Assets
| Type | Time | Amount | Unit |
|---|---|---|---|
| ifrs-full:Assets | 2024-12-31 | 2254800000 | vUSD |
| ifrs-full:Assets | 2023-12-31 | 2343900000 | vUSD |
Revenue
| Type | Start date | End date | Amount | Unit |
|---|---|---|---|---|
| ifrs-full:Revenue | 2024-01-01 | 2024-12-31 | 4040100000 | vUSD |
| ifrs-full:Revenue | 2023-01-01 | 2023-12-31 | 3691900000 | vUSD |
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<mrv:CorporateGovernanceReport contextRef="ctx2" id="fact1067" xml:lang="en">CORPORATE GOVERNANCE  At NORDEN, our view is that responsible and  transparent governance facilitates long-term value  creation aligned with shareholder interest.  NORDENâs governance principles and structure are set out to ensure  alignment with long-term shareholder interests to enable prudent  management of NORDEN in accordance with relevant national  and international regulations, applicable corporate governance  recommendations as well as to align with the risk framework  specified by the Board of Directors. Furthermore, the ongoing  management of NORDEN is based on the underlying Company  values of flexibility, reliability, empathy and ambition as well as the  Companyâs guiding purpose of enabling smarter global trade.  Governance structure  NORDEN has a two-tier governance structure consisting of a Board  of Directors and an Executive Management ensuring a clear sepa-  ration and that no individuals are part of both management bodies.  The shareholders have the ultimate authority over the Company and  exercise their rights by passing resolutions at general meetings.  Resolutions are adopted by simple majority of votes, unless other-  wise provided by legislation or by NORDENâs articles of association.  The Articles of Association are available on the Companyâs website.  Generally, resolutions to amend the Articles of Association require a  quorum of at least two-thirds of the voting share capital represented  at a general meeting and a majority of at least two-thirds of the votes  cast, as well as of the voting share capital represented at the general  meeting. In addition, certain resolutions on changes of the share-  holdersâ dividend or voting rights or the transferability of shares, as  set out in the Danish Companies Act, require a special supermajority  of at least 9/10 of the votes and of the capital represented.  The Board of Directors determines and approves strategies, poli-  cies, overall goals and budgets for the Company. In addition, it sets  out the risk management framework and supervises the work and  procedures carried out by the day-to-day management. The Board  of Directors appoints the Executive Management and determines its  responsibilities and remuneration. Apart from the agreed remuner-  ation, no transactions are conducted between related parties and  the Board, and the Board does not operate with any form of incen-  tive-based remuneration.  The first level of management comprises the CEO and CFO, who  makes up the Executive Management. The Executive Management  is responsible for the day-to-day management, organisation and  development of NORDEN, for managing assets, liabilities and  equity, for accounting and reporting, and for preparing and imple-  menting the strategy. The day-to-day contact between the Board  of Directors and the Executive Management is primarily handled by  the Chair and the CEO. The Executive Management participates in  board meetings and is supplemented by other managers in strategic  meetings when relevant.  The second management level includes employees with managerial  responsibilities and refers directly to the Executive Management.  Board work  The Board of Directors sets out an annual work schedule to ensure  that all relevant issues are discussed during the year, through a  combination of regular board meetings and strategy seminars. In line  with the focus on short- and long-term activities, the Board of Direc-  tors is engaged in upholding NORDEN's purpose of enabling smarter  global trade. This is, among other areas, reflected in the strategic  discussions and priorities set by the Board of Directors and the Exec-  utive Management, in the regular updates provided by the Executive  Management to the Board, as well as in the remuneration targets set  forth for Executive Management by the Board. In 2024, the Board of  Directors held 13 board meetings. The attendance rate was 100%.  Board committees  As part of the Board of Directorsâ work and structure, four subcommit-  tees have been established to ensure dedicated focus and strength-  ened oversight on recurring topics deemed of high importance for the  governance of the Company. See overview of committees on page 36.  Board qualifications and evaluation  For the Board of Directors to be able to perform its managerial and  strategic tasks, and at the same time act as a sounding board to the  Executive Management, the following skills are deemed particularly  relevant:  ⢠Insight into shipping and trading  ⢠Commodity trade  ⢠General management  ⢠Strategic development  ⢠Risk management  ⢠Investment, finance and accounting  ⢠International experience  ⢠ESG competences  The Board of Directors and the Executive Management conducted  a self-assessment of the composition, qualifications and dynamics  of the Board of Directors in 2024 with assistance from a third-party  adviser. The assessment concluded that the Board of Directors  possesses relevant skills and has good working relationships and  dynamics. A similar assessment is planned for 2026.  Board composition and remuneration  The Board of Directors is made up of nine members. Six are elected  for a term of one year by the shareholders, while three members  are elected for a term of four years by the employees. At the Annual  General Meeting in March 2024, Klaus Nyborg, Johanne C F Riegels,  Karsten Knudsen, Robert Hvide Macleod, Ian McIntosh and Vibeke  Bak Solok were all re-elected as board members.  During 2024, new employee representatives for the Board were  elected for a four-year period. Henrik Røjel was re-elected as  employee-elected board member whereas Ruhi Hermansen and  Sofie Schønherr were elected as new employee elected board  members.  The Board of Directors has set a target outlining that 40% of the  shareholder-elected board members should be represented by  females by 2025. Currently, the percentage of shareholder-elected  board members which are female is 33% and thus not yet meeting  NORDEN's target. To achieve this objective, the search process for  female candidates will continue in 2025, with the aim of aligning the  ratio of female board members with our objective by 2026.  Further details on the diversity levels in NORDEN can be found in  the sustainability statement of this report, while NORDENâs Diver-  sity, Equity &amp; Inclusion policy can be found at https://norden.com/  investor/governance/policies-and-charters.  Board remuneration increased to USD 0.9 million in 2024, after  eight years of unchanged board remuneration. The increase was  approved at the Annual General Meeting 2024. Specific board remu-  neration can be found in the Remuneration Report 2024 at https://  norden.com/about/governance/remuneration.  Executive Management remuneration  The remuneration of the Executive Management follows the  principles set out in the Companyâs remuneration policy, and the  specific remuneration components granted for the Executive  Management are set out in the separate Remuneration Report 2024.  Adherence to Danish corporate governance recommendations  The Board of Directors has reviewed its adherence to each recom-  mendation as provided by the Danish Committee on Corporate  Governance, following a âcomply or explainâ approach.  NORDEN follows all recommendations from the Danish Committee  on Corporate Governance, except for 3.4.2 that is related to the  recommendation that the majority of the members of the board  committees are independent. The Chair, Klaus Nyborg, has been a  member of the Board of Directors for more than 12 years and can  thus not be regarded as independent according to the criteria.  As a result, NORDEN is no longer complying with the recommen-  dation that the majority of the members of the board committees  are independent, as Klaus Nyborg remains a member of the Audit  Committee, Remuneration Committee and Nomination Committee.  At the Annual General Meeting held in March 2024, it was  announced that Karsten Knudsten would not seek re-election at the  Annual General Meeting in 2025, and consequently a search to find  a replacement was initiated. The search is now finalised, and an inde-  pendent board member will be proposed at the upcoming Annual  General Meeting on 12 March 2025. Subject to approval, the share-  holder-elected Board will have a majority of independent members  and all committees, except the Nomination Committee, will be in  compliance with recommendations.  NORDENâs position on each specific recommendation is summa-  rised in the corporate governance statement available at: https://  norden.com/about/governance/governance.  Planned board activity for 2025  The Board of Directors has planned 12 board meetings for 2025. The  Annual General Meeting will be held on 12 March 2025.  BOARD COMMITTEES  The four subcommittees have been established to ensure  dedicated focus on recurring topics deemed of high importance  to the governance of NORDEN.  Audit Committee  The Audit Committee consists of:  ⢠Vibeke Bak Solok (Chair)  ⢠Karsten Knudsen  ⢠Klaus Nyborg  ⢠Johanne C F Riegels (observer)  The committee supervises financial reporting,  transactions with closely related parties, auditing  and sustainability-related matters. The terms of  reference are published on NORDENâs website,  where a statement of control and risk manage-  ment in connection with financial reporting can  also be found (in accordance with section 107b  of the Danish Financial Statements Act). During  the year, the committee held four meetings with  100% attendance.  Risk Committee  The Risk Committee consists of:  ⢠Karsten Knudsen (Chair)  ⢠Robert Hvide Macleod  ⢠Ian McIntosh  The purpose of the committee is to assist the  Board of Directors in its oversight of the Groupâs  overall risk-taking tolerance and management of  market, credit and liquidity risks. The committeeâs  terms of reference are available on NORDENâs  website. During the year, the committee held four  meetings with 92% attendance.  Remuneration Committee  The Remuneration Committee consists of:  ⢠Klaus Nyborg (Chair)  ⢠Karsten Knudsen  ⢠Robert Hvide Macleod  ⢠Ian McIntosh  The committee is responsible for supervising  the implementation of the Groupâs remunera-  tion policy, which specifies the remuneration of  the Board of Directors and Executive Manage-  ment. The Remuneration policy as well as the  committeeâs terms of reference are available  on NORDENâs website. During the year, the  committee held four meetings with 100% attend-  ance.  Nomination Committee  The Nomination Committee consists of:  ⢠Klaus Nyborg (Chair)  ⢠Johanne C F Riegels  The committee is responsible for describing the  qualifications required in the Board of Directors  and the Executive Management. The committee  is also in charge of an annual assessment of  the competences, knowledge and experience  present in the two management bodies. The  committeeâs terms of reference are available  on NORDENâs website. During the year, the  committee held seven meetings with 100%  attendance.  </mrv:CorporateGovernanceReport>
<mrv:SustainabilityReport contextRef="ctx2" id="fact1327" xml:lang="en">ESG IN NORDEN  As a global provider of ocean-based freight  services and logistics solutions, NORDEN has  a pivotal role in shaping a more sustainable  future. Our ESG efforts emphasise our dedication  to addressing the critical challenges and  opportunities in environmental leadership, social  responsibility and corporate governance.  Environmental, Social and Governance (ESG) activities are  embedded in NORDEN's overall business strategy and purpose of  enabling smarter global trade. Based on our ESG efforts and ambi-  tions, we have a unique opportunity to push forward the develop-  ment and improvements of our industry.  While we focus on all aspects of ESG, our most significant concern  is our environmental impact due to the urgent global decarbonisa-  tion challenge. With shipping responsible for approximately 3% of  global carbon emissions, our industry has a responsibility to act and  reduce its climate impact.  E: Delivering on the decarbonisation agenda  In terms of the environmental agenda, NORDEN has an ambition to  reach net-zero emissions by 2050, supported by our medium-term  target of a 16% reduction in energy intensity (EEOI) by 2030  compared to FY 2022 as baseline, equivalent to a 2% average reduc-  tion per year. Since 2022, we have improved our EEOI by 14% and  are thus well on track to reach our medium-term target.  In the short term, NORDEN contributes to reducing environmental  impact by offering low emission freight products and services and  providing transparency on emission outputs to our customers.  Throughout the year, we have continued the focus on our four  climate initiatives: voluntary speed reductions, CO2-based hull clean-  ings, using the most energy-efficient vessels and investing in fuel  transparency. Looking ahead, we are focused on developing sustain-  able shipping solutions and investing in new vessels equipped with  emission-reducing technologies, aiming to achieve our net-zero  emissions target by 2050.  Biofuels will be an important part of the solution for developing the  sustainable solutions of the future. With our investment in the biofuel  company Mash Makes in 2023, NORDEN has secured future access  to low emission fuels - an important step in our ambition to help our  customers decarbonise their supply chains. Through our partnership  with Mash Makes, we conducted the first successful engine trials in  2024.  In 2024, NORDEN was the first company to conduct a 100% biofuel  bunkering on board a vessel in Singapore, showing that the demand  for biofuel is materialising with customers. Furthermore, we also  entered into jupitea partnership with the global mining company  BHP, where NORDEN replaced fossil fuels with approximately  1,000 tonnes of 100% biofuel on a voyage between Australia and  Rotterdam.  During the year, we also experienced increased interest in our  carbon insetting solution, Book &amp; Claim, where we entered into an  agreement with Meta in which they pay for biofuels being burnt on  NORDEN-operated vessels. Our Book and Claim system tracks and  allocates the associated carbon reductions to the customer, allowing  them to purchase and track the benefits of biofuel emissions reduc-  tions even when not available for their cargo's voyage.  S: People is our most important resource  NORDEN is a people and value-driven company and continuously  work on strengthening our position as an attractive workplace,  offering an inclusive and engaging working environment in which all  employees have equal opportunities for realising their potential.  An inclusive, diverse and equal culture where people are encour-  aged to be open about their viewpoints creates an organisation  where people feel respected, included and motivated.  By measuring engagement, turnover and retention rates, as well as  the age and representation of the least represented gender across  organisational levels, we continuously gather insights on areas for  improvement.  Another key priority for NORDEN is setting high standards for health  and safety in our value chain. Operating at sea involves safety and  security risks that must be managed carefully to safeguard the  crew and external personnel. Outsourcing technical management  and upholding a service that complies with NORDENâs stand-  ards requires a close, continuous dialogue and a comprehensive  reporting framework.  Enhancing the health and well-being of seafarers directly corre-  lates with improved performance on vessels and success in both  recruiting and keeping talented workers. To maintain excellent  working conditions, NORDEN has implemented an Technical  Manager Code of Conduct and a HSEQ (Health, Safety, Environment  and Quality) framework to further guide our collaboration with third-  party managers. This framework helps ensure that all our partner-  ships meet high standards within safety, well-being of employees,  sustainability and environmental protection.  G: Trust is a key component of our business  Being a global company that operates in regions where concepts of  integrity and good business ethics vary, it is critical for NORDEN to  strive to uphold the highest standards for business conduct in our  operations and ensure transparent and ethical business practices  through a strong focus on anti-corruption and bribery, sustainable  procurement and human rights.  Corruption and bribery have severe consequences for sustain-  able development. It leads to weak institutions, hinders economic  growth and potentially endangers the health and safety of  employees. To maintain a strong zero-tolerance culture in regards  to bribery and corruption, all employees are required to acknowl-  edge and sign the Employee Code of Conduct, and all suppliers  are requested to sign the Supplier Code of Conduct, which outlines  the ethical, social and environmental standards that all employees  and suppliers are expected to follow. Furthermore, all employees  are required to complete anti-corruption and sanctions e-learning  courses once a year. During the year, all eligible employees passed  the courses.  In 2024, NORDEN launched a new reporting tool of unethical  requests covering all of NORDENâs operated fleet. This enables us  to monitor requests for facilitation payments globally with reporting  from all port visits and transits which give insights to current risks,  development in the risk landscape and the effectiveness of the  programme, strengthening our mitigation plans and how we ensure  the prevention of future corruption incidents.  In 2024, NORDEN also conducted a Human Rights Impact Assess-  ment that gave us added insight into our human rights risks across  the organisation and value chain. We conducted our first Human  Rights Impact Assessment in 2015 and have repeated this assess-  ment every two years since.  ESG initiatives for 2025  Looking into 2025, we will continue our climate, decarbonisation  and biofuel initiatives based on the commercial breakthrough with  our low-emission contracts and Book &amp; Claim offerings which have  gained increased interest from customers across industries.  Furthermore, we will continue to focus on developing an engaging  and inclusive working environment and increasing the share of the  underrepresented gender in all levels of the organisation.  A leadership programme, Leadership Essentials, was launched in  2024. This programme is developed to define what good leadership  looks like and to build a shared language and leadership culture  across NORDEN. In 2025, all managers across levels will undergo  training in translating the Leadership Essentials into everyday behav-  iour and decision-making.  In addition, NORDEN will finalise the adaption to report in  conformity with the European Sustainability Reporting Standards  (ESRS), ensuring that we comply with regulatory reporting standards  ensuring trust, transparency and comparability.  Norden's material topics and monitoring indicators  Sustainability priorities  ESRS section  Material topics  Monitoring indicators  2024  2023  2022  Ambitions  Environmental  E1 Climate Change  Efficient operation of our vessels TTW EEOI on all assets (reduction vs. baseline)  8.5 (14%)  9.0 (10%)  9.9 (NA)  Reduce 16% by 2030 on 2022 baseline  Enabling our customers  to decarbonise their  Total CO2e emissions from scopes 1 &amp; 2 ('000 ton) ¹  4,397  3,835  4,287  Reduce GHG emissions to net zero by 2050  Decreasing value  supply chains  Social  S1 Own Workforce  Overall engagement score  84  84  83  &gt; Index 80 by 2025  Offering an inclusive,  engaging, equal and  Diversity (share of least represented gender)  39%  41%  40%  Min. of 40% share of least represented gender  Diversity, Equity  safe working  &amp; Inclusion  environment  Diversity in Management (share of least represented gender)  38%  38%  37%  Min. of 40% share of least represented gender  Retention rate / Employee turnover  90% / 13% 94% / 15%  94% / 9%  &gt; 90% retention rate  S2 Workers in Value Chain  Health &amp; Safety  LTIR  1.3  1.0  0.8  &lt; 0.8  Governance  G1 Business Conduct  Sustainable Procurement  Suppliers screened for ESG (%)  68%  55%  NA  75% strategic suppliers by 2026  Galvanising sustainable  business conduct  Staff completed e-learning course  100%  100%  99%  100% e-learning completed  Anti-corruption  and bribery  The total number of corruption or bribery incidents  0 0 0 0 at all times  ¹ Location-based scope 2  CASE STORY  Initial biofuel tests off to a great start  In 2023, NORDEN invested a minority stake  in the Danish-Indian biofuels scale-up Mash  Makes, which researches and develops biofuel.  The investment is a strategic partnership, where  NORDEN secures access to renewable fuels,  specifically biooil, at favourable pricing. The  partnership places us at the forefront of the  research and development of future renewable  fuels, where we can also benefit from future  renewable biooils once developed.  In 2024, we conducted the first successful engine  lab trials with the biofuel together with Mash  Makes.  The partnership between NORDEN and Mash  Makes is proof that collaboration is key for  developing the sustainable fuel sources of the  future and the success of the trial is a testament to  the commercial potential.  Towards the end of the year, the initial lab trials  led to the first biofuel trials on board an actual  vessel. The trials will be running on an ongoing  basis in 2025.  ENVIRONMENTAL  Maritime shipping is the most carbon-efficient  method for transporting goods, emitting  significantly less CO2 per tonne-mile compared  to trucks, trains or airplanes. However, shipping  transports almost 90% of global trade and,  given the vast size, the industry contributes to  approximately 3% of global CO2 emissions. Hence,  despite being the most sustainable choice for  transportation, the industry still has a responsibility  to continuously work on reducing its climate  impact.  NORDEN has an ambition to be on the frontier of this change, and  we are dedicated to helping customers decarbonise their supply  chains. Our commitment extends beyond our operations as we  actively contribute to innovating solutions through collaborations  in industry organisations and exploring opportunities within the  upstream production of sustainable fuels.  To concentrate our environmental efforts and maintain transparency  and progression, we have identified two key topics within NORDENâs  environmental agenda: the efficient operation of our vessels and the  reduction of emissions across the value chain. The strategies and  goals within these topics are closely linked to our long-term target of  reaching net-zero emissions by 2050 and our medium-term target of  reaching a minimum 16% reduction in emissions by 2030.  To reach these targets, we work proactively with developing more  sustainable shipping solutions such as our carbon insetting solu-  tion, Book &amp; Claim, and offering voyages powered by low emission  biofuels. Furthermore, we provide carbon emissions transparency  through pre and post voyage emissions reports and pledge that, by  2030, all new vessel orders made by NORDEN will be equipped with  zero-emission technology.  