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| ifrs-full:Assets | 2023-12-31 | 8159800 | dkk |
| ifrs-full:Assets | 2022-12-31 | 7193900 | dkk |
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| ifrs-full:Revenue | 2023-01-01 | 2023-12-31 | 6078400 | dkk |
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<mrv:CorporateGovernanceReport contextRef="ctx-1" id="s7_notesesefdkgaap__7__7" xml:lang="en">General disclosuresBasis of preparationThe sustainability section for Netcompany Group has been prepared on a consolidated basis with the same scope as the financial statement, ex-cluding joint-ventures and non-controlling inter-ests. These will be included in our 2024 annual reporting. The sustainability statement covers thevalue chain of Netcompany Group with respect to impacts, risks, and opportunities in the main parts of our upstream and downstream value chain. No information regarding intellectual prop-erty or know-how has intentionally been omitted.We have not published targets in this report, as we are working on prioritising our sustainability focus areas with an ambition to set mid- and long-term targets aligned with our overall strate-gic ambitions.Time horizons and outcome uncertaintyUnless otherwise stated, we distinguish between short-term, medium-term and long-term when re-ferring to time horizons. Short-term is the report-ing period in our financial statements â one year; medium-term is from the end of the short-term up to five years; long-term is defined as more than five years. The value chain information described in this re-port is based on a combination of desk research, direct engagement with members of our value chain, and expert statements. Restatement of 2022 figuresTo prepare for the Corporate Sustainability Reporting Directive (CSRD), we have aligned our ESG KPI reporting with applicable definitions and requirements from the European Sustainability Reporting Standards (ESRS). The 2022 ESG KPIs reported in the Netcompany ESG Report 2022 have been restated accordingly and constitute our new baseline. Restatements, if any, are stat-ed in the accounting principles concerning the relevant KPI.Financial effectsThe financial effects of our efforts in 2023 are deemed limited. The transition to prepare for the Corporate Sustainability Reporting Directive (CSRD), the EU Taxonomy Regulation, and initiate actions aligned with our material topics are in the initial phase. Organisationally, we have em-bedded the sustainability reporting and strategy responsibility into the Group Finance function under the CFO, and in that relation upscaled the number of people working in this area. Our tradi-tion for ensuring professional and social opportu-nities for our people has persisted in 2023, while we in the environmental area have signed our first Power Purchase Agreement (PPA) â collec-tively with no material impact on our financials.Disclosures stemming from other legislation or generally accepted sustainability reporting pronouncementsThis sustainability statement supports our annual Communication on Progress to the UN Global Compact for the financial year 2023, from 1 January to 31 December 2023. It describes the 2023 sustainability initiatives and key figures of Netcompany Group. It is an integral part of Netcompany Groupâs Annual Report 2023 and constitutes disclosures stemming from our ac-count of social responsibility, cf. section 99a, statement of the underrepresented gender, cf. 99b, statement of data ethics, cf. section 99d, and statutory statement on section 107d of the Danish Financial Statements Act. See the following sections for disclosures re-quired by Danish legislation. This report shows how environmental, social and ethical risks are managed in Netcompany Group. It is reported using the ESG Reporting Guide 2.0 by Nasdaq and the criteria established through the UN Global Compact as guiding tools. NSPAARRETNCGS2022Management responsibilitiesComposition The composition of Netcompanyâs management is a two-tier structure consisting of the Board of Directors and Executive Management. The two bodies are independent, and, as required by the Danish Companies Act, neither the Chair or the Vice Chair is an executive officer of Netcompany. There are no overlaps between the role and responsibilities of the Chair or Vice Chair and the CEO. The Board of Directors, which is appointed by the shareholders, supervises the work of the Executive Management and is respon-sible for the overall and strategic manage-ment and proper organisation of Netcompany Groupâs activities. The Executive Management is responsible for Netcompany Groupâs day-to-day management. The division of responsi-bility between the Board of Directors and the Executive Management is set out in the Rules of Procedures for the Board of Directors and in the Executive Management Instructions. Our shareholders exercise their rights at the gen-eral meeting. The general meeting adopts deci-sions, such as the election of Board members and the auditor, in accordance with applicable law. As a listed company, we observe the Danish Recommendations on Corporate Governance, which are based on the comply-or-explain princi-ple. We fully comply with 40 out of the 40 recom-mendations according to the Danish Committee on Corporate Governance and annually prepare a statement on corporate governance for the financial year. Our Corporate Governance Statement forms part of the Managementâs Report and can be viewed under Documents and Governance on the website*. Board of Directors The Board of Directors of Netcompany currently consists of five members, all of whom are elected by shareholders at the Annual General Meeting. According to the Articles of Association, the Board of Directors must consist of at least three and no more than seven members. The Board of Directors appoints a Chair and a Vice Chair among its members. Each member is elected for a one-year term, and members may be re-elected. The Board of Directors meets at least six times a year and conducts extraordinary meetings when relevant. One hundred percent (100%) of the five mem-bers of the Board of Directors are consid-ered independent according to the Danish Recommendations on Corporate Governance and applicable standards and guidelines.Board Committees In order to support the Board of Directors in Netcompany Group A/S, we have established three board committees: the Audit Committee, the Remuneration Committee, and the Nomination Committee.The main purpose of the committees includes preparatory tasks and making recommenda-tions to the Board of Directors, who makes final decisions on subjects at hand. The main tasks and duties for each committee are set out in theseparate committee charters. The charters are reviewed and, if deemed necessary, updated, and approved by the Board of Directors annu-ally. The members of the board committees, including the committee chair, are appointed by the Board of Directors among its own members. *https://netcompany.com/investor/governance/Audit CommitteeThe Audit Committee consists of three mem-bers of the Board of Directors, Ã
sa Riisberg (Committee Chair), Susan Cooklin, and Bart Walterus, and its purpose is to assist the Board of Directors with the oversight of, among oth-ers, the financial-, sustainability-, and statutory audit matters, internal control and risk man-agement, whistleblower procedures, external auditor and related tasks of the Netcompany Group. Further, the Audit Committee supervis-es the external auditorâs independence and the procedure for election of an external auditor.The Audit Committee meets at least four times a year in connection with our financial report-ing and the preparation of the Annual Report. In addition to the regular meetings, the Audit Committee convenes for a full day dedicated to risk management, where a deep dive into the Risk Management Framework and reported risks is conducted.Remuneration CommitteeThe Remuneration Committee consists of two members of the Board of Directors, Juha Christensen (Committee Chair) and Bo Rygaard. Its purpose is to assist the Board of Directors by preparing and presenting pro-posals and recommendations on matters related to the remuneration of our Board of Directors and Executive Management. This includes, among others, the annual review of the Remuneration Policy, ensure the re-munerationsâ compliance with the approved Remuneration Policy, incentive programmes and specific targets, overseen the pension, retirement, death, disability or life assurance schemes for the Executive Management, and preparation of the Remuneration Report.The Remuneration Committee meets at least twice a year.Nomination CommitteeThe Nomination Committee consists of two members of the Board of Directors, Juha Christensen (Committee Chair), and Bo Rygaard. Its purpose is to assist the Board of Directors by preparing and presenting decisionproposals and recommendations on mat-ters related to the composition of our Board of Directors and Executive Management, including the nomination of candidates and evaluation of the composition of the Board of Directors and Executive Management. When assessing this, the committee must take the Diversity, Equity, and Inclusion Policy into account, including its target figures for the underrepresented gender. Furthermore, it must annually review the Diversity, Equity, andInclusion Policy, and recommend any updates regarding the target figures and policy for the gender composition of the Board of Directors and other managerial functions. The Nomination Committee meets at least twice a year.Executive ManagementThe Executive Management currently con-sists of three members, André Rogaczewski (Netcompany Group CEO), Claus Jørgensen (Netcompany Group COO), and Thomas Johansen (Netcompany Group CFO). Together, they form the management registered with the Danish Business Authority. The Executive Management is responsible for the day-to-day management. The Board of Directors has laid down instructions for the work of the Executive Management, including the division of work between the Board of Directors and Executive Management in the Board of Directors approved Executive Management Instructions. The day-to-day operations include, among others, the continuous improvement of our busi-ness, making sure we operate in compliance with the Articles of Association, general policies and guidelines, and other applicable rules and reg-ulations, as well as the continuous reporting to the Board of Directors on Netcompany Groupâs activities, financial state, and other matters of significance. Together with the Board of Directors, the Executive Management has established a pro-cedure for an annual evaluation of their coop-eration. The procedure consists of a formalised dialogue between the Chair and the CEO, and the outcome is presented to the Board of Directors. The Board of Directors and the Executive Management have consistently evaluated their cooperation as good and constructive, and with informative dialogues both at formal board meet-ings and via informal dialogue between meetings. The Chair of the Board of Directors also regu-larly meets and engages in discussions with the Executive Management. In addition, the Chair of the Audit Committee regularly meets informally and engages in cooperative discussions with the Group CFO. 2023* 2022Attendance at board meetings 100% 94%§Accounting principlesThe attendance for each board member (in percent) is found by dividing the total number of board meeting held divided by the number of board meetings the member attended. The total attendance (in percent) is found by dividing the sums of the individual membersâ attendance by the total number of board members.Written resolutions and risk day are not counted as part of the total number of board meetings held. The number of board meetings attended by a member is based solely on the number of board meetings held during the period in which the member is sitting on the board and the attendance of that board member only includes board meetings held before their resignation. If a board member steps down and/or is not re-elect-ed at the general meeting, the total board attendance excludes any resigned board memberâs attendance when calculating the total attendance of the board. Likewise, the number of committee meetings at-tended by a member is based solely on the number of committee meetings held during the period in which the member is sitting on the committee and excludes committee meetings held before their election or after their resignation.For committee meetings, only board members of the given committee are counted as part of the total committee meetings.DiversityIn the following section, we report in accor-dance with the Danish Financial Act, section 99b (6), the Danish Financial Act, section 107d, and the Danish Corporate Governance Recommendations. Our Diversity, Equity, and Inclusion Policy, as approved by the Board of Directors, covers all said requirements and recommendations.Diversity, Equity, and Inclusion PolicyOur Diversity, Equity, and Inclusion Policy applies to all levels at Netcompany and is considered by the Board of Directors if a new board member is proposed at a general meeting, and in connec-tion with the hiring and promotion of persons to managerial positions. The Diversity, Equity, and Inclusion Policy provides the basis for our work to create equal career opportunities for all other employees and is, among others, intended to increase focus on the share of women and other minorities in the managerial positions. Our Diversity, Equity, and Inclusion Policy applies to everyone at Netcompany â from the Board of Directors and Executive Management through to all other employees and includes requirements from both hard and soft law.We have a focus on equal gender distribution both at Netcompany and generally within the IT sector, as there are statistically fewer women in the IT industry. We wish to be a workplace where everyone feels included and valued for who they are and what they do. We also consider other aspects of diversity in addition to gender e.g., age, or educational and commercial background. We have extended our diversity outlook to in-clude other social identity attributes, which are described in our Diversity, Equity, and Inclusion Policy. We strive to achieve diversity on multiple social identity attributes through our openness, recruit-ment processes, our internal advancement pro-grammes, targets set for gender representation in accordance with legislation, and our social gath-erings where employees can meet and socialise. We see and appreciate the value of diversity. Not only as a competitive advantage with the results of innovative ideas and better problem-solving but also as a matter of conforming to what we believe is right. We have achieved advancements in enhancing inclusivity initiatives within our management. Through tailored training programmes and poli-cies, we have cultivated a more inclusive culture, equipping managers to hire, lead and engage all our people, including our management group.Gender diversityWe are required to provide an overview of the gender diversity in the Board and at other man-agerial levels even if there is an equal gender distribution.âOther management levelsâ is to be understood as the first two management levels below the Board of Directors. The first management level below the Board of Directors is the Executive Management, including the persons who are organisationally at the same management level as the Executive Management. The second man-agement level includes people with personnel re-sponsibilities and who report directly to the first management level.As set out in the applicable legislation and the guidance provided by the Danish Business Authority, a boardâs gender distribution is con-sidered equal if the split between the genders is 40%/60% or equivalent, depending on the size of the board. As the Board of Directors as of 31 December 2023 consists of five persons, and two of them are females, we have an equal distri-bution of genders on the Board of Directors, and no target will be set. Our Diversity, Equity, and Inclusion Policy covers, among others, the requirements of the Danish Financial Statements Act section 99b (6) even with Netcompany being exempt from such requirements.In addition to the table on this page, the Danish Financial Statements Act section 99b requires us to make certain statements to ensure compli-ance with the legislation.As of 31 December 2023, Netcompany Group A/S has had less than 50 employees in the fi-nancial year 2023 due to our organisational structure with Netcompany Group A/S being a holding company and with only the Executive Management formally employed in the entity.2023*Board of DirectorsTotal number of members 5The underrepresented gender (female) in % 40%Target number of members of the underrepresented gender (female) in % N/ATarget year N/AExecutive ManagementTotal number of members 3The underrepresented gender (female) in % 0%Target number of members of the underrepresented gender (female) in % N/ATarget year N/ANetcompany is therefore exempt from the re-quirement to prepare a policy to increase the un-derrepresented gender and from setting a target for the underrepresented gender at the manage-rial level.As we are exempt from setting targets for the underrepresented gender as described above, we are naturally also exempt from the obligation to provide a status update, an action plan for its targets, or a description of the applicable policy implemented to reach said targets. Despite being exempt from the above-mentioned legislation, we monitor and report on the gender* Sustainability key figure subject to limited assurancediversity of our people, including the managerial layers. Reference is made to the Social section. In addition, we strive to maintain a minimum share of 40% of the underrepresented gender in our Board of Directors, in line with the Danish Financial Statements Act section 99b (6).§Accounting principlesOnly the two legal genders (male/female), as set out in the applicable legislation, are considered when calculating the share of the underrepre-sented gender (female) in the Board of Directors. The share of female members of the Board of Directors (in percent) can be found by dividing the number of female board members by the to-tal number of board members in percent.The number of female members is found by counting the number of female board members sitting on the board from the Annual General Meeting in March until the end of year.EnvironmentE</mrv:CorporateGovernanceReport>
<mrv:LinkToCorporateGovernanceReport contextRef="ctx-1" id="s7_notesesefdkgaap__7__8" xml:lang="en">https://netcompany.com/investor/governance/</mrv:LinkToCorporateGovernanceReport>
<mrv:StatementOfTargetFiguresAndPoliciesForTheUnderrepresentedGender contextRef="ctx-1" id="s7_notesesefdkgaap__7__10" xml:lang="en">Board of DirectorsTotal number of members 5The underrepresented gender (female) in % 40%Target number of members of the underrepresented gender (female) in % N/ATarget year N/AExecutive ManagementTotal number of members 3The underrepresented gender (female) in % 0%Target number of members of the underrepresented gender (female) in % N/ATarget year N/ANetcompany is therefore exempt from the re-quirement to prepare a policy to increase the un-derrepresented gender and from setting a target for the underrepresented gender at the manage-rial level.As we are exempt from setting targets for the underrepresented gender as described above, we are naturally also exempt from the obligation to provide a status update, an action plan for its targets, or a description of the applicable policy implemented to reach said targets. Despite being exempt from the above-mentioned legislation, we monitor and report on the gender* Sustainability key figure subject to limited assurancediversity of our people, including the managerial layers. Reference is made to the Social section. In addition, we strive to maintain a minimum share of 40% of the underrepresented gender in our Board of Directors, in line with the Danish Financial Statements Act section 99b (6).§Accounting principlesOnly the two legal genders (male/female), as set out in the applicable legislation, are considered when calculating the share of the underrepre-sented gender (female) in the Board of Directors. The share of female members of the Board of Directors (in percent) can be found by dividing the number of female board members by the to-tal number of board members in percent.The number of female members is found by counting the number of female board members sitting on the board from the Annual General Meeting in March until the end of year.</mrv:StatementOfTargetFiguresAndPoliciesForTheUnderrepresentedGender>
