NORDEN’s fleet during the reporting period. GHG removals and storage projects in the value chain (metric tonnes): Total amount of GHG removals and storage in metric tonnes of CO2e disaggregated and separately disclosed for the amount related to our operations and our upstream and downstream value chain and broken down by removal activity. GHG emission reductions or removals by the purchase of carbon credits (metric tonnes): The total amount of carbon credits outside our value chain in metric tonnes of CO2e that are cancelled in the reporting period or planned to be cancelled in the future, aligning with ESRS E1-7. Air quality NOx (metric tonnes): Following TR-MT-120a.1. Nitrogen oxide emis- sions from combustion of fuels from operated vessels. NO2 emis- sions from the energy produced by the main engine are multiplied by the Tier 1 NOx limit (17 g/kWh) or Tier 2 NOx limit (14.4 g/kWh) following the 4th IMO GHG study. Calculated basis bunker consump- tion on operated voyages based on data from IMOS and Spinergie. SOx (metric tonnes): Following TR-MT-120a.1 and IMO 4th GHG study. Sulphur oxide emissions mainly stem from burning the sulphur compound in the fuel from operated vessels. SO2 emis- sions are calculated from the fuel quantity consumed during the year multiplied by the average sulphur content in the bunker fuel purchased by NORDEN’s Bunker department. Calculated basis bunker consumption on operated voyages based on data from IMOS and Spinergie. PM10 (metric tonnes): Following the TR-MT-120a and IMO 4th GHG study. PM10 emissions are influenced by engine type and fuel sulphur content. NORDEN uses the same average sulphur content used in the SOx calculation and assumes 175/195 g/kwh in engine output (SFOC) based on the engine efficiency of the main/auxiliary engine. Calculated based on bunker consumption from operated vessel voyages based on data from IMOS and Spinergie. PM2.5 (metric tonnes): Following ESRS E2-4 and IMO 4th GHG study. PM2.5 emissions are influenced by engine type and fuel sulphur content. NORDEN uses the same average sulphur content used in the SOx calculation and assumes 175/195 g/kwh in engine output (SFOC) based on the engine efficiency of the main/auxiliary engine. Calculated based on bunker consumption from operated vessel voyages based on data from IMOS and Spinergie. Estimated to be 92% of the PM10. NMVOC (metric tonnes): Following ESRS E2-4 and IMO 4th GHG study. NMVOC emissions are influenced by engine type. NORDEN assumes 175/195 g/kwh in engine output (SFOC) based on the engine efficiency of the main/auxiliary engine. Calculated based on bunker consumption from operated vessel voyages based on data from IMOS and Spinergie. HM (metric tonnes): Following ESRS E2-4 and IMO 4th GHG study. ESRS E2-4 requires the reporting company to report HM emissions to water and air. NORDEN uses the conversion factors reported by the US EPA for HM air pollution. Calculated based on bunker consumption from operated vessel voyages based on data from IMOS and Spinergie. Water pollution HM (metric tonnes): Following ESRS E2-4. HM in water stems from scrubber-fitted vessels. We estimate the water pollution using values from the ICCT. Emissions into water are only relevant for open- looped scrubbers since pollutants stem from the wash water. PAH (metric tonnes): Following ESRS E2-4. The concentration of PAHs in the discharged wash water is assumed to comply with IMO guidelines as described in the Resolution MEPC.340(77) of 50 µg/l (2.25 g/MWh). Emissions into water are only relevant for open- looped scrubbers since pollutants stem from the wash water. Ecological impacts Shipping duration in marine protected areas or areas of protected conservation status (days): Following TR-MT-160a.1, but NORDEN reports only on days in emission control areas (ECA) based on a materiality assessment. Total ECA days are calculated as the sum of sea and port days in ECA zones on owned or operated voyages based on data from IMOS and Spinergie. Percentage of fleet implementing ballast water exchange (%): Following TR-MT-160a.2, reporting only on owned vessels by NORDEN in the reporting period. Calculated as the residual between vessels having implemented ballast water treatment system and the total number of owned vessels. Does not include the tugs used for the Gabon project. Percentage of fleet implementing ballast water treatment (%): Following TR-MT-160a.2, calculated as the percentage of NORDEN's vessels having implemented ballast water treatment divided by the number of owned vessels. Reported by the internal technical depart- ment on NORDEN’s owned vessels. Does not include the tugs used for the Gabon project. The number of spills and releases to the environment: Following TR-MT-160a.3, NORDEN reports on all spills that significantly harm the environment from owned vessels. Reported by vessel technical manager on NORDEN’s owned vessels. The aggregate volume of spills and releases to the environment (m3): Following TR-MT-160a.3, NORDEN reports on all spills that significantly harm the environment from owned vessels. Reported by vessel technical manager on NORDEN’s owned vessels. Activity measures Number of shipboard employees: Following TR-MT-000.A. Ship- board employees are those employees who work aboard the enti- ty’s vessels during the reporting period. Reported as the average number of employees. Total distance travelled by vessels: Following TR-MT-000.B. Reported as the sum of nautical miles travelled on owned or oper- ated voyages during the reporting period. Does not include the tugs used for the Gabon project. Operating days: Following TR-MT-000.C. Operating days are calcu- lated as the number of available days in a reporting period minus the aggregate number of days that the vessels are off-hire due to unfore- seen circumstances. Including internal voyages. Deadweight tonnage: Following TR-MT-000.D. Deadweight tonnage is the sum, for all owned vessels at the end of the reporting period, of the difference in displacement in deadweight tons between the light displacement and the loaded displacement. Does not include the tugs used for the Gabon project. Number of vessels in the total shipping fleet: Following TR-MT- 000.E. Reported as the number of owned vessels at the end of the reporting period. Does not include the tugs used for the Gabon project. Number of vessel port calls: Following TR-MT-000.F. Reported as the number of vessel port calls in the reporting period for owned or operated voyages. Twenty-foot equivalent unit (TEU) capacity: NORDEN does not report on this metric in the SASB Marine Transportation standard as it is considered out of scope. Social performance Own workforce General statement of scope and boundaries: Scope for the full- time workforce, accounted for as full-time equivalent (FTE) onshore, includes permanent and time-limited employees (fixed-term, student jobs and temporary hires) in NORDEN’s offices, except for the indicators ‘Retention’ and ‘Turnover’, in which the scope includes average FTE amount onshore relating to permanent employees, excluding fixed-term, student roles and temporary hires. All social KPIs are based on NORDEN’s HR system, Fairsail. Following the defi- nition in the ESRS, significant employment is defined as countries with more than 50 employees measured as headcount. NORDEN’s own workforce includes primarily employees and to a limited extent non-employees who are either self-employed or provided by companies that primarily perform employment activi- ties. Given the limited extent of non-employee workers, NORDEN is not considering the disclosure requirement (DR) S1.7: Characteristics of non-employee workers in the undertaking’s own workforce, to be material and will therefore not report on the DR. Employees (FTE): Average full-time equivalent number of employees onshore as defined in NORDEN’s HR system. Nationalities represented (of the total workforce): Number of nationalities in the total workforce based on NORDEN’s HR system. New hires: Calculated as the sum of headcounts being hired during the reporting period. Locations: NORDEN’s office locations are divided into “Headquar- ters” and “Other Offices”. Other Offices consist of our offices in Limassol, Dubai, Singapore, Melbourne, Shanghai, Tokyo, Owendo, Abidjan, Rio de Janeiro, Santiago, Annapolis, Vancouver and Bremen. NORDEN’s HR system and aligns with the ESRS 1-9: Diversity Indica- tors. The gender distribution in percentage at top management: Top management is defined as the senior management in the Corporate Governance section. The number of each gender divided by total top management headcount based on NORDEN’s HR system and aligning with the ESRS 1-9: Diversity Indicators. Other levels of management: The other levels of management are characterised as Executive Management as well as employees with employee responsibilities referring to the Executive Management team. Employee turnover as a total number: The number of leavers (all leavers) in the reporting period based on NORDEN’s HR system aligning with the ESRS S1-6: Characteristics of the undertaking’s employees. Turnover rate: The number of leavers (all leavers) in the reporting period divided by the number of employees at the beginning of the reporting period based on NORDEN’s HR system as per the ISO 30414 standard and GRI 401-01 b with age data from HR system birth dates. Retention rate: One minus the number of resignations (voluntary leavers) in the reporting period divided by the number of employees at the beginning of the reporting period based on NORDEN’s HR system based on GRI 401-01 b with age data from HR system birth dates. Overall engagement score: Provided by a third-party supplier of the Engagement and Harassment Survey. The score is standardised to per cent, with 100% representing maximum engagement. The survey recurs on an annual basis. All NORDEN’s employees are part of the engagement survey. A third party provides benchmark scores with NORDEN’s knowledge of calculations and weights of bench- mark categories. Lowest represented gender among own workforce (%): The percentage of the average number of the gender with the lowest represented FTE out of the total average number of FTEs during the year