Our ambitions and goals are not just about meeting regulatory  requirements or industry standards; they reflect NORDENâs commit-  ment to environmental leadership and our proactive role in shaping  a more sustainable future for global shipping.  ESRS E1 Climate Change  Impacts, risks and opportunities  Governance  Our governance model closely aligns executive remuneration with  progress in reducing emissions and increasing efficiency, dedicating  15% of Executive Management's compensation to sustainability  objectives. This incentive structure is linked to critical metrics such  as improving emission efficiency (EEOI), enhancing workforce  engagement and promoting diversity. These KPIs support our stra-  tegic commitment to achieving net-zero emissions by 2050, fostering  a transition to zero-carbon shipping and delivering on our strategic  objective to decarbonise our customerâs value chain.  NORDEN's transition plan is integrated into the overall business  strategy and financial planning, focusing on enabling customers to  meet their decarbonisation commitments.  Management is responsible for upholding NORDENâs risk manage-  ment policy and for overseeing and discussing strategic risks and  opportunities. NORDENâs risk profile and exposure are reported  to the Board of Directors regularly. Internally, our Risk Committee  assists the Board of Directors with its oversight of the Groupâs  overall risk-taking tolerance and management of market, credit and  liquidity risks as well as climate-related risks. Our Decarbonisation  team makes proposals as to how these opportunities and risks can  be linked to the commercial business. Our Audit Committee iden-  tifies and manages risks related to financial reporting and auditing,  among others. The transition plan has received full approval from  NORDEN's Board of Directors and is overseen by the ESG Execu-  tive Body, emphasising strong organisational commitment. In the  reporting period, NORDEN has reported a 6% improvement in EEOI.  Strategy  In alignment with the 1.5°C target of the Paris Agreement, NORDEN  has articulated a transition plan aimed at achieving net-zero emis-  sions by 2050 and a 16% reduction in the Energy Efficiency Oper-  ational Indicator (EEOI) by 2030, which is equivalent to an average  short-term reduction in EEOI of 2% per annum.  In the short-term, we are continuing our four climate initiatives,  which are all crucial tools in reaching our climate goals:  ⢠Voluntary speed reduction: Proactively reducing vessel speeds  beyond profit/loss considerations for emissions reduction.  Using the most energy-efficient vessels: Increasing usage of the25% most energy-efficient vessels in the world, to improve fleet  emissions performance.  surveys to ensure fuel quality and efficiency.  decreases resistance and enhances fuel economy.  Additionally, NORDEN offers tailored low emission freight solu-  tions to our customers and we have in 2024 increased our focus on  biofuels. Depending on a customerâs needs, NORDEN can develop  freight solutions enabling emission reduction of up to 85% by a well-  to-wake approach.  In the short- to medium-term, we consider our Book &amp; Claim system,  the strategic partnership with the Mærsk McKinney Møller Center  for Zero Carbon Shipping and the investment in Mash Makes as  key levers for our ambition to reduce EEOI by 16% by 2030. Book  &amp; Claim is a carbon insetting system that enables direct reduction  of GHG emissions within the industry in which they are generated.  Carbon insets supports demand for low-carbon fuel and thus  contributes to financing and accelerating the decarbonisation of the  industry. Carbon insetting addresses this challenge by providing a  mechanism allowing us to disconnect the physical burning of biofuel  onboard our vessel from the customer purchasing and claiming the  associated emissions reduction. Through this mechanism, carriers  such as NORDEN can operate on low emission fuel where possible  in the fleet and offer an emission reduction solution to all our  customers at a competitive price, regardless of their trading routes  and other constraints that would prevent them from being serviced  directly on low-carbon fuels. Currently, the supply of low-carbon  fuels such as biofuel is limited both in terms of production and  geographical availability. This means that it is not possible to offer  biofuels on the same conditions to all our customers looking to  reduce maritime emissions within their supply chains. Therefore,  carbon insetting is a vital component of delivering emission reduc-  tion in the short and medium term.  In the long term, NORDEN will be exploring the production of  alternative biofuels like ammonia or methanol to eventually provide  CO2e-neutral freight services, highlighting our commitment to  pioneering sustainable shipping solutions.  Risks and opportunities  NORDEN's process for identifying and assessing climate-related  physical and transitional risks is conducted by an in-house team of  commercial and environmental specialists. This team thoroughly  Achievements &amp; initiatives 2024  ⢠Reduced our EEOI by 14% since 2022.  ⢠Conducted the first ever 100% biofuel bunkering in the port of  Singapore on board a NORDEN vessel.  ⢠Conducted the first commercial trial of biofuel onboard a vessel  together with Mash Makes.  ⢠Entered into a partnership with BHP under which NORDEN  supplied 1,000 tonnes of 100% biofuel used on a voyage  between Australia and the Netherlands.  ⢠Signed an agreement to assist several customers in lowering  their emissions through NORDENâs emissions reduction solu-  tion, Book &amp; Claim.  evaluates potential transitional and acute risks associated with  climate-related scenarios, specifically, the RCP 1.9 and RCP 8.5 path-  ways. These scenarios reflect a spectrum of possible future climate  outcomes, from more optimistic low greenhouse gas concentration  trajectories to high-emission scenarios. Based on the risk analysis,  the team formulates mitigation actions to manage identified risks  and leverages opportunities to enhance the company's resilience.  This includes incorporating weather routing systems, diversifying  business activities, and investing in low emission technology. The  team also explores opportunities arising from the transition to a  low-carbon economy, such as the development of new low emission  products or services, or improvements in operational efficiency.  The company recognises that while its agile operator model typically  shields it from significant impacts of physical climate risks, under the  RCP 8.5 scenario, the increased frequency and intensity of extreme  weather events could lead to higher risks of damage to vessels  and cargo, potentially eroding margins. To mitigate these risks,  NORDEN is relying on extensive use of weather routing systems for  pricing, securing comprehensive insurance coverage, and carefully  assessing freight contracts for chronic risks.  As the maritime industry evolves rapidly with technological inno-  vations, particularly in fuel sources and vessel efficiency, there is  an inherent risk of our assets declining in value. This devaluation is  a direct consequence of the transition towards low-emission tech-  nologies and could potentially lead to assets becoming stranded  before the end of their useful life. NORDEN operates an asset-light  fleet strategy, which mitigates this risk. This approach enhances our  agility and flexibility, allowing us to adapt more readily to techno-  logical advancements and market shifts without incurring significant  losses on asset value. By being an operator of assets, we mitigate  the financial risk of declining asset prices that are tied to older, less  efficient technologies.  In the table overview on page 52, we list key transitional and physical  risks for NORDEN alongside mitigation actions and opportunities  arising from these risks based on our analysis.  Climate change mitigation policy  As of 2024, NORDEN has adopted a climate change mitiga-  tion policy. The climate change mitigation policy articulates our  approach to mitigating the risks of climate change by reducing EEOI  by 16% by 2030 and being net zero by 2050.  Metrics &amp; targets  Decreasing value chain emissions  As part of our ambition to decarbonise our customersâ supply chains,  NORDEN aims to be carbon neutral by 2050. This is aligned with the  climate ambitions outlined by the Danish governmentâs climate part-  nership with the Danish maritime sector of achieving carbon neutrality  by 2050. Providing transparency is the first step towards decreasing  value chain emissions, mapping the full extent of our GHG emissions  and focusing on the ones on which NORDEN has a material impact.  We apply a materiality threshold to our scope 3 categories to ensure  focus on material sustainability topics. If any category is estimated to  contribute less than 1% to the total scope 3 emissions, it falls below  our materiality threshold and is deemed immaterial for external  reporting purposes. In line with this approach, although relevant,  the following GHG Scope 3 categories have been determined to be  âmaterialâ, ârelevant, but not materialâ and ânot relevant or materialâ:  Transitional risks  Mitigating risks  Opportunities  Policy &amp; Legal  ⢠Implementation of new regulation which impacts NORDEN  ⢠Decreasing residual value risk by shifting exposure to operator  ⢠Asset-light operator model and ablility to quickly shift market  more negatively than competitors.  activities and being less dependent on the owned fleet.  exposure and navigate new legislation.  ⢠Failure to comply with reporting and compliance regulations  ⢠Monitoring policy, legal and regulatory sustainability  ⢠Offering regulatory and carbon tax services to third parties in  (ESRS, EU Taxonomy &amp; CII).  landscapes.  the NORDEN tanker pool.  Technology  ⢠Accelerated decline in value of existing assets due to  ⢠Actively testing and operating zero-emission ships, investing  ⢠Agile model allowing NORDEN to perform relatively well  technological innovation, e.g. fuel sources and vessel efficiency.  in R&amp;D related to low-carbon fuels and, from 2030, only order  compared to our peers.  ships with zero-emission technology.  ⢠Offering innovative and sustainable freight solutions to our  ⢠Investing in data analytics to keep developing market-leading  customers.  operational systems.  Market  ⢠Declining demand for seaborne transportation services driven  ⢠Diversification of business activities.  ⢠Increasing market share through stronger branding and  by lower demand for fossil fuel products and higher marginal  ⢠Providing low emission freight options by working with our  superior offering.  costs (fuel costs, carbon tax, capital costs).  partners to co-create sustainable shipping solutions.  ⢠Empowering our customers to reduce their CO2e emissions by  ⢠Premature investments in low emission freight products not  ⢠Securing long-term alternative fuel supply contracts.  offering low emission alternatives competitive with the price of  aligned with market demands.  carbon.  ⢠Increasing funding cost and/or potential lack of funding  Providing logistic solutions supporting a circular economy.  availability for activities not aligned with sustainable investment  Book-and-claim offering.  demands (e.g. the EU Taxonomy, Poseidon principles and SBTi).  ⢠Insufficient supply of alternative fuel sources.  Reputation  ⢠External stakeholdersâ perception of NORDENâs climate  ⢠Support industry-wide research within new forms of propulsion,  ⢠Delivering net-zero emissions from our operations by 2050.  footprint and initiatives.  low emission fuels and eFuels with Mærsk McKinney Møller  ⢠Becoming an industry leader in helping customers decarbonise  ⢠Unable to attract and retain talented employees with high  Center for Zero Carbon Shipping.  their supply chains.  decarbonisation ambitions.  ⢠New and ambitious climate strategy.  ⢠Improving transparency of emissions reporting.  Physical risks  Acute  ⢠Margin erosion due to more frequent extreme weather events  ⢠Extensive use of weather routing systems when pricing and  ⢠Leveraging our use of data to improve predictions and decision-  (e.g. drought or storm).  assessing the risk of freight contracts.  making.  Chronic  ⢠Scarcity of water, impacting trade patterns and volumes.  ⢠Including the impact of chronicle risks when evaluating business  ⢠Expansion of logistics offerings to non-core activities via Assets  ⢠Rising sea levels, impacting port operations and trade patterns.  opportunities.  &amp; Logistics business unit.  EU Taxonomy  NORDEN has decided to report in  accordance with the EU Taxonomy, which  is intended to provide transparency on  what is considered eligible and aligned  with environmentally sustainable activities.  Taxonomy eligibility and alignment are expressed  through three KPIs:  Turnover, capital expenditure (CapEx) and operating expendi-  ture (OpEx). NORDEN has Taxonomy-eligible activities within the  'Sea and Coastal Freight Water Transport, Vessels For Port Oper-  ations, and Auxiliary Activities' category, based on the compa-  nyâs turnover, CapEx and OpEx. NORDEN has aligned activities  within turnover and CapEx, but not within the OpEx KPIs. The EU  Taxonomy tables for all KPIs are located on p. 82. Please refer to  the ESG accounting policies related to the EU Taxonomy for the  methodology behind our eligibility alignment assessment.  Turnover:  Taxonomy-eligible revenue is 79% for 2024, while Taxonomy-  aligned revenue is 0% (rounded) for 2024.  Capital expenditures:  Taxonomy-eligible CapEx is calculated to be 100% for 2024,  while Taxonomy-aligned CapEx is 0% for 2024. NORDEN does  not have any technically aligned CapEx plan, but this is to be  considered within the coming years.  Operating expenditures:  Taxonomy-eligible OpEx is 75% for 2024, while Taxonomy-  aligned OpEx is 0% for 2024.  GHG scope 3 categories  GHG number  Material  Purchased goods and services  1 Capital goods  2 Fuel- and energy-related activities  3 Upstream transportation and distribution  4 Downstream leased assets  13  Relevant, but not material  Waste generated in operations  5 Business travel  6 Employee commuting  7 Investments  15  Not relevant or material  Upstream leased assets (reported in scope 1)  8 Downstream transportation and distribution  9 Processing of sold products  10  Use of sold products  11  End of life treatment of sold products  12  Franchises  14  Our total GHG scope 1, 2 and 3 CO2 -equivalent emissions were  7.9m tonnes â an increase of 0.4m tonnes compared to 2023. Scope  1 CO2e emissions have increased by 15% year-on-year, while scope  3 CO2e emissions have decreased by 5% year-on-year, driven by an  increasing share of vessels being operated by NORDEN, while fewer  vessels have been on time-charter out. Given our target of net-zero  by 2050, we must reduce emissions by 3.7% on an annual basis from  2022 levels to realise this ambition.  CO2e emissions  ('000 tonnes)  2024  2023  2022  % Scope 1 GHG emissions  4,397 3,834  4,287  15%  Scope 2 GHG emissions  0.5  0.4  0.4  25%  Scope 3 GHG emissions  3,499  3,693  3,826  -5%  - GHG 1: purchased goods and services  147  187  266 -22%  - GHG 2: capital goods  5 18  6 -15%  - GHG 3: fuel and energy-related activities  900  823  904  9%  - GHG 13: downstream leased assets  2,448  2,665  2,650  -8%  Total GHG emissions  7,896  7,528  8,113  5%  Efficient operation of our vessels  Efficient operation of vessels is an integral part of NORDENâs oper-  ator business model. We monitor the fuel efficiency of vessels using  the EEOI measure. On NORDENâs owned and operated vessels, we  continuously monitor fuel efficiency, determining optimal speeds  in EEOI is supported by continued weak markets in Dry Cargo and  Tankers making lower speeds more attractive compared to baseline  period.  In the table below, we have summarised performance from 2023 to  2024 of the key metrics that drive the development in EEOI:  Energy consumption and mix  Perceiving energy consumption as a material sustainability impact,  NORDEN reports on development in fuel consumption from crude  oil and petroleum products, fuel consumption for renewable sources  and energy intensity in conformity with the ESRS. By monitoring  these metrics, NORDEN aims to create transparency on the share of  fuel consumption from renewable sources, allowing stakeholders to  see progress on a medium and long-term basis.  Furthermore, it allows stakeholders to distinguish between reduc-  tions being created by operational decisions like reduced speeds  or customers being willing to pay for low emission freight solutions,  which is seen in an increasing share of renewable fuel consumption.  Finally, we report on the share of heavy fuel oil (HFO) in our fuel  consumption to provide transparency on whether reductions in air  pollutants are driven by a lower share of HFO, having high emission  factors for pollutants like SOX and PM2.5, further outlined in the ESRS  index on page 83.  NORDENâs fuel consumption from renewable sources increased  from 19,790 MWh in 2023 to 42,140 MWh in 2024. This corresponds  to 0.3% of NORDENâs fuel consumption on our operated vessels.  During the reporting period, NORDEN entered into a biofuel agree-  ment with BHP, which entails the burning of approximately 1,000  tonnes of B100 biofuel.  Additionally, we are experiencing good traction on our carbon  insetting solution to support the decarbonisation of our customersâ  supply chains by bridging emission reductions made on NORDENâs  biofuel voyages with customers looking to reduce emissions. Since  the supply of low-carbon fuels such as biofuel is limited both in  terms of production and geographic availability, the system provides  an option for customers willing to pay to reduce emissions, who have  previously been limited by trading routes. Being able to offer this  solution to our customers, we are expecting an increasing share of  renewable fuel consumption in the short to medium term.  Metric  2024  2023  Fuel consumption from crude oil and petroleum  products  15,844,670 13,861,565  Fuel consumption for renewable sources  42,140  19,790  Energy intensity  254  266  ESRS E2 Pollution  Impacts, risks and opportunities  Maritime shipping, while efficient in terms of CO2 emissions relative  to the distance and weight of goods transported, presents multi-  faceted environmental challenges. The varied nature of vessels,  their cargo, fuels and materials renders them complex entities  with a broad environmental footprint that spans both air and water  ecosystems. In terms of pollutants, vessels, through combustion and  energy transformation for propulsion and power, emit a mix of air  pollutants. The primary ones include sulfur oxides (SOX), nitrogen  oxides (NOX) and particulate matter (PM). In addition, although less  prevalent, vessels emit non-methane volatile organic compounds  (NMVOCs) and heavy metals (HM) into the air. These emissions are  particularly concerning in high-traffic maritime areas and can travel  great distances, affecting communities and regions far from the  source. Efforts to regulate and reduce such emissions have led to  a sustainability trade-off. The implementation of scrubbers to cut  SOX emissions, for example, has resulted in an increased release of  pollutants into the sea through wash water from scrubbers. While  striving to curb high sulfur bunker fuel use without scrubbers, these  Material topics, metrics and targets  Pollution to air  Perceiving air pollution to be material, NORDEN monitors and  reports on emissions of nitrogen oxides (NOX), sulfur oxides (SOX),  particulate matter (PM2.5/PM10), NMVOC and HM in air, which are  significant air pollutants associated with maritime transport. These  emissions largely originate from the combustion processes within  vessel engines and are a direct consequence of the fuels used. A  breakdown of the development by air pollutant types can be found  in the table below:  Pollution to water  NORDEN reports the emissions of HM and polycyclic aromatic  hydrocarbons (PAHs) into the water. These pollutants stem from the  operation of vessels having installed open-looped scrubbers. Scrub-  bers are systems installed on vessels to reduce the sulfur content in  exhaust gases by spraying seawater into the exhaust stream.  In the reporting period, NORDEN operated 94 vessels with open-  looped scrubbers corresponding to 18% of the total vessels oper-  ated. Total pollutants in water have increased from 30 metric tons in  2023 to 64 metric tons in 2024. Heavy metals in water have increased  from 29 metric tons in 2023 to 62 metric tons in 2024, while PAHs  have increased from 1 metric tons in 2023 to 2 metric tons in 2024.  The change is driven by more scope 1 voyages and a larger share of  vessels with open-looped scrubbers.  In addition to the pollutants above, NORDEN tracks the ecological  impact of our operations through the performance indicators from the  SASB Marine Transportation Standard, including spills. Development  in performance indicators can be found in the SASB table on page 82.  NORDENâs EEOI framework  NORDEN uses the EEOI metric as a performance indicator for fuel efficiency. EEOI measures the  relationship between CO2 emissions from bunker fuel consumption and transport work (tonne-  nautical miles). NORDEN reports three different versions of EEOI:  1. TTW all assets: For the entire fleet including TCO vessels  and based on TTW emissions only.  2. TTW operating assets: For the operated fleet excluding  TCO vessels and based on TTW emissions only.  3. WTW operating assets: For the operated fleet excluding  TCO vessels and on a well-to-wake (WTW) basis, i.e.,  including upstream emissions related to the extraction,  processing and transportation of bunker fuel for our  vessels. This measure is presented on a CO2 equivalent  basis.  NORDEN's primary measure is the TTW EEOI all assets  presented on a fleet-adjusted basis. NORDEN has divided  EEOI into the main drivers that affect performance as this  allows NORDEN to follow developments in the indicator on a  more granular level. CO2 emission drivers are split into speed  and bunker type, while transport work drivers are determined  by cargo utilisation, laden utilisation and fleet composition.  The relationship between EEOI and the drivers listed is  described as:  ⢠Bunker type: EEOI is impacted by the WTT and TTW CO2e  emissions related to the bunker type. Increasing the share  of biofuel would decrease emissions and thereby EEOI.  Cargo utilisation: Measures the utilisation of cargo capacityduring a voyage. Cargo hold utilisation is a number  between zero and one. Higher cargo utilisation would  increase transport work and fuel consumption as more  energy is required for propulsion at a given speed with  more cargo. The effect of increasing cargo utilisation is a  decreasing EEOI.  and total miles. Laden miles are miles, where the vessel  carries cargo. Transport work is calculated as the product  of nautical miles and cargo carried. Holding everything else  constant, higher laden utilisation would increase transport  work and decrease EEOI.  sition. To make EEOI more comparable, NORDEN reports  performance across vessel types and outlines the fleet-ad-  justed EEOI, enabling a more transparent explanation of  variations in the performance indicator year-on-year.  ESRS E4 Biodiversity &amp; ecosystems  Impacts, risks and opportunities  Our operations impacts biodiversity and ecosystems directly by poten-  tially introducing non-indigenous species (NIS), contributing to under-  water noise and sailing through marine-protected areas, and indirectly  by emitting GHG emissions leading to changes of ecosystems. While  being aware of the impacts of our operations, it remains challenging to  fully identify, assess and quantify the severity of the impacts.  