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<mrv:StatementOfTheDiversityPolicies contextRef="ctx-1" id="s7_notesesefdkgaap__7__9" xml:lang="en">Gender diversityWe are required to provide an overview of the gender diversity in the Board and at other man-agerial levels even if there is an equal gender distribution.âOther management levelsâ is to be understood as the first two management levels below the Board of Directors. The first management level below the Board of Directors is the Executive Management, including the persons who are organisationally at the same management level as the Executive Management. The second man-agement level includes people with personnel re-sponsibilities and who report directly to the first management level.As set out in the applicable legislation and the guidance provided by the Danish Business Authority, a boardâs gender distribution is con-sidered equal if the split between the genders is 40%/60% or equivalent, depending on the size of the board. As the Board of Directors as of 31 December 2023 consists of five persons, and two of them are females, we have an equal distri-bution of genders on the Board of Directors, and no target will be set. Our Diversity, Equity, and Inclusion Policy covers, among others, the requirements of the Danish Financial Statements Act section 99b (6) even with Netcompany being exempt from such requirements.In addition to the table on this page, the Danish Financial Statements Act section 99b requires us to make certain statements to ensure compli-ance with the legislation.As of 31 December 2023, Netcompany Group A/S has had less than 50 employees in the fi-nancial year 2023 due to our organisational structure with Netcompany Group A/S being a holding company and with only the Executive Management formally employed in the entity.2023*Board of DirectorsTotal number of members 5The underrepresented gender (female) in % 40%Target number of members of the underrepresented gender (female) in % N/ATarget year N/AExecutive ManagementTotal number of members 3The underrepresented gender (female) in % 0%Target number of members of the underrepresented gender (female) in % N/ATarget year N/ANetcompany is therefore exempt from the re-quirement to prepare a policy to increase the un-derrepresented gender and from setting a target for the underrepresented gender at the manage-rial level.As we are exempt from setting targets for the underrepresented gender as described above, we are naturally also exempt from the obligation to provide a status update, an action plan for its targets, or a description of the applicable policy implemented to reach said targets. Despite being exempt from the above-mentioned legislation, we monitor and report on the gender* Sustainability key figure subject to limited assurancediversity of our people, including the managerial layers. Reference is made to the Social section. In addition, we strive to maintain a minimum share of 40% of the underrepresented gender in our Board of Directors, in line with the Danish Financial Statements Act section 99b (6).§Accounting principlesOnly the two legal genders (male/female), as set out in the applicable legislation, are considered when calculating the share of the underrepre-sented gender (female) in the Board of Directors. The share of female members of the Board of Directors (in percent) can be found by dividing the number of female board members by the to-tal number of board members in percent.The number of female members is found by counting the number of female board members sitting on the board from the Annual General Meeting in March until the end of year.</mrv:StatementOfTheDiversityPolicies>
<mrv:StatusOfAchievementOfTargetFigureOtherManagementLevels contextRef="ctx-1" id="s7_notesesefdkgaap__7__22" xml:lang="en">As set out in the applicable legislation and the guidance provided by the Danish Business Authority, a boardâs gender distribution is con-sidered equal if the split between the genders is 40%/60% or equivalent, depending on the size of the board. As the Board of Directors as of 31 December 2023 consists of five persons, and two of them are females, we have an equal distri-bution of genders on the Board of Directors, and no target will be set.</mrv:StatusOfAchievementOfTargetFigureOtherManagementLevels>
<mrv:StatusOfAchievementOfTargetFigureOfUnderrepresentedGenderBoardOfDirectors contextRef="ctx-1" id="s7_notesesefdkgaap__7__15" xml:lang="en">As set out in the applicable legislation and the guidance provided by the Danish Business Authority, a boardâs gender distribution is con-sidered equal if the split between the genders is 40%/60% or equivalent, depending on the size of the board. As the Board of Directors as of 31 December 2023 consists of five persons, and two of them are females, we have an equal distri-bution of genders on the Board of Directors, and no target will be set.</mrv:StatusOfAchievementOfTargetFigureOfUnderrepresentedGenderBoardOfDirectors>
<mrv:StatementOfCorporateSocialResponsibility contextRef="ctx-1" id="s7_notesesefdkgaap__7__24" xml:lang="en">EU TaxonomyThe EU Taxonomy is a regulatory framework in-troduced by the European Union. The Taxonomy plays a role in the European Green Deal that aims towards several environmental goals, including the goal of no greenhouse gas emissions by 2050. The Taxonomy framework is a tool to aid in the transition towards a greener and more sustainable economy. By establishing a clear and standardised classification system and a unified language for what is considered sustainable economic activities, the framework can enable investors and companies to make informed de-cisions on environmentally sustainable activities and determine the degree of sustainability of a given investment. The EU Taxonomy revolves around six climate objectives: Climate change mitigation Climate change adaptation Sustainable use and protection of water and marine resources Transition to a circular economy Pollution prevention and control Protection and restoration of biodiversity and ecosystemsFor the financial year 2022, we reported on el-igibility and alignment for the first two climate objectives. During 2023, the EU Commission ad-opted the annex for the remaining four environ-mental objectives.Alignment share of eligibility - revenueAlignment share of eligibility - Capex41.9%23.5%Alignment share of eligibility - Opex44.1%The three diagrams show the share of Taxonomy alignment for revenue, Capex, and Opex of the Taxonomy eligible activities, calculated as the total alignment figure divided by the total eligibility figure.The reporting scope for the EU Taxonomy for 2023 is as follows:Eligibility reporting Climate change mitigation Climate change adaptation Sustainable use and protection of water and marine resources Transition to a circular economy Pollution prevention and control Protection and restoration of biodiversity and ecosystemsEligible activitiesEligible activities are predetermined by the EU. The economic activities with the largest environmental impact, positive and negative, have been identified by the EU.Eligible economic activities for the financial year 2023 in Netcompany are:Climate change mitigation 6.5. Transport by motorbikes, passenger cars and light commercial vehicles8.1. Data processing, hosting, and related activities8.2. Data-driven solutions for GHG emissions reductionsTransition to a circular economy 4.1. Provision of IT/OT data-driven solutionsAlignment reporting Climate change mitigation Climate change adaptationAligned activitiesFor an eligible economic activity to be classi-fied as sustainable, it must comply with the technical screening criteria of the activity, by contributing to at least one of the six environ-mental objectives, whilst doing no significant harm to the remaining objectives. EU Minimum Safeguards: Along with comply-ing with the technical screening criteria, the Group must meet the safeguard requirements for human rights, anti-corruption, fair compe-tition, and taxation. Climate change mitigation 8.1. Data processing, hosting, and related activitiesTaxonomy 2023RevenueTaxonomy-eligible revenue share grew 2 percent-age points from 5.9% to 7.9% (DKK 156m). This development was driven by the introduction of the circular economy environmental objective which accounted for 0.9 percentage point of the growth, and revenue growth in data processing and hosting activity services which accounted for 1.1 percentage points. Taxonomy-aligned revenue share grew by DKK 6m, as a result of a 3.1% revenue growth in Taxonomy-aligned data processing and hosting services, which was lower compared to the Groupâs total revenue growth of 9.6%. This resulted in a 0.2 percentage points decrease in Taxonomy-aligned revenue ending the year on a 3.3% alignment share. Consequently, the alignment share of reve-nue eligibility decreased from 60.0% to 41.9%. Additionally to the above mentioned, the reason for the decrease was a shift in the allocation key, which is measured as activity in the data centres.CapexTaxonomy-eligible Capex share decreased 12 percentage points, from 14.9% to 2.9%. The de-crease was due to a lower level of investments in data centre hardware and fewer additions of right of use assets (leasing cars) of DKK 16.1m. Concurrently, significant additions to non-eligible Capex in 2023 further diluted the eligibility share. Consequently, Taxonomy-aligned Capex share decreased 4 percentage points, from 4.7% to 0.7%.The alignment share of capitalised eligibility decreased from 31.7% to 23.5%. Additionally to the above mentioned, the reason for the decrease was a shift in the allocation key, which is measured as activity in the data centres.OpexTaxonomy-eligible Opex share grew 46.1 percent-age points, from 34.8% to 80.9%. In monetary amounts, the increase was DKK 127.7m, which would amount to an 546.1% increase. The dis-crepancy between the percentage point increase and the monetary increase, was a result of an updated cost base constituting the Taxonomy-eligible Opex. The increase in the eligibility share was impacted by an increase in data processing and hosting activity throughout 2023. Taxonomy-aligned Opex share grew 14.8 per-centage points from 20.9% to 35.7%. In monetary amounts the increase was DKK 52.9m, which was a result of an increase in Taxonomy-aligned data processing and hosting activity in 2023.Consequently, the alignment share of eligible op-erating expenses decreased from 58.5% to 44.1%. Additionally to the above mentioned, the reason for the decrease was due to a shift in the alloca-tion key, which is measured as activity in the data centres.Collaboration For the activity data processing, hosting, and related activities, we cooperate with third-party data centre co-host operators. Our operational engineers are responsible for the daily operations and monitoring of the servers both remotely and on-premises, while the co-host entity is responsible for housing, security, electricity, and cooling. Due to the nature of our data centre operations, collaboration is a must when ensuring alignment with the technical screening criteria established for the activity. During 2023, we actively worked towards assessing, documenting, and ensur-ing compliance, together with our data centre suppliers. Alignment progressAligning with the sustainability criteria set out by the EU Taxonomy, is of strategic importance to us. For the first time, in 2023, we incorporated Taxonomy alignment criteria into our procure-ment of new data centre hardware, to ensure compliance with the technical screening criteria. In 2024, we will embed the relevant technical screening criteria in our global Procurement Policy, to support alignment with the EU Taxonomy sustainability criteria. Enabling activitiesAs an IT services provider who can enable other industries in their sustainable transition, Netcompany resides at the core of the EU Taxonomy in terms of eligible activities. Activities associated with the Information Technology and Communications sector are predominantly classified as enabling activities. Through opti-misation, monitoring, complex calculations, AI, and real time data, IT has the capabilities to streamline company infrastructure and business processes, resulting in optimised energy and re-source use. IT can aid customers in their efforts towards reducing carbon emissions and preserv-ing natureâs resources, by presenting accurate data in real time, and giving companies the ability to only use the exact amount of power and re-sources needed to operate.Proportion of revenue from products or services associated with Taxonomy-aligned economic activities 2023Substantial contribution DNSHTaxonomy Absolute Climate Climate Water and Biodiversity aligned revenue Proportion Climate Climate Water and Biodiversity change change marine Circular and Minimum proportion Enabling Transitional NACE(DKK of revenue change change marine Circular and mitigation adaptation resources economy Pollution ecosystems safeguardsof revenue activity activity Economic activitiescodesmillion)(%)mitigation adaptation resources economy Pollution ecosystems (Y/N)(Y/N)(Y/N)(Y/N)(Y/N)(Y/N)(Y/N)2022 (%)ETA. Taxonomy-eligible activitiesA.1 Environmentally sustainable activities (taxonomy-aligned)8.1 Data processing, hosting and related activities J63.11 202.3 3.3% Y N N N N N Y Y Y Y Y Y 3.5% TRevenue of environmentally sustainable activities (Taxonomy-aligned) (A.1) 202.3 3.3% 3.3% 0% 0% 0% 0% 0% Y Y Y Y Y Y 3.5%Of which enabling 0% 0% 0% 0% 0% 0% 0% 0% Y Y Y Y Y YOf which transitional 202.3 100% 100% Y Y Y Y Y Y 100%A.2 Taxonomy-Eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)4.1 Provision of IT/OT data-driven solutions J62 71.2 1.2% EL 0%8.1 Data processing, hosting and related activities J63.11 209.5 3.4% EL 2.4%8.2 Data-driven solutions for GHG emissions reductions J62 0.2 0.0% EL 0%Revenue of Taxonomy- eligible but not environmentally sustainable activities (not Taxonomy- aligned activities) (A.2) 280.9 4.6% 3.4% 1.2% 2.4%Revenue of Taxonomy-eligible activities (A.1 + A.2) 483.2 7.9% 5.9%B Taxonomy-non-eligible activitiesRevenue of Taxonomy-non-eligible activities (B) 5,595.2 92.1%Total (A+B) 6,078.4 100%Proportion of Capex from products or services associated with Taxonomy-aligned economic activities 2023Substantial contribution DNSHTaxonomy Absolute Climate Climate Water and Biodiversity aligned Capex Proportion Climate Climate Water and Biodiversity change change marine Circular and Minimum proportion Enabling Transitional NACE(DKK of Capex change change marine Circular and mitigation adaptation resources economy Pollution ecosystems safeguardsof Capex activityactivity Economic activitiescodesmillion)(%)mitigation adaptation resourceseconomy Pollution ecosystems (Y/N)(Y/N)(Y/N)(Y/N)(Y/N)(Y/N)(Y/N)2022 (%)ETA. Taxonomy-eligible activitiesA.1 Environmentally sustainable activities (taxonomy-aligned)8.1 Data processing, hosting and related activities J63.11 5.9 0.7% Y N N N N N Y Y Y Y Y Y 4.7% TCapex of environmentally sustainable activities (Taxonomy-aligned) (A.1) 5.9 0.7% 0.7% 0% 0% 0% 0% 0% Y Y Y Y Y Y 4.7%Of which enabling 0% 0% 0% 0% 0% 0% 0% 0% Y Y Y Y Y YOf which transitional 5.9 100% 100% Y Y Y Y Y Y 100%A.2 Taxonomy-Eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)4.1 Provision of IT/OT data-driven solutions J62 1.8 0.2% EL 0%6.5 Transport by motorbikes, passenger cars and light commercial vehicles N77.11 11.6 1.3% EL 7.0%8.1 Data processing, hosting and related activities J63.11 5.9 0.7% EL 3.1%Capex of Taxonomy- eligible but not environmentally sustainable activities (not Taxonomy- aligned activities) (A.2) 19.4 2.2% 2.0% 0.2% 10.2%Capex of Taxonomy-eligible activities (A.1 + A.2) 25.3 2.9% 14.9%B Taxonomy-non-eligible activitiesCapex of Taxonomy-non- eligible activities (B) 845.0 97.1%Total (A+B) 870.3 100%Proportion of Opex from products or services associated with Taxonomy-aligned economic activities 2023Substantial contribution DNSHTaxonomy Absolute Climate Climate Water and Biodiversity aligned Opex Proportion Climate Climate Water and Biodiversity change change marine Circular and Minimum proportion Enabling Transitional NACE(DKK of Opex change change marine Circular and mitigation adaptation resources economy Pollution ecosystems safeguardsof Opex activity activity Economic activitiescodesmillion) (%)mitigation adaptation resourceseconomy Pollution ecosystems (Y/N)(Y/N)(Y/N)(Y/N)(Y/N)(Y/N)(Y/N)2022 (%)ETA. Taxonomy-eligible activitiesA.1 Environmentally sustainable activities (taxonomy-aligned)8.1 Data processing, hosting and related activities J63.11 66.6 35.7% Y N N N N N Y Y Y Y Y Y 20.9% TOpex of environmentally sustainable activities (Taxonomy-aligned) (A.1) 66.6 35.7% 35.7% 0% 0% 0% 0% 0% Y Y Y Y Y Y 20.9%Of which enabling 0% 0% 0% 0% 0% 0% 0% 0% Y Y Y Y Y YOf which transitional 66.6 100% 100% Y Y Y Y Y Y 100%A.2 Taxonomy-Eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)4.1 Provision of IT/OT data-driven solutions J62 8.9 4.8% EL 0%8.1 Data processing, hosting and related activities J63.11 75.6 40.5% EL 13.9%Opex of Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) (A.2) 84.5 45.2% 40.5% 4.8% 13.9%Opex of Taxonomy-eligible activities (A.1 + A.2) 151.1 80.9% 34.8%B Taxonomy-non-eligible activitiesOpex of Taxonomy-non- eligible activities (B) 35.7 19.1%Total (A+B) 186.8 100%Minimum SafeguardsThe Minimum Safeguards encompass four foun-dational pillars: Human rights, taxation, corrup-tion, and fair competition. These pillars represent the EUâs commitment to fostering responsible and sustainable economic practices. Collectively, they form the cornerstone of ethical and respon-sible business conduct.To align with the EU Taxonomy, we have extend-ed our due diligence (DD) process to our value chain and all the actors within it, i.e., custom-ers, suppliers, and other business relationships. In alignment with the requirements, our value chain accountability applies the two pillars: Human rights and corruption. Our accountabil-ity in the case of the pillars taxation and fair competition applies within the limits of our own operations. Taxation: We ensure compliance with tax laws by following our established tax risk management process as stated in our Tax Policy. In 2023, Netcompany Group paid more than DKK 141m in corporate income taxes. We paid indirect taxes such as VAT and other similar taxes in the excess of DKK 901m. Our employees paid approximately DKK 1,019m in personal income taxes, based on the salaries they earned through their employment with Netcompany. In 2023, the Group contributed more than DKK 2,062m in direct and indirect taxes to the societies in the countries we operate in. For details on our Tax Policy, reference is made to the Financial statements section, Note 12. Fair competition: We enable fair competition by ensuring the implementation and promotion of our Code of Conduct, which stipulates that all board members and employees in Netcompany shall, in their work, comply with applicable laws and regulations and perform their duties per good business practices, our values, and ethical guidelines. Reference is made to the Corporate culture section.To ensure that our adoption of a sustainabil-ity due diligence (SDD) process is coherent, its structure and content are based on the OECD Due Diligence Guidance for Responsible Business Conduct and take into consideration the OECD