based on NORDEN’s HR system. Lowest represented gender among managers (%): Average number of the gender with the lowest represented FTE in manager positions out of a total average number of FTEs. A manager position is defined as a person responsible for a team of at least one other FTE as defined in the HR system. Lowest represented gender among commercial roles (%): The percentage of the average number of the gender with the lowest represented FTE out of the total average number of FTEs in commer- cial roles during the year based on NORDEN’s HR system. Commer- cial roles include the CEO, ship operators, charterers, FFA traders, commercial and portfolio managers. The remaining are considered support roles. Workers in the value chain General statement of scope and boundaries: NORDEN defines workers in the value chain as all non-employee workers whose work and/or workplace is controlled by the undertaking but are not included in the “Own Workforce” scope. Based on the materiality assessment of NORDEN’s social impacts, the scope of workers in the value chain includes our seafearers on our owned vessels, who are employed by technical managers. Lost time incident rate (LTIR): Following TR-MT-320a.1. Calculated based on the number of registered work-related accidents which cause a seafarer to be unable to work for more than 24 hours per 1 million working hours due to work-related injury. Numbers are reported by vessel technical managers on NORDEN’s owned vessels. Accident &amp; safety management The number of marine casualties and percentage classified as very serious: Marine casualties include fatalities. The percentage classi- fied as very serious is calculated as the number of fatalities divided by the number of LPIs and fatalities in the reporting period. The number of Conditions of Class or Recommendations: Following TR-MT-540a.2 and reported on owned vessels by the vessel tech- nical manager. Calculated as the count of conditions of class or recommendations. The number of port state control (1) deficiencies and (2) detentions: Following TR-MT-540a.3 and reported on owned vessels by the vessel technical manager. Calculated as the count of conditions of class or recommendations. Governance performance Sustainable procurement Strategic suppliers screened for ESG (%): The number of strategic suppliers screened for ESG-related risks divided by the total stra- tegic suppliers for NORDEN. ESG-related risks are screened by an external service provider (EcoVadis). Strategic suppliers are defined based on three critical metrics: spending, materiality to NORDEN and whether the vendor is in a high-risk country. High-risk countries are defined through the EcoVadis country risk scores. Business conduct The number of calls at ports in countries that have the 20 lowest rankings in Transparency International’s Corruption Perception Index: Following TR-MT-510a.1. Calculated as the number of port calls (see definition of port calls under activity measures) being in the 20 lowest rankings in the Transparency International’s Corrup- tion Perception Index. The total amount of monetary losses because of legal proceedings associated with bribery or corruption / The total amount of fines for violation of anti-corruption and anti-bribery laws (USD): Following TR-MT-510a.2 and ESRS G1-4. Reported by the Head of Group Legal and is validated against spending in the audited financial state- ments. The number of convictions and the amount of fines for violation of anti-corruption and antibribery laws: Following the ESRS G1-4. Reported by the Head of Group Legal. Staff completed E-learning course: Share of eligible employees having passed NORDEN's Anti-Corruption course. Eligible employees are full-time employees on a permanent contract who have worked with NORDEN the entire reporting year. Employees on maternity or sickness leave are considered non-eligible. Retrieved from our external provider of anti-corruption courses and HR system. Board Gender with lowest representation share on Board of Directors (%): Percentage of shareholder-elected gender with lowest representa- tion on the Board of Directors out of the total number of sharehold- er-elected board members at year end. Double materiality assessment This section describes NORDEN's materiality assessment process and complies with the disclosure requirement IRO-1: description of the process to identify and assess material impacts, risks and oppor- tunities. The section should allow readers to fully understand the process for determining which disclosure requirements to includein our sustainability statement. During the reporting period, NORDEN diligently carried out a double materiality assessment to deepen our integration of ESG consider- ations into the core of our business operations. This exercise was essential not only for identifying the topics under the ESRS that are materially significant from an ESG standpoint but also to ensure that these topics are consistent with our operational ethos, according to which ESG is a fundamental component of our short, medium and long-term strategy formulation. The Board of Directors, in conjunction with the ESG Executive Body, is responsible for setting the strategic direction for our environmental sustainability ambitions. Our ESG Executive Body is composed of senior management members and in-house ESG specialists, ensuring a robust and informed approach to sustainability governance. Integral to the double materiality assessment was our engagement with relevant stakeholders. This crucial step provided us with a deeper understanding of our sustainability impacts and influences. By mapping our stakeholders in conformity with the ESRS guidelines, we identified key groups ranging from customers and financiers to shareholders, industry associations, regulators and employees. We then engaged in a process of stakeholder prioritisation. Our internal teams, who maintain regular and in-depth interactions with these stakeholders, assessed the relevance of each group through a consul- tative process that evaluated their interest in NORDEN's operations and their influence over them. Stakeholders with a significant rele- vance score were then categorised as 'key stakeholders, and a subse- quent list of these key entities was compiled. To facilitate their input, we crafted stakeholder engagement letters that outlined the nature of the feedback sought and the context of the engagement. Having collected feedback from our key stakeholders, NORDEN has identified our sustainability matters using the sub-topics of the ESRS as initial guidance. In addition to this, we utilised the MSCI ESG materiality map, the SASB Marine Transportation reporting standard and guidance from the International Maritime Organization (IMO) to identify the most significant sustainability impacts related to our operations in the marine transportation sector. The impacts were articulated into sustainability topics and subsequently assessed from a financial perspective. We evaluated the sustainability factors or 'capitals' relevant to our business model. We focused on identifying sustainability factors that influence or may influence our enterprise value considering both short, medium and long-term effects. For this, financial materiality was defined as impacts enabling a risk or oppor- tunity with more than 5 percentage points' impact on gross margins (CMII). Following the double materiality process, we identified which sub-topics within the five sections of the ESRS are material: • Climate change • Pollution • Own workforce • Workers in the value chain • Business conduct Our impact assessment identified other topics, which were not deemed material from a financial perspective in this reporting period. This includes topics within Water and marine resources (E3) and Biodiversity (E4) such as habitat degradation and intensity of pressure on marine resources and the spread of non-indigenous species. While being considered material from a sustainability perspective, the topics are regulated by the IMO, which NORDEN is required to adhere to, thus mitigating the financial materiality of these topics. The result of our double materiality assessment is the below outlined material topics for NORDEN. These serve as our focus and enable us to track and deliver on our overall sustainability priorities. Category Sub-topic Metric Environmental ESRS E1 Climate change Energy consumption Environmental ESRS E1 Climate change Decreasing value chain emissions Environmental ESRS E1 Climate change Efficient operation of our vessels Environmental ESRS E2 Pollution Improve air quality Environmental ESRS E2 Pollution Reduce water pollution Social ESRS S1 Own workforce Culture Social ESRS S1 Own workforce Diversity, Equity &amp; Inclusion (DE&amp;I) Social ESRS S2 Workers in the value chain Health &amp; safety Governance ESRS G1 Business conduct Corruption and bribery Governance ESRS G1 Business conduct Sustainable procurement EU Taxonomy Turnover NORDEN’s revenue-generating activities are generally consid- ered eligible. Revenue from time chartered-out vessels (TCO) and subleases as well as income earned from the administration of pool arrangements are not considered eligible. The latter is reported as part of 'Other operating income' in the Consolidated Financial State- ments. The reported turnover corresponds to "Revenue - services rendered, external", which can be found in the "2.1 Segment infor- mation" note. Aligned turnover decreased from 1% (USD 35m) to 0% (USD 6m) in 2023 driven by fewer vessels in the portfolio aligning with the EEDI criteria and weaker market conditions, thus decreasing the aligned turnover. Capital expenditures CapEx as defined in the Taxonomy is considered equivalent to the 'additions' and 'prepayments on vessels and newbuildings', as set out in note 3.4 to the Consolidated Financial Statements, and additions to 'Right-of-use assets' as set out in note 3.5 to the Consolidated Finan- cial Statements. CapEx related to the acqusition in 4.13: Manufacture of biogas and biofuels for use in transport and of bioliquids can be found in note 3.7.3 in the 'Revenue and other income' line. Therefore we have increased our aligned CapEx from 0% in 2022 to 4% in 