We have identified the risk of introducing NIS as a material topic  due to the scale of the impact. NORDEN does not have any policies,  metrics or targets for the topic, but we are focused on reducing the  likelihood of the impact by performing regular hull cleanings and  applying best-in-class anti-fouling paint on owned vessels and on  some key partner vessels.  Additionally, NORDEN reports on the number of vessel days in  Marine Protected Areas (MPA) in the SASB Marine Transportation  Index. We do not have any policies or targets for this metric.  Biodiversity policy  NORDEN is following the industry standard enforced by the IMO.  This approach ensures that we remain aligned with the best avail-  able practices while we await regulation from policymakers. Not  complying with the regulation of the IMO may lead to financial  penalties, while potentially hurting business relationships by not  demonstrating commitment to environmental compliance. Both are  considered material financial risks.  CASE STORY  Using carbon insetting to help customers  decarbonise their supply chains  To assist Meta with its ambition to lower its emissions,  NORDEN and Meta entered into an agreement to under  which Meta was pay for biofuel and track the associated  emissions reductions through NORDENâs emissions  reduction solution, Book &amp; Claim.  NORDENâs Book &amp; Claim solution works by NORDEN  burning biofuel on a NORDEN-operated vessel and  the emission reduction being allocated to a third-party  customer, in this case Meta, using a book and claim  chain of custody system.  âOur Book &amp; Claim solution allows customers  of marine transportation across the globe to  take advantage of emissions reductions from  biofuels, even when biofuels are not physi-  cally available to be bunkered on a specific  trading route or voyage.â  Anne Jensen, COO of Assets &amp; Logistics  The solution is developed to enable NORDENâs direct  customers and clients in other industries which are  dependent on marine transportation and seeking to  decarbonise their supply chains to credibly invest in  maritime decarbonisation.  SOCIAL  NORDEN is a people and value-driven  organisation guided by our purpose of enabling  smarter global trade. We continuously work to  strengthen our position as an attractive workplace  through promoting a diverse, inclusive, engaging,  healthy and safe working environment, in which  all employees have equal opportunities to realise  their full potential.  As a people-driven business, we are focused on fostering an inclu-  sive culture that values everyoneâs contributions, promotes equality  and diminishes safety risks. To create a foundation for such culture,  we are proactively working with pivotal aspects such as Diversity,  Equity &amp; Inclusion (DE&amp;I) within our offices and Health &amp; Safety  across our value chain.  ESRS S1 Own workforce  Impacts, risks and opportunities  NORDEN has identified promoting DE&amp;I as a key area of importance  within the social segment of our own workforce. Embracing DE&amp;I  is not just about fairness and ethical responsibility; it is business  critical. In this context, the shipping industry's historical male domi-  nance presents both a challenge and an opportunity for NORDEN  as we consider that driving the diversity agenda is a missed oppor-  tunity in our industry today. Diverse teams and an inclusive culture  with equal opportunities bring varied perspectives, experiences  and ideas, which are critical in a dynamic and globally intercon-  nected industry. By improving DE&amp;I figures, we are not only setting  a progressive example but also enhancing our potential problem-  solving abilities and overall operational performance.  It is vital to safeguard our strong, value-driven culture where we  strive to retain and develop our employees, maintain a high level  of well-being and engagement and attract a diverse range of new  employees. Sustaining a work environment where diverse employees  continue to thrive, have equal career development possibilities and  are motivated is essential for maintaining long-term success.  We carry out ongoing social impact discussions through our ESG  Executive Body in collaboration with in-house topic specialists. Our  ambition is to improve engagement, diversity and retention metrics,  since it, in our view, is a clear link between improving DE&amp;I and  organisational performance.  NORDENâs workforce is crucial to our success. A lack of diversity,  inclusiveness and equality among employees may significantly  impact their satisfaction. To address these risks, we regularly  monitor workforce metrics, encourage open communication and  implement policies that foster a sustainable culture.  There are opportunities related to fostering a diverse and inclu-  sive culture focused on equality as it enables great organisational  performance and allows us to attract and retain high-performing  employees. By investing in these areas, we aim to not only mitigate  risks but also to create a resilient and agile organisation capable of  adapting to changing market demands and sustaining a competitive  edge in the maritime industry. By promoting a sustainable culture,  NORDEN is likely to maintain the position of an attractive workplace  for new talent and strengthen our ability to retain and develop  employees, reducing the costs of hiring and integrating replace-  ments.  NORDEN has articulated several policies to address and mitigate  the risks related to the material topics, some of which are listed here:  https://norden.com/about/governance/policies-and-charters. All  relevant policies are described on page 80.  Diversity, Equity &amp; Inclusion  As a people and value-driven business, NORDEN considers diversity  a strength, and we actively work to ensure DE&amp;I in our organisation.  We aim for an organisation, where DE&amp;I accelerates our purpose of  enabling smarter global trade through diversity of gender, nation-  ality, age, work experience, educational background and other  attributes. We want to achieve this by harnessing all employeesâ  unique contributions into our operational foundation through  opening for different viewpoints and ways of thinking.  In total, NORDEN employees represented 52 different nationalities  in 2024, and the percentage of non-Danish employees has risen  from 57% in 2023 to 59% in 2024. Cross-cultural understanding and  respect are crucial in a multicultural environment, wherefore we in  2024 conducted training sessions on how to foster a strong feedback  culture, effective collaborations and unlock the potential of psycholog-  ical safety for all employees and managers.  In NORDEN, we aim to create a diverse management across our  managerial levels ranging from managers to the Board of Directors.  The members of NORDENâs Board of Directors cover a wide range  of competencies and experiences within international shipping,  finance, investment, strategy, digitalisation and risk management,  from both Danish and international businesses. This combination is  considered desirable as it ensures a broad approach to tasks and  contributes to ensuring qualified governance of NORDENâs stra-  tegic direction. Likewise, gender balance across managerial levels is  desirable and pursued on an ongoing basis in NORDEN, as part of  ensuring a diverse range of management skillsets and composition,  while promoting equal opportunity across NORDENâs organisation.  Our structured recruitment process empowers managers to  promote equality and broaden opportunities for both candidates  and existing employees. This includes seeking managerial candi-  dates with diverse backgrounds beyond shipping and actively  mitigating potential biases in the hiring process. This ensures that  NORDEN recruits based on qualifications, potential to develop and  ability to deliver on our strategy. Additionally, NORDEN has consist-  ently worked on increasing awareness of including candidates  of underrepresented genders in the recruiting process and has  assessed our promotion process to strengthen equal opportunities  for all employee groups.  NORDEN aims for a gender balance of a minimum of 40% of the  underrepresented gender across all levels which leaves up to 20%  flexibility for female, male and non-binary genders, recognising  that some employees may not wish to be categorised. The gender  balance in Executive Management and on the Board of Directors  remained unchanged in 2024. On the Board of Directors, share-  holder-elected women represented 33% (two out of six) of the  Board members in 2024. This gender balance does not yet meet  NORDEN's target of having a minimum of 40% shareholder-elected  female board members in 2025. To achieve this objective, we will  continue the search process in 2025, with the aim of aligning the  ratio of female board members with our objective by 2026. The  share of women in managerial positions in NORDEN was 38% in  Achievements &amp; initiatives 2024  ⢠Screened for DE&amp;I imbalances in our organisation through our  Engagement and Harassment Survey with the purpose of evaluating  the perception of DE&amp;I across age groups, gender, locations and  levels.  ⢠Launched a leadership development programme designed  to develop manager traits crucial for successful leadership in  NORDEN.  ⢠Re-introduced our trainee programme in collaboration with Danish  Shipping ensuring an ongoing strengthening of our talent pipeline.  ⢠Used the Womenâs Empowerment Principlesâ Gender Gap Anal-  ysis Tool to outline opportunities for improving performance on  gender-related topics and received a higher score than in 2023.  ⢠Implemented an HSEQ Framework including Life-Saving Rules and  established an audit programme for Technical Managers.  ⢠Conducted inspections onboard our vessels, visited technical  management offices and attended crew seminars assessing safety  approaches and general well-being of crew members.  ⢠Introduced a Service Level Agreement (SLA) to our Technical  Manager on the GABON project with the aim of aligning require-  ments and expectations on daily technical and operational matters,  fostering stronger collaboration and cooperation.  2024, unchanged compared to 2023. NORDEN aims to increase this  share to at least 40%.  ESRS S2 Workers in the value chain  Impacts, risks and opportunities  Managing and maintaining excellent working conditions are busi-  ness critical to NORDEN â both when it comes to its own workforce  and workers in the value chain. NORDEN's approach to managing  the relationship between material risks and opportunities related  to impacts towards workers in the value chain and dependencies  is centered on proactive engagement. Our ambition is not only  to ensure compliance with international legislation but also to set  higher standards. Having outsourced the technical management of  owned vessels, we classify our seafarers as workers in the value chain  in conformity with the ESRS, making Health &amp; Safety for workers in  the value chain a material topic for us. Operating at sea involves  safety and security risks that must always be managed carefully to  safeguard the crew and external personnel. Outsourcing technical  management and upholding a service that complies with interna-  tional law and NORDENâs standards requires a close, continuous  dialogue and a comprehensive reporting framework, to ensure trust  in the technical managerâs operation.  There are consequences associated with outsourcing services such  as technical management, as physical distances and differences  in corporate culture poses the risk of failing to notice incidents  or an undesirable culture, both of which could lead to inferior  working conditions, injuries and a negative effect on NORDENâs  reputation. NORDENâs responsibility is to investigate and manage  these salient risks and therefore, under its Human Rights Impact  Assessment (further detailed on page 68), covers risks associated  with outsourcing technical management. We regularly monitor and  review metrics associated with workers in the value chain, while  fostering open communication channels for feedback. Furthermore,  NORDEN has implemented a Technical Manager Code of Conduct  that supports a work environment with a sustainable culture and a  strong focus on health and safety, which is updated annually.  In our view, enhancing the rights and well-being of seafarers corre-  lates directly with improved performance on vessels and success  in both recruiting and keeping talented workers. Furthermore, this  commitment to seafarers' welfare aligns NORDEN with customers  and partners who share similar values, fostering stronger business  relationships.  NORDEN has articulated several policies to address and mitigate  the risks related to the material topics, some of which are listed here:  https://norden.com/about/governance/policies-and-charters. All  relevant policies are described on page 80.  Material topics, metrics and targets  Health &amp; safety  In 2024, NORDEN conducted ongoing inspections onboard our  vessels. In addition, we visited the offices of our technical managers  and attended crew seminars to assess their approach to safety.  During these visits, we emphasised our focus on safety and the  general health of the seafarers and contractors working onboard  our vessels. On-site visits enable NORDEN to evaluate our technical  managersâ approach to safety, as well as the safety culture they are  striving to uphold and implement onboard the vessels, through  training of crew and safety campaigns targeting critical work  processes onboard.  An HSEQ (Health, Safety, Environment and Quality) framework was  implemented in 2024 to further guide our cooperation with third-  party managers. This framework helps ensure that all our partner-  ships meet high standards within safety, well-being of employees,  sustainability, environmental protection and quality.  With the HSEQ framework in place, we are able to work more effec-  tively with our partners, reduce risks and improve overall perfor-  mance. It provides clear guidelines to make sure everyone is aligned,  accountable and working toward shared goals while keeping health,  safety and environmental care as top priorities.  NORDEN strives to set the same high standards for safety and  optimal working conditions onboard vessels as we do onshore. We  continuously ensure that our technical managers meet these stand-  ards. The number of injuries, by which crew members were unable to  work the following day, is measured through the Lost Time Incident  Rate (LTIR). LTIR is measured as lost time incidents per one million  working hours. Overall, LTIR increased to 1.3 in 2024 based on five  incidents in 4.0 million exposure hours, up from 1.0 in 2023.  At NORDEN, we have intensified our focus on safety awareness inter-  nally and in the cooperation with our Technical Managers.  Incident onboard a NORDEN barge  In November 2024, a serious incident occurred during the  unmooring operation of a barge in Gabon, where one of the  mooring crew members severely injured his foot. Consequently,  operations were halted, and the injured crew member was evacu-  ated to the nearest hospital for emergency medical attention.  Given the severity of the injury and the seriousness of the incident,  NORDEN initiated an investigation into the circumstances that led  to the event. Simultaneously, NORDEN's emergency response team  was activated to support the injured crew member and provide the  necessary comfort and assistance to him and his family.  The investigation concluded several findings which necessitated  immediate corrective actions before resuming operations, as well as  long-term preventive measures to enhance the safety and control of  mooring and unmooring operations.  Looking ahead  During 2025, NORDEN will focus on inspections of owned vessels,  conducting office visits and attending crew seminars to support  technical managers in developing high health and safety standards  and avoiding accidents onboard owned vessels. Focus will be on  investigating whether new preventive measures should be taken to  decrease LTIR and evaluating all technical managers through the  EcoVadis ESG scorecard.  Furthermore, we will carry out comprehensive audits of all Technical  Managers and other key partners to ensure compliance with both  NORDEN's internal standards and applicable regulatory require-  ments. These audits will serve to uphold best practices, identify  areas for improvement and reinforce a culture of safety, quality and  accountability across all operations.  GOVERNANCE  Our governance framework is designed to align  with the enduring interests of our stakeholders and  to manage NORDEN's operations in adherence  to all relevant local and international laws and  regulations. We are committed to maintaining  the highest ethical standards within our business  practices.  Operating internationally, NORDEN is aware that standards of  integrity and proper business conduct may differ across regions,  presenting unique challenges for conducting business. Recognising  the consequences of non-compliance, including legal action and  reputational damage, we prioritise robust governance to prevent  corruption and define clear expectations for ethical behaviour in all  our markets. Our unwavering commitment to combatting corruption  is for us a key component of enabling smarter global trade.  ESRS G1 Business Conduct  Impacts, risks and opportunities  NORDEN's governance structure is designed to integrate sustain-  ability targets with strategic business objectives. The Board of  Directors oversees ESG governance, while the ESG Executive Body,  comprising of representatives from Senior Management and special-  ists from core operational areas, formalises NORDENâs strategy and  policies. ESG accountability resides at board level, with ESG owners  within business functions driving initiatives to meet our targets.  Performance is measured against key performance indicators and is  reported quarterly to the Board, ensuring continuous alignment with  our ESG goals. Our Board members possess collective expertise in  global shipping management, strategy, financial oversight and risk  management, ensuring informed guidance in relation to business  conduct matters. This expertise underpins our commitment to ethical  business practices and supports our ability to navigate the complexi-  ties of international trade and sustainability.  NORDEN actively promotes a corporate culture rooted in compli-  ance and ethical integrity which aims to mitigate reputational risks  and clarify behavioural expectations for all employees, including the  Board of Directors. Our CFO oversees the ownership and enforce-  ment of our Anti-Corruption Compliance Programme and the overall  governance of the company.  Our corporate values and expectations are outlined in the Employee  Code of Conduct, accessible on the Intranet and disseminated to new  hires during onboarding. We require annual acknowledgement of the  Code by all employees to ensure comprehension of any updates and  continuous awareness.  Whistleblower scheme  Since 2011, we have maintained an independent whistleblower  scheme to empower employees and external partners to report any  operational or workplace concerns, ensuring the confidentiality and  anonymity of the reporting party. Concerns can be raised directly with  direct managers, the HR department or through the whistleblower  scheme. Reports received are handled by the Chair and Vice Chair of  the Board of Directors, along with the Head of Group Legal, ensuring  a thorough and impartial investigation.  In 2024, a total of five whistleblower reports were received, down  from six in 2023. Some cases concerned personal behaviour between  employees while others concerned supplier performance. Upon  the completion of the investigation, cases are classified as either  substantiated or unsubstantiated. All cases were investigated and  actions to address the complaints were carried out when required. Of  the cases closed in 2024, 60% were classified substantiated.  Whistleblower cases are taken very seriously. NORDEN continuously  enhances the awareness of good business conduct through educa-  tion and campaigns for both greater awareness of our whistleblower  scheme and the strengthening of our Speak Up culture with the aim of  which to minimise possible future cases. NORDEN has a strict non-retal-  iation policy vital to ensuring that employees feel safe raising concerns.  Responsible tax  As a company with global reach, NORDEN operates in multiple juris-  dictions with different tax rules and regulations. NORDEN complies  with the current tax legislation in the countries in which we operate,  and we comply with all applicable transparency rules, including coun-  try-by-country reporting. NORDEN does not use so-called tax havens  according to the European Union tax haven blacklist.  Sanctions  Due to the global nature of the shipping industry and the constantly  evolving geopolitical landscape, navigating sanctions requires an  agile and comprehensive approach to compliance, continuously  assessing risks and adapting strategies to align with evolving inter-  national laws and regulations. In NORDEN, sanctions compliance  is embedded in all parts of our organisation as it is part of our  day-to-day operations, conducting business in almost all countries in  the world. Sanctions compliance is implemented by having a robust  sanctions compliance framework, a specialist sanctions team and  formal processes and procedures in place to handle sanctions. To  uphold strong compliance, NORDEN requires all employees to take  a sanctions e-learning course once a year. All eligible employees  (excluding employees on leave, long-time sickness, etc.) passed the  course in 2024.  Impacts and risk  Following the double materiality assessment conducted during the  reporting period, NORDEN identified anti-corruption and bribery  along with sustainable procurement and contributing to human rights  as our key material impacts in governance.  The maritime industry is inherently international, making anti-cor-  ruption and bribery efforts critically important. For a company like  NORDEN, with a vast operational reach, the ability to ensure trans-  parent and ethical business practices across various legal and cultural  landscapes is not just a regulatory requirement but a fundamental  aspect of maintaining our licence to operate and safeguarding our  reputation. Therefore, the risk of non-compliance in this area is  considered material, as it may have significant legal consequences  and undermine stakeholder trust. Sustainable procurement and  contributing to human rights are other topics of material significance.  Our procurement practices directly impact our environmental foot-  print and social responsibility. It also influences our resilience against  supply chain disruptions, which has become increasingly relevant in  the face of global challenges. The material risks here include potential  environmental damage and the repercussions of associating with  suppliers who may not adhere to our sustainability and human rights  criteria, which could have far-reaching consequences for our business  and the communities we engage in.  Achievements &amp; initiatives 2024  Contributed to the elimination of all forms of maritime corruption on  a more systemic level through our active engagement with MACN,  which serves as a strong collective voice against corruption.  Launched a new tool for reporting of unethical requests covering all  of NORDENâs operated fleet. This enables us to monitor unethical  requests globally based on reporting from all port visits and transits.  