Guidelines for Multinational Enterprises and the United Nations (UN) Guiding Principles on Business and Human Rights.Value chain due diligenceOur due diligence (DD) process is overseen by our Executive Management and executed by Group Finance. In addition, Group Finance man-ages all direct communication related to our sus-tainability due diligence (SDD) with value chain actors in close coordination with Group Legal. Additionally, Group Legal maintains alignment of our Code of Conduct (CoC) with applicable in-ternational regulations. Reference is made to the Our people section. Lastly, Group Finance carries out the sustainability risk assessment.Due diligence governanceResponsibilities RolesExecutive Overall decision makingManagementOverall due diligence process responsibleEngagement with value chain ExternalFinanceactor responsibleadvisorsSustainability due diligence process responsibleCode of Conduct responsibleLegalEngagement support functionCode of Conduct PolicyOur Code of Conduct (CoC) is a key document outlining, among others, Minimum Safeguards (MS) requirements and communicates our ex-pectations to existing and new suppliers. The policy can be found under Policies on our websiteâs governance section*, and we continu-ously update it to address new MS requirements.In the financial year 2024, we will convey our CoCto all existing suppliers, and all new supplier con-tracts will include a clause mandating adherence to and compliance with our CoC.If any existing or potential supplier refuses or fails to commit to and comply with our CoC, our Executive Management will assess the business relationship on a case-by-case basis.Sustainability due diligenceOur sustainability due diligence process (SDD) follows a risk-centred approach that involves identifying, assessing, and managing en-vironmental, social, and governance (ESG) risks, including those related to the Minimum Safeguards, i.e., human rights and corruption. The SDD goal is to proactively prevent, mitigate, and, if required, address risks and impacts that may affect individuals and the environment with-in our organisation and our value chain.Our SDD has a threefold risk identification and assessment process:1. Initial risk assessment2. Value chain actor-specific sustainability risk assessment3. Final quality assuranceSustainability Initial risk assessmentdue diligenceHuman rights or Blacklistcorruption-sanctioned country?YesNoSustainability risk assessmentFinal quality assuranceYesPossiblyNoGreenYellowRedContinuous monitoring Engagement with Engagement withof value chain actorsvalue chain actorsvalue chain actorsAdequate response on engagementNoYesContinuous dialogueEvaluation of continuousand monitoringbusiness relationshipCommunication of findings in Annual ReportInitial risk assessmentThe initial risk mapping process entails classi-fying countries and business sectors into three groups: Blacklisted regions Potential risks, and Non-identified risksThis categorisation is guided by international reg-ulations and the identified risk factors associated with corruption and human rights violations. This scoring system enables risk assessors to assess the sustainability risks associated with existing or potential value chain actors before conducting a value chain actor-specific sustainability risk assessment. The categorisations are based on geographical and sectoral factors and, therefore, do not affect the value chain actor-specific risk assessment outcome. Instead, it serves as an in-dicator of priority for the risk assessor.BlacklistValue chain actors operating in countries subject to UN, EU or other applicable sanctions laws, or engaging in any form of business dealings with corporations, companies, or organisations locat-ed in countries, areas, or sectors which are on the same sanction lists, are blacklisted and ex-cluded from business dealings. The assessment is conducted by Group Legal on a case-by-case basis, as sanctioned lists are dynamic and regu-larly updated due to geo-political developments.Potential riskA value chain actor receiving a potential risk cate-gorisation in the initial risk assessment means that one or more of the below statements applies: A value chain actor located in a country listed on the EU sanctions list, provided that the sanctions do not pertain to human rights or corruption and the country is not part of the blacklist. A value chain actor operating in a country with a risk of human rights violations, as indicated by reliable, independent, verifiable and inter-nationally recognised informational sources regarding human rights. Similarly, a country for which such sources have not been assessed will also be subject to careful consideration and is considered a potential risk. A value chain actor conducting operations in a country with documented instances of corruption, based on internationally recognised sources.Non-identified riskWhen a value chain actor falls into any of the fol-lowing categories, the initial risk assessment has not revealed any initial risks that might impact the business relationship: A value chain actor situated in a country with a low occurrence of corruption, based on internationally recognised sources and which has not violated national corruption legislation through its own operations or through value chain activities. A value chain actor located in a country with no adverse human rights inflictions, as indicated by reliable, independent, verifiable and internationally recognised informational sources regarding human rights and which has not violated human rights through its own operations or through value chain activities.Sustainability due diligence frameworkOur sustainability due diligence framework per the OECD Due Diligence Guidance for Responsible Business Conduct encompasses the following six stages: 1. Embed responsible business conduct into policies & management systems 2. Identify & assess adverse impacts in operations, supply chains & business relationships3. Cease, prevent or mitigate adverse impacts 4. Track implementation and results5. Communicate how impacts are addressed6. Provide for or cooperate remediation when appropriate.Policy enforcing responsible business conductOur Code of Conduct (CoC) enforces responsi-ble business conduct within our operations and supply chain. Reference is made to the corporate culture section.Identify and assess adverse impactsOur sustainability due diligence process covers all topics and sub-topics outlined in the European Sustainability Reporting Standards (ESRS). It involves systematically identifying, evaluating, prioritising, and monitoring potential and actual impacts arising from our business activities. This evaluation considers various factors, including the nature of the activity, the business relation-ship, geographical location, and the industry of the involved value chain actor.Sustainability due diligence frameworkCommunicateIdentify & assess526how impacts adverse impacts inare addressedoperations, supplyProvide for or1chains & businesscooperate inrelationshipsEmbed responsible remediation whenbusiness conduct appropriateinto policies &TrackCease, prevent4management 3implementationor mitigatesystemsand resultsadverse impactsThe process commences with an initial risk assessment conducted via desktop research. Following this, we assess negative impacts based on their severity. When relevant, we col-laborate with internal and external experts who provide valuable insights and expertise in the field to enhance our understanding of the poten-tial and actual impacts within the ESRS frame-work. Lastly, a team of internal subject matter experts performs a final quality assurance. Once the risk evaluation is finalised, we engage directly with the value chain actor if deemed necessary.In the financial year 2023, we conducted a fo-cused sustainability risk assessment on value chain actors, evaluating them based on their significance to our business model. The selection of entities for this risk assessment was based on predefined financial and non-financial criteria. In 2024, we will perform sustainability due diligence on all value chain actors. Following the sustainability risk assessment, we differentiated between non-identified risks, potential and actual risks, and by our self-devel-oped colour scoring system of green (non-identi-fied risks), yellow (potential risks identified), and red (actual risks identified).Cease, prevent or mitigateOur sustainability due diligence process entails specific action depending on the colour scoring:Green score: This implies that no instances of human rights violations or corruption were de-tected, and as a result, no additional measures are needed. We will continue to conduct ongo-ing monitoring following green colour scoring guidelines.Yellow score: This signals potential human rights or corruption impacts, triggering a series of actions. First, the risk assessor examines public statements from the value chain actor to evaluate their strategies. Then, we convey our zero-tolerance policy and requests a written plan for impact mitigation from the value chain member in question. Further steps depend on their response or lack thereof. In case of an inad-equate or absent response concerning effective management of these issues, appropriate actionsare taken following red colour scoring guidelines. If the value chain actor can demonstrate effec-tive management of human rights or corruption impacts, its score remains unchanged, and we monitor progress in mitigating these issues through ongoing communication.Red score: A red score signals actual human rights violations or corruption. This leads to specific actions: First, the risk assessor exam-ines the value chain actorâs public statements to understand its management of these issues. Second, we interact with the value chain ac-tor, enforcing our zero-tolerance policy and requesting a written plan for addressing the im-pacts. The next steps depend on their response. Inadequate or no response results in escalation to Executive Management to determine next step. If the value chain actor provides an ade-quate response, its score remains unchanged, and we monitor progress in mitigating these is-sues through ongoing communication.Track implementation and resultsWe continuously monitor our value chain actors regarding human rights and corruption con-cerns, with monitoring frequency determined by their colour score from the sustainability risk assessment. Green score: Monitoring occurs every five years to uphold ethical standards. Yellow score: Monitoring occurs every three yearsto track progress in addressing these concerns. Red score: Monitoring and assessment occur annually to track corrective actions, continuously assess adverse impacts, and evaluate the via-bility of maintaining a business relationship with non-compliant parties. Communication of findingsFollowing our sustainability risk assessment, we identified 14* value chain actors which had either human rights or corruption impacts and in some cases both. We identified 3 value chain actors with actual risk of impacts and 12 value chain actors with potential risk of impacts. Of the 14 value chain actors we identified, one had both a direct and an indirect impact. Below is a sum-mary of our sustainability due diligence process for these impacts, which outlines the following categories: The nature of our business relationship Where in the value chain the risk is identified Geographical location of identified value chain actor The business sectors of identified value chain actors An account of our mitigating actions and engagement, along with insights into the nature of the dialogue Concluding remarks on progress or resolutions achievedActual impacts Customer or supplier Value chain findings Geographical findings Sector findings Actions ResultHuman rightsCustomers: 1 Direct impacts: 2 Europe Food serviceDuring 2024, an engagement letter will We will await a response from our The risk assessment revealed Transportbe sent to the customer and supplier, customer and supplier and based on the the violation of human rights Suppliers: 1Indirect impact through requesting additional details on their response, we will act accordingly and, if according to the Universal value chain activities: 0strategies for mitigating and remedying relevant, as described in the Remediation Declaration of Human Rightsthe situation.section. We will provide an update on the progress in the 2024 Annual Report.CorruptionCustomers: 1 Direct impacts: 1 Europe Other membership During 2024, an engagement letter will be We will await a response from our The risk assessment revealed the organisationsent to the customer, requesting additional customer and based on the response, we violation of national corruption Suppliers: 0Indirect impact through details on their strategies for mitigating will act accordingly and, if relevant, as laws.value chain activities: 0and remedying the situation.described in the Remediation section. We will provide an update on the progress in the 2024 Annual Report.Potential impacts Customer or supplier Value chain findings Geographical findings Sector findings Actions ResultHuman rightsCustomers: 9 Direct impacts: 1 Middle EastFinancialDuring 2024, an engagement letter will We will await a response from our The risk assessment revealed EuropeOther membership be sent to all customers, requesting customers and based on the response, the potential violation of human Suppliers: 0Indirect impact through organisationadditional details on their strategies for we will act accordingly and, if relevant, as rights according to the Universal value chain activities: 8Social Insurancemitigating and remedying the situation.described in the Remediation section. We Declaration of Human RightsAdministrativewill provide an update on the progress in Petroleumthe 2024 Annual Report.ManufacturingDomestic intelligenceCorruptionCustomers: 7 Direct impacts: 3 AmericaSecurityDuring 2024, an engagement letter will We will await a response from our The risk assessment revealed EuropeAdministrativebe sent to all customers and suppliers, customers and suppliers and based on the potential the violation of national Suppliers: 2Indirect impact through Middle EastFinancialrequesting additional details on their response, we will act accordingly and, if corruption laws.value chain activities: 6Social Insurancestrategies for mitigating and remedying relevant, as described in the Remediation Petroleumthe situation.section. We will provide an update on the Manufacturingprogress in the 2024 Annual Report.Domestic Intelligence*14 value chain actors correspond to 0.6% of the total number of value chain actors assessed in 2023Remediation Human rightsOur standard procedure for addressing human rights impacts involves initiating dialogue with value chain actors to offer support and mitigate potential or actual adverse impacts. We believe that disengagement is not always the most ef-fective solution in sensitive or problematic sit-uations, as this can trigger additional negative impacts. While we may not always be able to provide remedy to the affected party directly, we are committed to assisting in enhancing and improving the management of human rights impacts. CorruptionOur approach to addressing corruption varies based on whether a value chain actor has been convicted of corruption, presents clear indi-cations of corruption, or is under suspicion of involvement in corruption due to geographical location or business sector.In cases where a value chain actor has been convicted of corruption practices or in cases where a value chain actor shows clear indica-tions of corruption, and cannot provide evidence of innocence, we will implement the red colour score guidelines.§Accounting principlesAssessment of alignment criteriaWhen assessing compliance with the alignment criteria for the activity 8.1 Data processing, host-ing, and related activities, we have engaged in dialogue with our third-party data centre co-host operators, and our data centre hardware manu-facturers. They have provided signed documen-tation regarding each of the applicable technical screening criteria, as outlined in a template pre-pared by Group Finance.RevenueEligible Eligible revenue consists of the following com-ponents: External revenue associated with data centre hosting and related activities. This is comprised of both revenues generated using Netcompanyâs own hardware and revenue gen-erated by using third-party cloud computing solu-tions as a hosting service towards external clients.External revenue derived from the activities; Data-driven solutions for GHG emissions reduc-tions and Provision of IT/OT data-driven solutionsrelated to the transition to a circular economy. Revenue allocation has been performed by dis-secting the delivery towards the client, to locate the exact proportion of the revenue matching the activity description. Should the Taxonomy-eligible activity be a part of a bigger performanceobligation without a stand-alone performance obligation, the revenue is not reported as Taxonomy-eligible.AlignedAligned revenue consists of external revenue de-rived from data centre hosting and related activi-ties, where the operational process of the hosting activity complies with the technical screening criteria set out by the EU Taxonomy legislation. Due to the nature of cloud computing and host-ing activities, an allocation key has been used to separate the Taxonomy-aligned revenue streams from the non-aligned. Electricity consumption for each data centre co-host location, has been used as allocation key, as it states an accurate representation of the distribution between the two locations. Reference is made to Note 3 in the Financial Statements. CapexEligibleEligible Capex consists of additions to tangible assets of property, plant and equipment (includ-ing additions to leased assets) and additions to intangible assets, associated with Taxonomy-eligible activities. Climate change mitigation 6.5. Transport by motorbikes, passenger cars and light commercial vehiclesAdditions added to leased cars in the company car sheet, in accordance with IFRS 16. 8.1. Data processing, hosting, and related activitiesAdditions to hardware used in our data centre operations. Transition to a circular economy 4.1. Provision of IT/OT data-driven solutionsAdditions added to intangible assets matching the activity description, in accordance with IAS 38. AlignedAligned Capex consists of additions to tangible assets of property, plant and equipment (including additions to leased assets, that complies with the technical screening criteria of the activity. Climate change mitigation 8.1. Data processing, hosting, and related activitiesAdditions to hardware used in our data centre operations. Electricity consumption for hardware used in data centre operations for each data centre co-host location, has been used as allocation key. Reference is made to Note 18 in the Financial Statements. OpexThe denominator for Opex corresponding the requirements set out by the EU Taxonomy leg-islation, is comprised of the following direct cost: Research and development (R&D); building renovation measures; short-term leases; mainte-nance and repair, and other direct cost related to ensuring the daily operations and servicing of as-sets of property, plant, and equipment (including leases), including services outsourced to a third party, that is principally related to an asset and is necessary to ensure the continued and effective functioning of such assets. EligibleEligible Taxonomy Opex consists of the relevant direct cost (as described above), for the follow-ing Taxonomy activities. Climate change mitigation 8.1. Data processing, hosting, and related activitiesDirect cost ensuring the day-to-day operations of Data processing and hosting activities, for opera-tions owned by Netcompany. Included are direct cost that ensures that the data centre assets can perform their intended purposes.AlignedAligned Taxonomy Opex consists of the relevant Taxonomy defined direct cost, related to the pro-portion of the following activities that complies with the technical screening criteria. 