2023. CapEx incurred is generally considered eligible, except if CapEx is incurred directly relating to chartering out vessels. Operating expenditures OpEx as defined in the Taxonomy covers expenditures directly related to chartering, maintaining and operating vessels, and is equivalent to 'Vessel operating costs' as presented in the "income statement" in the Consolidated Financial Statements less operating costs for owned vessels and daily running costs for leased vessels (expenses related to the service component in note 3.5). OpEx incurred is generally considered to be eligible under the Taxonomy, except if relating to owned vessel OpEx or vessels chartered out. NORDEN includes costs related to the bunker, as these are consid- ered crucial for the effective functioning of the asset (time-chartered vessels on short-term leases). There has been no change in the aligned OpEx from 2022 to 2023, since the costs included are based on time-chartered vessels, where NORDEN doesn't have documen- tation on the vessel's EEDI. Review of alignment To align with the EU Taxonomy, eligible economic activities must a) contribute to one or more of six environmental objectives, b) do no significant harm (DNSH) to the remaining objectives and c) meet the minimum social safeguards. The six environmental objectives outlined in the EU Taxonomy are climate change mitigation, climate change adaptation, sustainable use of water &amp; marine sources, circular economy, pollution prevention and a healthy ecosystem. Following the identification of eligible activities, NORDEN has applied the technical screening criteria under the EU Taxonomy to evaluate whether our activities are aligned with one of the EU objec- tives, do no significant harm to other Taxonomy objectives and are aligned with the minimum social safeguards criteria. Almost all NORDEN’s activities fall under activity number 6.10: 'Sea and coastal freight water transport, vessels for port operations, and auxiliary activities'. During the reporting period, NORDEN invested in MASH Makes, whose activities are described under activity number 4.13: ‘Manufacture of biogas and biofuels for use in transport and of bioliquids’. In the section below, we describe the process of screening our activities for the technical criteria in the Taxonomy of each activity in NORDEN. Activity number 6.10: Sea and coastal freight water transport, vessels for port operations, and auxiliary activities' Our assessment of alignment is based on the technical criteria from substantial contribution to climate change mitigation. Following the technical criteria, alignment forbids vessels from being dedi- cated to the transport of fossil fuels. Therefore, tanker vessels are excluded from the alignment criteria, despite the ability of tanker vessels to transport soft oils. This trade is considered immaterial for the consideration of including some share of product tanker activ- ities as eligible and potentially aligned. Dry cargo vessels are only subject to potential taxonomy alignment if the EEDI is 10% below the requirement applicable on 1 April 2022, and if the vessels can run based on zer- direct CO2 emission fuels or on fuels from renewable sources. The latter includes vessels eligible for running on biofuel (ref: activity number 4.13). Currently, NORDEN only has EEDI scores on owned vessels, where the building contract was placed on or after 1 January 2013, or the vessel was delivered on or after 1 July 2015. The EEDI scores are collected from our technical managers. As of 2023, the required EEDI for bulk vessels is calculated using the IMO reference line equa- tion and subtracting 20%. Alignment with the screening EEDI criteria requires that a vessel’s EEDI is 10% below the required EEDI, i.e. 10% below the phase 3 IMO EEDI requirement. During the financial year 2023, NORDEN operated four vessels aligned with the EEDI criteria. All of these are eligible for running on biofuel as per certification from the Danish Maritime Authorities (Søfartsstyrelsen) to run at a 100% biofuel capacity. Therefore, solely vessels under the Danish International Ship Register (DIS) are subject to alignment, as certi- fication for 100% biofuel consumption has not been obtained by other flag authorities. NORDEN notes that all its vessels can run at 30% biofuel capacity without pre-certification from any flag state. Having secured alignment with the technical criteria under the objective of climate mitigation, we assess whether the activity does harm to any of the remaining environmental objectives, i.e., live up to all the DNSH criteria. Below is a review of NORDEN’s alignment with the remaining five objectives: Climate adaption Activity number 6.10 is expected to be affected by changing temperatures, leading to more frequent extreme weather events (e.g. drought or storms) and scarcity of water, impacting trade patterns and volumes. NORDEN does not consider physical climate risks to have a material impact on our economic activity. This is due to our agile operator model, allowing us to comply and adapt to changing trade patterns. NORDEN intends to leverage our use of data to improve predictions and decision-making, mitigating the impact on our business relative to our peers. In addition, we intend to expand our logistics offering beyond tramp shipping via the Assets &amp; Logistics business unit. The IPCC has five major climate scenarios: RCP 1.9, 2.6, 4.5, 6 and 8.5. RCP 1.9 would impose limited climate risks, but heavy transi- tional risks for NORDEN (following the Paris agreement), while RCP 8.5 would increase the physical climate risks as the frequency and intensity of extreme weather would surge. This could potentially lead to margin erosion as the risks of damage to ships and cargo increase. NORDEN intends to mitigate the risks related to climate change by extensive use of weather routing systems when pricing, securing appropriate insurance coverage and assessing the risk of freight contracts as well as including chronicle risks when evaluating business opportunities. Based on the assessment above, we believe NORDEN is aligned with the generic climate adaption criteria for DNSH. Water NORDEN is monitoring and assessing the impact of our operation on marine life. As part of our adaption of the SASB Marine Transpor- tation reporting standard, we report on the share of owned vessels having implemented ballast water treatment systems (BWTS), voyage duration in marine-protected areas and oil spills. These are all consid- ered relevant issues to NORDEN. Having a high percentage of our vessels with BWTS, we avoid the risk of invasive species. We reduce water pollution using best management practices/policies aligned with the Directive 2000/60/EC stating that companies should take measures to prevent, reduce and control water pollution. NORDEN follows IMO standards for all its operations and considers IMO’s regulation on water regulation to be adequate in terms of doing no significant harm to the waters in which we sail. Based on the review above, we believe NORDEN is aligned with the generic water criteria for DNSH. Circular economy Aligned with Regulation (EU) No 1257/2013, NORDEN has implemented waste management plans and uses the best techniques available to reduce the environmental impact of waste management. NORDEN keeps track of the waste generated on board vessels and the disposal of such via the onboard logbooks which are reported to the technical managers. NORDEN’s business model involves operating a modern fleet of vessels, selling and redelivering vessels long before vessel end-of-life. Should NORDEN face situations where recycling of a vessel is relevant, NORDEN has a Responsible Ship Recycling Policy meaning we have measures in place to manage waste at the end-of-life of the vessel. NORDEN complies with Annex V. This requires ships to take meas- ures to prevent accidental loss of garbage and to have equipment on board to collect and store garbage, as well as procedures to ensure that it is disposed of properly. Annex V is enforced by the IMO and is thus a standard in the shipping industry. Pollution prevention All technical criteria under the objective are considered IMO stand- ards. Thus, NORDEN is required to comply. Based on the review above, we believe NORDEN is aligned with the generic pollution prevention criteria for DNSH. Biodiversity All technical criteria under the objective are considered IMO stand- ards. Thus, NORDEN is required to comply. Based on the review above, we believe NORDEN is aligned with the generic biodiversity criteria for DNSH. Activity number 4.13: ‘Manufacture of biogas and biofuels for use in transport and of bioliquids’ Our alignment assessment is based on the technical criteria from substantial contribution to climate change mitigation. Following the technical criteria, alignment requires that the biomass used, whether agricultural or forest-based, complies with specific guide- lines outlined in the relevant articles of Directive (EU) 2018/2001. This includes avoiding the use of food and feed crops to produce biofuels and bioliquids. Furthermore, the process must achieve at least 65% greenhouse gas emission savings compared to the fossil fuel comparator. MASH Makes leverages a non-food feedstock using cashew nutshell press cake, which undergoes pyrolysis generating biofuel and biochar/carbon capture. This results in a GHG reduction of more than 65% compared to fossil fuels. The activities are there- fore in alignment with the technical criteria of activity number 4.13. Having secured alignment with the technical criteria under the objective of climate mitigation, we assess whether the activity harms any of the remaining environmental objectives, i.e., live up to all the DNSH criteria. Below is a review of NORDEN’s alignment with the remaining five objectives: Climate adaption Our activities under 4.13 are highly affected by climate change. MASH Makes uses feedstock to produce biogas, biofuel and biochar, which could be seriously affected by scarcity of water, droughts, increasing temperatures and other conditions. The impact of climate change is mitigated by the technology being able to run on almost all organic non-food feedstock types, thereby