Successfully renewed our EcoVadis certification and have been  recognised by EcoVadis as being in the worldâs top 5% sustainable  companies within the shipping industry, achieving a gold score. The  framework ensures NORDEN is measured against the latest sustaina-  bility criteria.  Successfully renewed our Tcertification (TRACE). To achieve a  Tcertification, companies must undergo a heavily benchmarked and  comprehensive due diligence review, analysis and approval process.  This certification ensures that a company has been thoroughly vetted  and trained.  ⢠Screened 66% of our strategic suppliers for ESG criteria.  Material topics, metrics and targets  Anti-corruption and bribery  Corruption is a major obstacle to sustainable development. Corrup-  tion leads to weak institutions, insecurity, destroys justice and fairness  and deprives people of basic needs such as health care, educa-  tion, clean water, sanitation for health and housing. It also hinders  economic growth, threatens environmental resources and destroys  innovation, making our world even more turbulent.  NORDEN calls numerous ports all over the world every single day.  Occasionally, NORDEN faces challenges, particularly in countries  presenting a high risk of corruption. In this business context, making  the right choice becomes more complex, yet increasingly impor-  tant, as non-compliance may entail legal and reputational risks and  damage our licence to operate.  Corruption escalates costs and endangers the safety and well-being  of the workers in our value chain, while posing a legal and reputational  risk. Therefore, NORDEN takes firm measures to prevent any form of  corruption as part of its ambition to enable smarter global trade. In  2024, NORDEN had 9,738 port calls across 129 countries.  Following the SASB Marine Transportation standard, NORDEN  reports on the number of port calls in the world's 20 most corrupt  countries, applying the Transparency Internationalâs Corruption  Perception Index (CPI). The result indicates a decrease in port calls  with a high risk of corruption from 2023 to 2024. No changes to the  current set-up were deemed necessary due to the decrease.  NORDEN conducts risk assessments at country level and job function  level applying both the CPI and Maritime Anti-Corruption Network  (MACN) Incident Data. The assessment makes it possible for us to  conduct an integrity risk assessment resulting in a corruption risk  map from which we can devise a possible action plan. To address  the appropriate compliance training requirements for employees,  identification of specific risks linked to departments and job functions  has been undertaken and resulted in a categorisation where different  roles require different training. This assessment enables NORDEN to  identify risks and trends ensuring that necessary training is provided.  Furthermore, NORDEN uses third-party due diligence tools to assess  potential corruption risks when engaging with external partners,  suppliers and contractors through MACN and Tcertification (TRACE).  Based on these analyses, NORDEN reviews the Anti-Corruption  Compliance Programme at least every second year.  NORDEN has an anti-corruption working group consisting of anti-cor-  ruption specialists. The group meets monthly to analyse and discuss  risks and actions. NORDEN takes a systematic approach to assessing  corruption and bribery risks, particularly in countries deemed high  risk. The specialists are dedicating time to conduct country risk  assessments and engage with masters and operators guiding on the  specific challenges for the port of call.  Furthermore, NORDEN conducts due diligence investigations of busi-  ness relations as an integrated part of its business conduct, ensuring  compliance with legal requirements and stakeholdersâ expectations,  improving internal decision-making, raising risk awareness and  protecting NORDENâs reputation. NORDEN has a complex third-party  landscape and currently has different due diligence procedures in  place for various third-party groups. The main third-party groups in  NORDEN are agents, brokers and suppliers.  All NORDENâs third-party contacts are screened daily on several  potential risk factor issues, including sanctions lists, global law  enforcement lists, vessel information and politically exposed persons.  NORDEN has zero tolerance towards bribery, and our Anti-Corruption  Policy clearly outlines the refusal of all types of facilitation payments.  To ensure a culture of exemplary conduct with strong procedures,  NORDEN has an Anti-Corruption Compliance Programme in place.  The programme helps ensure that corruption and bribery risks are  identified, that concerns are reported and that measures are taken to  mitigate any identified risks throughout the organisation.  Moreover, this programme covers third-party responsibility, gifts and  entertainment, commissions, conflicts of interest, sponsorships and  political and charitable contributions as topics within the broader  compliance agenda.  In 2024, NORDEN implemented new measurements to decrease the  likelihood of corruption on owned vessels and launched a new tool  for reporting unethical requests covering all of NORDENâs operated  fleet. This enables us to monitor requests for bribery and facilitation  payments globally based on reporting from all port visits and tran-  sits, which provides insight into current risks, development in the risk  landscape and the effectiveness of the programme, strengthening  our mitigation plans and ensuring the prevention of future corruption  incidents.  NORDENâs Anti-Corruption Programme is incorporated into NORDENâs  Employee Code of Conduct which is provided to new hires during  onboarding and must be acknowledged annually by all employees to  ensure comprehension of any updates and continuous awareness.  To ensure compliance with the programme, a compliance manager  has been appointed. The role of the compliance manager is to ensure  that relevant policies and procedures are followed and that risk  assessments, due diligence and monitoring are conducted regularly.  NORDENâs compliance manager reports to the CEO if any issues arise  UN Global Compact  NORDENâs CEO, Jan Rindbo, comments: "NORDEN remains committed to  upholding the principles of the UN Global Compact (UNGC) and supports the  worldwide movement to accelerate and scale the collective impact of responsible  and sustainable business."  In April 2024, NORDEN submitted its 2024 Communication on Progress (COP) in line with the requirements.  NORDEN has remained an active participant of the UNGC since  2009 and adheres to the following UN Sustainable Development  Goals (SDGs), which are mapped to each of the E, S and G-re-  lated activities that we consider relevant to our core business:  Environment:  ⢠13.1: Strengthen resilience and adaptive capacity to  climate-related hazards and natural disasters in all countries.  ⢠17.16: Enhance the global partnership for sustainable devel-  opment, complemented by multi-stakeholder partnerships  that mobilise and share knowledge, expertise, technology  and financial resources, to support the achievement of the  sustainable development goals in all countries, in particular  developing countries.  Social:  ⢠5.5: Ensure womenâs full and effective participation and equal  opportunities for leadership at all levels of decision-making in  political, economic and public life.  ⢠5.C: Adopt and strengthen sound policies and enforceable  legislation for the promotion of gender equality and the  empowerment of all women and girls at all levels.  ⢠8.5: By 2030, achieve full and productive employment and  decent work for all women and men, including for young  people and persons with disabilities, and equal pay for work  of equal value.  ⢠8.7: Take immediate and effective measures to eradicate  forced labour, end modern slavery and human trafficking and  secure the prohibition and elimination of the worst forms of  child labour, including recruitment and use of child soldiers  and by 2025 end child labour in all its forms.  ⢠8.8: Protect labour rights and promote safe and secure  working environments for all workers.  ⢠10.2: By 2030, empower and promote the social, economic  and political inclusion of all, irrespective of age, sex, disability,  race, ethnicity, origin, religion or economic or other status.  ⢠10.3: Ensure equal opportunity and reduce inequalities of  outcome, including by eliminating discriminatory laws, poli-  cies and practices and promoting appropriate legislation,  policies and action in this regard.  Governance:  ⢠16.5: Substantially reduce corruption and bribery in all their  forms.  ⢠17.16: Enhance the global partnership for sustainable develop-  ment complemented by multi-stakeholder partnerships that  mobilise and share knowledge, expertise, technologies and  financial resources to support the achievement of sustainable  development goals in all countries, particularly developing  countries.  that need to be addressed immediately or discussed. The compliance  manager provides regular updates to the ESG Executive Body.  All relevant policies are described on page 80.  NORDEN continues to be an active member of the MACN, a network  working to eliminate all forms of corruption in the maritime industry  and enabling fair trade to the benefit of society at large. MACN has  grown to include more than 215 companies representing the maritime  supply chain, emerging as a leading example of collective action  against corruption. MACN and its members work with raising aware-  ness of the challenges faced, implementing anti-corruption principles,  co-developing and sharing best practices, collaborating with govern-  ments, non-governmental organisations and civil society to identify  and mitigate the root causes of corruption and creating a culture of  integrity within the maritime community. In high-risk areas where  MACN has introduced collective actions, the reported corruption  requests have dropped.  On behalf of NORDEN, our external technical managers carry out  anti-corruption training for the workers in our value chain to ensure  alignment with legislation and NORDENâs Anti-Corruption Compli-  ance Programme. NORDEN requires its technical managers to be  members of MACN and promotes awareness internally and externally  regarding MACN tools and helpdesks. For chartered vessels, an  anti-corruption instruction is sent to captains and agents.  NORDEN tracks performance through two indicators: Eligible  employees trained in NORDENâs anti-corruption course in the current  year as well as number of confirmed bribery cases.  NORDEN requires all employees to take an e-learning course annually  on anti-corruption. All eligible employees (excluding employees on  leave, long-time sickness, etc.) passed the course in 2024.  The anti-corruption course focuses on the complexity of corruption  and trains employees to identify and assess situations in which corrup-  tion can occur. Additionally, employees are trained in the severity of  corruption and potential consequences. The course covers topics  such as anti-corruption practices, bribery and facilitation payments,  gifts and entertainment, conflicts of interest, indirect bribery via  commissions, fraud, third-party procedures and NORDENâs whistle-  blower scheme.  In 2024, NORDEN had zero bribery cases in line with our ambitions. In  2025, NORDEN will implement steps to further improve the measuring  of the effectiveness of the Anti-Corruption Compliance Programme  and engage further with MACN on systematic challenges and risks.  In order to further strengthen the focus on anti-corruption in 2024,  NORDEN introduced three new KPIs: the percentage of technical  managers assessed through the EcoVadis platform in the current year,  the percentage who has signed the latest revised Technical Manager  Code of Conduct and the percentage who meets NORDEN's require-  ment of being members of MACN. NORDEN is actively engaging with  Central Mare to ensure that all technical managers join MACN, aiming  to achieve 100% membership.  Sustainable procurement  As a globally operating company, we interact with numerous suppliers  around the world, and it is a priority for NORDEN to ensure sustain-  able procurement in collaboration with our external stakeholders.  NORDEN seeks to enable sustainable procurement by integrating  ESG matters into our procurement processes and decisions.  In 2023, NORDEN began assessing and working with strategic  suppliers, i.e. suppliers that are critical to business operations, to  become more sustainable. Throughout 2024, using EcoVadis, we  continued to assess our strategic suppliers both on potential risk  and attained ESG scorecards on 25 of our key strategic suppliers.  Following the new transparency act, we plan to increase audits and  supplier reporting regarding human rights.  In 2024, we were able to assess potential risk of 66% of our strategic  suppliers, well above our target of 60% set in 2023. During the year,  Procurement additionally participated along with HSEQ in the audit  of one of our key suppliers, resulting in an improved way of working  for the supplier. As we continue to gain knowledge of our suppliersâ  activities, we are better equipped to make decisions in relation to our  sourcing strategy.  The KPI set out for 2025 is to ensure that at least 75% of our strategic  suppliers have been screened for ESG criteria by 2026.  Looking ahead, we will continue our focus on securing ESG score-  cards on strategic suppliers, carry out audits and put improvement  plans into place where needed. We will work on further embedding  sustainable procurement in the business and conduct at least one  on-site supplier visit. Lastly, we will continue our focus on preparing  for legislation on sustainable procurement following the ESRS.  Working with human rights  As a global company, NORDEN is dedicated to implementing due  diligence and mitigation measures to respect human rights. In 2024,  NORDEN conducted a Human Rights Impact Assessment (HRIA)  that led to added insight into and understanding of our potential  and actual human rights risks across the organisation and value  chain. NORDEN always strives to abide by policies and grievance  mechanisms all compliant with, and upholding to, the highest  international regulations, standards and best practice recommen-  dations, as stated in the International Bill of Human Rights, the  International Labour Organisation's Declaration on Fundamental  Principles and Rights at Work, the United Nations Guiding Principles  for Business and Human Rights (UNGPs), Danish Shipping and the  Danish Institude for Human Rights.  NORDEN has a responsibility to consider any human right violations  it might cause, contribute to, or be directly linked to. Based on a  thorough risk assessment of NORDENâs various areas of operations  and value chain, a Human Rights Impact Assessment is carried out  every two years. For this process, NORDEN utilises a mixed-method  approach combining qualitative and quantitative data, including  surveys, interviews with stakeholders, employees and managers and  on-site inspections, ensuring an in-depth understanding of the poten-  tial risks and that diverse perspectives are considered and respected.  Following the findings from the previous HRIA, NORDEN has imple-  mented multiple prevention, mitigation and remediation plans and  procedures. These include the hiring of a HSEQ manager, carrying  out on-site audits of suppliers and technical managers, the adoption  of a Technical Manager Code of Conduct, the implementation of  supplier screenings and self-assessments through EcoVadis, Speak Up  Campaigns in offices and on board vessels and the implementation of  an Incident Management Instruction plan.  The learnings from the previous HRIA also led to improvements in this  yearâs methodology. Not only were a larger number of key informant  interviews conducted, including external stakeholders, a more thor-  ough assessment methodology was designed to better quantify and  classify the risks in terms of severity and likelihood of impact. The  findings from this yearâs HRIA, along with proposed preventive and  mitigating actions, were reviewed and approved by the responsible  ESG Executive Body representative.  The salient risks identified were:  ⢠Health and safety of workers in dry docks shipyards and during  vessel repairs.  To alleviate these risks, several mitigating actions have been imple-  mented. These include measures such as thorough supplier vetting,  on-site audits and self-assessments, vessel and shipyard visits, weekly  communications of security risks to Executive Management, close  monitoring of the implementation of security guidelines for logistics  operations, campaigns advocating for incident reporting channels  and setting health and safety requirements for technical managers to  be carried out when external personnel board a vessel.  In 2025, NORDEN will continue to focus on defining areas of actions  and take proactive measures to prevent human rights violations.  NORDEN aims to continuously secure ESG scorecards on strategic  suppliers, engage in conversations regarding our suppliersâ suppliers  and their auditing procedures, continue to raise awareness through  our Speak Up campaign and compliance programme, continue  to carry out regular audits of suppliers and technical managers,  systemise due diligence and on-site auditing, implement a crisis  management plan as well as implement a due diligence process for  dry dock shipyards.  ESG ACCOUNTING POLICIES  The reporting boundaries  The ESG report comprises activities in the parent company and  all subsidiaries. The accounting policies are applicable for the  reporting period: 1 January â 31 December 2024.  ESG metrics follow the below boundaries unless otherwise speci-  fied:  ⢠Owned and leased vessels (excl. time chartered-out ('TCO') and  third-party pool-managed vessels).  ⢠Employees on shore (scoped as own workforce).  ⢠Crew on board vessels (scoped as workers in the value chain).  ⢠All NORDEN offices across the world.  Statement on carbon insetting  The greenhouse gas emissions intensity information presented in  the report reflects calculations that account for the allocation of  low-emission transport activity to selected customers. The emission  intensity presented is therefore not appropriate for use in custom-  er-specific greenhouse gas emissions calculations.  Changes to accounting policy and previously  reported metrics  ⢠Change in emission factors applied for scope 3 (GHG 1 and 2):  Changed from previously being reported by a third-party provider  of emission factors. NORDEN uses the United States Environ-  mental Protection Agency (U.S EPA) emission factors until we  move to primary ones. Emission factors were updated on the 20th  of April 2023.  ⢠Change in scope 2 calculation method: Changed from previously  being reported by a third-party provider of emission factors.  NORDEN uses the carbon footprint scope 2 emission factors.  Emission factors were updated in July 2024. NORDEN reports  on scope 2 emissions from our 18 offices, of which one based  on actual consumption data. The remaining offices are based on  the average CO2e per FTE derived from the office having actual  consumption data multiplied by the number of FTEs at the respec-  tive office. Please see the accounting policies for scope 2 emis-  sions for further description of the methodology applied.  Data quality and data collection  The reporting principles of balance, clarity, accuracy, reliability,  timeliness and comparability are applied when collecting informa-  tion and data that form the basis for NORDENâs ESG performance.  NORDEN has built and implemented models for reporting environ-  mental KPIs based on data from our Integrated Maritime Operations  System (IMOS) and Spinergie for logistics operations in Gabon.  Besides providing more insights into the development of key indica-  tors for fuel efficiency, the models allow for checking and reporting  extreme observations and enable NORDEN to identify potential  errors on an ongoing basis. This ensures the accuracy and reliability  of data points reported for internal and external stakeholders.  The HR department enters HR data into our HR system, Fairsail.  Post data entry, HR personnel can immediately review, analyse, and  visualise the impact of their data entry in our HR visualisation tool.  This tool allows for an instantaneous check, ensuring that the data  aligns with actual HR metrics and facilitating any necessary correc-  tions or updates in real time. Subsequently, numbers are checked  and validated by our finance department before being shared with  internal and external stakeholders. Other social KPIs stem from our  technical managers. Numbers are reported monthly and validated  by our internal technical department and finance department.  Having implemented the SASB Marine Transportation standard in  2022, NORDEN reports values for the previous two years allowing  for comparability. All accounting policies following the accounting  standards from the SASB Marine Transportation reporting standard  are marked by âTR-MTâ. The SASB reporting standard can be found  at https://www.sasb.org/standards/download/?lang=en-us  During the reporting year, NORDEN has continued the process  of complying with the upcoming ESRS requirements. All metrics  calculated in conformity with the ESRS are listed in the ESRS Index  table, which can be found on page 47. The full ESRS can be found on  page 83.  The development in company-specific material ESG performance  indicators can be found in the ESG Materiality Matrix in the introduc-  tion section, while supporting indicators are disclosed in the rele-  vant sections of the ESG report. Accounting metrics from the SASB  Marine Transportation standard can be found on page 82.  NORDEN applies a 5% threshold for changes to previously reported  emission figures in the ESG statements. The threshold is based on  the percentage change in the respective GHG scopes. Differences  below the selected threshold will be accounted for in the current  reporting period. Changes to previously reported figures are moni-  tored continuously in our internal controls and reporting tools.  For inclusion of GHG categories, NORDEN applies a 1% materiality  threshold of total scope 3 emissions to ensure focus on our main  impacts. Although not part of external reporting, NORDEN esti-  mates and tracks development in all relevant GHG categories and  will include GHGs, when they exceed the 1% materiality threshold.  Environmental performance  Energy consumption  Total energy consumed (TJ): Calculated by adding up tonnes of fuel  and electricity usage, applying their higher heating values (HHV) of  40.2MJ/kg for heavy fuel oil, 42.7MJ/kg for distillate fuel oil, 41.7MJ/  kg for very low sulphur residuals, 37 MJ/kg for biofuel, and 0.0036  MWh/TJ for electricity. Following TR-MT-110a.3., but NORDEN  reports on total energy consumed in TJ instead of GJ.  Total energy consumption from fossil sources (MWh): Following  ESRS E1-5. Since NORDEN is in one of the high climate impact  sectors as defined in the ESRS, we must disaggregate into fossil  sources. However, only the fuel consumption from crude oil and  petroleum products is relevant to NORDEN. Calculated by adding  up tonnes of fuel and electricity usage, applying their higher heating  values (HHV) of 40.2MJ/kg for heavy fuel oil, 42.7MJ/kg for distillate  fuel oil, 41.7MJ/kg for very low sulphur residuals.  