8.1. Data processing, hosting, and related activitiesDirect cost ensuring the day-to-day operations of Netcompany data processing and hosting activities, for operations owned by Netcompany. Included are direct cost that ensures that the assets can perform their intended purpose. Electricity consumption for hardware used in data centre operations for each data centre co-host location, has been used as allocation key.Double countingDouble counting has been avoided in thefollowing way:RevenueEach activity that generated Taxonomy eligible oraligned revenue, have separate performanceobligations. As a result, the threat of doublecounting is not present in the Taxonomy revenuereporting schedule.CapexActivities incurring capitalised costs as eitherTaxonomy-eligible or aligned, do not generate thesame types of costs. 4.1. Provision of IT/OT data-driven solutionsAdditions to intangible assets classified as soft-ware (Note 16). 6.5. Transport by motorbikes, passenger cars and light commercial vehiclesAdditions to right-of use assets in the form of leasing contract for cars (Note 18). 8.1. Data processing, hosting and related activitiesAdditions to tangible assets classified as equip-ment (Note 18).Based on the assessment above, the threatof double counting is not present in theTaxonomy Capex schedule. Opex 8.1. Data processing, hosting and related activitiesCost of service relates to Netcompany-owned and controlled data centre and hosting opera-tions (Note 3). 4.1. Provision of IT/OT data-driven solutionsMaintenance cost of service related to a capital-ised intangible asset (Note 3).The above Taxonomy Opex does not share thesame internal cost identification delivery and isnot internally classified. EEnvironmentThe environmental reporting landscape is un-dergoing a significant transformation, transi-tioning from informal, non-binding guidelines to enforceable regulations via e.g. the Corporate Sustainability Reporting Directive (CSRD). This transition drives a need for an increased focus on how we approach and report environmental matters. Consequently, our reporting efforts will increasingly emphasise data quality and align with stringent legal requirements. During this transition, our focus centres on build-ing a solid foundation for our reporting practices. As a first step, we have expanded our environ-mental reporting and obtained limited assurance on selected KPIs.Climate change is material to our business. As a growing IT service company and data centre user, we recognise the need to decrease the negative climate-related impact of our business. Additionally, customers and other stakeholders increasingly expect comprehensive information on our climate-related initiatives and data. This moves sustainability performance closer to the business, providing both risk and opportunity. Climate change and our carbon emissions are not only matters we must address as a responsi-ble corporate citizen â addressing them is a strategic imperative to meet the growing ex-pectations of our customers, investors, and other stakeholders.EOur emissionsSince 2017, we have reported on our Scopes 1, 2 and 3 emissions. In our efforts to improve data quality and the total scope of our emissions, we have expanded our Scope 3 reporting to include five categories in 2023 compared to one catego-ry (business travel) in the previous years. In 2023, we made our first Power Purchase Agreement (PPA), in which we ensure additionality of renew-able energy to the energy grid. In addition, we buy Guarantees of Origin (GoOs) in our efforts to decrease our overall emissions.Scope 1 and 2Scope 1 emissionsOur scope 1 emissions derive from fuel from leased cars and gas for office heating. The de-velopment of the year followed expectations and was on par with 2022, by a slight increase of 6.5% from 1,459.2 to 1,553.9 tonne COîe. Our leasing car fleet activity that makes up the major-ity of Scope 1 emissions saw no changes during the year.Scope 2 emissionsOur Scope 2 accounts for electricity and district heating for data centres and offices.Scope 2 location-based emissions increased 19.3% from 1,450.5 to 1,730 tonne COîe. The in-crease was primarily caused by moving into new headquarters and new offices in Greece. Due to the growth in the company, our new office buildings are considerably larger in size and as a result uses an increased amount of electricity. Due to the reporting nature, the location-based method does not take investments in renewable energy into consideration.Scope 2 market-based emissions decreased by 72.9% from 1,575.4 to 427.4 tonne COîe. The improvement was a direct result of our renewable energy investments during the year. During 2023, 100% of our electricity consump-tion on the European energy grid was covered by Guarantee of Origin certificates, compared to 57.4% during 2022, which was an increase of 42.6 percentage points. 2023* 2022 %Scope 1 GHG emissionsGross Scope 1 GHG emissions (tCOîe) 1,553.9 1,459.2 6.5%Scope 2 GHG emissionsGross location-based Scope 2 GHG emissions (tCOîe) 1,730.0 1,450.5 19.3%Gross market-based Scope 2 GHG emissions (tCOîe) 427.4 1,575.4 -72.9%§Accounting principlesScope 1 greenhouse gas (GHG) emissions refer to the direct emissions from sources that are owned or controlled by an organisation. Direct GHG emissions is comprised of the sum of greenhouse gases, which are converted to COî equivalents. The emissions arise from the combustion of fuel products related to Netcompany leased cars and natural gas used as heating in office buildings. To calculate GHG emissions the newest version of DEFRA GHG Conversion factors (2023) has been used.Scope 2 greenhouse gas (GHG) emissions re-fer to the indirect emissions resulting from the generation of purchased energy that is used by an organisation. Scope 2 emissions occur at the facility where the energy is generated, thus being classified as indirect emissions. The emissions 2023* 2022 %Significant Scope 3 GHG emissionsTotal gross indirect (Scope 3) GHG emissions (tCOîe) 68,518.4 53,566.7 27.9%1. Purchased goods and services 49,736.3 41,371.9 20.2%2. Capital goods 3,987.0 2,724.2 46.4%3. Fuel- and energy-related activities services 514.7 448.2 14.8%6. Business travel 8,225.8 9,022.4 -8.8%7. Employee commuting 6,054.7 NîA N/Aare linked to the electricity and district heating consumption related to Netcompany office ac-tivities, and electricity consumption related to Netcompany controlled data centre operations. Scope 2 market-based emissions are calculated by taking the specific energy sources an organi-sation uses for its purchased electricity, heat, or steam. Renewable energy purchases and credits are considered, when accounting for indirect GHG emissions, using the market-based approach.Renewable energy certificatesCertificates for purchase of renewable energy are only used as documentation if a Guarantee of Origin/cancellation statement is either in hand or asigned letter of intent assuring the arrival of such a statement is present at the time of reporting. Entities on the European energy grid has been covered by Guarantees of Origin, excluding the Norwegian entity which has been covered by a letter of intent. To calculate GHG emissions, the newest version of the European residual mix has been used for European entities. For entities located outside of Europe, the newest version of IEA country factors has been used. Scope 2 location-based emissions are calculated by taking the specific energy sources an organi-sation uses for its purchased electricity, heat, or steam, calculated using average emission fac-tors for the regional or national energy grid. This method reflects the energy mix with the specific area of consumption and does not consider any purchase of renewable energy or credits. To cal-culate GHG emissions, the newest version of the IEA country factors has been used. 2022 KPI figures have been restated according to the accounting principles described above.Scope 3Total gross indirect (Scope 3) GHG emissionsTotal gross Scope 3 emissions increased by 27.9% from 53,566.7 to 68,518.4 tonne COîe. This increase was primarily a result of an increase in purchased goods and services emissions of 8,364.4 tonne COîe, and the inclusion of the Employee commuting category in the Scope 3 reporting scope, which accounted for a 6,054.7 tonne COîe Scope 3 emissions increase.In 2023, our Scope 3 reporting includes the fol-lowing five categories: 1. Purchased goods and services Emissions increased by 20.2% from 41,371.9 to 49,736.3 tonne COîe. This was primarily driven by the Netcompany-Intrasoft entities, which accounted for 78.6% of the increase, with the majority being related to a higher level of freelancer purchases, that was a direct result of the growth in the business unit.2. Capital goods Emissions increased by 46.4% from 2,724.2 to 3,987 tonne COîe. This development was impacted by the headquarters relocation and the moving into new offices in Greece, that resulted in an increase in leasehold additions and an increase in equipment additions.3. Fuel-and-energy-related activities Emissions increased by 14.8% from 448.2 to 514.7 tonne COîe. Emissions related to this scope 3 category derived from the direct and indirect emissions reported under scope 1 and 2 and the development is therefore directly linked to these two emission categories.6. Business travel Emissions decreased by 8.8% from 9,022.4 to 8,225.8 tonne COîe. The improvement was driven by improved data quality related to plane travel emissions in our Vietnamese entity. During 2023 we transitioned to a supplier that was able to deliver supplier specific COîe data. As a result, the emission from supplier specific data was significantly lower and presented a more accurate emission figure. This development was a result of our efforts to increase our sustainability reporting and KPI data quality.7. Employee commuting Emissions were reported for the first time in 2023. The emissions were calculated based on a Group-wide survey with a 78% response rate.For the remaining Scope 3 categories, we made the following assessment regarding materiality:Subject to further assessment before deeming materiality5. Waste generated in operations8. Upstream leased assets11. Use of sold products15. InvestmentsNot relevant4. Upstream transportation and distribution 9. Downstream transportation and distribution 10. Processing of sold products 12. End-of-life treatment of sold products13. Downstream leased assets14. Franchises§Accounting principlesScope 3 emissions are the indirect greenhouse gas emissions attributed to an organisationâs val-ue chain. 1: Purchased goods and services GHG emissions associated with the Groupâs pur-chase of goods and services, are calculated as the amount of direct cost including VAT associat-ed with a specific type, multiplied by a matching emission factor from DEFRAS Table 13 direct spend based emission factors. The direct cost has been converted to GBP using the average exchange rate of the month, to align with the cur-rency used in the spend based emissions factors. 2: Capital goods GHG emissions associated with the Groupâs ad-ditions to tangible assets, are calculated as the amount of capitalised cost associated with a specific type, multiplied by a matching emission factor from DEFRAS Table 13 direct spend based emission factors. The capitalised amount has been converted to GBP using the average exchange rate of the month, to align with the currency used in the spend based emissions factors. 3: Fuel- and energy-related activitiesGHG emissions related to the fuel- and energy- related activities not accounted for in Scope 1 or Scope 2, is comprised of indirect emissions associated with the production of purchased fuels and electricity. The GHG emission are being calculated using the newest version of the IEA country factors, multiplied by the Scope 1 and Scope 2 consumption.6: Business travelGHG emissions associated with the Groupâs business travel activities, are calculated as the amount of direct cost including VAT associated with plane, taxi, train, bus, ferry, and accommo-dation, multiplied by a matching emission factor from DEFRAS Table 13 direct spend based emis-sion factors. The direct cost has been converted to GBP using the average exchange rate of the month, to align with the currency used in the spend based emissions factors. For the emissions derived from plane travel for the entities within Denmark, United Kingdom, Norway, Netherlands, and Poland, the majority is based on supplier specific data. The part of the direct cost related to supplier specific data, has been subtracted from the direct cost base of the spend-based emission calculation, to avoid dou-ble counting.7: Employee commutingGHG emissions related to employee commuting is related to the indirect emissions generated from the transportation of employees between their homes and their place of work.The emission has been calculated based on the answers of a Group-wide survey, that took place during September 2023. The survey included questions regarding: Means of transportation and type, for example electric or diesel vehicle. Distance to work, and average weekly days spent working in the office. To calculate the GHG emis-sions, the newest version of DEFRAâs Business travel-land emissions factors has been used. The response rate for the survey was 78%.2022 KPI figures have been restated according to the accounting principles described above.GHG intensity based on net revenue2023* 2022 %GHG intensity based on net revenueTotal GHG emissions (location-based) per net revenue (tCOîe/DKK million) 11.8 10.2 15.0%Total GHG emissions (market-based) per net revenue (tCOîe/DKK million) 11.6 10.2 12.2%Energy consumption and mixEnergy consumption and mix 2023 2022Fuel consumption from crude oil and petroleum products (MWh) 7,425.8 6,598.7Fuel consumption from natural gas (MWh) 614.2 664.7Consumption of purchased or acquired electricity, heat, steam, and cooling from non-renewable sources (MWh) 880.5 2,738.2Total non-renewable energy consumption (MWh) 8,920.5* 10,001.6Share of non-renewable sources in total energy consumption (%) 52.8%* 71.0%Consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sources (MWh) 7,982.8 4,089.3Total renewable energy consumption (MWh) 7,982.8* 4,089.3Share of renewable sources in total energy consumption (%) 47.2%* 29.0%Total energy consumption (MWh) 16,903.3* 14,090.9§Accounting principlesGHG intensity based on net revenue has been calculated as gross Scope 1, Scope 2 mar-ket-based/location-based, and gross Scope 3 emissions divided by reported net revenue in DKK million (Note 3).Our overall energy consumption increased by 20% from 14,090.9 to 16,903.3 megawatt-hours. This increase was primarily a result of our head-quarters relocation and our new office buildings in Greece.Our total renewable energy share improved by 18.2 percentage points, increasing from 29% to 47.2%.§Accounting principlesEnergy from non-renewable sources covers fuel consumption related to the Groupâs leasing car fleet, natural gas consumption related to heat-ing of office building, consumption of electricity related to Netcompany controlled data centre operations and office activities and district heat-ing related to office activities. For conversion from 3litre and m consumption, to megawatt-hours, Defra/DEECâs Fuel conversion factors from 2012 have been used. Energy from renewable sources covers district heating and electricity related to office activ-ities and Netcompany controlled data centre operations.2022 KPI figures have been restated according to the accounting principles described above.Scope 1 / Energy mix / Category 3 Scope 2 / Energy mix / Category 3Data hierarchyDiesel Petrol Gas Electricity District heating1. Actual consumption directly stated on the invoice from the vendors 94.1% 86.0% 38.8% 54.4% 1.0%2. Data through vendor online portal or similar 24.7% 59.2%3. Data supplied by the vendor open request through written communication 14.7% 0.0%4. Estimations performed based on historical data 39.9% 1.6% 8.1%5. Estimations performed based on average price per unit of consumption (kwh, litres, mî), for Netcompany Group purchases in the relevant period 5.8% 13.2% 21.3% 4.3% 31.7%6. Estimations based on average publicly available average price pr. unit of consumption (kwh, litres, mî) 0.2% 0.8% 0.2%Scope 3Data hierarchyPurchased goods and services Capital goods Business travel1. GHG emission data supplied directly by the supplier 31.6%2. GHG emission calculated based on actual purchase / weight3. GHG emission calculated on the base of net-spend 100% 100% 68.4%Data hierarchyThe reported environmental performance follows the data hierarchy principles stated below. Scope 1, 2 & Scope 3, category 61. Actual consumption directly stated on the invoice from the vendors.2. Data through vendor online portal or similar.3. Data supplied by the vendor open request through written communication.4. Estimations performed based on historical data. 5. Estimations performed based on average 3price pr. unit of consumption (kwh, litre, m), for Netcompany Group purchases in the relevant period. 