decreasing the reli- ance on specific feedstocks. Based on the assessment above, we believe the activities under 4.13 are aligned with the generic climate adaption criteria for DNSH. Water As NORDEN is running an operation with no water usage or impact on water in the area, we believe the activities under 4.13 are aligned with the generic water criteria for DNSH. Pollution prevention Since MASH Makes uses pyrolysis to produce biochar and biofuel, the DSNH criteria are not relevant for NORDEN. Therefore, we believe the activities under 4.13 are aligned with the generic pollu- tion prevention criteria for DNSH. Biodiversity MASH Makes' portfolio projects are located outside the EU. The technical criteria of Appendix D do not apply to MASH Makes' projects, but the company collaborates with reputable NGOs for the application of biochar and related afforestation/farming efforts, acknowledging these as beyond the direct operational scope. This partnership approach leverages NGO expertise in environmental management and sustainable agriculture, ensuring responsible and effective execution of these activities, in line with our commitment to sustainability and social responsibility. Therefore, we believe the activities under 4.13 are aligned with the generic conversation of biodiversity criteria for DNSH. The assessment shows that NORDEN complies with the DNSH criteria of the EU Taxonomy. Before we can account for alignment with the EU Taxonomy, a review of whether our activities are aligned with the minimum social safeguards criteria is required. Minimum safeguards The OECD Guidelines are considered a standard for responsible busi- ness conduct. The guidelines cover a wide range of issues, including labour rights, bribery and corruption, environmental protection and human rights. NORDEN has human rights policies aligning with the OECD and UN Guidelines and is deeply involved in securing an anti-corruption foundation for shipping with its activities involving MACN and focusing on educating its employees in anti-bribery via e-learning courses. MASH Makes works continuously to ensure that employees enjoy safe, healthy and fair working conditions. In line with these commitments, NORDEN has implemented a rigorous due diligence process to identify and address salient human rights risks in its operations. This process involved conducting multiple interviews with employees and managers, providing an in-depth understanding of the potential risks related to NORDEN's activities. The findings from these interviews, along with proposed preventive and mitigating actions, were thoroughly reviewed and approved by NORDEN's ESG owner. Based on such argumentation, we believe NORDEN is aligned with the minimum safeguards criteria that enable EU Taxonomy-aligned activities reporting under both activity numbers 4.13 and 6.10. POLICIES Anti-Corruption Compliance Programme: The purpose is to ensure compliance with key anti-corruption legislation, mitigate NORDEN’s reputational risks and guide employees in what is expected when working for NORDEN. The policy applies to all employees and the Board of Directors. Ownership and enforcement of the programme rest with the Head of Asset Management, and the programme is accessible on the Intranet and described in the Employee Code of Conduct. Anti-Harassment Policy: NORDEN is committed to ensuring all employees are treated equally and with respect, safeguarded from harassment, abuse and violence in the workplace, regardless of their background or characteristics. This applies to all forms of harass- ment, whether physical, verbal, sexual or psychological, and includes all NORDEN employees and contractors. The policy, overseen by the Head of People &amp; Sustainability, extends to any work-related setting and is integral to our corporate culture. It is detailed on our website, Intranet and in the Employee Code of Conduct. Data Ethics Policy: The policy states our data ethics principles, describing how we collect, store, process and protect data for the benefit of our employees, customers, business partners and other stakeholders. This Data Ethics Policy applies to all employees and has been prepared in accordance with GDPR requirements and section 99 d of he Danish Financial Statements Act. Ownership and enforcement of the policy rest with the CFO and it is available on our website. Diversity, Equity &amp; Inclusion Policy: NORDEN is committed to respecting and promoting diversity, offering equal opportunities and ensuring fair treatment for all employees. We strictly oppose any form of discrimination, whether based on race, gender identity, religion, political views or any other distinguishing characteristics. Our employment practices, including hiring, remuneration, training and advancement, are governed by relevant and objective criteria. The policy, overseen by the Head of People &amp; Sustainability, applies to every NORDEN employee and is detailed on our website, Intranet and in the Employee Code of Conduct. Employee Code of Conduct: NORDEN's Employee Code of Conduct outlines the ethical, social and environmental standards all employees are expected to follow. It serves as a guide for deci- sion-making and maintaining high standards of business conduct. The Code encompasses policies that reinforce NORDEN's commit- ment to sustainability and supersedes less stringent laws or regula- tions. Ownership and enforcement of the Code rest with the Head of People &amp; Sustainability. It is accessible on the Intranet, provided to new hires during onboarding and must be acknowledged annually to ensure comprehension of any updates. Flexible Woking Policy: NORDEN values flexibility, offering remote work and flexible hours to foster work-life balance and inclusivity. This policy, suited to all employees, balances flexibility with main- taining connectivity, innovation and performance. Office presence may be required for certain roles and situations. The policy is approved by the Head of People &amp; Sustainability and is available on our Intranet. Health and Safety Policy: NORDEN prioritises a safe and healthy workplace, addressing physical, emotional, mental and spiritual well-being. We aim to exceed legal standards and align with ILO principles on workplace health and safety. This policy, overseen by the Head of People &amp; Sustainability, applies to all employees and is detailed on our website, Intranet and in our Employee Code of Conduct. Human Rights Policy: NORDEN is committed to upholding human and labour rights as outlined in the International Bill of Human Rights and the International Labour Organisation's Declaration. This encompasses rights related to compensation, labour practices, privacy, association, religion and work hours. The Head of People &amp; Sustainability ensures these principles are integrated into our culture and practices. The policy is detailed on our website, intranet and Employee Code of Conduct. We expect all employees and busi- ness partners to adhere to these standards, reinforced through our Responsible Supply Chain Management process, Supplier Code of Conduct including and Technical Manager Code of Conduct. Modern Slavery Act: Conducting business in a legal, ethical and socially responsible manner is core to NORDEN and in line with our values. We are committed to ensuring that modern slavery or human trafficking does not occur in any part of our business or supply chain. NORDEN’s framework for respecting human and labour rights is operationalised by the UN Guiding Principles on Business and Human Rights (UNGP), which draws on the International Bill of Human Rights, the International Labour Organisation’s Declaration of Fundamental Principle and Rights at Work and the Rio Declaration on Environment and Development. Ownership and enforcement rest with the Head of People &amp; Sustainability and the policy is available on NORDEN’s website, Intranet and described in our Employee Code of Conduct. Sanctions Compliance Programme: NORDEN's Sanctions Compli- ance Programme is implemented to ensure that NORDEN, its affili- ated companies and employees do not engage in any transactions in breach of the sanctions policy. The sanctions policy is defined by the Board of Directors and it is the responsibility of the Head of Risk Management to ensure the Sanctions Compliance Programme is followed and the sanctions policy is implemented and available on our Intranet. Supplier Code of Conduct: The Supplier Code of Conduct supports NORDEN in building a sustainable practice by establishing systems and processes to manage our adverse impacts on human and labour rights, environment and anti-corruption through our purchasing practices. NORDEN expects all our suppliers, at any time, to be able to declare in writing their stage of implementation. Ownership and enforcement of the Code rest with the Head of Procurement and is part of the contractual agreement. The Supplier Code of Conduct is available on our website. Tax Policy: The purpose of the Tax Policy is to define the global management of taxes, including governance and structuring. As part of NORDEN’s responsible approach to tax, NORDEN aims to increase sustainable growth and value creation for society and our stakeholders through reliable and effective tax management. NORDEN uses the arm's length principle of pricing in line with OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration and applies this consistently across our businesses. The Board of Directors of NORDEN approves general tax principles and exercises governance over corporate tax affairs through regular updates on our tax positions. Ownership and enforcement of the policy rest with the CFO and the policy is available on our website. Technical Manager Code of Conduct: NORDEN's Technical Manager Code of Conduct outlines the ethical, social and environmental standards which all NORDEN’s technical managers are expected to follow. It serves as a guide for maintaining high standards of business conduct. The Code encompasses policies that reinforce NORDEN's commitment to sustainability and supersedes less strin- gent laws or regulations. Ownership and enforcement of the Code rest with the Head of Technical Management, and is part of the basis