Total energy consumption from renewable sources (MWh):  Following ESRS E1-5. Includes fuel consumption on operated  voyages for renewable sources, including biomass (also comprising  industrial and municipal waste of biological origin), biofuels, biogas,  and hydrogen from renewable sources. Calculated by adding up  tonnes of fuel and electricity usage, applying the higher heating  values of 37 MJ/kg for biofuel.  Energy intensity (MWh/USD): Following ESRS E1-5. Calculated as  the total energy consumption (MWh) per net revenue (USD).  Heavy fuel oil as a % of total energy consumed: Following  TR-MT110a.3. Calculated as the heavy fuel oil consumption multi-  plied by 40.2MJ/kg and divided by the total energy consumed from  bunker consumption on owned or operated voyages.  Renewables as a % of total energy consumed: Following  TR-MT110a.3. Calculated as the biofuel consumption multiplied by  37MJ/ kg and divided by the total energy consumed from bunker  consumption on owned or operated voyages.  Energy efficiency operational indicator (gCO2 /cargo-nauti-  cal-mile): The energy efficiency operational indicator (EEOI) is a  measurement of energy efficiency defined as the amount of CO2  emitted per tonne of cargo transported 1 nautical mile. Transport  work expresses the mass of cargo transported over distance, as  registered in the Integrated Maritime Operations System (IMOS).  The relative relationship between CO2 emitted and transport work  measures the fleetâs operational efficiency.  NORDEN provides EEOI with different boundaries:  1. EEOI TTW on operating assets: vessels operated by NORDEN,  based on tank-to-wake (TTW) emissions, and only including CO2  emissions using factors from FUEL EU.  2. EEOI WTW on operating assets: vessels operated by NORDEN  but based on well-to-wake (WTW) emissions and reported in CO2  equivalent emissions using the 100-year horizon GWP values from  AR6 and FUEL EU.  3. EEOI TTW on all assets: including TCO vessels, based on TTW  emissions, and only including CO2 emissions using factors from  AR6 and FUEL EU.  All metrics are reported per vessel type. Logistics operation is not  included in EEOI.  Greenhouse gas emissions  CO2 equivalent emissions (1,000 tonnes): All emissions are reported  as CO2 equivalents calculated by the 100-year time horizon GWP  values from IPCC (6th assessment report) in conformity with the  ESRS E1-6 and using emission factors from FUEL EU.  Gross Scope 1 GHG Emissions: Direct emissions from NORDENâs  consumption of fuel from owned and chartered-in vessels.  Consumption is allocated across reporting periods based on  contract service performance criteria. The pool's allocation of emis-  sions is based on the poolâs distribution model. Including bunker  consumption on ballast leg prior to voyage operation by NORDEN,  which could be considered part of GHG #4: Upstream transportation  and distribution. NORDEN includes these emissions in our Gross  Scope 1 GHG Emissions as we consider the emissions to be part of  our own operation.  Gross Scope 2 GHG Emissions: Indirect emissions from purchased  electricity and district heating. Electricity and heating usage of  NORDEN based on actual data from our Hellerup office and estima-  tion of the remaining offices' usage. Emissions from these offices are  based on the average CO2e per FTE derived from the office having  actual consumption data multiplied by the number of FTEs at the  respective office.  ⢠Location-based: Not considering renewable energy certificates  (RECs) or power purchase agreements (PPAs). Simply using loca-  tion-based grid average emission factors from carbon footprint  (2024).  Market-based: Reflects the GHG emissions from the electricitythat NORDEN has purposefully chosen (or the lack of a choice). In  2024, NORDEN only had a green electricity purchase agreement  for the Hellerup office.  Gross Scope 3 GHG Emissions: Indirect upstream and downstream  emissions from third-party activities and operational management  services. Based on our materiality threshold of 1%, below the GHG  recommendation of 5%, NORDEN includes the following scope 3  GHG categories in our external reporting framework:  ⢠Purchased goods and services (GHG #1): Overhead, administra-  tion and port costs as classified in the NORDEN chart of accounts  are converted into emissions based on the U.S. EPA (2023) catego-  risation of costs.  ⢠Capital goods (GHG #2): Capital expenditures (CapEx) such as  investments in vessel newbuildings, scrubbers or dry docking of  vessels are converted into emissions based on costs and the CEDA  Group categorisation: Shipbuilding and repairing. The USD aligns  with the âtransferred from prepayments during the yearâ in the  financial statement notes related to tangible assets and additional  CapEx investments related to dry docking, scrubbers and similar.  Thus, the emissions related to investments in newbuildings are  accounted for at the vessel's delivery. Follows cash usage and is not  allocated over the depreciation schedule of the asset or upgrade.  ⢠Fuel and energy-related activities (GHG #3): Upstream emis-  sions related to direct bunker consumption using CO2 equivalent  emission factors from FUEL EU based on fuel types on owned  or operated voyages using data from IMOS and Spinergie. The  upstream emission factor on biofuel is based on actual emission  factors provided by the supplier.  ⢠Upstream transportation &amp; distribution (GHG #4): Upstream  transportation emissions on our purchased goods and services  based on CEDA Group categorisation of costs. Since upstream  transportation and distribution are part of the emission factors  applied by a third-party provider, GHG #4 is included despite  being below our 1% threshold and reported as part of purchased  goods and services in the reported figures.  ⢠Downstream leased assets (GHG #13):  â Emissions from TCO voyages are included based on contract  service performance in the reporting period. NORDENâs share of  TCO emissions in the NORDEN Tanker Pool is allocated based on  the distribution model. The residual between total emissions gener-  ated by TCO voyages in the NORDEN Tanker Pool and NORDENâs  share of these is not part of NORDENâs scope of emissions.  â Emissions related to operating third-party vessels generating  management fees in the NORDEN Tanker Pool. Estimated as the  difference between the total emissions from operated vessels and  the NORDEN share of these based on the distribution model. The  residual is accounted for as emissions related to the operational  management of pool vessels.  GHG categories 5, 6, 7 and 15 are considered relevant for NORDEN  but fall below our materiality threshold of 1% of total scope 3 emis-  sions. NORDEN continues to monitor development in the GHG  categories internally, but these will not be part of our externally  reported ESG metrics subject to the emissions exceeding our  selected threshold.  GHG emissions intensity: Following ESRS E1-6. Calculated as total  GHG emissions (CO2e) per net revenue (USD).  EEDI (gCO2 /cargo-capacity-mile): Following TR-MT-110a.4. The  calculations follow methodologies outlined in IMO MEPC 66/21/  Add.1, Annex 5, 2014. The average EEDI is a simple average of the  EEDI value of all new ships added to NORDENâs fleet during the  reporting period. Only including owned vessels at the end of the  reporting period.  GHG removals and storage projects in the value chain (metric  tonnes): Total amount of GHG removals and storage in metric tonnes  of CO2e disaggregated and separately disclosed for the amount  related to our operations and our upstream and downstream value  chain and broken down by removal activity.  GHG emission reductions or removals by the purchase of carbon  credits (metric tonnes): The total amount of carbon credits outside  our value chain in metric tonnes of CO2e that are cancelled in the  reporting period or planned to be cancelled in the future.  Air quality  NOX (metric tonnes): Following TR-MT-120a.1. Nitrogen oxide  emissions from combustion of fuels from operated vessels. NO2  emissions from the energy produced by the main engine are multi-  plied by the Tier 1 NOX limit (17 g/kWh) or Tier 2 NOX limit (14.4 g/  kWh) in accordance with the 4th IMO GHG study. Calculated basis  bunker consumption on operated voyages based on data from IMOS  and Spinergie. NORDEN assumes distribution of fuel consumption  between ME and AE of 90%/10%.  SOX (metric tonnes): Following TR-MT-120a.1 and the IMO 4th  GHG study. Sulphur oxide emissions mainly stem from burning the  sulphur compound in the fuel from operated vessels. SO2 emis-  sions are calculated from the fuel quantity consumed during the  year multiplied by the average sulphur content in the bunker fuel  purchased by NORDENâs Bunker department. Calculated basis  bunker consumption on operated voyages based on data from IMOS  and Spinergie.  PM10 (metric tonnes): Following the TR-MT-120a and the IMO 4th  GHG study. PM10 emissions are influenced by engine type and fuel  sulphur content. NORDEN uses the same average sulphur content  used in the SOX calculation and assumes 175/195 g/kwh in engine  output (SFOC) based on the engine efficiency of the main/auxiliary  engine. Calculated based on bunker consumption from operated  vessel voyages based on data from IMOS and Spinergie.  PM2.5 (metric tonnes): Following ESRS E2-4 and the IMO 4th GHG  study. PM2.5 emissions are influenced by engine type and fuel  sulphur content. NORDEN uses the same average sulphur content  used in the SOX calculation and assumes 175/195 g/kwh in engine  output (SFOC) based on the engine efficiency of the main/auxiliary  engine. Calculated based on bunker consumption from operated  vessel voyages based on data from IMOS and Spinergie. Estimated  to be 92% of the PM10.  NMVOC (metric tonnes): Following ESRS E2-4 and the IMO 4th GHG  study. NMVOC emissions are influenced by engine type. NORDEN  assumes 175/195 g/kwh in engine output (SFOC) based on the  engine efficiency of the main/auxiliary engine. Calculated based on  bunker consumption from operated vessel voyages based on data  from IMOS and Spinergie.  HM (metric tonnes): Following ESRS E2-4 and the IMO 4th GHG  study. ESRS E2-4 requires the reporting company to report HM  emissions to water and air. NORDEN uses the conversion factors  reported by the US EPA for HM air pollution. Calculated based on  bunker consumption from operated vessel voyages based on data  from IMOS and Spinergie.  Water pollution  HM (metric tonnes): Following ESRS E2-4. HM in water stems from  scrubber-fitted vessels. We estimate the water pollution using values  from the ICCT. Emissions into water are only relevant for open-  looped scrubbers since pollutants stem from the wash water.  PAH (metric tonnes): Following ESRS E2-4. The concentration of  PAHs in the discharged wash water is assumed to comply with IMO  guidelines as described in the Resolution MEPC.340(77) of 50 µg/l  (2.25 g/MWh). Emissions into water are only relevant for open-  looped scrubbers since pollutants stem from the wash water.  Ecological impacts  Shipping duration in marine-protected areas or areas of protected  conservation status (days): Following TR-MT-160a.1, but NORDEN  reports only on days in emission control areas (ECA) based on a  materiality assessment. Total ECA days are calculated as the sum  of sea and port days in ECA zones on owned or operated voyages  based on data from IMOS and Spinergie.  Percentage of fleet implementing ballast water exchange (%):  Following TR-MT-160a.2, reporting only on owned vessels by  NORDEN in the reporting period. Calculated as the residual  between vessels having implemented a ballast water treatment  system and the total number of owned vessels. Does not include the  tugs used for the Gabon project.  Percentage of fleet implementing ballast water treatment (%):  Following TR-MT-160a.2, calculated as the percentage of NORDEN's  vessels having implemented ballast water treatment divided by the  number of owned vessels. Reported by the internal technical depart-  ment on NORDENâs owned vessels. Does not include the tugs used  for the Gabon project.  The number of spills and releases to the environment: Following  TR-MT-160a.3, NORDEN reports on all spills that significantly harm  the environment from owned vessels. Reported by vessel technical  manager on NORDENâs owned vessels.  The aggregate volume of spills and releases to the environment  (m3): Following TR-MT-160a.3, NORDEN reports on all spills that  significantly harm the environment from owned vessels. Reported by  vessel technical manager on NORDENâs owned vessels.  Activity measures  Number of shipboard employees: Following TR-MT-000.A. Ship-  board employees are those employees who work aboard the enti-  tyâs vessels during the reporting period. Reported as the average  number of employees.  Total distance travelled by vessels: Following TR-MT-000.B.  Reported as the sum of nautical miles travelled on owned or oper-  ated voyages during the reporting period. Does not include the tugs  used for the Gabon project.  Operating days: Following TR-MT-000.C. Operating days are calcu-  lated as the number of available days in a reporting period minus the  aggregate number of days that the vessels are off-hire due to unfore-  seen circumstances. Including internal voyages.  Deadweight tonnage: Following TR-MT-000.D. Deadweight tonnage  is the sum, for all owned vessels at the end of the reporting period,  of the difference in displacement in deadweight tons between the  light displacement and the loaded displacement. Does not include  the tugs used for the Gabon project.  Number of vessels in the total shipping fleet: Following  TR-MT000.E. Reported as the number of owned vessels at the end of  the reporting period. Does not include the tugs used for the Gabon  project.  Number of vessel port calls: Following TR-MT-000.F. Reported as  the number of vessel port calls in the reporting period for owned or  operated voyages.  Twenty-foot equivalent unit (TEU) capacity: NORDEN does not  report on this metric in the SASB Marine Transportation standard as  it is considered out of scope.  Social performance  Own workforce  General statement of scope and boundaries: Scope for the full-  time workforce, accounted for as full-time equivalent (FTE) onshore,  includes permanent and time-limited employees (fixed-term jobs,  student jobs and temporary hires) in NORDENâs offices, except for  the indicators âRetentionâ and âTurnoverâ, in which the scope includes  average FTE number onshore relating to permanent employees,  excluding fixed-term jobs, student roles and temporary hires. All  social KPIs are based on NORDENâs HR system, Fairsail. Following  the definition in the ESRS, significant employment is defined as  countries with more than 50 employees measured as headcount.  NORDENâs own workforce includes primarily employees and to  a limited extent non-employees who are either self-employed or  provided by companies that primarily perform employment activi-  ties. Given the limited extent of non-employee workers, NORDEN is  not considering the disclosure requirement (DR) S1.7: Characteristics  of non-employee workers in the undertakingâs own workforce, to be  material and will therefore not report on the DR.  Employees (FTE): Average full-time equivalent number of  employees onshore as defined in NORDENâs HR system.  Nationalities represented (of the total workforce): Number of  nationalities in the total workforce based on NORDENâs HR system.  New hires: Calculated as the sum of headcounts being hired during  the reporting period.  Locations: NORDENâs office locations are divided into 'Headquar-  ters' and 'Other Offices'. Other Offices consist of our offices in  Limassol, Dubai, Singapore, Melbourne, Shanghai, Tokyo, Owendo,  Abidjan, Rio de Janeiro, Santiago, Annapolis, Vancouver and  Bremen.  The gender distribution in number at top management: Top  management is defined as the senior management in the Corpo-  rate Governance section. The number of each gender is based on  NORDENâs HR system and aligns with the ESRS 1-9: Diversity Indica-  tors.  The gender distribution in percentage at top management: Top  management is defined as the senior management in the Corporate  Governance section. The number of each gender divided by total  top management headcount based on NORDENâs HR system and  aligning with the ESRS 1-9: Diversity Indicators.  Total number of turnover: The number of leavers (all leavers) in the  reporting period based on NORDENâs HR system aligning with the  ESRS S1-6: Characteristics of the undertakingâs employees.  Turnover rate: The number of leavers (all leavers) in the reporting  period divided by the number of employees at the beginning of the  reporting period based on NORDENâs HR system as per the ISO  30414 standard and GRI 401-01 b with age data from HR system  birth dates.  Retention rate: One minus the number of resignations (voluntary  leavers) in the reporting period divided by the number of employees at  the beginning of the reporting period based on NORDENâs HR system  based on GRI 401-01 b with age data from HR system birth dates.  Engagement score: Provided by a third-party supplier of the  Engagement and Harassment Survey. The score is standardised  to per cent, with 100% representing maximum engagement. The  survey recurs on an annual basis. All of NORDENâs own employees  are part of the engagement survey. A third party provides bench-  mark scores with NORDENâs knowledge of calculations and weights  of benchmark categories.  Lowest represented gender among own workforce (%): The  percentage of the average number of the gender with the lowest  represented FTE out of the total average number of FTEs during the  year based on NORDENâs HR system.  Lowest represented gender among managers (%): Average number  of the gender with the lowest represented FTE in manager positions  out of a total average number of FTEs. A manager position is defined  as a person responsible for a team of at least one other FTE as  defined in the HR system.  Lowest represented gender among commercial roles (%): The  percentage of the average number of the gender with the lowest  represented FTE out of the total average number of FTEs in commer-  cial roles during the year based on NORDENâs HR system. Commer-  cial roles include the CEO, ship operators, charterers, FFA traders,  commercial and portfolio managers. The remaining are considered  support roles.  Male-to-female pay ratio (%): Following ESRS S1-16. Calculated as  the ratio between male and female average gross hourly earnings  based on base salary, excluding pension and working hours as spec-  ified in the employment contract based on data from NORDENâs HR  system. Reported by employee location and distinguished between  support and commercial employees.  Total remuneration ratio (%): Following ESRS S1-16. Annual total  remuneration for the undertakingâs highest-paid individual divided  by the median employee's annual total remuneration excluding the  highest-paid individual.  Workers in the value chain  General statement of scope and boundaries: NORDEN defines  workers in the value chain as all non-employee workers whose  work and/or workplace is controlled by the undertaking but are not  included in the 'own workforce' scope. Based on the materiality  assessment of NORDENâs social impacts, the scope of workers in the  value chain includes our seafearers on our owned vessels, who are  employed by technical managers.  Lost time incident rate (LTIR): Following TR-MT-320a.1. Calculated  based on the number of registered work-related accidents which  cause a seafarer to be unable to work for more than 24 hours per  1 million working hours due to work-related injury. Numbers are  reported by vessel technical managers on NORDENâs owned  vessels.  Rest hour violations intensity: Calculated as the number of rest hour  violation hours divided by the working hours in the reporting period  by shipboard employees. Numbers are reported by vessel technical  managers on NORDENâs owned vessels. The calculation of ship-  board employees follows the TR-MT-000.A. In 2023, the numbers  exclude the logistics operation in Gabon.  Accident &amp; safety management  The number of marine casualties and percentage classified as very  serious: Marine casualties are calculated as the number of fatalities.  The percentage classified as very serious includes LTIs and fatalities,  with fatalities considered very serious. Reported on owned vessels  by the vessel technical manager.  The number of conditions of class or recommendations: Following  TR-MT-540a.2 and reported on owned vessels by the vessel tech-  nical manager.  The number of port state control (1) deficiencies and (2) detentions:  Following TR-MT-540a.3 and reported on owned vessels by the  vessel technical manager.  Governance performance  Sustainable procurement  Strategic suppliers screened for ESG (%): The number of strategic  suppliers screened for ESG-related risks divided by the total stra-  tegic suppliers for NORDEN. Strategic suppliers for NORDEN are  defined based on three critical metrics; spending, materiality for  NORDEN and whether the vendor is in a high-risk country.  Business conduct  The number of calls at ports in countries that have the 20 lowest  rankings in Transparency Internationalâs Corruption Perception  Index: Following TR-MT-510a.1. Calculated as the number of port  calls (see definition of port calls under activity measures) being in  the 20 lowest rankings in the Transparency Internationalâs Corrup-  tion Perception Index.  The total amount of monetary losses because of legal proceedings  associated with bribery or corruption / The total amount of fines for  violation of anti-corruption and anti-bribery laws (USD): Following  TR-MT-510a.2 and ESRS G1-4. Reported by the Head of Group Legal  and is validated against spending in the audited accounts.  The number of convictions and the amount of fines for violation  of anti-corruption and anti-bribery laws: Following the ESRS G1-4.  Reported by the Head of Group Legal.  Staff completed E-learning course: Share of eligible employees  having passed NORDEN's Anti-Corruption course. Eligible  employees are full-time employees on a permanent contract who  have worked with NORDEN the entire reporting year. Employees on  maternity or sickness leave are considered non-eligible. Retrieved  from our external provider of anti-corruption courses and HR system.  Board  Gender with lowest representation share on Board of Directors (%):  Percentage of shareholder-elected gender with lowest representa-  tion on the Board of Directors out of the total number of sharehold-  er-elected board members at year end.  Double materiality assessment  This section describes NORDEN's materiality assessment process  and complies with the disclosure requirement IRO-1: description of  the process to identify and assess material impacts, risks and oppor-  tunities. The section should allow readers to fully understand the  process for determining which disclosure requirements to include in  our sustainability statement.  The DMA follows a structured governance process, with clearly  defined roles and responsibilities to ensure the accuracy and  relevance of the DMA and the selection of DPs for inclusion in the  sustainability statement. The Board of Directors bears the ultimate  responsibility for reviewing the DMA, ensuring that all relevant IROs  have been captured. Before being presented to the Board of Direc-  tors, the DMA is up for review and approval by the ESG Body and  Audit Committee.  In preparation for the ESRS being implemented in 2025, we have  performed a DMA during the reporting period. To the extent  possible, we seek to base all our rankings on objective criteria,  however, we do see several IROs needing to be evaluated based on  judgement using internal stakeholders with expertise in the areas.  