6. Estimations based on average publicly available average price pr. unit of 3consumption (kwh, litres, m). Scope 3, category 1, 2 & 3 1. GHG emission data supplied directly by the supplier.2. GHG emission calculated based on actual purchase / weight.3. GHG emission calculated on the base of net-spend. Environment initiativesRepurposing office furnitureOur goal is to promote the sustainable management of office furniture across all our offices. We achieve this by reselling, donating, and implementing eco-friendly disposal methodsfor our furniture. Donations and reselling have occurred through Netcompany partnerships, sucas Danish furniture supplier, Holmriis. The initiative is active in our entities in Denmark, the Netherlands, Norway, Poland, the United Kingdom, and Vietnam.Environmental waste managementSince 2022, we have introduced residual waste sorting programs in all our office locations. We are committed to segregating our waste to maximise recycling and reduce the volume of waste deposited in landfills. The initiative is active in our entities in Denmark, Greece, the Netherlands, Norway, Poland, the United Kingdom, and Vietnam. We are committed to responsible e-waste management. We have established internal protocols to guarantee the appropriate reuse or disposal of all IT equipment. Our collaborations extend to NGOs, schools, childcare facilities, and responsible business partners. This aligns with our ISO 14001 goal to achieve an 80% refurbishment, reuse, or recycling rate for laptops by 2026. In 2023, we have refurbished, reused or recycled 98% of our laptops in Denmark, the Netherlands, Norway, Poland, the United Kingdom, and Vietnam.Say goodbye to plastic campaignWe significantly reduced plastic in most of our offices to move into a plastic-free future for all entities. The initiative is active in our entities in Denmark, Greece, the Netherlands, Norway, Poland, the United Kingdom, and Vietnam.Since 2022, we have transitioned to using less water plastic bottles at our Danish offices. This aligns with our ISO 14001 goal of reducing plastic water bottle consumption in our Danish office by 60% by 2026. In 2023, we have reduced our plastic water bottle consumption by 41% compared to 2022.ISO 14001 certificationIn 2023, we demonstrated our commitment to attaining ISO 14001 certifications in the majority of our entities. Our entities in Denmark, Poland, the United Kingdom, Greece, Norway, the Netherlands, Luxembourg, Belgium, and Romania currently hold ISO 14001 certifications. By 2024, we anticipate obtaining ISO 14001 certification for our entity in Vietnam. Our ISO 14001 aspects include increasing the use of renewable energy sources, improving circular economy practices, and reducing resource consumption. These aspects are in alignment with our primary environmental focus on addressing climate change.SocialSOur peopleMaterial aspects related to our peopleOur people are the backbone of our company, driving innovation and delivering exceptional results. Our efforts to support our people in their personal and professional development are founded on our shared ambition to deliver value for our customers. We want to cultivate an inclusive culture, ensuring every employee feels supported and valued. Our commitment extends to providing equitable career oppor-tunities for all, ensuring a level playing field for every team member. Our double material-ity assessment process, as described in the Double materiality assessment section, reflects our dedication to secure employment, reten-tion, work-life balance, social dialogue, gender equality, equal pay for equal work, training, and skills development. It serves as our blueprint for promoting employment inclusion, diversity and safeguarding privacy. The most material aspects related to our people are: Attracting and retaining top talent and promoting work-life balanceAt the core of our business model, we emphasise secure employment and a balanced work-life approach. These factors are fundamental to our capacity to attract, retain, and inspire top talent. We recognise that a motivated and stable workforce is essential for delivering exceptional customer results.Providing equal development opportunities for everyoneInvesting in training and skills development is at the core of our strategy, and we continuously work on developing our learning environments. We remain committed to continuously upskilling our people through job-specific training and on-the-job learning. We are committed to empowering our employees to reach their full potential regardless of back-ground and social identity. Equity, inclusion and diversity are driving forces behind our ability to deliver, innovate and grow in an industry charac-terised by a shortage of qualified labour.Cultivating an engaged workforce We are committed to encouraging social dia-logue as we recognise the effect of an engaged and supportive work environment and the direct impact of work-life balance on our employeeâs well-being, satisfaction and productivity. As a people-driven company, we strive to cultivate a respectful and secure atmosphere and safeguard our employeesâ privacy. Policies and workforce impactsOur workforce plays a critical role in our business model and strategy, and ensuring their well-be-ing and satisfaction is essential. We also strive to create an environment that harnesses various opportunities while effectively managing associ-ated risks. To address potential impacts on our employees, we have implemented policies that uphold human and labour rights as a core aspect of our commitment.Code of Conduct PolicyOur Code of Conduct (CoC) Policy serves as a guiding light for ethical decision-making. Embracing this cultivates trust, loyalty, and in-tegrity while upholding robust business practices aligned with ethical values, policies, and appli-cable laws. It encompasses a broad range of ethical dimensions, including personal conduct, workplace safety and environment, conflicts of interest, confidential information, data privacy and ethics, human rights (including discrimina-tion and labour rights), freedom of association and collective bargaining, and the fight against unfair business practices such as anti-corruption, bribery, fraud, insider trading, taxation, and envi-ronmental responsibility.Our CoC Policy aligns with several internationally recognised human rights instruments, includ-ing the International Bill of Human Rights, the International Labour Organisation Declaration on Fundamental Principles and Rights at Work, and The Modern Slavery Act. We maintain a zero-tolerance stance against forced, bonded, or compulsory labour, slavery, human trafficking, and child labour throughout our value chain. Human Rights commitmentsWe remain committed to respecting human rights across our value chain. Our commitment aligns with the United Nations Guiding Principles on Business and Human Rights (UNGP) and the OECD Guidelines for Multinational Enterprises. We adhere to a zero-tolerance policy towards any discrimination, harassment, or bullying due to any social identity, including age, culture, nationality, ethnicity, gender, physical abilities, experience, political and religious beliefs, sexual orientation, and other attributes. We are a people-centric business, and our employees are the backbone of our business. Fostering an inclusive culture where everyone feels supported, empowered and treated fairly is essential. We actively engage with stakeholders, including expert advisors and employees, to ensure effec-tive human rights management and compliance. We conduct a human rights due diligence pro-cess to identify potential human rights concerns comprehensively. Reference is made to the EU Taxonomy Minimum Safeguards section. In addi-tion, our Whistleblower system enables individ-uals linked to Netcompany to report violations, including potential human rights impacts, con-fidentially. Reference is made to the Corporate culture section.Our Code of Conduct Policy outlines our expec-tations and commitments, applying to anyone conducting business on behalf of Netcompany, including employees, suppliers, contractors, and external business partners. The policy, including our human rights commitments, are approved by the Board of Directors and overseen by the Audit Committee. The policy applies to Netcompany Group. Diversity, Equity, and Inclusion PolicyOur Diversity, Equity and Inclusion (DEI) Policy is approved by our Board of Directors and over-seen by the Executive Management in com-pliance with applicable laws and regulations. The policy applies to our entities in Denmark, the Netherlands, Norway, Poland, the United Kingdom and Vietnam. Reference is made to the Management responsibilities, Diversity section.Additionally, we actively participate in the Confederation of Danish Industry (DI)âs Special Committee for Diversity, collaborating on tangi-ble initiatives to promote diversity and equality within organisations.Harassment and Sexual Harassment PolicyOur Harassment and Sexual Harassment Policy provides a framework outlining the roles and responsibilities of all Netcompany employees, including mentors, project managers, colleagues, Human Resources, and Executive Management. In the event of a harassment or sexual harass-ment complaint, Human Resources investigates the matter. Depending on the severity of the misconduct, disciplinary actions, including po-tential dismissal, will be taken against the perpe-trator. Additionally, individuals in leadership roles who neglect to report suspected harassment or sexual harassment will be subject to disciplinary actions following employment laws.Reports of harassment or sexual harassment are submitted through our whistleblower system or to Human Resources who is responsible for informing Executive Management. Reference is made to the Corporate Culture section. Group Human Resources approves our Harassment and Sexual Harassment Policy and the policy applies to our entities in Denmark, the Netherlands, Norway, Poland, the United Kingdom, and Vietnam. A separate Harassment Policy covering our Greek entity is mandated by Greek legislation and governed by local Human Resources.Health and Safety PolicyOur Health and Safety Policy establishes a frame-work defining the responsibilities of our Work Environment Organisation (WEO). The function is responsible for (1) ensuring compliance with health and safety legislation, regulations and re-quirements, (2) preventing workplace injuries, and (3) conducting ongoing assessments of the work environment. WEO consists of a Group Health and Safety Coordinator and a Head of Health and Safety. Local offices have designated local Health and Safety leads. The Policy is approved by Group Human Resources and overseen by WEO, which evaluates the work environment and conducts statutory assessment meetings in compliance with applicable laws and regulations. The Policy applies to our entities in Denmark, the Netherlands, Norway, Poland, the United Kingdom, and Vietnam. In Greece, Belgium, Luxembourg, and Romania, we comply with the ISO 45001 Health and Safety Management System. The process is monitored by health and safety officers and designated personnel. Internal audits are conducted by certified Facility teams.Anti-Slavery and Human Trafficking PolicyOur Anti-Slavery and Human Trafficking Policy reflects our stance against modern slavery as mandated by Section 54 of the Modern Slavery Act 2015. Violations of ethical guidelines or com-petition laws will be investigated and may result in disciplinary actions, including dismissal, busi-ness relationship termination, and reporting to authorities under applicable laws.Our expectations and commitments are com-municated during onboarding and at the outset of a business relationship and reinforced as appropriate. This policy applies to all individuals representing Netcompany, including employees, suppliers, contractors, and external partners, and is overseen by our Board of Directors. The policy applies to Netcompany UK Limited.Employee Resource Group PolicyOur Employee Resource Groups (ERGs) Policy provides a framework for how ERGs are admin-istered. The policy is grounded in our values and commitment to the UN Global Compact. The ERGs aim to drive groupsâ inclusion, engagement and belonging, particularly at risk of vulnera-bility. These efforts are overseen by Executive Management and are designed to encourage social dialogue, providing valuable insights to address well-being-related impacts. Reference is made to the Engaging our people paragraph. This policy applies to all individuals, including all levels of leadership, and is overseen by Group Human Resources. The policy applies to our entities in Denmark, the Netherlands, Norway, Poland, the United Kingdom and Vietnam.Engaging with our peopleIn our commitment to fostering an inclusive and engaged workplace, we value input from our employees. We maintain open channels for direct and indirect engagement. Our direct engage-ment occurs through our Social and Employee Satisfaction surveys, as well as meetings with Employee Resource Groups (ERGs) leadership where we actively look into employee sugges-tions for workplace improvement. Our indirect engagement predominantly occurs through our ERGs and development including our buddy- and long-term mentoring programme and structured performance appraisals. Professional and personal developmentSince our inception, we have believed in the concept of IT people leading IT people. All new employees are paired with a personal bud-dy during onboarding. Our buddy program is designed to warmly welcome new hires to Netcompany methodology, technology, and pro-cesses and help them establish internal social networks with colleagues to foster good relations and a supportive social atmosphere.In addition, new employees are paired with a personal mentor during onboarding, ensuring consistent guidance and development as they transition between projects and managers. Mentors play a pivotal role in nurturing their menteesâ growth throughout their careers, contributing significantly to their professional and managerial advancement.Annual performance appraisals are conducted for all employees to evaluate their performance, aligning them with organisational goals and fostering a culture of continuous feedback and improvement.Social surveyOur Social surveys gathers insight related to any challenges faced by our people and to identify new ways to improve the conditions of their work environment. The survey covering our entities in Denmark, the Netherlands, Norway, Poland, the United Kingdom, and Vietnam was established in 2023 and will, from 2024, be performed annually, while the survey covering Netcompany-Intrasoft is performed bi-annually.Our Employee Resource Groups (ERGs) are driving change from the bottom up. They are voluntary groups, led by individuals who share characteristics or life experiences. Sponsored by an employee at Partner-level, these ERGs empower all permanent employees to partici-pate and initiate within these areas: Multi-culture @ Netcompany LGBTQ+ and allies @ Netcompany Women @ Netcompany People with disabilities and allies @ Netcompany Veterans @ Netcompany Age @ NetcompanyThe ERGs provide a platform for sharing perspectives, promoting inclusivity, and ad-dressing workplace challenges. The ERGs have driven many of the organisational changes initiated in 2023, such as enabling proper accessibility for people with disabil-ities at our new headquarters in Denmark, adding an option for employee selection of pronouns, updating the Harassment and Sexual Harassment Policy in Denmark, the Netherlands, Norway, Poland, the United Kingdom and Vietnam, and a new dress code policy covering our entities in Denmark, the Netherlands, Norway, Poland, the United Kingdom, and Vietnam.Employee satisfaction surveyOur Employee satisfaction survey is adminis-tered to quantify employee satisfaction using the Employee Net Promoter Score (eNPS), as-sessed on a scale from -100 to +100. The eNPS is conducted annually for our entities in Denmark, the Netherlands, Norway, Poland, the United Kingdom, Vietnam, and Netcompany-Intrasoft. 2023* 2022eNPS +25 +33The eNPS has declined from 2022 to 2023, pri-marily due to lower scores in some of our major markets. The lower activity primarily in the Danish business, has led to some employees experienc-ing missed opportunities to obtain desired and challenging assignments.§Accounting principlesOur Employee Net Promoter Score (eNPS) is calculated by subtracting the percentage of de-tractors from the percentage of promoters based on employee responses. Those with a predeter-mined end date are excluded across our entities in Denmark, the Netherlands, Norway, Poland, the United Kingdom, Vietnam, and Netcompany-Intrasoft. In our entities Denmark, the Netherlands, Norway, Poland, the United Kingdom, and Vietnam, employees on leave are included during the survey period. Netcompany-Intrasoft does not include employees on parental, maternity, * Sustainability key figure subject to limited assuranceunpaid, and sick leave. New hires with less than a weekâs seniority in our entities in Denmark, the Netherlands, Norway, Poland, the United Kingdom, and Vietnam or less than three weeks at Netcompany-Intrasoft are also excluded.Freelancers are generally not part of the survey, except for 15 freelancers in managerial roles in Netcompany-Intrasoft. The 2023 response rate is 80% (2022: 82%).Survey distribution is platform-specific: Our entities in Denmark, the Netherlands, Norway, Poland, the United Kingdom, and Vietnam use SurveyXact, while Netcompany-Intrasoft uses Willis Towers Watson.Channels to raise concerns We address adverse impacts on our people with multiple grievance mechanisms for reporting and remedying. Our processes, whether through direct or indirect engagement, are approached case-by-case, providing valuable insights to enhance our remediation procedures contin-uously. Besides the option to report violations anonymously through our whistleblower system, all employees can directly initiate a case with Human Resources through our intranet, ensur-ing accessibility for Netcompany employees in Denmark, the Netherlands, Norway, Poland, the United Kingdom, and Vietnam. Specifically in Netcompany-Intrasoft, the channel to raise concerns is through the local Human Resources Business Partner. Human Resources initiates dialogue with all parties to facilitate a resolution, including necessary disciplinary actions and rem-edies in line with applicable policies. Indirectly, impacted individuals are encouraged to connect with their mentors, colleagues, man-agers, business unit directors, or top manage-ment for guidance and support when reporting incidents and seeking resolution. In some cases, any previously mentioned third parties may raise a case on behalf of the impacted individual. Our engagement channels with our people enable us to gather ongoing feedback on the efficiency of our grievance mechanisms. Reference is made to the Engaging with our people section. As mandated by law, we also engage with work-ersâ representatives, including Work Environment Groups or Work Councils in Poland and the Netherlands. Managing impacts on our people Our focus is to set clear objectives and enhance our ability to prevent, mitigate, and address poten-tial employee negative impacts and create pos-itive impacts on our people. We identify and re-solve employee-related issues through our internal administrative processes case-by-case. The Chief Operating Officer (COO) and Chief People Officer (CPO) are responsible for this area and approves policy adaptations. Attracting and retaining top talent and promoting work-life balanceWe focus on secure employment by tailoring our practices to align with local regulatory and con-tractual standards. Moreover, we equip our lead-ers with the tools to support employee well-be-ing, especially during demanding periods.Netcompany instructorsTwice a year, we assess instructor availability and nominate new candidates, all subject to approval by Business Unit Directors. Instructors for specific courses undergo observation or co-instruct alongside experienced peers, and preparatory pre-sessions are available for some courses. We monitor and evaluate the effectiveness of our initiatives to promote and maintain a balanced work-life balance for our people, including the assessment of leadership training programs through Netcompany Academy. In addition, we keep our people engaged and motivated by providing interesting projects, responsibilities, development opportunities, social activities and employee benefits.Providing equal development opportunities for everyoneTraining is fundamental in creating positive train-ing and skills development impacts. External training and certifications are provided when needed. Via Netcompany Academy, we offer a range of courses tailored to employeesâ job roles to positively contribute to their personal and professional growth, covering our entities in Denmark, the Netherlands, Norway, Poland, the United Kingdom, and Vietnam. These cours-es cover project management, communication skills, technical skills, leadership development, and more, enabling our people to develop their skills continually. In close collaboration with the business, Group Human Resources continuously evaluates and updates existing courses while developing new ones to ensure that our work-force has the necessary skills. We measure the effectiveness of each course through internal surveys that assess relevance and instructor performance.We provide instructor-led training, webinars, e-learning programs, certification courses, workshops, and conferences for our entities in Greece, Belgium, Luxembourg, Romania, and South Africa. These initiatives enhance our organisational skillset, and our training procedures align with the ISO 29993:2017 Standard. To facilitate the procedures, we use a cloud-based Learning Management System (LMS) and MOOC providers. We perform annual training needs analyses to ensure the efficacy of these training programs. Equity is central to us. Our performance and pro-motion process aims to evaluate all employees based on their performance, mitigating biases. Human Resources works closely with the man-agement group to ensure they understand and navigate this process effectively. In 2023, we developed a Social strategy to strengthen our DEI approach, covering our entities in Denmark, the Netherlands, Norway, Poland, the United Kingdom, and Vietnam.Cultivating an engaged workforce We foster open dialogue through Employee Resource Groups (ERGs) and works councils, creating a safe culture for employees to share concerns without fear of discrimination or ha-rassment. Reference is made to the Engaging with our people paragraph. Our Chief People Officer (CPO) and Chief Operating Officer (COO) actively oversee ERGs and their progress. We enhance communication channels, gatheringemployee input through ERGs, work councils, and