for the contract between the parties and must be acknowledged by the technical managers annually to ensure comprehension of any updates. Whistleblower scheme: NORDEN promotes a speak-up culture where employees are encouraged to report misconduct without fear of retaliation. This applies to everyone associated with NORDEN, including workers in our value chain and external partners. Reports can be made anonymously and are managed by the Head of Group Legal and the Board of Directors. The whistleblower scheme is detailed on our website, Intranet and in our Employee Code of Conduct. ESG PERFORMANCE DATA SASB Marine transportation index Topic Metric Unit Code 2023 2022 2021 Greenhouse Gas Emissions Scope 1 bunker emissions Metric tonnes (t) CO2e TR-MT-110a.1 3,834,437 4,271,580 4,519,456 Total energy consumed (TJ) Terajoules (TJ) TR-MT-110a.3 49,901 55,809 58,707 Percentage heavy fuel oil Percentage (%) TR-MT-110a.3 5.9% 7.1% 5.9% Percentage renewable Percentage (%) TR-MT-110a.3 0.1% 0.1% 0.0% Average Energy Efficiency Design Index (EEDI) for new vessels CO2 per capacity-nm TR-MT-110a.4 4.3 4.1 3.3 Air Quality NOx Metric tonnes (t) TR-MT-120a.1 101,678 117,620 123,965 SOx Metric tonnes (t) TR-MT-120a.1 9,894 10,889 11,220 PM10 Metric tonnes (t) TR-MT-120a.1 4,941 5,692 5,987 Ecological Impacts Shipping duration in marine-protected areas or areas of protected conservation status Number of travel days TR-MT-160a.1 21,458 23,321 23,456 Percentage of fleet implementing ballast water treatment Percentage (%) TR-MT-160a.2 100% 95% 81% Percentage of fleet implementing ballast water exchange Percentage (%) TR-MT-160a.2 0% 5% 0% Number of spills and releases to the environment Number TR-MT-160a.3 0 0 0 Aggregate volume of spills and releases to the environment Number, cubic metres TR-MT-160a.3 0 0 0 Health &amp; Safety Lost Time Incident Rate (LTIR) Rate TR-MT-320a.1 1.0 0.8 0.8 Number of calls at ports in countries that have the 20 lowest rankings in Transparency International’s Corruption Perception Number Business Ethics Index TR-MT-510a.1 58 52 83 The total amount of monetary losses as a result of legal proceedings associated with bribery or corruption Reporting currency TR-MT-510a.2 0 0 0 Accident &amp; Safety Management Number of marine casualties Number TR-MT-540a.1 0 2 0 Percentage (%) TR-MT-540a.1 Percentage classified as very serious (very serious = the total loss of the ship, a death, or severe damage to the environment) 0% 33% 0% Number of Conditions of Class or Recommendations NumberTR-MT-540a.215 15 NA Number of port state control deficiencies NumberTR-MT-540a.326 61 NA Number of port state control detentions NumberTR-MT-540a.30 1 NA Number of shipboard employees Number TR-MT-000.A 461 546 636 Total distance travelled by vessels Nautical miles (nm) TR-MT-000.B 13,989,053 14,219,344 14,585,771 Operating days Days TR-MT-000.C 196,388 203,674 198,799 Deadweight tonnage Thousand DWT TR-MT-000.D 1,573 1,201 1,738 Number of vessels in total shipping fleet Number TR-MT-000.E 19 21 31 Number of vessel port calls Number TR-MT-000.F 9,496 10,139 10,377 Twenty-foot equivalent unit (TEU) capacity TEU TR-MT-000.G NA NA NA ESRS index Disclosure Section Sub Section Metric Unit requirement 2023 2022 E1 - Climate change Energy consumption and mix Fuel consumption from crude oil and petroleum products MWh ESRS E1-5 13,861,565 15,492,959 Fuel consumption for renewable sources MWh ESRS E1-5 19,790 14,470 Energy intensity USD / MWh ESRS E1-5 266 343 Gross scopes 1, 2, 3 and total GHG emissions Gross Scope 1 GHG Emissions Metric tonnes (t) CO2 eq ESRS E1-6 3,834,437 4,271,580 Gross Scope 2 GHG Emissions ESRS E1-6 Location based Metric tonnes (t) CO2 eq ESRS E1-6 418.1 531.0 Market based Metric tonnes (t) CO2 eq ESRS E1-6 347.9 NA Gross Scope 3 GHG Emissions Metric tonnes (t) CO2 eq ESRS E1-6 3,693,383 3,826,419 Total Gross GHG Emissions Location based Metric tonnes (t) CO2 eq ESRS E1-6 7,528,238 8,113,403 Market based Metric tonnes (t) CO2 eq ESRS E1-6 7,528,168 NA GHG emissions intensity Location based USD/Metric tonnes (t) CO2 eqESRS E1-6490 655 Market based USD/Metric tonnes (t) CO2 eqESRS E1-6490 NA GHG removals and storage through projects Metric tonnes (t) CO2 eq ESRS E1-7 0 0 GHG emission reductions or removals by purchase of carbon credits Metric tonnes (t) CO2 eq ESRS E1-7 0 0 E2 - Pollution Pollution of air, water and soil NOx Metric tonnes (t) ESRS E2-4 101,678 117,620 SOx Metric tonnes (t) ESRS E2-4 9,894 10,889 PM2.5 Metric tonnes (t) ESRS E2-4 4,546 5,236 NVMOC Metric tonnes (t) ESRS E2-4 4,147 4,636 Heavy metals in air Metric tonnes (t) ESRS E2-4 70 76 Heavy metals in water Metric tonnes (t) ESRS E2-4 29 38 PAHs Metric tonnes (t) ESRS E2-4 1 1 S1 - Own workforce Characteristics of the undertaking's employees Total number, employee turnover HC ESRS S1-6 NM NM Rate of employee turnover % ESRS S1-6 NM NM Diversity indicators The gender distribution in number and percentage at top management level amongst its employees FTEs/% ESRS S1-9 NM NM The distribution of employees by age group: under 30 years old, 30-50 years old; over 50 years old % ESRS S1-9 NM NM G1 - Business conduct Confirmed incidents of corruption or bribery The total number and nature of confirmed incidents of corruption or bribery # ESRS G1-4 0 0 The number of convictions and the amount of fines for violation of anti-corruption and antibribery laws ESRS G1-4 0 0 Total GHG emissions disaggregated by scopes 1 and 2 and material scope 3 categories Retrospective Target years '000 metric tonnes Base year N-1 N = 2023 % N / N-1 2025 2030 2050 Scope 1 GHG emissions Gross Scope 1 GHG emissions (tCO2e) 4,287 4,287 3,834 -11% NA NA 0 Percentage of Scope 1 GHG emissions from regulated emission trading schemes (%) NA NA NA NA NM NM NM Scope 2 GHG emissions Gross location-based scope 2 GHG emissions (tCO2e) 0.4 0.4 0.4 19% NA NA 0 Gross market-based scope 2 GHG emissions (tCO2e) NA NA 0.3 NA NA NA 0 Material scope 3 GHG emissions Total gross indirect (scope 3) GHG emissions (tCO2e) 3,826 3,826 3,693 -4% NA NA 0 GHG 1: Purchased goods and services 266 266 187 -30% NA NA 0 GHG 2: Capital goods 6 6 18 189% NA NA 0 GHG 3: Fuel and energy-related activities 904 904 823 -9% NA NA 0 GHG 13: Downstream leased assets 2,650 2,650 2,665 1% NA NA 0 Total GHG emissions Total GHG emissions (location-based) (tCO2e) 8,113 8,113 7,528 -7% NA NA 0 Total GHG emissions (market-based) (tCO2e) NA NA 7,528 NA NA NA 0 EU Taxonomy Turnover USDm % Y;N;N/ELY;N;N/ELY;N;N/ELY;N;N/ELY;N;N/ELY;N;N/EL Y/N Y/N Y/N Y/N Y/N Y/N Y/N % E T A. TAXONOMY-ELIGIBLE ACTIVITIES (A.1. + A.2.) A.1. Environmentally sustainable activities (Taxonomy-aligned) (A.1) Sea and coastal freight water transport CCM 6.10 6 0% Y N N N N N Y Y Y Y Y Y Y 1% E - Turnover of environmentally sustainable activities (Taxonomy-aligned) (A.1) 6 0% 0% 0% 0% 0% 0% 0% Y Y Y Y Y Y Y 1% Of which enabling 6 0% 0% 0% 0% 0% 0% 0% Y Y Y Y Y Y Y 1% E Of which transitional 0 0% 0% A.2 Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) Sea and coastal freight water transport CM 6.10 2,860 Turnover of Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) (A.2) 2,860 78% 78% 0% 0% 0% 0% 0% 80% Total turnover of Taxonomy-elgible activities (A.1 + A.2) 2,866 78% B. TAXONOMY-NON-ELIGIBLE ACTIVITIES Turnover of Taxonomy non-eligible activities 820 22% Total (A+B) 3,686 100% CapEx USDm % Y;N;N/ELY;N;N/ELY;N;N/ELY;N;N/ELY;N;N/ELY;N;N/EL Y/N Y/N Y/N Y/N Y/N Y/N Y/N % E T A. TAXONOMY-ELIGIBLE ACTIVITIES (A.1. + A.2.) A.1. Environmentally sustainable activities (Taxonomy-aligned) (A.1) Manufacture of biogas and biofuels for use in transport and of bioliquids CCM 4.13 13 4% Y N N N N N Y Y Y Y Y Y Y 0% E - CapEx of environmentally sustainable activities (Taxonomy-aligned) (A.1) 13 4% 4% 0% 0% 0% 0% 0% Y Y Y Y Y Y Y 0% Of which enabling 13 4% 4% 0% 0% 0% 0% 0% Y Y Y Y Y Y Y 0% E Of which transitional 0 0% 0% A.2 Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) Sea and coastal freight water transport CCM 6.10 320 96% EL CapEx of Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) (A.2) 320 96% 96% 0% 0% 0% 0% 0% 99% Total turnover of Taxonomy-eligible activities (A.1 + A.2) 333 100% B. TAXONOMY-NON-ELIGIBLE ACTIVITIES CapEx of Taxonomy non-eligible activities 0 0% Total (A+B) 333 100% OpEx USDm % Y;N;N/ELY;N;N/ELY;N;N/ELY;N;N/ELY;N;N/ELY;N;N/EL Y/N Y/N Y/N Y/N Y/N Y/N Y/N % E T A. TAXONOMY-ELIGIBLE ACTIVITIES (A.1. + A.2.) A.1. Environmentally sustainable activities (Taxonomy-aligned) (A.1) Sea and coastal freight water transport CCM 6.10 0% Y N N N N N Y Y Y Y Y Y Y 0% E OpEx of environmentally sustainable activities (Taxonomy-aligned) (A.1) 0 0% 0% 0% 0% 0% 0% 0% Y Y Y Y Y Y Y 0% Of which enabling 0% 0% 0% 0% 0% 0% 0% Y Y Y Y Y Y Y 1% E Of which transitional 0% 0% A.2 Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) Sea and coastal freight water transport CM 6.10 2,379 OpEx of Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) (A.2) 2,379 75% 75% 0% 0% 0% 0% 0% 75% Total turnover of Taxonomy-eligible activities (A.1 + A.2) 2,379 75% B. TAXONOMY-NON-ELIGIBLE ACTIVITIES OpEx of Taxonomy non-eligible activities 803 25% Total (A+B) 3,183 100%</mrv:StatementOfCorporateSocialResponsibility>
   <mrv:StatementOfTheDiversityPolicies contextRef="ctx1" id="fact4494" xml:lang="en">Material topics, metrics and targets Diversity, Equity &amp; Inclusion As a people-driven business, NORDEN considers diversity a strength in the world of shipping and actively works to embed DE&amp;I in our organisation. We aim for an organisation, where DE&amp;I accelerates our purpose of enabling smarter global trade through diversity of thought, gender, nationality, age, work experience, educational back- ground and other attributes. We want to achieve this by harnessing all employees’ unique contributions into our operational foundation, while opening up for different viewpoints and ways of thinking. At NORDEN, we base all recruitment, promotion and rewarding on performance, potential, behaviour and ability to deliver on our strategy and do not accept discrimination. NORDEN aims for a gender balance of a minimum of 40% of the underrepresented gender, which leaves up to 20% flexibility for female, male and non-binary genders, recognising that some employees may not wish to be categorised. Furthermore, our recruitment process enables managers to focus on promoting equality and broadening oppor- tunities for new and existing talents. This includes screening our job ads for non-inclusive language and actively mitigating any potential</mrv:StatementOfTheDiversityPolicies>