Our DMA has followed three steps inspired by the published imple-  mentation guidance from EFRAG:  Step 1: Understanding the context of our operations.  ⢠Mapping of our activities, products/services and geographic loca-  tions of these activities.  ⢠Mapping of business relationships and upstream/downstream  value chain.  ⢠Mapping of affected stakeholders across our activities and busi-  ness relationships.  Step 2: Identifying the actual and potential  IRO related to sustainability matters.  ⢠Creating a, to the extent possible, complete list of IROs for further  assessment and analysis. In addition to the sub-topic list provided  by the ESRS following AR 16, which serves as a guide for topics to be  considered in the assessment, NORDEN leverages IMO, SASB, GRI  and MSCI sustainability reporting frameworks for the identification  of sector/entity-specific matters.  Step 3: Assessing and determining the material  IROs related to sustainability matters.  ⢠Applying objective criteria using appropriate quantitative and/  or qualitative thresholds to assess the materiality of current and  potential impacts. Materiality is based on severity and, for poten-  tial impacts, likelihood. All IROs are assessed on a gross basis.  ⢠The criteria are scale, scope and irremediable character of the  impact, for actual negative impacts. For potential and actual  positive impacts, we will include an estimate of the likelihood of  occurrence.  ⢠Financial materiality to be assessed based on objective thresholds  for likelihood and magnitude. We are evaluating whether the IROs  have a material impact on financial position, cash flows or access  to capital/impact on the cost of capital.  Our primary focus has been on conducting in-depth internal ana-  lyses and leveraging established industry frameworks and regula-  tory guidelines (such as IMO, SASB, and MSCI) to identify and assess  the impacts, risks, and opportunities (IROs) related to the DMA. This  strategic emphasis ensured that our internal processes were thor-  oughly developed and robust before initiating deeper stakeholder  engagement.  Waiting on the sector-specific disclosure requirements under the  ESRS, NORDEN has initially identified relevant sustainability matters  leveraging existing sector-specific sustainability reporting stand-  ards such as the SASB Marine Transportation and the MSCI ESG  materiality map. Additionally, we have used regulations enforced  by the IMO for guidance (e.g. guidelines of biofouling), arguing that  IMO regulation is centred around mitigating the key impacts of the  shipping industry.  Impact materiality  The impact materiality assessment is based on the three criteria  for severity: scale, scope and irremediability as well as likelihood.  Scores are considered continuous within their ranges from 0-5.  Scores for each IRO were averaged between severity and likelihood  to generate a final impact materiality score.  Financial materiality  Risk and opportunities are rated based on the principles for financial  materiality. The assessment is based on two criteria: the likelihood  of occurrence and the potential magnitude of financial effects in  the short, medium and long term. Size of impact is based on the  expected impact on net profit. The overall score is based on the  average between likelihood and size.  DMA process and results  After developing the framework for evaluating materiality, we  organised three dedicated workshops focusing on Environmental,  Social and Governance topics. The primary goal of these workshops  was to assess the materiality of each identified IRO by leveraging the  expertise of topic owners and in-house specialists.  Prior to the workshops, participants were provided with briefing  documents that included a full list of IROs, detailed scoring criteria,  and summaries of relevant research findings. This preparation  ensured that all attendees had a clear understanding of the assess-  ment framework and were ready to contribute effectively to the  discussions.  During the workshop, each IRO was presented along with any avail-  able data and supporting research. Participants engaged in struc-  tured discussions, sharing insights based on their areas of expertise.  For topics with clear and established research on the impacts of the  industry (mainly climate change, air pollution and invasive species),  materiality was recognised based on existing literature and industry  consensus, aligning with the EFRAG guidelines. No further internal  analysis was conducted of these topics, as their significance was  already well-documented.  For other topics with less clarity regarding their impacts, the team  performed qualitative assessments. They relied on their professional  judgement, supported by existing reporting frameworks, studies  within specific sub-topics, and comparisons with industry peers. This  approach allowed us to evaluate the severity and likelihood of each  IRO in the absence of extensive quantitative data.  Scores were assigned through participant consensus, ensuring  that diverse perspectives were considered and that the evaluations  were balanced and objective. The workshops resulted in a list of  material IROs for each ESG dimension. All IROs are categorised as  short, medium or long term. NORDEN defines short term as current  reporting period, mid term as within a time frame of five years and  long-term as a time frame exceeding 5 years.  As a result of the double materiality process, we identified the  following six topical standards of the ESRS as material:  ⢠Climate change  ⢠Pollution  ⢠Biodiversity &amp; ecosystems  ⢠Own workforce  ⢠Workers in the value chain  ⢠Business conduct  While these topics are considered material and are included in our  Sustainability Statement, we have assessed other topics from the  ESRS and determined that E3, E5, S3, and S4 are non-material for  NORDEN. Below, we provide detailed reasoning for their exclusion:  E3 Water and Marine Resources: NORDEN's operations involve  maritime transportation, which primarily occurs on international  waters and within port facilities. Our vessels do not engage in signifi-  cant water withdrawal activities from freshwater sources. Water used  on board is minimal and primarily for domestic purposes, sourced  from port facilities where it is already treated and regulated.  E5 Resource Use and Circular Economy: Waste generated  includes operational waste (e.g., packaging, maintenance waste)  and domestic waste from crew activities. The primary materials  consumed in our operations are fuels, which are addressed under  E1: Climate Change and E2: Pollution. Other material consumption,  such as lubricants, paints, and maintenance supplies, is minimal in  quantity. Generally, shipping is not a very waste-intensive industry  making the topic less relevant for us.  S3 Affected Communities: NORDENâs operations are primarily  conducted offshore and within established port facilities, which are  industrial areas with existing infrastructure and regulations. Our  interactions with local communities are limited. We do see some  interaction with local communities in our upstream value chain  from shipyards and in our logistics project in Gabon. However, the  scale and scope of those operations do not justify an inclusion in  our external reporting. S3 is a topical standard that could become  material if we scale our logistics business significantly.  S4 Consumers and End-users: NORDEN does not produce  consumer goods or products that are consumed or used by  end-users in the traditional sense. Our services facilitate the trans-  portation of goods owned by our customers. Hence, the topical  standard is not relevant for us.  We keep monitoring these areas and will reassess their materiality  annually or if circumstances change. Should any of these topics  become more relevant due to operational changes, stakeholder  concerns or emerging risks, we will update our materiality assess-  ment accordingly.  Limitations and areas for further clarification  While NORDEN has undertaken a comprehensive DMA, there  are several areas where the impacts of our operations remain  challenging to fully identify, assess, or quantify. These limitations  primarily arise due to the following factors:  We are aware that our operations, particularly maritime transport,  contribute to noise pollution, which can have adverse effects on  marine life and nearby communities. However, at present, we do  not have sufficient data to evaluate the scope or scale of this impact  accurately. In the absence of concrete data, we have applied a best  guess approach in our assessment, acknowledging the limitations  of this method. We are open to adopting new research and method-  ologies as they emerge, and we plan to reevaluate this impact once  more robust data or assessment tools become available.  Certain sustainability matters, such as biodiversity impacts, are  areas where scientific understanding and industry best practices  are still evolving. While we recognise the potential significance of  these issues, the long-term impacts, especially in relation to specific  ecosystems, are not yet fully understood or quantifiable.  NORDEN will perform a yearly reassessment of the DMA to ensure  that our materiality assessments remain current and reflective of  both internal and external changes. Key triggers for reassessment  will include the availability of new research and data, mergers and  acquisitions (M&amp;A) activity, or the initiation of new logistics projects.  These events may introduce new IROs or shift the scale and scope  of existing impacts, requiring a fresh evaluation of our sustainability  matters.  and subtracting 20%. Alignment with the screening EEDI criteria  requires that a vesselâs EEDI is 10% below the required EEDI, i.e. 10%  below the phase 3 IMO EEDI requirement. During the financial year  2024, NORDEN operated one vessels aligned with the EEDI criteria.  All of these are eligible for running on biofuel as per certification  from the Danish Maritime Authorities (Søfartsstyrelsen) to run at a  100% biofuel capacity. Therefore, solely vessels under the Danish  International Ship Register (DIS) are subject to alignment, as certi-  fication for 100% biofuel consumption has not been obtained by  other flag authorities. NORDEN notes that all its vessels can run at  30% biofuel capacity without pre-certification from any flag state.  Having secured alignment with the technical criteria under the  objective of climate mitigation, we assess whether the activity does  harm to any of the remaining environmental objectives, i.e., live up to  all the DNSH criteria. Below is a review of NORDENâs alignment with  the remaining five objectives:  Climate adaptation  Activity number 6.10 is expected to be affected by changing temper-  atures, leading to more frequent extreme weather events (e.g.  drought or storms) and scarcity of water, impacting trade patterns  and volumes.  NORDEN does not consider physical climate risks to have a material  impact on its economic activity. This is due to our agile operator  model, allowing us to comply with and adapt to changing trade  patterns.  NORDEN intends to leverage its use of data to improve predictions  and decision-making, mitigating the impact on its business relative  to its peers. In addition, we intend to expand our logistics offering  beyond tramp shipping via the Assets &amp; Logistics business unit.  The IPCC has five major climate scenarios: RCP 1.9, 2.6, 4.5, 6 and  8.5. RCP 1.9 would impose limited climate risks, but heavy transi-  tional risks for NORDEN (following the Paris agreement), while RCP  8.5 would increase the physical climate risks as the frequency and  intensity of extreme weather would surge. This could potentially  lead to margin erosion as the risks of damage to ships and cargo  increase. NORDEN intends to mitigate the risks related to climate  change by extensive use of weather routing systems when pricing,  securing appropriate insurance coverage and assessing the risk of  freight contracts as well as including chronicle risks when evaluating  business opportunities.  Based on the assessment above, we believe NORDEN is aligned with  the generic climate adaptation criteria for DNSH.  Water  NORDEN is monitoring and assessing the impact of our operation  on marine life. As part of our adaption of the SASB Marine Transpor-  tation reporting standard, we report on the share of owned vessels  having implemented ballast water treatment systems (BWTS),  voyage duration in marine-protected areas and oil spills. These are  all considered relevant issues to NORDEN. Having a high percentage  of our vessels with BWTS, we avoid the risk of invasive species. We  reduce water pollution using best management practices/policies  aligned with the Directive 2000/60/EC stating that companies  should take measures to prevent, reduce and control water pollu-  tion. NORDEN follows IMO standards for all its operations and  considers IMOâs regulation on water regulation to be adequate in  terms of doing no significant harm to the waters in which we sail.  Based on the review above, we believe NORDEN is aligned with the  generic water criteria for DNSH.  Circular economy  Aligned with Regulation (EU) No 1257/2013, NORDEN has imple-  mented waste management plans and uses the best techniques  available to reduce the environmental impact of waste management.  NORDEN keeps track of the waste generated on board vessels and  the disposal of such via the onboard logbooks, which are reported  to the technical managers.  NORDENâs business model involves operating a modern fleet  of vessels, selling and redelivering vessels long before vessel  end-of-life. Should NORDEN face situations in which recycling of  a vessel is relevant, NORDEN has a Responsible Ship Recycling  Policy meaning we have measures in place to manage waste at the  end-of-life of the vessel.  NORDEN complies with Annex V. This requires ships to take meas-  ures to prevent accidental loss of garbage and to have equipment on  board to collect and store garbage, as well as procedures to ensure  that it is disposed of properly. Annex V is enforced by the IMO and is  thus a standard in the shipping industry.  Pollution prevention  All technical criteria under the objective are considered IMO stand-  ards. Thus, NORDEN is required to comply.  Based on the review above, we believe NORDEN is aligned with the  generic pollution prevention criteria for DNSH.  Biodiversity  All technical criteria under the objective are considered IMO stand-  ards. Thus, NORDEN is required to comply. Based on the review  above, we believe NORDEN is aligned with the generic biodiversity  criteria for DNSH.  Minimum safeguards  The OECD Guidelines are considered a standard for responsible busi-  ness conduct. The guidelines cover a wide range of issues, including  labour rights, bribery and corruption, environmental protection  and human rights. NORDEN has human rights policies aligning with  the OECD and UN Guidelines and is deeply involved in securing an  anti-corruption foundation for shipping with its activities involving  MACN and focusing on educating its employees in anti-bribery via  e-learning courses. Mash Makes works continuously to ensure that  employees enjoy safe, healthy and fair working conditions.  In line with these commitments, NORDEN has implemented a  rigorous due diligence process to identify and address salient  human rights risks in its operations. This process involved  conducting multiple interviews with employees and managers,  providing an in-depth understanding of the potential risks related  to NORDEN's activities. The findings from these interviews, along  with proposed preventive and mitigating actions, were thoroughly  reviewed and approved by NORDEN's ESG owner.  Based on such argumentation, we believe NORDEN is aligned with  the minimum safeguards criteria that enable EU Taxonomy-aligned  activities reporting under both activity numbers 4.13 and 6.10.  POLICIES  Anti-Corruption Compliance Programme: The purpose is to ensure  compliance with key anti-corruption legislation, mitigate NORDENâs  reputational risks and guide employees in what is expected when  working for NORDEN. The policy applies to all employees and the  Board of Directors. Ownership and enforcement of the programme  rest with the Head of Asset Management, and the programme is  accessible on the Intranet and described in the Employee Code of  Conduct.  Anti-Harassment Policy: NORDEN is committed to ensuring all  employees are treated equally and with respect, safeguarded from  harassment, abuse and violence in the workplace, regardless of their  background or characteristics. This applies to all forms of harass-  ment, whether physical, verbal, sexual or psychological, and includes  all NORDEN employees and contractors. The policy, overseen by the  Head of People &amp; Sustainability, extends to any work-related setting  and is integral to our corporate culture. It is detailed on our website,  Intranet and in the Employee Code of Conduct.  Climate Mitigation Policy: The policy states our commitment  to achieving net-zero emissions by 2050 across all GHG scopes,  describing how we measure and reduce emissions through initia-  tives such as lower vessel speeds, regular hull cleanings, and the use  of biofuels. Ownership and enforcement of the policy rest with the  COO of Assets and Logistics, and it is available on our website.  Data Ethics Policy: The policy states our data ethics principles,  describing how we collect, store, process and protect data for the  benefit of our employees, customers, business partners and other  stakeholders. This Data Ethics Policy applies to all employees and  has been prepared in accordance with GDPR requirements and  section 99 d of the Danish Financial Statements Act. Ownership  and enforcement of the policy rest with the CFO, and it is available  on our website https://norden.com/investor/governance/poli-  cies-and-charters.  Diversity, Equity &amp; Inclusion Policy: NORDEN is committed to  respecting and promoting diversity, offering equal opportunities  and ensuring fair treatment for all employees. We strictly oppose  any form of discrimination, whether based on race, gender identity,  religion, political views or any other distinguishing characteristics.  Our employment practices, including hiring, remuneration, training  and advancement, are governed by relevant and objective criteria.  The policy, overseen by the Head of People &amp; Sustainability, applies  to every NORDEN employee and is detailed on our website, Intranet  and in the Employee Code of Conduct. In compliance with Ã
RL 107d.  Employee Code of Conduct: NORDEN's Employee Code of  Conduct outlines the ethical, social and environmental standards  all employees are expected to follow. It serves as a guide for deci-  sion-making and maintaining high standards of business conduct.  The Code encompasses policies that reinforce NORDEN's commit-  ment to sustainability and supersedes less stringent laws or regula-  tions. Ownership and enforcement of the Code rest with the Head of  People &amp; Sustainability. It is accessible on the Intranet, provided to  new hires during onboarding and must be acknowledged annually  to ensure comprehension of any updates.  Flexible Woking Policy: NORDEN values flexibility, offering remote  work and flexible hours to foster work-life balance and inclusivity.  This policy, suited to all employees, balances flexibility with main-  taining connectivity, innovation and performance. Office presence  may be required for certain roles and situations. The policy is  approved by the Head of People &amp; Sustainability and is available on  our Intranet.  Health and Safety Policy: NORDEN prioritises a safe and healthy  workplace, addressing physical, emotional, mental and spiritual  well-being. We aim to exceed legal standards and align with ILO  principles on workplace health and safety. This policy, overseen by  the Head of People &amp; Sustainability, applies to all employees and  is detailed on our website, Intranet and in our Employee Code of  Conduct.  Human Rights Policy: NORDEN is committed to upholding human  and labour rights as outlined in the International Bill of Human  Rights and the International Labour Organisation's Declaration.  This encompasses rights related to compensation, labour practices,  privacy, association, religion and work hours. The Head of People &amp;  Sustainability ensures these principles are integrated into our culture  and practices. The policy is detailed on our website, Intranet and  in our Employee Code of Conduct. We expect all employees and  business partners to adhere to these standards, reinforced through  our Responsible Supply Chain Management process, Supplier Code  of Conduct and Technical Manager Code of Conduct.  Modern Slavery Act: Conducting business in a legal, ethical and  socially responsible manner is core to NORDEN and in line with our  values. We are committed to ensuring that modern slavery or human  trafficking does not occur in any part of our business or supply  chain. NORDENâs framework for respecting human and labour  rights is operationalised by the UN Guiding Principles on Business  and Human Rights (UNGP), which draws on the International Bill of  Human Rights, the International Labour Organisationâs Declaration  of Fundamental Principle and Rights at Work and the Rio Declaration  on Environment and Development. Ownership and enforcement rest  with the Head of People &amp; Sustainability, and the policy is available  on NORDENâs website, Intranet and described in our Employee  Code of Conduct.  Sanctions Compliance Programme: NORDEN's Sanctions Compli-  ance Programme is implemented to ensure that NORDEN, its affili-  ated companies and employees do not engage in any transactions  in breach of the sanctions policy. The sanctions policy is defined by  the Board of Directors, and it is the responsibility of the Head of Risk  Management to ensure the Sanctions Compliance Programme is  followed and the sanctions policy is implemented and available on  our Intranet.  Supplier Code of Conduct: The Supplier Code of Conduct supports  NORDEN in building a sustainable practice by establishing systems  and processes to manage our adverse impacts on human and labour  rights, environment and anti-corruption through our purchasing  practices. NORDEN expects all our suppliers, at any time, to be able  to declare in writing their stage of implementation. Ownership and  enforcement of the Code rest with the Head of Procurement and is  part of the contractual agreement. The Supplier Code of Conduct is  available on our website https://norden.com/investor/governance/  policies-and-charters.  Tax Policy: The purpose of the Tax Policy is to define the global  management of taxes, including governance and structuring. As  part of NORDENâs responsible approach to tax, NORDEN aims  to increase sustainable growth and value creation for society and  our stakeholders through reliable and effective tax management.  NORDEN uses the arm's length principle of pricing in line with OECD  Transfer Pricing Guidelines for Multinational Enterprises and Tax  Administration and applies this consistently across our businesses.  The Board of Directors of NORDEN approves general tax principles  and exercises governance over corporate tax affairs through regular  updates on our tax positions. Ownership and enforcement of the  policy rest with the CFO and the policy is available on our website.  Technical Manager Code of Conduct: NORDEN's Technical Manager  Code of Conduct outlines the ethical, social and environmental  standards which all NORDENâs technical managers are expected  to follow. It serves as a guide for maintaining high standards of  business conduct. The Code encompasses policies that reinforce  NORDEN's commitment to sustainability and supersedes less  stringent laws or regulations. Ownership and enforcement of the  Code rest with the Head of Technical Management, and it is part of  the basis for the contract between the parties and must be acknowl-  edged by the technical managers annually to ensure comprehension  of any updates.  Whistleblower scheme: NORDEN promotes a speak-up culture  where employees are encouraged to report misconduct without fear  of retaliation. This applies to everyone associated with NORDEN,  including workers in our value chain and external partners. Reports  can be made anonymously and are managed by the Head of Group  Legal and the Board of Directors. The whistleblower scheme is  detailed on our website, Intranet and in our Employee Code of  Conduct.  Template 1 in Annex XII under the Complementary Delegated Act  Nuclear energy-related activities  1.  The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative electricity generation facilities that produce energy from  No  nuclear processes with minimal waste from the fuel cycle.  2.  The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for the purposes  No  of district heating or industrial processes such as hydrogen production, as well as their safety upgrades, using best available technologies.  3.  The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity or process heat, including for the purposes of district  No  heating or industrial processes such as hydrogen production from nuclear energy, as well as their safety upgrades.  Fossil gas-related activities  4.  The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels.  No  5.  The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels.  No  6.  The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels.  No  </mrv:SustainabilityReport>