beginning 2024 through social surveys. In 2023, we streamlined ERG governance, granting ERGs improved access to decision-makers and action-takers, making the process more effi-cient. This simplification removes multiple layersin establishing new initiatives, measuring our initiativesâ effectiveness, and refining strategies based on feedback.Our leadership development programmes, such as the New Manager Seminar, as part of Netcompany Academy, underscore leadersâ rolesin preventing these issues. Our Code of Conduct Policy outlines reporting procedures. We conduct individual investigations, respecting victimsâ con-sent, and take customised actions for each case, ensuring swift resolution.In July 2023, we improved access controls in our Human Resources system, further limiting access to personal data across our entities in Denmark, the Netherlands, Norway, Poland, the United Kingdom, and Vietnam. We educate our workforce on GDPR and HR procedures, includ-ing training for hiring managers. Our Privacy Policy is regularly evaluated, and Group Legal en-sures compliance with applicable legislation. Our Security Policy allows employees to report secu-rity issues, including personal data privacy con-cerns and our people are annually obligated to perform mandatory security awareness training. Furthermore, our Greek entity adheres to GDPR through regular training sessions, focusing on both data protection and security awareness, which are mandatory for all employees upon hiring. These training programs are admin-istered and monitored through our Learning Management System, ensuring accountability. We perform an annual review of access controls and rights pertaining to company systems and tools. This ensures exclusive accessibility to au-thorised personnel.We maintain an ongoing dialogue regarding our internal practices across Shared Services. This ensures that diverse perspectives from various departments are carefully considered when implementing procedures. This collaborative approach allows us to incorporate various view-points, promoting an effective decision-making process. Actively engaging stakeholders enables us to tackle potential challenges and seize op-portunities with greater insight. Characteristics of our peopleWe are committed to mirroring the diversity of the societies we serve by promoting inclusivity across various projects and roles. Diversity, equi-ty and inclusion are strategic drivers in attracting, managing, and developing our people. Gender distributionWhile IT historically has been a male-dominated field, we work to welcome an increasing number of women in traditional IT education, the broad industry, and our organisation. Our policies are designed to ensure equal promotion opportuni-ties and remuneration for all employees, regard-less of gender. Additionally, we organise events and initiatives to promote gender diversity and inclusivity.When it comes to reporting on gender distribu-tion, we engage with advisors to align our re-porting with best practices. Legal constraints in some of our operating countries, and limitations imposed by reporting obligations to public institu-tions have confined our reporting to the two legal sexes, male and female, which align with current regulatory frameworks. Initiated in 2023, we offer employees to voluntarily specify their preferred gender pronouns in their email signatures, en-hancing individual identity recognition. This optionis available for our people in Netcompany Group. Number of employees (headcount) by gender excl. freelancers 2023* 2022Male 4,917 4,552Female 1,829 1,607Other 0 0Not reported 0 0Total employees 6,746 6,159In 2023, we saw an increase in our total work-force. Our entities in Denmark, the Netherlands, 2023 highlightsWomen in techIn honour of International Womenâs Day (IWD), we actively engaged in multiple initiatives promoting women. Our involvement included participation in the 2023 âSummit on Gender Equality in Computingâ and active participa-tion in events like âWomen in Digitalâ, âWomen in Tech Summitâ, and hosting an empower-ing âTech Talkâ for women. Furthermore, we proudly sponsored the IWD event organised by Women Techmakers. The events were per-formed in our entities in Vietnam and Greece. Furthermore, throughout the year, we actively engaged in various initiatives aimed at ad-dressing the gender gap, supporting female-led networks, and offering career guidance in the tech industry. Our participation included key events such as Women in Tech, Women in Tech Summit, SheCodes Hackathon, Girl Code Meetup, and Ahead Partnership â Girltech. These initiatives were held across our entities in the Netherlands, Norway, Poland, the United Kingdom, and Vietnam.Women in NetcompanyWe focus on language-neutrality in job ads and event descriptions to promote diversity and inclusion. We also host Women in Netcompany events to strengthen internal networks, facil-itated through Employee Resource Groups (ERGs), allowing for effective feedback on fe-male-focused initiatives. The events were held in our entities in Denmark, the Netherlands, Norway, Poland, the United Kingdom, Vietnam, and Netcompany-Intrasoft.Number of employees in Headcount Share Headcount Share Management by gender2023*2023*20222022Male 978 81.7% 867 83.6%Female 219 18.3% 170 16.4%Total employees 1,198 100% 1,036 100%Reporting on gender distribution in management applies to the entire group, including foreign subsidiaries, and should therefore not be associat-ed with Netcompany Group A/Sâ statutory disclosure on gender distribution in management, cf. §99b of the Danish Financial Statements Act.Norway, Poland, the United Kingdom, and Vietnam saw historically lowered growth due to moderate business opportunities in these mar-kets, while we observed growth in our other enti-ties. Likewise, we observed a positive trend in the development in female representation compared to 2022, which aligns with our ambition for 2023, indicating that we continue to progress toward increasing our representation of women. A cross-reference is made to Note 7 in the finan-cial statements as the most representative figure for total employees, which is presented in terms of average employees.§Accounting principlesThe total headcount of employees at Netcompany Group is computed by aggregat-ing the employee count across all countries of operation while excluding freelancers and con-tractors. This calculation is based on an average taken over the reporting period from January 1, 2023, to December 31, 2023. The KPI for the total employee count has been revised from previous reporting, which was previously reported on FTEs. The 2022 figure has been restated accord-ing to the accounting principles described above. âGender distributionâ is defined as the headcount of employees whose legally recognised gender is female or male. The âGender distributionâ at Netcompany Group is computed by summing the total aggregated headcount of both women and men, respectively, across all countries of operation while excluding freelancers and con-tractors. This calculation is based on an average taken over the reporting period from January 1, 2023, to December 31, 2023. The KPI for gen-der distribution has been revised from previous reporting, which previously only reported on the share of women. The 2022 figure has been restated according to the accounting principles described above.Gender distribution in managementIn 2023, we saw a rise in people on the man-agement level due to our yearly promotions and a lower turnover rate than historically. Likewise, we observed a positive trend in the development in percentage of women in management, which aligns with our ambition for 2023, indicating that we continue to progress toward increasing our representation of women. §Accounting principlesManagement is defined as three levels below the administrative management and supervi-sory bodies: Partners, principles and managers in Denmark, the Netherlands, Norway, Poland, United Kingdom and Vietnam. Management is defined as two levels below the administrative management and supervisory bodies: Directors and managers in Netcompany-Intrasoft. Gender distribution at Netcompany Group is com-puted by summing the total aggregated headcount of both women and men in the Management, respectively, excluding freelancers and contrac-tors. These aggregated numbers in headcount are divided by the total combined headcount for women and men in the management to calculate the distribution share for each gender, respective-ly. This calculation is based on an average taken over the reporting period from January 1, 2023, to December 31, 2023. The KPI for gender distribution has been revised from previous reporting, which previously only reported on the share of women â managers, principals and partners. The 2022 figurehas been restated according to the accounting principles described above.Geographic distributionWe want to support a culture where all our peo-ple treat each other and all stakeholders with mutual respect and feel free to be their authen-tic selves, regardless of their social identity. We maintain a zero-tolerance stance on any dis-crimination, harassment or bullying, regardless of personal characteristics, such as age, culture, nationality, ethnicity, gender, physical ability, po-litical or religious beliefs, sexual orientation, or other attributes. These standards are explicitly described in our Anti-Harassment and Sexual Harassment Policy, which is presented to all new employees during their onboarding programme.Number of employees Operating entities(Headcount)Belgium 329Cyprus 3Denmark 2,384Greece 2,091Jordan 48Kenyaî 1Luxembourg 123Netherlands, The 180Norway 355Poland 330Romania 6South Africa 11United Arab Emirates 5United Kingdom, The 598United States of America 2Vietnam 282î The Kenyan entity was sold in February 2023§Accounting principlesThe geographic distribution of employees is computed by aggregating the total headcount of employees within the specific geographical lo-cations where our operating entities are located. This calculation is based on an average taken over the reporting period from January 1, 2023, to December 31, 2023.Employment characteristicsThe majority of our workforce consists of perma-nent employees, a deliberate choice to provide secure and stable employment for our team. Thisstrategy is fundamental to attracting, retaining, and motivating top talent and maintaining a valu-able pool of knowledge, experience, and talent crucial for our long-term success. Retaining our skilled workforce ensures continuity and preserves institutional knowledge, enhancing the quality and efficiency of our operations. Temporary employees are an integral part of our business, especially in Belgium and Luxembourg, where they constitute a significant portion of our workforce. We do not offer non-guaranteed hour contracts as this does not align with our business model. §Accounting principlesâPermanent employeesâ is defined as the head-count of employees with an employment con-tract, whether or not they have a fixed end date. This includes student assistants and trainees but excludes freelancers and contractors. The num-ber of âPermanent employeesâ at Netcompany Group is computed by aggregating the permanent employee count. This calculation is based on an average taken over the reporting period from January 1, 2023, to December 31, 2023.âTemporary employeesâ is defined as the headcount of employees whose employment is contingent upon the conclusion of a specific project or has a predetermined time limit. This includes interns but excludes freelancers and contractors. The number of âTemporary employeesâ at Netcompany Group is computed by aggregating the temporary employee count. The calculation is based on an average taken over the reporting period from January 1, 2023, to December 31, 2023.âNon-guaranteed hours employeesâ is defined as the headcount of employees employed with no contractual assurance of a minimum or set numberof working hours. The number of âNon-guaranteed hours employeesâ at Netcompany Group is computed by aggregating the non-guaranteed Number of Number of Number of Number of permanent temporary non-guaranteed employees employees employees hours employees Gender(Headcount)*(Headcount)(Headcount)(Headcount)Male 4,917 4,069 849 0Female 1,829 1,643 186 0Total employees 6,746 5,711 1,035 0* Sustainability key figure subject to limited assurancehours employee count. This calculation is based on an average taken over the reporting period from January 1, 2023, to December 31, 2023.Employee turnoverEmployee turnover 2023 2022Rate 19.0% 23.8%Number of employees 1,285 1,464In 2023, we experienced a reduction in the over-all turnover rate from 2022 to 2023. The turnover rate in 2022 was high compared to historical data, particularly in the first six months. In 2023, the turnover rate returned to a level resembling patterns seen in earlier years, demonstrating a positive trajectory from a lower baseline.§Accounting principlesâEmployee turnoverâ is defined as the cumu-lative headcount of employees who have de-parted from Netcompany Group, whereas the âEmployee turnover rateâ is defined as the pro-portion of employees who have left Netcompany Group expressed as a percentage.The total number of employees who left Netcompany Group is computed by aggregat-ing departures across all countries of operation from January 1 to December 31, 2023, excluding freelancers and contractors. To determine the percentage of departing employees, the total is divided by the average number of employees during the same period, aligning with the annual reporting method.Employee distribution We embrace age diversity within our workforce as it facilitates knowledge transfer, professional growth, and effective problem-solving, and en-sures that we harness collective experiences. By combining the strengths of different age groups, we drive innovation and growth â individually and as a business. Number of employees Age distribution(Headcount)<30 2,746>30;<50 3,349>50 651In 2023, our age distribution underlines our com-mitment to hiring young talents and providing them with opportunities to develop further in their career.§Accounting principlesThe age distribution of employees is computed by aggregating the total headcount of employees under 30 (29 or younger), employees between 30 and 50 (30 to 49), and employees aged 50 or above, excluding freelancers and contractors. This calculation is based on an average taken over the reporting period from January 1, 2023, to December 31, 2023.SicknessIn 2023, the average sickness rate stood at 3.1%* (2022: 3.4%). In 2023, we experienced a decline in absence rates. Initiatives focusing on increased on-site presence, teamwork, and well-being have provided an overall healthier hybrid workplace balance. We maintain ongoing internal monitoring of sick-ness absence levels, along with other key indica-tors, as part of our commitment to safeguarding the well-being and safety of our employees.§Accounting principlesSickness absence is calculated by dividing the total sickness hours in Netcompany Group by the aggregated norm working hours. This calculation is based on data from January 1 to December 31, and includes all employees in headcounts within Netcompany Group, exclud-ing freelancers and contractors. The 2022 figure has been restated according to the accounting principles described above.Annual total remuneration ratioTo ensure a transparent and meaningful insight into the highest earning employee pay ratio at Netcompany, our reporting is based on the re-muneration of the highest earning employee compared to employees in Netcompany Group (as opposed to Netcompany Group A/S as this employs only the Executive Management). The highest earning employee remuneration package is composed and proposed by the Remuneration Committee and approved by the Board of Directors and is in accordance with our Remuneration Policy as approved at the Annual General Meeting 2023. In 2023, the total remuneration ratio is 1:26* (2022: 1:21%). In 2023, the highest earning em-ployee was the Chief Financial Officer (CFO) earning DKK 10.9m, which is a significant in-crease from previous years. The increase was due to extraordinary remuneration in form of a Matching Shares Programme (MSP) resulting in an increase of DKK 6.2m. Comparably in 2022, the highest earning employee was the Chief Operating Officer (COO) earning DKK 8.3m. Please refer to our Remuneration Report for further details on remuneration.§Accounting principlesThe total remuneration ratio is calculated by di-viding the highest-earning employeeâs total annu-al salary by the median annual salary for employ-ees in Netcompany, with the annual salary being defined as taxable income plus any employer and employee-paid pension contributions.A list of every employeeâs monthly gross salary for October is created to calculate the median salary. The employee with the median salary is then selected and calculated in full, where every taxable salary element plus pension contributions are included. If the selected employee has irreg-ular salary elements during the year (January 1 to December 31), another employee with the same monthly gross salary is selected instead.Customer satisfaction (Net Promoter Score)In our commitment to fostering valuable and impactful partnerships, we conduct an annual Customer Satisfaction Survey using the Net Promoter Score (NPS) system. 2023* 2022NPS +36 +55Compared to 2022 the customer base included for the 2023 NPS calculation has been substan-tially increased reflecting the customer base for the Group and ensuring consistency going for-ward. Despite the lower score in 2023 compared to 2022, NPS for the Group at +36 is still consid-ered as highly satisfactory.