   <mrv:StatementOfTargetFiguresAndPoliciesForTheUnderrepresentedGender contextRef="ctx1" id="fact4514" xml:lang="en">Diversity in management The gender balance of the Board of Directors remained unchanged in 2023. This was due to the fact that members leaving the Board were replaced with mebers of the same gender. On the Board of Directors, shareholder-elected women represented 33% (two out of six) of the board members in 2023. The gender balance does therefore not yet meet NORDEN's target of having a minimum of 40% shareholder-elected female board members in 2025. For the Board of Directors to meet the objective on gender diversity, the Board intends to propose female candidates at the Annual General Meeting in 2025, bringing the ratio of females on the Board of Direc- tors in line with our 2025 objective. The members of NORDEN’s Board of Directors cover a wide range of competencies and experiences within international shipping, finance, investment, strategy, digitalisation and risk management, from both Danish and international business. This combination is considered desirable as it ensures a broad approach to decisions and contributes to ensuring qualified govern- ance of NORDEN’s strategic direction. Likewise, gender balance on a managerial level is desirable and pursued on an ongoing basis in NORDEN, as part of ensuring a diverse range of management skillsets and composition, while promoting equal opportunity across the organisation. The share of underrepresented gender in Executive Management was 0% in 2023, which is unchanged from 2022. This is due to no change in the Executive Management. NORDEN has a target of a 40% share of the underrepresented gender by 2027. The other levels of management currently consist of 14 employees with 23% constituting the underrepresented gender. NORDEN aims to increase the share of the underrepresented gender in managerial positions to at least 40% by 2027. To gradually increase the share of the underrepresented gender, we conduct unbiased hiring and always include all genders when screening for new employees to be part of the other levels of management. As this is the first year of setting a target figure for the other levels of management, naturally the target figure has not been reached, and above mentioned initia- tives are thus of focus and still considered on track Diversity in management Managment levelMetric2023 Total number of members 6 Percentage of underrepresented gender 33% Target figures in percentage 40% Board Year of acheivement of target figure 2025 Total number of members 14 Percentage of underrepresented gender 23% Other levels of Target figures in percentage 40% management Year of acheivement of target figure 2027 Diversity in the workforce The share of the underrepresented gender among employees was 41% in 2023, up from 40% in 2022, reaching our target of 40%. Among management and senior management, the share of the underrepre- sented gender was 38% and 20%, respectively, in 2023, compared to 37% and 20% in 2022. NORDEN aims to increase the share of the underrepresented gender in managerial positions to at least 40% by 2025. Commercial roles represent an employee group to which we have, historically, had the most difficulty in attracting and retaining women. Since 2020, the share of women in commercial roles has increased from 17% to 23%. Another representation of NORDEN's diversity efforts is the 52 different nationalities in 2023. Furthermore, the percentage of non-Danish employees has risen to 57% from 54% in 2023. Diversity across employee groups 2023 2022 Share of underrepresented gender in sharehold- er-elected members of the Board of Directors 33% 33% Share of underrepresented gender in Executive Management 0% 0% Share of underrepresented gender in Senior Management 20% 20% Share of underrepresented gender in managerial positions 38% 37% Share of underrepresented gender among employees 41% 40% Share of underrepresented gender among employees in commercial roles 23% 23% Gender distribution in senior management Gender 2023 2022 Female 1 1 Male 4 4 Total 5 5 Engagement score NORDEN’s overall employee engagement score was 84 in 2023 – an increase on 2022. The score is above our ambition of 80, while exceeding the global benchmark provided by Ennova, which bench- marks against all industries for each of the four indicators. NORDEN performs well within most sub-categories, but aims to strengthen the feedback culture. The response rate of our latest survey was 94%, corresponding to 461 of 489 employees (as of September 2023). New hires are categorised according to location, average age and female ratio. In 2023, NORDEN hired 110 employees with an average age of 38 years and 28% being female. Females represented 38% of leavers in 2023. Despite the net effect of new hires and leavers resulting in a decreasing share of the underrepresented gender, the gender ratio is still above our ambition of 40%. The average age of leavers was approximately 37 years. Retention and turnover rates The overall retention rate was 94% in 2023, the same as in 2022. Retention rates are measured across locations, age groups and gender. Although differences are considered non-material, NORDEN is monitoring the development in retention across cate- gories, to capture and address any signs of imbalances due to, for example, a lack of inclusivity. The turnover rate among full-time employees was 15% in 2023, up from 9% in 2022, with the lowest turnover rate seen in the 30-50 age group. Retention rate across age groups Gender &lt; 30 30 - 50 &gt; 50 Total Female 94% 94% 100% 95% Male 93% 92% 97% 93% Total 94% 93% 99% 94% Turnover rate across age groups Gender &lt; 30 30 - 50 &gt; 50 Total Female 15% 12% 17% 13% Male 23% 12% 21% 15% Total 19% 12% 19% 15% Total number of employee turnover Gender Total Female 22 Male 37 Total 59 2023 achievements &amp; initiatives • Maintained our focus on inclusion, which is measured through our engagement survey. The survey showed the same high perception of inclusion in 2023 as in 2022. The inclusion section focuses on respect, trust, the ability to raise discrimination concerns and the possibility of being yourself at work. • Strengthened DE&amp;I in our processes and working instruc- tions for recruiting, promoting and rewarding with the aim of strengthening equal gender distribution in general and in managerial as well as commercial roles. • Introduced an anti-harassment policy with the purpose of contributing to a respectful and inclusive working environ- ment and introduced a Speak Up campaign. • Developed and implemented a Technical Manager Code of Conduct, outlining common principles for how to adhere to social, ethical and environmental standards. This has been signed by all technical managers. • Visited technical management offices, attended crew semi- nars and conducted inspections on-board our vessels to promote safety and well-being. Distribution of employees across age groups Year &lt; 30 30 - 50 &gt; 50 Total 2022 17% 66% 17% 100% 2023 19% 65% 16% 100% In 2024, focus will be on increasing the share of the underrepre- sented gender in commercial and managerial roles. The gender distribution in number at top management: Top management is defined as the senior management in the Corpo- rate Governance section. The number of each gender is based on</mrv:StatementOfTargetFiguresAndPoliciesForTheUnderrepresentedGender>
   <sob:StatementByExecutiveAndSupervisoryBoards contextRef="ctx1" id="fact4748" xml:lang="en">STATEMENT BY THE BOARD OF DIRECTORS AND EXECUTIVE MANAGEMENT The Board of Directors and the Executive Management have today consid- ered and adopted the Annual Report of Dampskibsselskabet NORDEN A/S for the financial year 1 January–31 December 2023. The Consolidated Financial Statements are prepared in accordance with IFRS Accounting Standards as adopted by the EU and additional requirements stated in the Danish Financial Statements Act. The Parent Company Financial Statements are prepared in accordance with the Danish Financial Statements Act. The Management’s Review is also prepared in accordance with the Danish Financial Statements Act. In our opinion, the Consolidated Financial Statements and the Parent Company Financial Statements give a true and fair view of the financial posi- tion at 31 December 2023 of the Group and the Parent Company and of the results of the Group’s and the Parent Company’s operations and the Group’s consolidated cash flows for the financial year 2023. In our opinion, the Management’s Review provides a fair review of the devel- opment in the operations and financial circumstances of the Group and the Parent Company, of the results for the year and of the financial position of the Group and the Parent Company as well as a description of the most significant risks and elements of uncertainty, which the Group and the Parent Company are facing. In our opinion, the ESG performance data on pages 43-66 is presented in accordance with the stated accounting policies on pages 67–76 and provides a fair and balanced view of the Group’s sustainability performance and social responsibility for the financial year 2023. In our opinion, the Annual Report of Dampskibsselskabet NORDEN A/S for the financial year 1 January–31 December 2023 with the file name "norden- 2023-12-31-en.zip" is prepared, in all material respects, in compliance with the ESEF Regulation. We recommend that the Annual Report be adopted at the annual general meeting on 12 March 2024.</sob:StatementByExecutiveAndSupervisoryBoards>
   <sob:PlaceOfSignatureOfStatement contextRef="ctx1" id="fact4780" xml:lang="en">Copenhagen</sob:PlaceOfSignatureOfStatement>
   <sob:DateOfApprovalOfAnnualReport contextRef="ctx1" id="fact4781">2024-02-08</sob:DateOfApprovalOfAnnualReport>
   <cmn:NameAndSurnameOfMemberOfExecutiveBoard contextRef="ctx2" id="fact5090" xml:lang="en">Jan Rindbo</cmn:NameAndSurnameOfMemberOfExecutiveBoard>