<mrv:StatementOfCorporateSocialResponsibility contextRef="ctx2" id="fact4078" xml:lang="en">Reporting standards  Although NORDEN is not currently required to report under the  ESRS due to having fewer than 500 full-time employees on average,  we have proactively aligned our sustainability disclosures with the  topical standards to ensure comparability, enhance transparency,  and a seamless transition into fully compliant CSRD reporting.  During the year, we carried out our Double Materiality Assess-  ment (DMA) in accordance with EFRAG implementation guidelines  and received pre-assurance from the Groupâs auditors that the  process used by Management to identify reported information is in  conformity with the ESRS 2 IRO-1. This forward-looking approach  positions NORDEN well for the 2025 reporting year, when the ESRS  will become mandatory for the Group.  In line with our commitment to transparency and reliability, NORDEN  has also obtained limited assurance on selected material metrics  and targets that correspond to the ESRS data points. These can be  found in the ESRS index on page 83.  Double materiality assessment:  Following the double materiality process, we have identified  sub-topics within the six topical standards of the ESRS to be material:  ⢠E1: Climate Change  ⢠E2: Pollution  ⢠E4: Biodiversity &amp; Ecosystems  ⢠S1: Own Workforce  ⢠S2: Workers in the Value Chain  ⢠G1: Business Conduct  We provide a more detailed explanation of exclusion of topical  standards in the DMA process description, which can be found in  our accounting policies.  and route planning. By distinguishing between operated and  chartered-out voyages, we can identify the impact of our efforts,  while still taking responsibility for all tonnage that we deliver to our  customers by reporting EEOI based on all assets.  During 2024, the tank-to-wake (TTW) EEOI on all assets decreased  from 9.0 grams CO2/tonne-mile to 8.5, corresponding to a decrease  of 6%. The EEOI reduction is impacted by the decision to trade up  in vessel sizes with capesize accounting for 10% of transport work  in 2024 vs. 2% in 2023. After adjusting for changes to fleet compo-  sition, the EEOI has decreased from 8.8 to 8.5 corresponding to a  decrease of 3%.  The decrease on a like-for-like basis is mainly driven by higher cargo  utilisation and a higher share of renewables, while being offset by  lower laden utilisation and slightly higher speed. The development  </mrv:StatementOfCorporateSocialResponsibility>
<mrv:DescriptionofTheTaxonomyRegulation contextRef="ctx2" id="fact4135" xml:lang="en">Key metrics  2024  2023  % TTW EEOI (g CO2/tonne-mile)  8.5  9.0  -6%  WTW EEOI (g CO2e/tonne-mile)  9.9  10.7  -7%  Cargo hold utilisation  82.3%  81.4%  0.9%p  Laden utilisation  74.8%  78.2%  -3.4%p  Avg. speed (kts)  11.3  11.3  0%  Avg. fleet (dwt)  73,501  61,316  20%  Renewable fuel share  0.3%  0.1%  0.2%p  Breakdown of EEOI by vessel and type  2024  2023  WTW Ops  TTW Ops  TTW  WTW Ops  TTW Ops  TTW  % TTW all assets  Multi-purpose  29.8  25.0  27.6  28.5  23.9  23.9  15.5%  Handysize  11.7  9.8  9.8  11.6  9.8  9.9  -0.9%  Supramax  8.4  7.1  7.2  8.2  6.9  7.1  1.9%  Panamax  8.6  7.2  7.4  8.4  7.1  7.4  -0.7%  Capesize  5.4  4.5  4.7  7.3  NM  Dry cargo  9.0  7.5  7.7  9.2  7.8  7.9  -2.9%  Fleet-adjusted  9.0  7.5  7.7  8.8  7.4  7.9  -3.3%  Handysize T  26.9  22.4  22.8  27.5  23.0  22.9  -0.6%  MR  16.6  13.9  14.1  17.4  14.6  14.5  -2.7%  LR2  7.8  6.5  6.6  6.0  5.1  5.1  28.4%  Tankers  16.5  13.9  14.0  17.9  15.0  14.8  -5.1%  Fleet-adjusted  16.5  13.9  14.0  17.2  14.5  14.4  -2.5%  Total  9.9  8.3  8.5  10.7  8.9  9.0  -5.6%  Fleet-adjusted  9.9  8.3  8.5  9.9  8.3  8.8  -3.2%  regulatory developments illustrate the complex interplay between  reducing atmospheric pollution and protecting water quality.  Another complexity is related to our ambition to improve fuel effi-  ciency and reduce the EEOI by applying anti-fouling paint. This  is a special coating applied to the hull and, in some cases, to the  propeller of a vessel to slow the growth and facilitate detachment  of subaquatic organisms, commonly known as fouling, which attach  to the hull and have a substantial impact on the vessel's hydrody-  namic performance. Specifically, it will result in increased resist-  ance through the water due to elevated friction resulting from the  considerably rougher hull surface caused by the fouling. As a direct  consequence, fuel consumption is expected to rise significantly.  While improving fuel efficiency, and hence reducing the relative  CO2e emissions from vessel operation, there is an increased risk of  water pollution related to the biocide effect of persistent anti-fouling  components. The industry started to have more focus on this topic,  and new biocide-free coatings are already in the market, but the  effectiveness to prevent fouling growth is still yet to be proven.  Pollution policy  NORDEN is following the industry standard enforced by the IMO.  This approach ensures that we remain aligned with the best avail-  able practices while we await regulation from policymakers. Not  complying with the regulation of the IMO may lead to financial  penalties, while potentially hurting business relationships by not  demonstrating commitment to environmental compliance. Both are  considered material financial risks.  Development by air pollutant type  Metric  2024  2023  NOX  115,290  101,678  SOX  11,284  9,894  PM2.5  5,239  4,546  NVMOC  4,751  4,147  HM  76  70  Development in pollutants in water  Metric  2024  2023  HM  62  29  PAH  2 1 EU Taxonomy  Turnover  NORDENâs revenue-generating activities are generally consid-  ered eligible. Revenue from time chartered-out vessels (TCO) and  subleases as well as income earned from the administration of pool  arrangements are not considered eligible. The latter is reported as  part of 'Other operating income' in the Consolidated Financial State-  ments. The reported turnover corresponds to 'Revenue - services  rendered, external', which can be found in the '2.1 Segment informa-  tion' note. Aligned turnover increased from USD 6m in 2023 to USD  14m in 2024 (0%).  Capital expenditures  CapEx as defined in the Taxonomy is considered equivalent to the  'additions' and 'prepayments on vessels and newbuildings', as set  out in note 3.4 to the Consolidated Financial Statements, and addi-  tions to 'Right-of-use assets' as set out in note 3.5 to the Consoli-  dated Financial Statements. CapEx incurred is generally considered  eligible, except if CapEx is incurred directly relating to chartering  out vessels. 0% of CapEx was aligned in 2024, down from 4% in  2023, which was impacted by the Mash Makes acquisition.  Operating expenditures  OpEx as defined in the Taxonomy covers expenditures directly related  to chartering, maintaining and operating vessels, and is equivalent  to 'Vessel operating costs' as presented in the "income statement" in  the Consolidated Financial Statements less operating costs for owned  vessels and daily running costs for leased vessels (expenses related  to the service component in note 3.5). OpEx incurred is generally  considered to be eligible under the Taxonomy, except if relating to  owned vessel OpEx or vessels chartered out. NORDEN includes costs  related to the bunker, as these are considered crucial for the effective  functioning of the asset (time-chartered vessels on short-term leases).  There has been no change in the aligned OpEx from 2023 to 2024,  since the costs included are based on time-chartered vessels, where  NORDEN has no documentation on the vessel's EEDI.  Review of alignment  To align with the EU Taxonomy, eligible economic activities must  a) contribute to one or more of six environmental objectives, b) do  no significant harm (DNSH) to the remaining objectives and c) meet  the minimum social safeguards. The six environmental objectives  outlined in the EU Taxonomy are climate change mitigation, climate  change adaptation, sustainable use of water &amp; marine sources,  circular economy, pollution prevention and a healthy ecosystem.  Following the identification of eligible activities, NORDEN has  applied the technical screening criteria under the EU Taxonomy to  evaluate whether our activities are aligned with one of the EU objec-  tives, do no significant harm to other Taxonomy objectives and are  aligned with the minimum social safeguards criteria.  All NORDENâs activities fall under activity number 6.10: 'Sea and  coastal freight water transport, vessels for port operations, and  auxiliary activities'. In the section below, we describe the process of  screening our activities for the technical criteria in the Taxonomy of  each activity in NORDEN.  Activity number 6.10: Sea and coastal freight water transport,  vessels for port operations, and auxiliary activities'  Our assessment of alignment is based on the technical criteria from  substantial contribution to climate change mitigation. Following the  technical criteria, alignment forbids vessels from being dedicated to  the transport of fossil fuels. Therefore, tanker vessels are excluded  from the alignment criteria, despite the ability of tanker vessels  to transport soft oils. This trade is considered immaterial for the  consideration of including some share of product tanker activities as  eligible and potentially aligned. Dry cargo vessels are only subject to  potential taxonomy alignment if the EEDI is 10% below the require-  ment applicable on 1 April 2022, and if the vessels can run based on  zero-direct CO2 emission fuels or on fuels from renewable sources.  The latter includes vessels eligible for running on biofuel (ref: activity  number 4.13).  Currently, NORDEN only has EEDI scores on owned vessels, where  the building contract was placed on or after 1 January 2013, or the  vessel was delivered on or after 1 July 2015. The EEDI scores are  collected from our technical managers. As of 2024, the required EEDI  for bulk vessels is calculated using the IMO reference line equation  ESG PERFORMANCE DATA  SASB Marine transportation index  Topic  Metric  Unit  Code  2024  2023  2022  Greenhouse Gas Emissions  Scope 1 bunker emissions  Metric tonnes (t) CO2e  TR-MT-110a.1  4,396,938  3,834,437  4,271,580  Total energy consumed (TJ)  Terajoules (TJ)  TR-MT-110a.3  57,193  49,901  55,809  Percentage heavy fuel oil  Percentage (%)  TR-MT-110a.3  11.2%  5.9%  7.1%  Percentage renewable  Percentage (%)  TR-MT-110a.3  0.3%  0.1%  0.1%  Average Energy Efficiency Design Index (EEDI) for new vessels  CO2 per capacity-nm  TR-MT-110a.4  2.1  4.3  4.1  Air Quality  NOX  Metric tonnes (t)  TR-MT-120a.1  115,290  101,678  117,620  SOX  Metric tonnes (t)  TR-MT-120a.1  11,284  9,894  10,889  PM10  Metric tonnes (t)  TR-MT-120a.1  5,694  4,941  5,692  Ecological Impacts  Shipping duration in marine-protected areas or areas of protected conservation status  Number of travel days  TR-MT-160a.1  22,203  21,458  23,321  Percentage of fleet implementing ballast water treatment  Percentage (%)  TR-MT-160a.2  100%  100%  95%  Percentage of fleet implementing ballast water exchange  Percentage (%)  TR-MT-160a.2  0%  0%  5%  Number of spills and releases to the environment  Number  TR-MT-160a.3  0 0 0 Aggregate volume of spills and releases to the environment  Number, cubic metres  TR-MT-160a.3  0 0 0 Health &amp; Safety  Lost Time Incident Rate (LTIR)  Rate  TR-MT-320a.1  1.3  1.0  0.8  Number  Business Ethics  Number of calls at ports in countries that have the 20 lowest rankings in Transparency Internationalâs Corruption Perception Index  TR-MT-510a.1  43  58  52  The total amount of monetary losses as a result of legal proceedings associated with bribery or corruption  Reporting currency  TR-MT-510a.2  0 0 0 Accident &amp; Safety Management  Number of marine casualties  Number  TR-MT-540a.1  0 0 2 Percentage classified as very serious (very serious = the total loss of the ship, a death, or severe damage to the environment)  Percentage (%)  TR-MT-540a.1  0%  0%  33%  Number of Conditions of Class or Recommendations  Number TR-MT-540a.2  29  15  15  Number of port state control deficiencies  Number TR-MT-540a.3  38  26  61  Number of port state control detentions  Number TR-MT-540a.3  1 0 1 Number of shipboard employees  Number  TR-MT-000.A  431  461  546  Total distance travelled by vessels  Nautical miles (nm)  TR-MT-000.B  15,867,410  13,989,053  14,219,344  Operating days  Days  TR-MT-000.C  200,557  196,388  203,674  Deadweight tonnage  Thousand DWT  TR-MT-000.D  1,725  1,573  1,201  Number of vessels in total shipping fleet  Number  TR-MT-000.E  14  19  21  Number of vessel port calls  Number  TR-MT-000.F  9,738  9,496  10,139  Twenty-foot equivalent unit (TEU) capacity  TEU  TR-MT-000.G  NA  NA  NA  ESRS index  Disclosure  Section  Sub Section  Metric  Unit  requirement  2024  2023  2022  E1 - Climate change  Energy consumption and mix  Fuel consumption from crude oil and petroleum products  MWh  ESRS E1-5  15,844,670  13,861,565  15,492,959  Fuel consumption for renewable sources  MWh  ESRS E1-5  42,140  19,790  14,470  Energy intensity  USD / MWh  ESRS E1-5  254  266  343  Gross scopes 1, 2, 3 and total GHG emissions  Gross Scope 1 GHG Emissions  Metric tonnes (t) CO2 eq  ESRS E1-6  4,396,938  3,834,437  4,271,580  Gross Scope 2 GHG Emissions  Location based  Metric tonnes (t) CO2 eq  ESRS E1-6  522  418  531  Market based  Metric tonnes (t) CO2 eq  ESRS E1-6  427  348  NA  Gross Scope 3 GHG Emissions  Metric tonnes (t) CO2 eq  ESRS E1-6  3,499,026  3,693,383  3,826,419  Total Gross GHG Emissions  Location based  Metric tonnes (t) CO2 eq  ESRS E1-6  7,896,487  7,528,238  8,113,403  Market based  Metric tonnes (t) CO2 eq  ESRS E1-6  7,896,392  7,528,168  NA  GHG emissions intensity  Location based  USD/Metric tonnes (t) CO2 eq ESRS E1-6  512  490  655  Market based  USD/Metric tonnes (t) CO2 eq ESRS E1-6  512  490  NA  E2 - Pollution  Pollution of air, water and soil  NOX  Metric tonnes (t)  ESRS E2-4  115,290  101,678  117,620  SOX  Metric tonnes (t)  ESRS E2-4  11,284  9,894  10,889  PM2.5  Metric tonnes (t)  ESRS E2-4  5,239  4,546  5,236  NVMOC  Metric tonnes (t)  ESRS E2-4  4,751  4,147  4,636  Heavy metals in air  Metric tonnes (t)  ESRS E2-4  76  70  76  Heavy metals in water  Metric tonnes (t)  ESRS E2-4  62  29  38  PAHs  Metric tonnes (t)  ESRS E2-4  2 1 1 G1 - Business conduct  Confirmed incidents of corruption or bribery  The total number and nature of confirmed incidents of corruption or bribery  # ESRS G1-4  0 0 0 The number of convictions and the amount of fines for violation of anti-corruption and  antibribery laws  # ESRS G1-4  0 0 0 Total GHG emissions disaggregated by scopes 1 and 2 and material scope 3 categories  Retrospective  Target years  '000 metric tonnes  Base year  N-1  N = 2024  % N / N-1  2025  2030  2050  Scope 1 GHG emissions  Gross Scope 1 GHG emissions (tCO2e)  4,287  3,834  4,397  15%  NA  NA  0 Percentage of scope 1 GHG emissions from regulated emission trading schemes (%)  NA  NA  NA  NA  NM  NM  NM  Scope 2 GHG emissions  Gross location-based scope 2 GHG emissions (tCO2e)  0.4  0.4  0.5  25%  NA  NA  0 Gross market-based scope 2 GHG emissions (tCO2e)  NA  0.3  0.4  23%  NA  NA  0 Material Scope 3 GHG emissions  Total gross indirect (scope 3) GHG emissions (tCO2e)  3,826  3,693  3,499  -5%  NA  NA  0 GHG 1: Purchased goods and services  266  187  147  -22%  NA  NA  0 GHG 2: Capital goods  6 18  5 -15%  NA  NA  0 GHG 3: Fuel and energy-related activities  904  823  900  9%  NA  NA  0 GHG 13: Downstream leased assets  2,650  2,665  2,448  -8%  NA  NA  0 Total GHG emissions  Total GHG emissions (location-based) (tCO2e)  8,125  7,515  7,878  5%  NA  NA  0 Total GHG emissions (market-based) (tCO2e)  NA  7,515  7,878  5%  NA  NA  0 EU Taxonomy  Turnover  USDm  % Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL  Y/N  Y/N  Y/N  Y/N  Y/N  Y/N  Y/N  % E T A. TAXONOMY-ELIGIBLE ACTIVITIES (A.1. + A.2.)  A.1. Environmentally sustainable activities (Taxonomy-aligned) (A.1)  Sea and coastal freight water transport  CCM 6.10  14  0%  Y N N N N N Y Y Y Y Y Y Y 0%  E - Turnover of environmentally sustainable activities  (Taxonomy-aligned) (A.1)  14  0%  0%  0%  0%  0%  0%  0%  Y Y Y Y Y Y Y 0%  Of which enabling  14  0%  0%  0%  0%  0%  0%  0%  Y Y Y Y Y Y Y 0%  E Of which transitional  0 0%  0%  A.2 Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)  Sea and coastal freight water transport  CCM 6.10 3,139  79%  EL  Turnover of Taxonomy-eligible but not environmentally  sustainable activities (not Taxonomy-aligned activities) (A.2)  3,139  79%  79%  0%  0%  0%  0%  0%  78%  Total turnover of Taxonomy-elgible activities (A.1 + A.2)  3,153  79%  B. TAXONOMY-NON-ELIGIBLE ACTIVITIES  Turnover of Taxonomy non-eligible activities  815  21%  Total (A+B)  3,968  100%  CapEx  USDm  % Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL  Y/N  Y/N  Y/N  Y/N  Y/N  Y/N  Y/N  % E T A. TAXONOMY-ELIGIBLE ACTIVITIES (A.1. + A.2.)  A.1. Environmentally sustainable activities (Taxonomy-aligned) (A.1)  Sea and coastal freight water transport  CCM 6.10  0 0%  Y N N N N N Y Y Y Y Y Y Y 0%  E - Manufacture of biogas and biofuels for use in  transport and of bioliquids  CCM 4.13  0 0%  Y N N N N N Y Y Y Y Y Y Y 4%  E - CapEx of environmentally sustainable activities  (Taxonomy-aligned) (A.1)  0 0%  0%  0%  0%  0%  0%  0%  Y Y Y Y Y Y Y 4%  Of which enabling  0 0%  0%  0%  0%  0%  0%  0%  Y Y Y Y Y Y Y 4%  E Of which transitional  0 0%  0%  A.2 Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)  Sea and coastal freight water transport  CCM 6.10  525  100%  EL  CapEx of Taxonomy-eligible but not environmentally  sustainable activities (not Taxonomy-aligned activities) (A.2)  525  100%  100%  0%  0%  0%  0%  0%  96%  Total turnover of Taxonomy-eligible activities (A.1 + A.2)  525  100%  B. TAXONOMY-NON-ELIGIBLE ACTIVITIES  CapEx of Taxonomy non-eligible activities  2 0%  Total (A+B)  527  100%  OpEx  USDm  % Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL Y;N;N/EL  Y/N  Y/N  Y/N  Y/N  Y/N  Y/N  Y/N  % E T A. TAXONOMY-ELIGIBLE ACTIVITIES (A.1. + A.2.)  A.1. Environmentally sustainable activities (Taxonomy-aligned) (A.1)  Sea and coastal freight water transport  CCM 6.10  0 0%  Y N N N N N Y Y Y Y Y Y Y 0%  E OpEx of environmentally sustainable activities  (Taxonomy-aligned) (A.1)  0 0%  0%  0%  0%  0%  0%  0%  Y Y Y Y Y Y Y 0%  Of which enabling  0%  0%  0%  0%  0%  0%  0%  Y Y Y Y Y Y Y 0%  E Of which transitional  0%  0%  A.2 Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities)  Sea and coastal freight water transport  CCM 6.10 2,422  75%  EL  OpEx of Taxonomy-eligible but not environmentally  sustainable activities (not Taxonomy-aligned activities) (A.2)  2,422  75%  75%  0%  0%  0%  0%  0%  75%  Total turnover of Taxonomy-eligible activities (A.1 + A.2)  2,422  75%  B. TAXONOMY-NON-ELIGIBLE ACTIVITIES  OpEx of Taxonomy non-eligible activities  822  25%  Total (A+B)  3,245  100%  </mrv:DescriptionofTheTaxonomyRegulation>