§Accounting principlesCustomer satisfaction (NPS) score is assessed based on survey feedback from a random sample representative of 50 customers across Netcompany Denmark, Netcompany Netherlands, Netcompany Norway, Netcompany UK and Netcompany-Intrasoft. The number of participating customers from each entity is selected according to 1) turnover distribution between markets and 2) customer type distribution in each market, i.e., private and public (including EU), based on the cus-tomers with the highest turnover over the period of January 1, 2023, to September 31, 2023. One to two respondents representing each custom-er are pointed out by the responsible custom-er-owner, so the NPS score is based on respon-dents who have a relationship with Netcompany and are active in the common engagement. When calculating the overall NPS score for custom-ers where two respondents have answered the NPS survey, we calculate the average score of the two scores and round up to the nearest whole number. The response rate is 79% (2022: 69%). The final NPS score is calculated by subtracting the percentage of detractors from the percentage of promoters.Our social efforts We foster a social community that spans teams, borders, and delivery units. Our social clubs and communities serve as the heart of our social activities, offering various events for everyone to enjoy. We cater to various interests, from sports like football and laser tag to cultural nights and ceramics workshops. Our social clubs welcome event ideas from anyone, and everyone is en-couraged to join. We recognise the importance of social connections in retaining and attracting top talent, and our diverse range of social events of-fers newcomersâ and our more seasoned people alike the opportunity to connect with peers and build valuable networks across the organisation. This applies to our entities in Denmark, Greece (Thessaloniki), the Netherlands, Norway, Poland, the United Kingdom, and Vietnam. Promoting employee well-beingWe provide a range of initiatives to support both physical and mental health. We offer our people the chance to participate in various sports clubs, encouraging an active lifestyle. Our annual Fitness Challenge is open to all, regardless of fitness levels, allowing colleagues to engage in sports activities across borders and within their teams in our enti-ties Denmark, the Netherlands, Norway, Poland, the United Kingdom, and Vietnam. In our Greek entity, we provide an online platform support room, offering on-demand mental health support.GovernanceGCorporate culture Our Code of Conduct (CoC) describes the corpo-rate culture of trust, loyalty, and integrity that we are committed to promote and uphold, as well as the ethical values which we choose to follow in Netcompany. Our CoC applies to the Board of Directors, the Executive Management and all employees of Netcompany Group A/S including subsidiaries. In addition, our CoC applies to anyone who con-ducts business for, or on behalf of, Netcompany including any supplier, contractor, external busi-ness partner, and other party directly linked to the operations, products, or services of Netcompany, or employee of such, or similar.The CoC is based on internationally recognised ethical principles, guidelines, and conven-tions e.g., the OECD Guidelines for Multilateral Enterprises, UN Guiding Principles on Business and Human Rights, UN Declaration of Human Rights and the Convention on the Rights of the Child, ILO Conventions, and applicable laws and regulations, e.g., the EU Corporate Sustainability Reporting Directive and the EU Taxonomy. We are in the process of implementing a due diligence process in accordance with OECD Due Diligence Guidance for Responsible Business Conduct and applicable laws and regula-tions, e.g., the EU Corporate Sustainability Due Diligence Directive throughout the Group, and we expect our business partners to adhere to the same standards. Our CoC is publicly available and communicat-ed internally to ensure that our principles are embedded throughout the Group. Reference is made to the Minimum Safeguards section.In addition to our CoC, we have implemented a variety of corporate policies that sets the out-line for a good corporate culture and ensures Netcompany follows applicable legal require-ments and corporate governance recommen-dation. These policies include, among other, an Anti-Bribery- and Anti-Corruption Policy, Tax Policy, Investor Policy, Remuneration Policy, Data Ethics Policy, Diversity, Equity, and Inclusion Policy, and our Whistleblower Policy.Where relevant in this report, selected policies are described in detail. Anyone who becomes aware of an actual or potential violation of our CoC, a Netcompany policy, or the law, is en-couraged to speak up and various channels are available to use. Depending on the concern, we encourage e.g., employees to start by discussing the matter with the closest manager or address-ing the concern to Group Legal. This section is part of our reporting on 99a in the Danish Financial Statements Act.Training Netcompanyâs employees are trained to ensure that all employees follow Netcompanyâs core values and standards as set out in the Code of Conduct.As part of the onboarding process for every new employee, a training session with focus on Netcompanyâs Code of Conduct (CoC) is man-dated for all on their first day. This includes an immersive training to ensure that every individual is well-versed in our ethical guidelines, business standards, and policies. Every employee embarks on a training journey tailored to familiarise them with our princi-ples and practices. Within one week of joining Netcompany, all employees are required to de-clare their understanding and acknowledgment of our policies and confirm to have read and understood them. This declaration is facilitated through a systematic procedure wherein indi-viduals fill in and submit a receipt through our internal portal. Employees are encouraged to ask questions or reach out to the relevant de-partments if any questions arise. The employees are tested in regard to their understanding of the mandatory policies. Our Anti Bribery- and Anti-Corruption Policy states that each principal and all relevant employees will receive relevant training and new employees will be briefed on the Anti-Bribery- and Anti-Corruption Policy as a part of the welcome orien-tation. At a minimum, key employees will receive mandatory training, including compliance with anti-corruption laws, regulations, or standard con-ducts relevant for the companyâs field of business.WhistleblowingWe are subject to legal requirements under na-tional law, standards, and recommendations in regard to the protection of whistleblowers and at all times adhere to such. We imple-mented a whistleblower system prior to the EU Whistleblower Directive coming into force, and subsequently we adjusted our whistleblower system to comply with the directive and national implementation where applicable. We have an independent and autonomous whis-tleblower system that allows reporting of serious offences, other serious matters or matters which are illegal pursuant to EU law within a number of specific areas as defined in the EU Whistleblower Directive with full anonymity. All persons relat-ed to Netcompany, both external and internal, such as employees, members of the Executive Management and Board of Directors, auditors, lawyers, suppliers and other business partners of Netcompany may use the whistleblower system to report violations. Our independent and autono-mous whistleblower system is ensured by having reports and system maintained by our external law firm which oversees and ensures proper han-dling of any reports. In 2023, five reports were submitted via the whistleblower system. Four of the reports were assessed to be in scope by the external law firm, and appropriate action was taken. We take whis-tleblowing cases very seriously, so employees and partners are made aware of good conduct and that they can report any incidents through the whistleblower portal. The total number of re-ports are provided by our external law firm at the end of the financial year.All reports of possible violations as set out in our Whistleblower Policy and Whistleblower Procedure, made in good faith will be respond-ed to in a respectful, professional manner, as promptly and confidentially as possible, and we will ensure the possibility to make reports with full anonymity. We will respond with no unfavour-able treatment or unfavourable consequences as a reaction to a report and as required by applica-ble law.Anti-bribery and anti-corruptionWe actively work to prevent corruption and brib-ery in all business undertakings. In 2018, we ad-opted an Anti-Bribery and Anti-Corruption Policy that complements our CoC, setting high ethical standards and ensuring compliance with rele-vant laws. This policy provides clear guidelines on offering or receiving gifts and hospitality to ensure they do not serve as attempts to improp-erly influence decisions and that all actions are transparent. As part of our reporting on the Danish Financial Statements Act section 99a, we have imple-mented organisational procedures to maintain constant oversight over company expenses. The main risks are identified as gestures in relation to gifts and hospitality, e.g. benefits, experiences, and meals etc. exchanged between our people and customers, business relations, and public officials. An integral part of these procedures is our approval system. Every gesture, if offered or received, necessitates approval from a desig-nated superior. This not only ensures that every transaction aligns with our principles but also aids in creating an environment of accountability and transparency. The policy serves a dual pur-pose: On one hand, it assists our people in ensur-ing that their actions always mirror the values of Netcompany. On the other hand, it protects our employees from any potential unfounded accu-sations of unethical conduct. Any allegations or incidents indicating potential violations of our Anti-Bribery and Anti-Corruption Policy as well as any actions subject to the anti-corruption and anti-bribery laws, will be promptly investigated by Group Legal if reported internally or, if reported through our whistleblow-ing system, in accordance with our procedure for such whistleblower reports. If any violations are confirmed, they are all promptly addressed, and corrective measures are undertaken. Furthermore, all outcomes, find-ings, and decisions relating to such investigations are systematically reported to the relevant indi-vidual or department within the administrative, management, and supervisory bodies. In 2023, we have not had any incidents, convic-tions, or fines for violation of anti-corruption and anti-bribery laws, or any breaches of procedures and standards in relation to anti-bribery and an-ti-corruption. Furthermore, we have not had any legal proceedings regarding corruption or bribery brought against us or our employees, and it not aware of any incidents in our value chain where we are directly involved.Data ethicsWith the following reporting on our Data Ethics Policy, Netcompany and our applicable subsidiar-ies comply with the requirements under section 99d of the Danish Financial Statements Act. We implemented our Data Ethics Policy in 2020 and have continued to report on our Data Ethics Policy since then. Our policy is based on three key principles: security, integrity, and trust. Our Data Ethics Policy is based on applicable legisla-tion, standards, and recommendations, and we aim to revise our policy whenever necessary e.g., in connection with new guidelines and legislation relevant for the handling of data or our role as an IT service provider. Working as an IT service provider we encounter many types of data, including personal data. In our own organisation we mainly process data about our employees and job applicants, provid-ed by the employees and job applicants them-selves. In our capacity as a supplier, we process data on behalf of our customers, for example in connection with the maintenance and hosting of their systems. We prioritise data ethics and best IT practices in all our operations. We operate with the âleast privilegeâ principle, granting users only the access necessary for their tasks and monitors such access controls continuously. This approach minimises the potential for data misuse and forms the foundation of our stringent access control measures. Employees who have access to a customerâs data is always visible and trans-parent for the customer. The data we process about our employees and job applicants includes regular personal data, such as names, addresses and phone numbers. We may also process special categories of per-sonal data, for example, health information. The data we process on behalf of our customers relates to their production data, which in some cases may also include both regular and special categories of personal data. Customer data is only used for the customerâs purpose, and we ensure that proper safeguards are in place to avoid unauthorised access to and use of data.Technical and organisational security is an essential part of any safe data processing. Netcompanyâs daily operations are based on a highly detailed security policy and organisa-tional procedures, all of which comply with the international security standard ISO/IEC 27001. We process all data with the utmost respect for the sensitivity of the data and any privacy rights â to make sure we earn the trust of our customers, employees, shareholders, and any other stakeholders. We run internal audit controls to secure com-pliance with both information security and data protection requirements as well as proper doc-umentation, and all our employees are regularly trained in the Netcompany Methodology. In addi-tion to these measures, we have all data securely stored at two different data centres to ensure that data availability is always upheld in the un-likely event of technical failures. Audits enable us to identify and address potential vulnerabilities promptly, ensuring our systems stay updated with the latest security standards. We use artificial intelligence (AI) and machine learning in some of our solutions, but never in a context where such services are used for either profiling, automated decision making or similar. Machine learning is instead used for the purpose of reducing energy consumption and climate impact. Our work to ensure diversity throughout the organisation is also part of our data ethical con-siderations in that it may help prevent uninten-tional biases in both the development of our own IT solutions and when advising our customers about the development of theirs. Whether we process personal data or other types of data, we always apply our standards for data ethics to the way we work, making sure that our processing activities and security mea-sures match the requirements for the data we are handling.Political influence and lobbying activities We support many causes which for some may be considered a politically influencing or lobbying activity e.g., participating in discussions at na-tional and EU level in relation to digitalisation, fe-male- and childrenâs rights, and other applicable industry subjects related to our sector. We aim to be fully transparent in relation to political influ-ence and lobbying activities and Netcompany is registered in the EU Transparency Register under the identification number 381394742467-81. No member of the Board of Directors, the Executive Management, or the Board Committees, has held a comparable position in public administration in the two years preceding their appointment. Fair payment practices We support fair payment practices and discour-age the use of an undertakingâs size to take advantage of suppliers, especially SMEs. Our standard payment practice is to pay invoices as agreed upon with each individual supplier in ac-cordance with applicable sector and geographi-cal standards. The majority of the invoices directed to Netcompany is paid within 30-60 days of receipt of proper invoice, except for a minority of the invoic-es, where customs set out otherwise and always in accordance with agreement with the suppliers. We have not had any legal proceedings in relation to outstanding late payments.</mrv:StatementOfCorporateSocialResponsibility>
<mrv:StatementOfPolicyForDataEthics contextRef="ctx-1" id="s7_notesesefdkgaap__7__25" xml:lang="en">Data ethicsWith the following reporting on our Data Ethics Policy, Netcompany and our applicable subsidiar-ies comply with the requirements under section 99d of the Danish Financial Statements Act. We implemented our Data Ethics Policy in 2020 and have continued to report on our Data Ethics Policy since then. Our policy is based on three key principles: security, integrity, and trust. Our Data Ethics Policy is based on applicable legisla-tion, standards, and recommendations, and we aim to revise our policy whenever necessary e.g., in connection with new guidelines and legislation relevant for the handling of data or our role as an IT service provider. Working as an IT service provider we encounter many types of data, including personal data. In our own organisation we mainly process data about our employees and job applicants, provid-ed by the employees and job applicants them-selves. In our capacity as a supplier, we process data on behalf of our customers, for example in connection with the maintenance and hosting of their systems. We prioritise data ethics and best IT practices in all our operations. We operate with the âleast privilegeâ principle, granting users only the access necessary for their tasks and monitors such access controls continuously. This approach minimises the potential for data misuse and forms the foundation of our stringent access control measures. Employees who have access to a customerâs data is always visible and trans-parent for the customer. The data we process about our employees and job applicants includes regular personal data, such as names, addresses and phone numbers. We may also process special categories of per-sonal data, for example, health information. The data we process on behalf of our customers relates to their production data, which in some cases may also include both regular and special categories of personal data. Customer data is only used for the customerâs purpose, and we ensure that proper safeguards are in place to avoid unauthorised access to and use of data.Technical and organisational security is an essential part of any safe data processing. Netcompanyâs daily operations are based on a highly detailed security policy and organisa-tional procedures, all of which comply with the international security standard ISO/IEC 27001. We process all data with the utmost respect for the sensitivity of the data and any privacy rights â to make sure we earn the trust of our customers, employees, shareholders, and any other stakeholders. We run internal audit controls to secure com-pliance with both information security and data protection requirements as well as proper doc-umentation, and all our employees are regularly trained in the Netcompany Methodology. In addi-tion to these measures, we have all data securely stored at two different data centres to ensure that data availability is always upheld in the un-likely event of technical failures. Audits enable us to identify and address potential vulnerabilities promptly, ensuring our systems stay updated with the latest security standards. We use artificial intelligence (AI) and machine learning in some of our solutions, but never in a context where such services are used for either profiling, automated decision making or similar. Machine learning is instead used for the purpose of reducing energy consumption and climate impact. Our work to ensure diversity throughout the organisation is also part of our data ethical con-siderations in that it may help prevent uninten-tional biases in both the development of our own IT solutions and when advising our customers about the development of theirs. Whether we process personal data or other types of data, we always apply our standards for data ethics to the way we work, making sure that our processing activities and security mea-sures match the requirements for the data we are handling.Political influence and lobbying activities We support many causes which for some may be considered a politically influencing or lobbying activity e.g., participating in discussions at na-tional and EU level in relation to digitalisation, fe-male- and childrenâs rights, and other applicable industry subjects related to our sector. We aim to be fully transparent in relation to political influ-ence and lobbying activities and Netcompany is registered in the EU Transparency Register under the identification number 381394742467-81. No member of the Board of Directors, the Executive Management, or the Board Committees, has held a comparable position in public administration in the two years preceding their appointment</mrv:StatementOfPolicyForDataEthics>
<sob:StatementByExecutiveAndSupervisoryBoards contextRef="ctx-1" id="s7_notesesefdkgaap__7__167" xml:lang="en">The Board of Directors and the Executive Man-agement have today considered and approved the Annual Report of Netcompany Group A/S for the financial year 1 January - 31 December 2023 for the Group and the Parent company. The Annual Report is prepared in accordance with IFRS Accounting Standards as adopted by the EU and additional requirements of the Danish Finan-cial Statements Act.In our opinion, the consolidated financial state-ments and the parent financial statements give a true and fair view of the Groupâs and the Parent companyâs financial position at 31 December 2023 and of the results of their operations and cash flows for the financial year 1 January - 31 December 2023 for the Group and the Parent.In our opinion, the management commentary contains a fair review of the development of the Groupâs and the Parent companyâs business, financial and non-financial matters, the results for the year and of the Parent companyâs finan-cial position and the financial position as a wholeof the entities included in the consolidated finan-cial statements, together with a description of the principal risks and uncertainties that the Group and the Parent company face. Netcompanyâs Sustainability section, including selected sustainability key figures and the related notes have been prepared in accordance with the accounting principles. In our opinion, they give a true and fair view of the organisationâs environmental, social and governance perfor-mance in accordance with these principles.In our opinion, the Annual Report for Netcompany Group A/S with the file name Netcompa-nyGroup-2023-12-31-en.zip for the financial year 1 January - 31 December 2023 for the Group and the Parent is conducted in compliance with the ESEF regulation.We recommend the Annual Report for adoption at the Annual General Meeting.</sob:StatementByExecutiveAndSupervisoryBoards>