   <cmn:NameAndSurnameOfMemberOfExecutiveBoard contextRef="ctx3" id="fact5092" xml:lang="en">Martin Badsted</cmn:NameAndSurnameOfMemberOfExecutiveBoard>
   <cmn:TitleOfMemberOfExecutiveBoard contextRef="ctx2" id="fact5091" xml:lang="en">CEO</cmn:TitleOfMemberOfExecutiveBoard>
   <cmn:TitleOfMemberOfExecutiveBoard contextRef="ctx3" id="fact5093" xml:lang="en">CFO</cmn:TitleOfMemberOfExecutiveBoard>
   <cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx4" id="fact5094" xml:lang="en">Klaus Nyborg</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
   <cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx6" id="fact5098" xml:lang="en">Johanne Riegels Østergård</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
   <cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx8" id="fact5102" xml:lang="en">Karsten Knudsen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
   <cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx10" id="fact5105" xml:lang="en">Robert Hvide Macleod</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
   <cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx11" id="fact5106" xml:lang="en">Ian McIntosh</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
   <cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx12" id="fact5107" xml:lang="en">Vibeke Bak Solok</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
   <cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx4" id="fact5095" xml:lang="en">Chair</cmn:TitleOfMemberOfSupervisoryBoard>
   <cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx6" id="fact5099" xml:lang="en">Vice chair</cmn:TitleOfMemberOfSupervisoryBoard>
   <cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx5" id="fact5096" xml:lang="en">Henrik Røjel</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
   <cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx7" id="fact5100" xml:lang="en">Christina Lerchedahl Christensen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
   <cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx9" id="fact5103" xml:lang="en">William Boatwright</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
   <cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx5" id="fact5097" xml:lang="en">(employee-elected)</cmn:TitleOfMemberOfSupervisoryBoard>
   <cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx7" id="fact5101" xml:lang="en">(employee-elected)</cmn:TitleOfMemberOfSupervisoryBoard>
   <cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx9" id="fact5104" xml:lang="en">(employee-elected)</cmn:TitleOfMemberOfSupervisoryBoard>
   <arr:IndependentAuditorsReportsAudit contextRef="ctx1" id="fact4782" xml:lang="en">INDEPENDENT AUDITOR’S REPORT</arr:IndependentAuditorsReportsAudit>
   <arr:AddresseeOfAuditorsReportOnAuditedFinancialStatements contextRef="ctx1" id="fact4783" xml:lang="en">To the shareholders of Dampskibsselskabet NORDEN A/S Report on the audit of the Consolidated Financial Statements and Parent Company Financial Statements</arr:AddresseeOfAuditorsReportOnAuditedFinancialStatements>
   <arr:OpinionOnAuditedFinancialStatements contextRef="ctx1" id="fact4786" xml:lang="en">Opinion We have audited the consolidated financial statements and the parent company financial statements of Dampskibsselskabet NORDEN A/S for the financial year 1 January – 31 December 2023, which comprise income state- ment, statement of financial position, statement of changes in equity and notes, including accounting policies, for the Group and the Parent Company, and a consolidated statement of comprehensive income and a consolidated statement of cash flows. The consolidated financial statements are prepared in accordance with IFRS Accounting Standards as adopted by the EU and additional requirements of the Danish Financial Statements Act, and the parent company financial statements are prepared in accordance with the Danish Financial Statements Act. In our opinion, the consolidated financial statements give a true and fair view of the financial position of the Group at 31 December 2023 and of the results of the Group's operations and cash flows for the financial year 1 January – 31 December 2023 in accordance with IFRS Accounting Standards as adopted by the EU and additional requirements of the Danish Financial Statements Act. Further, in our opinion the parent company financial statements give a true and fair view of the financial position of the Parent Company at 31 December 2023 and of the results of the Parent Company's operations for the financial year 1 January – 31 December 2023 in accordance with the Danish Financial Statements Act. Our opinion is consistent with our long-form audit report to the Audit Committee and the Board of Directors.</arr:OpinionOnAuditedFinancialStatements>
   <arr:KeyAuditMattersAudit contextRef="ctx1" id="fact4830" xml:lang="en">Key audit matters Key audit matters are those matters that, in our professional judgement, were of most significance in our audit of the financial statements for the financial year 2023. These matters were addressed during our audit of the financial statements as a whole and in forming our opinion thereon. We do not provide a separate opinion on these matters. For each matter below, our description of how our audit addressed the matter is provided in that context. We have fulfilled our responsibilities described in the "Auditor's responsi- bilities for the audit of the financial statements" section, including in relation to the key audit matters below. Our audit included the design and perfor- mance of procedures to respond to our assessment of the risks of material misstatement of the financial statements. The results of our audit procedures, including the procedures performed to address the matters below, provide the basis for our audit opinion on the financial statements. Key audit matter Valuation of intangible and tangible assets. Intangible and tangible assets amount to USD million 996 on 31 December 2023 as specified by Management in note 3.3, 3.4 and 3.5 to the consoli- dated financial statements. This area is significant to our audit due to the carrying value of intangible and tangible assets as well as the management judgements and assump- tions involved in impairment testing of these. Management monitors continuously the carrying value of intangible and tangible assets to determine, whether there are any indications of impair- ment. The assessment of impairment indicators is performed on a portfolio basis on the two cash-generating units (CGUs); Dry cargo and Tankers. The indications assessed by Management comprises, among other, vessel values, newbuilding prices and expectations to future development in short- and long-term freight and time charter rates. Management performs an impairment test if any indication of impairment exists and at least once a year for CGUs to which goodwill has been allo- cated. The impairment test is performed by comparing the carrying amount of intangible and tangible assets with their recoverable amount. The recover- able amount of the assets is determined as the higher of the net selling price and the value-in-use. If the carrying amount, exceeds the recoverable amount, as assessed by the impairment testing, the assets are written down to the lower recoverable amount. For details on the impairment tests performed by Management reference is made to note 3.2 in the consolidated financial statements. How our audit addressed the key audit matter We discussed with Management and evaluated the methodology by which indi- cations of impairment of intangible and tangible assets are monitored, including the identification of CGUs. For the CGU Dry Cargo, Management identified impairment indicators and assessed the recoverable amounts of assets allocated to the CGU. Our audit procedures to test Management’s assessment of the recoverable amount included, among others: • Testing of the value-in-use model and the valuation methodology prepared by Management. • Testing of the mathematical accuracy of the model and the reliability of data used in the calculation. • Testing the reasonableness of key assumptions and input data on basis of our knowledge of the business and industry together with supporting evidence such as budgets and externally observable market data related to expected short- and long-term freight and time charter rates, peer group information, interest rates etc. For the CGU Tankers, Management did not identify any impairment indicators. Our audit procedures to test Management’s assessment of impairment indica- tors included, among others: • Assessment of the conclusions from Management’s assessment of whether any indications of impairment exist. • Testing the reasonableness of Management’s assessment by comparing key assumptions and input data to supporting evidence such as exter- nally observable market data related to short, and long-term freight and time charter rates, pricing of newbuilding of vessels and vessel valuations prepared by external and independent ship valuation experts. We examined the adequacy of disclosures about key assumptions and sensi- tivity in note 3.2 to the consolidated financial statements.</arr:KeyAuditMattersAudit>
   <arr:DescriptionOfQualificationsOfAuditedFinancialStatements contextRef="ctx1" id="fact4810" xml:lang="en">Basis for opinion We conducted our audit in accordance with International Standards on Auditing (ISAs) and additional requirements applicable in Denmark. Our responsibilities under those standards and requirements are further described in the "Auditor's responsibilities for the audit of the consolidated financial statements and the parent company financial statements" (here- inafter collectively referred to as "the financial statements") section of our report. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion. Independence We are independent of the Group in accordance with the International Ethics Standards Board for Accountants' International Code of Ethics for Profes- sional Accountants (IESBA Code) and the additional ethical requirements applicable in Denmark, and we have fulfilled our other ethical responsibilities in accordance with these requirements and the IESBA Code. To the best of our knowledge, we have not provided any prohibited non-audit services as described in article 5(1) of Regulation (EU) no. 537/2014. Appointment of auditor We were initially appointed as auditor of Dampskibsselskabet NORDEN A/S on 9 March 2023 for the financial year 2023.</arr:DescriptionOfQualificationsOfAuditedFinancialStatements>
   <arr:StatementOnManagementsReviewAuditorsReportOnAuditedFinancialStatements contextRef="ctx1" id="fact4905" xml:lang="en">Statement on the Management's review Management is responsible for the Management's review. Our opinion on the financial statements does not cover the Management's review, and we do not express any form of assurance conclusion thereon. In connection with our audit of the financial statements, our responsibility is to read the Management's review and, in doing so, consider whether the Management's review is materially inconsistent with the financial statements or our knowledge obtained during the audit, or otherwise appears to be materially misstated. Moreover, it is our responsibility to consider whether the Management's review provides the information required under the Danish Financial State- ments Act. Based on the work we have performed, we conclude that the Management's review is in accordance with the financial statements and has been prepared in accordance with the requirements of the Danish Financial Statements Act. We did not identify any material misstatement of the Management's review.</arr:StatementOnManagementsReviewAuditorsReportOnAuditedFinancialStatements>
   <arr:StatementOfExecutiveAndSupervisoryBoardsResponsibilityForFinancialStatements contextRef="ctx1" id="fact4921" xml:lang="en">Management's responsibilities for the financial statements Management is responsible for the preparation of consolidated financial statements that give a true and fair view in accordance with IFRS Accounting Standards as adopted by the EU and additional requirements of the Danish Financial Statements Act and for the preparation of parent company financial statements that give a true and fair view in accordance with the Danish Finan- cial Statements Act. Moreover, Management is responsible for such internal control as Manage- ment determines is necessary to enable the preparation of financial state- ments that are free from material misstatement, whether due to fraud or error. In preparing the financial statements, Management is responsible for assessing the Group's and the Parent Company's ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting in preparing the financial state- ments unless Management either intends to liquidate the Group or the Parent Company or to cease operations, or has no realistic alternative but to do so.</arr:StatementOfExecutiveAndSupervisoryBoardsResponsibilityForFinancialStatements>
   <arr:StatementOfAuditorsResponsibilityForAuditAndAuditPerformed contextRef="ctx1" id="fact4937" xml:lang="en">Auditor's responsibilities for the audit of the financial statements Our objectives are to obtain reasonable assurance as to whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor's report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs and additional requirements applicable in Denmark will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered mate- rial if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of the financial statements. As part of an audit conducted in accordance with ISAs and additional require- ments applicable in Denmark, we exercise professional judgement and maintain professional scepticism throughout the audit. We also: • Identify and assess the risks of material misstatement of the financial state- ments, whether due to fraud or error, design and perform audit procedures responsive to those risks and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations or the override of internal control. • Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Group's and the Parent Company's internal control. • Evaluate the appropriateness of accounting policies used and the reasona- bleness of accounting estimates and related disclosures made by Manage- ment. • Conclude on the appropriateness of Management's use of the going concern basis of accounting in preparing the financial statements and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Group's and the Parent Company's ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditor's report to the related disclosures in the financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditor's report. However, future events or conditions may cause the Group and the Parent Company to cease to continue as a going concern. • Evaluate the overall presentation, structure and contents of the financial statements, including the note disclosures, and whether the financial state- ments represent the underlying transactions and events in a manner that gives a true and fair view. • Obtain sufficient appropriate audit evidence regarding the financial infor- mation of the entities or business activities within the Group to express an opinion on the consolidated financial statements. We are responsible for the direction, supervision and performance of the group audit. We remain solely responsible for our audit opinion. We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit. We also provide those charged with governance with a statement that we have complied with relevant ethical requirements regarding independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear on our independence, and where applicable, actions taken to eliminate threats or safeguards applied. From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the consolidated financial statements and the parent company financial statements of the current period and are therefore the key audit matters. We describe these matters in our auditor's report unless law or regulation precludes public disclosure about the matter.</arr:StatementOfAuditorsResponsibilityForAuditAndAuditPerformed>
   <arr:AuditorsReportOnXbrlTagging contextRef="ctx1" id="fact5006" xml:lang="en">Report on compliance with the ESEF Regulation As part of our audit of the Consolidated Financial Statements and Parent Company Financial Statements of Dampskibsselskabet NORDEN A/S, we performed procedures to express an opinion on whether the annual report of Dampskibsselskabet NORDEN A/S for the financial year 1 January – 31 December 2023 with the file name "norden-2023-12-31-en.zip" is prepared, in all material respects, in compliance with the Commission Delegated Regu- lation (EU) 2019/815 on the European Single Electronic Format (ESEF Regu- lation) which includes requirements related to the preparation of the annual report in XHTML format and iXBRL tagging of the Consolidated Financial Statements including notes. Management is responsible for preparing an annual report that complies with the ESEF Regulation. This responsibility includes: • The preparing of the annual report in XHTML format; • The selection and application of appropriate iXBRL tags, including exten- sions to the ESEF taxonomy and the anchoring thereof to elements in the taxonomy, for all financial information required to be tagged using judge- ment where necessary; • Ensuring consistency between iXBRL tagged data and the Consolidated Financial Statements presented in human readable format; and • For such internal control as Management determines necessary to enable the preparation of an annual report that is compliant with the ESEF Regula- tion. • Our responsibility is to obtain reasonable assurance on whether the annual report is prepared, in all material respects, in compliance with the ESEF Regulation based on the evidence we have obtained, and to issue a report that includes our opinion. The nature, timing and extent of procedures selected depend on the auditor’s judgement, including the assessment of the risks of material departures from the requirements set out in the ESEF Regulation, whether due to fraud or error. The procedures include: • Testing whether the annual report is prepared in XHTML format; • Obtaining an understanding of the company’s iXBRL tagging process and of internal control over the tagging process; • Evaluating the completeness of the iXBRL tagging of the Consolidated Financial Statements including notes; • Evaluating the appropriateness of the company’s use of iXBRL elements selected from the ESEF taxonomy and the creation of extension elements where no suitable element in the ESEF taxonomy has been identified; • Evaluating the use of anchoring of extension elements to elements in the ESEF taxonomy; and • Reconciling the iXBRL tagged data with the audited Consolidated Financial Statements. In our opinion, the annual report of Dampskibsselskabet NORDEN A/S for the financial year 1 January – 31 December 2023 with the file name "norden-2023- 12-31-en.zip" is prepared, in all material respects, in compliance with the ESEF Regulation.</arr:AuditorsReportOnXbrlTagging>
   <arr:SignatureOfAuditorsPlace contextRef="ctx1" id="fact5063" xml:lang="en">Copenhagen</arr:SignatureOfAuditorsPlace>
   <arr:SignatureOfAuditorsDate contextRef="ctx1" id="fact5064">2024-02-08</arr:SignatureOfAuditorsDate>
   <cmn:NameOfAuditFirm contextRef="ctx38" id="fact5397" xml:lang="en">EY Godkendt Revisionspartnerselskab</cmn:NameOfAuditFirm>
   <cmn:NameOfAuditFirm contextRef="ctx39" id="fact5408" xml:lang="en">EY Godkendt Revisionspartnerselskab</cmn:NameOfAuditFirm>
   <cmn:NameAndSurnameOfAuditor contextRef="ctx38" id="fact5399" xml:lang="en">Mikkel Sthyr</cmn:NameAndSurnameOfAuditor>
   <cmn:NameAndSurnameOfAuditor contextRef="ctx39" id="fact5403" xml:lang="en">Morten Weinreich Larsen</cmn:NameAndSurnameOfAuditor>
   <cmn:DescriptionOfAuditor contextRef="ctx39" id="fact5404" xml:lang="en">State Authorised Public Accountant</cmn:DescriptionOfAuditor>
   <cmn:IdentificationNumberOfAuditor contextRef="ctx39" id="fact5406" xml:lang="en">mne42791</cmn:IdentificationNumberOfAuditor>
   <cmn:DescriptionOfAuditor contextRef="ctx38" id="fact5400" xml:lang="en">State Authorised Public Accountant</cmn:DescriptionOfAuditor>
   <cmn:IdentificationNumberOfAuditor contextRef="ctx38" id="fact5402" xml:lang="en">mne26693</cmn:IdentificationNumberOfAuditor>
</xbrli:xbrl>