<sob:PlaceOfSignatureOfStatement contextRef="ctx-1" id="s7_notesesefdkgaap__7__168" xml:lang="en">Copenhagen</sob:PlaceOfSignatureOfStatement>
<sob:DateOfApprovalOfAnnualReport contextRef="ctx-1" id="s7_notesesefdkgaap__7__169">2024-01-25</sob:DateOfApprovalOfAnnualReport>
<cmn:NameAndSurnameOfMemberOfExecutiveBoard contextRef="ctx-66" id="s7_notesesefdkgaap__7__170" xml:lang="en">André Rogaczewski</cmn:NameAndSurnameOfMemberOfExecutiveBoard>
<cmn:TitleOfMemberOfExecutiveBoard contextRef="ctx-66" id="s7_notesesefdkgaap__7__171" xml:lang="en">Chief Executive Officer</cmn:TitleOfMemberOfExecutiveBoard>
<cmn:NameAndSurnameOfMemberOfExecutiveBoard contextRef="ctx-67" id="s7_notesesefdkgaap__7__172" xml:lang="en">Claus Jørgensen</cmn:NameAndSurnameOfMemberOfExecutiveBoard>
<cmn:TitleOfMemberOfExecutiveBoard contextRef="ctx-67" id="s7_notesesefdkgaap__7__173" xml:lang="en">Chief Operating Officer</cmn:TitleOfMemberOfExecutiveBoard>
<cmn:NameAndSurnameOfMemberOfExecutiveBoard contextRef="ctx-68" id="s7_notesesefdkgaap__7__174" xml:lang="en">Thomas Johansen</cmn:NameAndSurnameOfMemberOfExecutiveBoard>
<cmn:TitleOfMemberOfExecutiveBoard contextRef="ctx-68" id="s7_notesesefdkgaap__7__175" xml:lang="en">Chief Financial Officer</cmn:TitleOfMemberOfExecutiveBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-69" id="s7_notesesefdkgaap__7__176" xml:lang="en">Bo Rygaard</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx-69" id="s7_notesesefdkgaap__7__177" xml:lang="en">Chair</cmn:TitleOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-70" id="s7_notesesefdkgaap__7__178" xml:lang="en">Juha Christensen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx-70" id="s7_notesesefdkgaap__7__179" xml:lang="en">Vice Chair</cmn:TitleOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-71" id="s7_notesesefdkgaap__7__180" xml:lang="en">Ã
sa Riisberg</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-72" id="s7_notesesefdkgaap__7__181" xml:lang="en">Susan Helen Cooklin</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-73" id="s7_notesesefdkgaap__7__182" xml:lang="en">Bart Walterus</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<arr:OpinionOnAuditedFinancialStatements contextRef="ctx-1" id="s7_notesesefdkgaap__7__187" xml:lang="en">OpinionWe have audited the consolidated financial state-ments and the parent company financial state-ments of Netcompany Group A/S for the financial year 1 January â 31 December 2023, which com-prise statement of comprehensive income, state-ment of financial position, statement of changes in equity, cash flow statement and notes, includ-ing material accounting policy information, for the Group and the Parent Company. The consolidated financial statements and the parent company financial statements are prepared in accordance with IFRS Accounting Standards as adopted by the EU and additional requirements of 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 finan-cial position of the Group and the Parent Com-pany at 31 December 2023 and of the results of the Group's and the Parent Company's opera-tions and cash flows for the financial year 1 Janu-ary â 31 December 2023 in accordance with IFRS Accounting Standards as adopted by the EU and additional requirements of 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:DescriptionOfQualificationsOfAuditedFinancialStatements contextRef="ctx-1" id="s7_notesesefdkgaap__7__188" 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" (hereinafter col-lectively 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.IndependenceWe are independent of the Group in accordance with the International Ethics Standards Board for Accountants' International Code of Ethics for Pro-fessional Accountants (IESBA Code) and the additional ethical requirements applicable in Denmark, and we have fulfilled our other ethical responsibilities in accordance with these require-ments and the IESBA Code. To the best of our knowledge, we have not pro-vided any prohibited non-audit services as described in article 5(1) of Regulation (EU) no. 537/2014.Appointment of auditorWe were initially appointed as auditor of Netcom-pany Group A/S on 9 March 2021 for the financial year 2021. We have been reappointed annually by resolution of the general meeting for a total con-secutive period of 3 years up until the financial year 2023.</arr:DescriptionOfQualificationsOfAuditedFinancialStatements>
<arr:KeyAuditMattersAudit contextRef="ctx-1" id="s7_notesesefdkgaap__7__189" xml:lang="en">Key audit mattersKey audit matters are those matters that, in our professional judgement, were of most significance in our audit of the financial state-ments 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 mat-ter is provided in that context. We have fulfilled our responsibilities described in the "Auditor's responsibilities for the audit of the financial statements" section, including in relation to the key audit matters below. Accordingly, our audit included the design and performance 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.Revenue recognition, including the measure-ment and recognition of work in progressThe accounting principles and disclosures on rev-enue recognition related to projects are included in note 1 to the consolidated financial statements. On 31 December 2023, the carrying value of the Groupâs work in progress amounted to DKK 703 million. Significant judgement is required by Man-agement in determining the stage of completion and expected profit on work in progress, including assessment of specific project risks and assess-ment of potential onerous contracts. In addition, the Groupâs accounting for arrangements with multiple performance obligations is subject to complexity, as the total contract value is allocated to each identified performance obligation and rec-ognised as revenue as the services are delivered.Due to the complexity in the judgements com-bined with the significance of revenue and work in progress, we consider revenue recognition, includ-ing the measurement and recognition of work in progress to be a key audit matter.How our audit addressed the key audit matterAs part of our audit, we obtained an understand-ing of the Groupâs processes for assessment of time and cost-to-complete estimates, the pro-cesses for identification and assessment of per-formance obligations and the processes for iden-tification and assessment of project related risks including the risk of projects changing into oner-ous contracts.We assessed the internal controls relating to monitoring of project development, time registra-tion, estimation of time and cost-to-complete and identification and assessment of project risks and potential onerous contracts.We obtained an overview of the Groupâs projects in progress on 31 December 2023. On basis of risk and materiality we selected a sample of projects. For the selected sample, we tested Managementâs assumptions for assessment of stage of comple-tion, estimates of expected time and cost-to-com-plete and expected profits. To assess the accu-racy of Managementâs assumptions and estimates we performed look-back analysis by comparing the actual profit of completed projects with the expected profit from budgets. We analysed the budget deviations and discussed with Manage-ment the possible risk of similar deviations on pro-jects in progress on 31 December 2023.We tested the identification and accounting of arrangements with multiple performance obliga-tions by testing a sample of recognised arrange-ments to customer contracts and amendments. We tested the identification, assessment and accounting of project risks, potential onerous contracts, and warranty issues by application of data analysis and examination of supporting doc-umentation.</arr:KeyAuditMattersAudit>
<arr:AddresseeOfAuditorsReportOnAuditedFinancialStatements contextRef="ctx-1" id="s7_notesesefdkgaap__7__186" xml:lang="en">To the shareholders of Netcompany Group A/S</arr:AddresseeOfAuditorsReportOnAuditedFinancialStatements>
<arr:StatementOnManagementsReviewAuditorsReportOnAuditedFinancialStatements contextRef="ctx-1" id="s7_notesesefdkgaap__7__190" xml:lang="en">Statement on the Managementâs reviewManagement 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 assurance conclusion thereon.In connection with our audit of the financial state-ments, our responsibility is to read the Manage-ment's review and, in doing so, consider whether the Management's review is materially inconsist-ent with the financial statements, or our knowl-edge 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 by relevant law and regula-tions. Based on our procedures, we conclude that the Management's review is in accordance with the financial statements and has been prepared in accordance with the requirements of relevant law and regulations. We did not identify any material misstatement of the Management's review.</arr:StatementOnManagementsReviewAuditorsReportOnAuditedFinancialStatements>
<arr:StatementOfExecutiveAndSupervisoryBoardsResponsibilityForFinancialStatements contextRef="ctx-1" id="s7_notesesefdkgaap__7__191" xml:lang="en">Managementâs responsibilities for the financial statementsManagement is responsible for the preparation of consolidated financial statements and parent company 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 such internal control as Management determines is necessary to enable the prepara-tion of financial statements that are free from material misstatement, whether due to fraud or error.In preparing the financial statements, Manage-ment is responsible for assessing the Group's and the Parent Company's ability to continue as a going concern, disclosing, as applicable, mat-ters related to going concern and using the going concern basis of accounting in preparing the financial statements unless Management either intends to liquidate the Group or the Parent Com-pany or to cease operations, or has no realistic alternative but to do so.</arr:StatementOfExecutiveAndSupervisoryBoardsResponsibilityForFinancialStatements>
<arr:StatementOfAuditorsResponsibilityForAuditAndAuditPerformed contextRef="ctx-1" id="s7_notesesefdkgaap__7__192" xml:lang="en">Auditorâs responsibilities for the audit of the financial statementsOur objectives are to obtain reasonable assur-ance 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. Rea-sonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs and additional require-ments applicable in Denmark will always detect a material misstatement when it exists. Misstate-ments can arise from fraud or error and are con-sidered material if, individually or in the aggre-gate, 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 requirements applicable in Denmark, we exercise professional judgement and maintain professional scepticism throughout the audit. We also: Identify and assess the risks of material mis-statement of the financial statements, 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, inten-tional 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 circum-stances, 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 reasonableness of accounting estimates and related disclosures made by Management. Conclude on the appropriateness of Manage-ment's use of the going concern basis of accounting in preparing the financial state-ments 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 state-ments 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 statements represent the under-lying transactions and events in a manner that gives a true and fair view. Obtain sufficient appropriate audit evidence regarding the financial information of the entities or business activities within the Group to express an opinion on the consoli-dated financial statements. We are responsi-ble for the direction, supervision and perfor-mance of the group audit. We remain solely responsible for our audit opinion.We communicate with those charged with govern-ance 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 rel-evant ethical requirements regarding independ-ence, and to communicate with them all relation-ships 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 audi-tor's report unless law or regulation precludes public disclosure about the matter.</arr:StatementOfAuditorsResponsibilityForAuditAndAuditPerformed>
<arr:AuditorsReportOnXbrlTagging contextRef="ctx-1" id="s7_notesesefdkgaap__7__193" xml:lang="en">Report on compliance with the ESEF RegulationAs part of our audit of the Consolidated Financial Statements and Parent Company Financial State-ments of Netcompany Group A/S, we performed procedures to express an opinion on whether the annual report of Netcompany Group A/S for the financial year 1 January â 31 December 2023 with the file name NetcompanyGroup-2023-12-31-en.zip is prepared, in all material respects, in compli-ance with the Commission Delegated Regulation (EU) 2019/815 on the European Single Electronic Format (ESEF Regulation) which includes require-ments 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 Regula-tion. This responsibility includes: The preparing of the annual report in XHTML format; The selection and application of appropriate iXBRL tags, including extensions to the ESEF taxonomy and the anchoring thereof to ele-ments in the taxonomy, for all financial infor-mation required to be tagged using judge-ment where necessary; Ensuring consistency between iXBRL tagged data and the Consolidated Financial State-ments presented in human readable format; and For such internal control as Management determines necessary to enable the prepara-tion of an annual report that is compliant with the ESEF Regulation. Our responsibility is to obtain reasonable assur-ance 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 proce-dures selected depend on the auditorâs judge-ment, 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 pre-pared in XHTML format; Obtaining an understanding of the compa-nyâs iXBRL tagging process and of internal control over the tagging process; Evaluating the completeness of the iXBRL tagging of the Consolidated Financial State-ments including notes; Evaluating the appropriateness of the com-panyâs use of iXBRL elements selected from the ESEF taxonomy and the creation of extension elements where no suitable ele-ment in the ESEF taxonomy has been identi-fied; 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 Netcompany Group A/S for the financial year 1 January â 31 December 2023 with the file name Netcompa-nyGroup-2023-12-31-en.zip is prepared, in all material respects, in compliance with the ESEF Regulation.</arr:AuditorsReportOnXbrlTagging>
<arr:SignatureOfAuditorsPlace contextRef="ctx-1" id="s7_notesesefdkgaap__7__194" xml:lang="en">Copenhagen</arr:SignatureOfAuditorsPlace>
<arr:SignatureOfAuditorsDate contextRef="ctx-1" id="s7_notesesefdkgaap__7__195">2024-01-25</arr:SignatureOfAuditorsDate>
<cmn:NameOfAuditFirm contextRef="ctx-75" id="s7_notesesefdkgaap__7__197" xml:lang="en">EY Godkendt Revisionspartnerselskab</cmn:NameOfAuditFirm>
<cmn:NameOfAuditFirm contextRef="ctx-74" id="s7_notesesefdkgaap__7__196" xml:lang="en">EY Godkendt Revisionspartnerselskab</cmn:NameOfAuditFirm>
<cmn:IdentificationNumberCvrOfAuditFirm contextRef="ctx-74" id="s7_notesesefdkgaap__7__198" xml:lang="en">30700228</cmn:IdentificationNumberCvrOfAuditFirm>
<cmn:IdentificationNumberCvrOfAuditFirm contextRef="ctx-75" id="s7_notesesefdkgaap__7__199" xml:lang="en">30700228</cmn:IdentificationNumberCvrOfAuditFirm>
<cmn:NameAndSurnameOfAuditor contextRef="ctx-74" id="s7_notesesefdkgaap__7__200" xml:lang="en">Mikkel Sthyr</cmn:NameAndSurnameOfAuditor>
<cmn:DescriptionOfAuditor contextRef="ctx-74" id="s7_notesesefdkgaap__7__201" xml:lang="en">State Authorised Public Accountant</cmn:DescriptionOfAuditor>
<cmn:IdentificationNumberOfAuditor contextRef="ctx-74" id="s7_notesesefdkgaap__7__202" xml:lang="en">mne26693</cmn:IdentificationNumberOfAuditor>
<cmn:NameAndSurnameOfAuditor contextRef="ctx-75" id="s7_notesesefdkgaap__7__203" xml:lang="en">Morten Weinreich Larsen</cmn:NameAndSurnameOfAuditor>
<cmn:DescriptionOfAuditor contextRef="ctx-75" id="s7_notesesefdkgaap__7__204" xml:lang="en">State Authorised Public Accountant</cmn:DescriptionOfAuditor>
<cmn:IdentificationNumberOfAuditor contextRef="ctx-75" id="s7_notesesefdkgaap__7__205" xml:lang="en">mne42791</cmn:IdentificationNumberOfAuditor>
<gsd:NameOfSubmittingEnterprise contextRef="ctx-1" id="s7_notesesefdkgaap__7__221" xml:lang="en">Netcompany Group A/S</gsd:NameOfSubmittingEnterprise>
<gsd:NameOfReportingEntity contextRef="ctx-1" id="s7_notesesefdkgaap__7__215" xml:lang="en">Netcompany Group A/S</gsd:NameOfReportingEntity>
<gsd:AddressOfSubmittingEnterpriseStreetAndNumber contextRef="ctx-1" id="s7_notesesefdkgaap__7__222" xml:lang="en">Strandgade 3</gsd:AddressOfSubmittingEnterpriseStreetAndNumber>
<gsd:AddressOfReportingEntityStreetName contextRef="ctx-1" id="s7_notesesefdkgaap__7__216" xml:lang="en">Strandgade</gsd:AddressOfReportingEntityStreetName>
<gsd:AddressOfReportingEntityStreetBuildingIdentifier contextRef="ctx-1" id="s7_notesesefdkgaap__7__217" xml:lang="en">3</gsd:AddressOfReportingEntityStreetBuildingIdentifier>
<gsd:AddressOfSubmittingEnterprisePostcodeAndTown contextRef="ctx-1" id="s7_notesesefdkgaap__7__223" xml:lang="en">1401 Copenhagen</gsd:AddressOfSubmittingEnterprisePostcodeAndTown>
<gsd:AddressOfReportingEntityPostCodeIdentifier contextRef="ctx-1" id="s7_notesesefdkgaap__7__218" xml:lang="en">1401</gsd:AddressOfReportingEntityPostCodeIdentifier>
<gsd:AddressOfReportingEntityDistrictName contextRef="ctx-1" id="s7_notesesefdkgaap__7__219" xml:lang="en">Copenhagen</gsd:AddressOfReportingEntityDistrictName>
<gsd:IdentificationNumberCvrOfReportingEntity contextRef="ctx-1" id="s7_notesesefdkgaap__7__220" xml:lang="en">39488914</gsd:IdentificationNumberCvrOfReportingEntity>
<gsd:IdentificationNumberCvrOfSubmittingEnterprise contextRef="ctx-1" id="s7_notesesefdkgaap__7__224" xml:lang="en">39488914</gsd:IdentificationNumberCvrOfSubmittingEnterprise>
<gsd:InformationOnTypeOfSubmittedReport contextRef="ctx-1" xml:lang="en">Annual report</gsd:InformationOnTypeOfSubmittedReport>
<cmn:TypeOfAuditorAssistance contextRef="ctx-1" xml:lang="en">Auditor's report on audited financial statements</cmn:TypeOfAuditorAssistance>
<gsd:ToolForPreparingTheXBRLInstanceDocument contextRef="ctx-1" xml:lang="en">ParsePort XBRL Converter</gsd:ToolForPreparingTheXBRLInstanceDocument>
<gsd:ReportingPeriodStartDate contextRef="ctx-1" xml:lang="en">2023-01-01</gsd:ReportingPeriodStartDate>
<gsd:ReportingPeriodEndDate contextRef="ctx-1" xml:lang="en">2023-12-31</gsd:ReportingPeriodEndDate>
<gsd:PrecedingReportingPeriodStartDate contextRef="ctx-1" xml:lang="en">2022-01-01</gsd:PrecedingReportingPeriodStartDate>
<gsd:PredingReportingPeriodEndDate contextRef="ctx-1" xml:lang="en">2022-12-31</gsd:PredingReportingPeriodEndDate>
<gsd:LegalEntityIdentifierOfReportingEntity contextRef="ctx-1" xml:lang="en">5299006DEGAWX1Z1X779</gsd:LegalEntityIdentifierOfReportingEntity>
<fsa:ClassOfReportingEntity contextRef="ctx-1" xml:lang="en">Reporting class D</fsa:ClassOfReportingEntity>
<arr:TypeOfModifiedOpinionOnAuditedFinancialStatements contextRef="ctx-1" xml:lang="en">Opinion</arr:TypeOfModifiedOpinionOnAuditedFinancialStatements>
<arr:TypeOfBasisForModifiedOpinionOnAuditedFinancialStatements contextRef="ctx-1" xml:lang="en">Basis for Opinion</arr:TypeOfBasisForModifiedOpinionOnAuditedFinancialStatements>
</xbrli:xbrl>