<mrv:StatementOfTargetFiguresAndPoliciesForTheUnderrepresentedGender contextRef="ctx2" id="fact5313" xml:lang="en">Diversity in Management  Management  level  Metric  2024  2023  Total number of members  6 6 Board Percentage of underrepresented gender  33%  33%  Target figures in percentage  40%  40%  Year of achievement of target figure  2025  2025  In addition to our strategic work on diversity across Management,  we launched a leadership development programme in 2024 called  Leadership Essentials, which aims to define what good leadership  looks like in NORDEN. All managers across levels and locations will  be trained during 2024 and 2025, and newly hired and promoted  managers will be introduced and trained continuously through our  distinguished onboarding programme New@NORDEN. The Lead-  ership Essentials training programme is designed to strengthening  an inclusive leadership community and develop the manager traits  crucial for successful leadership in NORDEN, giving managers  hands-on training in translating the Leadership Essentials into  everyday behaviour and decision-making.  Furthermore, NORDEN re-introduced its trainee programme in  collaboration with Danish Shipping which will, along with the current  graduate programme in Singapore and the student worker scheme,  strengthen our diversity in educational backgrounds and spread  across age groups, while ensuring an ongoing talent pipeline of the  next shipping generation in NORDEN.  On an industry level, NORDEN aims to empower the diversity  agenda through Women in Shipping (WIS), a professional network  with the aim of achieving more diversity and equality within the  industry. NORDEN is represented by CEO Jan Rindbo as an Advisory  Network member and Sofie Schønherr as Board Member.  Metrics and targets  NORDEN tracks performance within DE&amp;I as a material topic  through four indicators: Engagement score, diversity, turnover rate  and retention rate. Additionally, we measure supporting indica-  tors such as new hires and job level share of the least represented  gender.  Engagement score  NORDENâs overall employee engagement score was 84 in 2024 â  same level as in 2023. The score is above our ambition of 80, while  exceeding the global benchmark provided by Ennova, which bench-  marks against all industries for each of the four indicators. NORDEN  performs well within the sub-categories 'engagement' and 'develop-  ment'. The response rate of our survey was 98%.  Our survey indicated lowest performance in questions related  to giving and receiving feedback among colleagues. While the  responses on feedback have a higher average score than our bench-  marks, NORDEN has prioritised creating a workplace with more  constructive feedback.  Gender representation  The share of the underrepresented gender among employees was  39% in 2024, down from 41% in 2023 and below our target of 40%.  Among Management and Senior Management, the share of the  underrepresented gender was 38% and 29%, respectively in 2024,  compared to 38% and 20% in 2023.  Diversity across employee groups  2024  2023  Share of underrepresented gender in sharehold-  er-elected members of the Board of Directors  33%  33%  Share of underrepresented gender in Executive  Management  0%  0%  Share of underrepresented gender in Senior  management  29%  20%  Share of underrepresented gender in managerial  positions  38%  38%  Share of underrepresented gender among  employees  39%  41%  Share of underrepresented gender among  employees in commercial roles  24%  23%  Gender distribution in Senior Management  Gender  2024  2023  Female  2 1 Male  5 4 Total  7 5 Commercial roles represent an employee group to which we have,  historically, had the most difficulty attracting and retaining females.  Since 2020, the share of women in commercial roles has increased  from 17% to 24%.  In 2024, NORDEN hired 77 employees with an average age of 36  years and of whom 41% were women. Women represented 32% of  leavers in 2024. The share of underrepresented gender decreased  from 41% to 39%, bringing the gender ratio below our ambition of  40%. The average age of leavers was approximately 39 years.  Retention and turnover rates  The overall retention rate was 90% in 2024, decreasing from 94% in  2023. The performance is in line with our ambition of 90% in reten-  tion among full-time employees. We track retention rates across  locations, age groups and gender. While differences are currently  considered immaterial, we continue to track retention trends across  these categories to identify and address any potential imbalances,  such as those arising from a lack of inclusivity. The turnover rate  among full-time employees was 13% in 2024, down from 15% in  2023, with the highest turnover among employees younger than 30  years old.  Retention rate across age groups  Gender  &lt; 30  30 - 50  50 &lt;  Total  Female  88%  92%  90%  91%  Male  88%  91%  87%  90%  Total  88%  91%  88%  90%  Turnover rate across age groups  Gender  &lt; 30  30 - 50  50 &lt;  Total  Female  16%  11%  13%  12%  Male  18%  11%  16%  13%  Total  17%  11%  14%  13%  Total number of employee turnover  Gender  Total  Female  21  Male  45  Total  66  Distribution of employees across age groups  Year  &lt; 30  30 - 50  50 &lt;  Total  2023  19%  65%  16%  100%  2024  16%  67%  17%  100%  Looking ahead  During 2025, NORDEN will focus on continuously increasing the  share of the underrepresented gender in commercial and manage-  rial roles.  To continue the development of a strong and engaging culture,  NORDEN will further implement Leadership Essentials globally with  the purpose of strengthening the leadership community and our  leadership culture.  Furthermore, to strengthen and reinforce our purpose, values and  connectivity, NORDEN will host its second round of NORDEN Days  in 2025. During this event, employees from all our global offices will  gather in Copenhagen for a week of learning, team bonding, idea  sharing and inspirational talks.  </mrv:StatementOfTargetFiguresAndPoliciesForTheUnderrepresentedGender>
<sob:StatementByExecutiveAndSupervisoryBoards contextRef="ctx2" id="fact5519" xml:lang="en">STATEMENT BY THE BOARD OF DIRECTORS AND EXECUTIVE MANAGEMENT  The Board of Directors and the Executive Management have today consid-  ered and adopted the Annual Report of Dampskibsselskabet NORDEN A/S  for the financial year 1 January â 31 December 2024.  The Consolidated Financial Statements are prepared in accordance with IFRS  Accounting Standards as adopted by the EU and additional requirements  stated in the Danish Financial Statements Act. The Parent Company Financial  Statements are prepared in accordance with the Danish Financial Statements  Act. The Managementâs Review is also prepared in accordance with the  Danish Financial Statements Act.  In our opinion, the Consolidated Financial Statements and the Parent  Company Financial Statements give a true and fair view of the financial posi-  tion at 31 December 2024 of the Group and the Parent Company and of the  results of the Groupâs and the Parent Companyâs operations and the Groupâs  consolidated cash flows for the financial year 2024.  In our opinion, the Managementâs Review provides a fair review of the devel-  opment in the operations and financial circumstances of the Group and the  Parent Company, of the results for the year and of the financial position of the  Group and the Parent Company as well as a description of the most significant  risks and elements of uncertainty, which the Group and the Parent Company  are facing.  In our opinion, the ESG performance data on pages 44 - 68 is presented in  accordance with the stated accounting policies on pages 69 â 79 and provides  a fair and balanced view of the Groupâs sustainability performance and social  responsibility for the financial year 2024.  In our opinion, the Annual Report of Dampskibsselskabet NORDEN A/S for  the financial year 1 January â 31 December 2024 with the file name "norden-  2024-12-31-en.zip" is prepared, in all material respects, in compliance with the  ESEF Regulation.  We recommend that the Annual Report be adopted at the annual general  meeting on 12 March 2025.  </sob:StatementByExecutiveAndSupervisoryBoards>
<sob:PlaceOfSignatureOfStatement contextRef="ctx2" id="fact5550" xml:lang="en">Copenhagen</sob:PlaceOfSignatureOfStatement>
<sob:DateOfApprovalOfAnnualReport contextRef="ctx2" id="fact5551">2025-02-06</sob:DateOfApprovalOfAnnualReport>
<cmn:NameAndSurnameOfMemberOfExecutiveBoard contextRef="ctx3" id="fact5973" xml:lang="en">Jan Rindbo</cmn:NameAndSurnameOfMemberOfExecutiveBoard>
<cmn:NameAndSurnameOfMemberOfExecutiveBoard contextRef="ctx4" id="fact5975" xml:lang="en">Martin Badsted</cmn:NameAndSurnameOfMemberOfExecutiveBoard>
<cmn:TitleOfMemberOfExecutiveBoard contextRef="ctx3" id="fact5974" xml:lang="en">CEO</cmn:TitleOfMemberOfExecutiveBoard>
<cmn:TitleOfMemberOfExecutiveBoard contextRef="ctx4" id="fact5976" xml:lang="en">CFO</cmn:TitleOfMemberOfExecutiveBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx5" id="fact5977" xml:lang="en">Klaus Nyborg</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx7" id="fact5981" xml:lang="en">Johanne C F Riegels</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx9" id="fact5985" xml:lang="en">Karsten Knudsen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx11" id="fact5988" xml:lang="en">Robert Hvide Macleod</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx12" id="fact5989" xml:lang="en">Ian McIntosh</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx13" id="fact5990" xml:lang="en">Vibeke Bak Solok</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx5" id="fact5978" xml:lang="en">Chair</cmn:TitleOfMemberOfSupervisoryBoard>
<cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx7" id="fact5982" xml:lang="en">Vice Chair</cmn:TitleOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx6" id="fact5979" xml:lang="en">Henrik Røjel</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx8" id="fact5983" xml:lang="en">Ruhi Hermansen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx10" id="fact5986" xml:lang="en">Sofie Schønherr</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx6" id="fact5980" xml:lang="en">(employee-elected)</cmn:TitleOfMemberOfSupervisoryBoard>
<cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx8" id="fact5984" xml:lang="en">(employee-elected)</cmn:TitleOfMemberOfSupervisoryBoard>
<cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx10" id="fact5987" xml:lang="en">(employee-elected)</cmn:TitleOfMemberOfSupervisoryBoard>
<arr:IndependentAuditorsReportsAudit contextRef="ctx2" id="fact5552" xml:lang="en">INDEPENDENT AUDITORâS REPORT Â </arr:IndependentAuditorsReportsAudit>
<arr:AddresseeOfAuditorsReportOnAuditedFinancialStatements contextRef="ctx2" id="fact5553" xml:lang="en">To the shareholders of Dampskibsselskabet NORDEN A/S  Report on the audit of the Consolidated Financial Statements and  Parent Company Financial Statements  </arr:AddresseeOfAuditorsReportOnAuditedFinancialStatements>
<arr:OpinionOnAuditedFinancialStatements contextRef="ctx2" id="fact5556" xml:lang="en">Opinion  We have audited the consolidated financial statements and the parent  company financial statements of Dampskibsselskabet NORDEN A/S for the  financial year 1 January â 31 December 2024, which comprise income state-  ment, statement of financial position balance sheet, statement of changes in  equity and notes, including material accounting policy information, for the  Group and the Parent Company, and a consolidated statement of compre-  hensive income and a consolidated statement of cash flows. The consoli-  dated financial statements are prepared in accordance with IFRS Accounting  Standards as adopted by the EU and additional requirements of the Danish  Financial Statements Act, and the parent company financial statements are  prepared in accordance with the Danish Financial Statements Act.  In our opinion, the consolidated financial statements give a true and fair view  of the financial position of the Group at 31 December 2024 and of the results  of the Group's operations and cash flows for the financial year 1 January â 31  December 2024 in accordance with IFRS Accounting Standards as adopted by  the EU and additional requirements of the Danish Financial Statements Act.  Further, in our opinion the parent company financial statements give a true  and fair view of the financial position of the Parent Company at 31 December  2024 and of the results of the Parent Company's operations for the financial  year 1 January â 31 December 2024 in accordance with the Danish Financial  Statements Act.  Our opinion is consistent with our long-form audit report to the Audit  Committee and the Board of Directors.  </arr:OpinionOnAuditedFinancialStatements>
<arr:DescriptionOfQualificationsOfAuditedFinancialStatements contextRef="ctx2" id="fact5580" xml:lang="en">Basis for opinion  We conducted our audit in accordance with International Standards on  Auditing (ISAs) and additional requirements applicable in Denmark. Our  responsibilities under those standards and requirements are further  described in the "Auditor's responsibilities for the audit of the consolidated  financial statements and the parent company financial statements" (here-  inafter collectively referred to as "the financial statements") section of our  report. We believe that the audit evidence we have obtained is sufficient and  appropriate to provide a basis for our opinion.  Independence  We are independent of the Group in accordance with the International Ethics  Standards Board for Accountants' International Code of Ethics for Profes-  sional Accountants (IESBA Code) and the additional ethical requirements  applicable in Denmark, and we have fulfilled our other ethical responsibilities  in accordance with these requirements and the IESBA Code.  To the best of our knowledge, we have not provided any prohibited non-audit  services as described in article 5(1) of Regulation (EU) no. 537/2014.  Appointment of auditor  We were initially appointed as auditor of Dampskibsselskabet NORDEN  A/S on 9 March 2023 for the financial year 2023. We have been reappointed  annually by resolution of the general meeting for a total consecutive period of  2 years up until the financial year 2024.  </arr:DescriptionOfQualificationsOfAuditedFinancialStatements>
<arr:KeyAuditMattersAudit contextRef="ctx2" id="fact5602" xml:lang="en">Key audit matters  Key audit matters are those matters that, in our professional judgement, were  of most significance in our audit of the financial statements for the financial  year 2024. These matters were addressed during our audit of the financial  statements as a whole and in forming our opinion thereon. We do not provide  a separate opinion on these matters. For each matter below, our description  of how our audit addressed the matter is provided in that context.  We have fulfilled our responsibilities described in the "Auditor's responsibil-  ities 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 mate-  rial misstatement of the financial statements. The results of our audit proce-  dures, including the procedures performed to address the matters below,  provide the basis for our audit opinion on the financial statements.  Key audit matter  Valuation of intangible and tangible assets.  Intangible and tangible assets amount to USD million 1,182 on 31 December  2024 as specified by Management in notes 3.3, 3.4 and 3.5 to the consoli-  dated financial statements.  This area is significant to our audit due to the carrying value of intangible  and tangible assets as well as the management judgements and assump-  tions involved in impairment testing of these.  Management monitors continuously the carrying value of intangible and  tangible assets to determine, whether there are any indications of impair-  ment. The assessment of impairment indicators is performed on a portfolio  basis on the two cash-generating units (CGUs); Dry cargo and Tankers.  The indications assessed by Management comprises, among other, vessel  values, newbuilding prices and expectations to future development in short-  and long-term freight and time charter rates.  Management performs an impairment test if any indication of impairment  exists and at least once a year for CGUs to which goodwill has been allo-  cated.  The impairment test is performed by comparing the carrying amount of  intangible and tangible assets with their recoverable amount. The recover-  able amount of the assets is determined as the higher of the net selling price  and the value-in-use.  If the carrying amount, exceeds the recoverable amount, as assessed by the  impairment testing, the assets are written down to the lower recoverable  amount.  For details on the impairment tests performed by Management, reference is  made to note 3.2 to the consolidated financial statements.  How our audit addressed the key audit matter  We discussed with Management and evaluated the methodology by which  indications of impairment of intangible and tangible assets are monitored,  including the identification of CGUs.  For the CGU Dry Cargo, Management identified impairment indicators and  assessed the recoverable amounts of assets allocated to the CGU. Our audit  procedures to test Managementâs assessment of the recoverable amount  included, among others:  ⢠Testing of the value-in-use model and the valuation methodology prepared  by Management.  ⢠Testing of the mathematical accuracy of the model and the reliability of data  used in the calculation.  ⢠Testing the reasonableness of key assumptions and input data on basis of our  knowledge of the business and industry together with supporting evidence  such as budgets and externally observable market data related to expected  short- and long-term freight and time charter rates, peer group information,  interest rates etc.  For the CGU Tankers, Management did not identify any impairment indicators.  Our audit procedures to test Managementâs assessment of impairment indica-  tors included, among others:  ⢠Assessment of the conclusions from Managementâs assessment of whether  any indications of impairment exist.  ⢠Testing the reasonableness of Managementâs assessment by comparing  key assumptions and input data to supporting evidence such as exter-  nally observable market data related to short, and long-term freight and  time charter rates, pricing of newbuilding of vessels and vessel valuations  prepared by external and independent ship valuation experts.  We examined the adequacy of disclosures about key assumptions and sensi-  tivity in note 3.2 to the consolidated financial statements.  </arr:KeyAuditMattersAudit>
<arr:StatementOnManagementsReviewAuditorsReportOnAuditedFinancialStatements contextRef="ctx2" id="fact5677" xml:lang="en">Statement on the Management's review  Management is responsible for the Management's review.  Our opinion on the financial statements does not cover the Management's  review, and we do not express any assurance conclusion thereon.  In connection with our audit of the financial statements, our responsibility  is to read the Management's review and, in doing so, consider whether the  Management's review is materially inconsistent with the financial statements,  or our knowledge obtained during the audit, or otherwise appears to be  materially misstated.  Moreover, it is our responsibility to consider whether the Management's  review provides the information required by relevant law and regulations.  Based on our procedures, we conclude that the Management's review is in  accordance with the financial statements and has been prepared in accord-  ance 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="ctx2" id="fact5692" xml:lang="en">Management's responsibilities for the financial statements  Management is responsible for the preparation of consolidated financial  statements that give a true and fair view in accordance with IFRS Accounting  Standards as adopted by the EU and additional requirements of the Danish  Financial Statements Act and for the preparation of parent company financial  statements that give a true and fair view in accordance with the Danish Finan-  cial Statements Act.  Moreover, Management is responsible for such internal control as Manage-  ment determines is necessary to enable the preparation of financial state-  ments that are free from material misstatement, whether due to fraud or error.  In preparing the financial statements, Management is responsible for  assessing the Group's and the Parent Company's ability to continue as a going  concern, disclosing, as applicable, matters related to going concern and  using the going concern basis of accounting in preparing the financial state-  ments unless Management either intends to liquidate the Group or the Parent  Company or to cease operations, or has no realistic alternative but to do so.  </arr:StatementOfExecutiveAndSupervisoryBoardsResponsibilityForFinancialStatements>
<arr:StatementOfAuditorsResponsibilityForAuditAndAuditPerformed contextRef="ctx2" id="fact5708" xml:lang="en">Auditor's responsibilities for the audit of the financial statements  Our objectives are to obtain reasonable assurance as to whether the finan-  cial statements as a whole are free from material misstatement, whether due  to fraud or error, and to issue an auditor's report that includes our opinion.  Reasonable assurance is a high level of assurance, but is not a guarantee that  an audit conducted in accordance with ISAs and additional requirements  applicable in Denmark will always detect a material misstatement when it exists.  Misstatements can arise from fraud or error and are considered material if, indi-  vidually or in the aggregate, they could reasonably be expected to influence  the economic decisions of users taken on the basis of the financial statements.  As part of an audit conducted in accordance with ISAs and additional require-  ments applicable in Denmark, we exercise professional judgement and  maintain professional scepticism throughout the audit. We also:  ⢠Identify and assess the risks of material misstatement of the financial state-  ments, whether due to fraud or error, design and perform audit procedures  responsive to those risks and obtain audit evidence that is sufficient and  appropriate to provide a basis for our opinion. The risk of not detecting a  material misstatement resulting from fraud is higher than for one resulting  from error, as fraud may involve collusion, forgery, intentional omissions,  misrepresentations or the override of internal control.  ⢠Obtain an understanding of internal control relevant to the audit in order to  design audit procedures that are appropriate in the circumstances, but not  for the purpose of expressing an opinion on the effectiveness of the Group's  and the Parent Company's internal control.  ⢠Evaluate the appropriateness of accounting policies used and the reasona-  bleness of accounting estimates and related disclosures made by Manage-  ment.  ⢠Conclude on the appropriateness of Management's use of the going  concern basis of accounting in preparing the financial statements and,  based on the audit evidence obtained, whether a material uncertainty  exists related to events or conditions that may cast significant doubt on the  Group's and the Parent Company's ability to continue as a going concern.  If we conclude that a material uncertainty exists, we are required to draw  attention in our auditor's report to the related disclosures in the financial  statements or, if such disclosures are inadequate, to modify our opinion.  Our conclusions are based on the audit evidence obtained up to the date  of our auditor's report. However, future events or conditions may cause the  Group and the Parent Company to cease to continue as a going concern.  ⢠Evaluate the overall presentation, structure and contents of the financial  statements, including the note disclosures, and whether the financial state-  ments represent the underlying transactions and events in a manner that  gives a true and fair view.  ⢠Plan and perform the group audit to obtain sufficient appropriate audit  evidence regarding the financial information of the entities or business units  within the group as a basis for forming an opinion on the group financial  statements and the parent company financial statements. We are respon-  sible for the direction, supervision and review of the audit work performed  for purposes of the group audit. We remain solely responsible for our audit  opinion.  We communicate with those charged with governance regarding, among  other matters, the planned scope and timing of the audit and significant audit  findings, including any significant deficiencies in internal control that we  identify during our audit.  We also provide those charged with governance with a statement that we  have complied with relevant ethical requirements regarding independence,  and to communicate with them all relationships and other matters that may  reasonably be thought to bear on our independence, and where applicable,  actions taken to eliminate threats or safeguards applied.  From the matters communicated with those charged with governance,  we determine those matters that were of most significance in the audit of  the consolidated financial statements and the parent company financial  statements of the current period and are therefore the key audit matters.  We describe these matters in our auditor's report unless law or regulation  precludes public disclosure about the matter.  </arr:StatementOfAuditorsResponsibilityForAuditAndAuditPerformed>
<arr:AuditorsReportOnXbrlTagging contextRef="ctx2" id="fact5778" xml:lang="en">Report on compliance with the ESEF Regulation  As part of our audit of the Consolidated Financial Statements and Parent  Company Financial Statements of Dampskibsselskabet NORDEN A/S, we  performed procedures to express an opinion on whether the annual report  of Dampskibsselskabet NORDEN A/S for the financial year 1 January â 31  December 2024 with the file name "norden-2024-12-31-en.zip" is prepared, in  all material respects, in compliance with the Commission Delegated Regu-  lation (EU) 2019/815 on the European Single Electronic Format (ESEF Regu-  lation) which includes requirements related to the preparation of the annual  report in XHTML format and iXBRL tagging of the Consolidated Financial  Statements including notes.  Management is responsible for preparing an annual report that complies with  the ESEF Regulation. This responsibility includes:  ⢠The preparing of the annual report in XHTML format;  ⢠The selection and application of appropriate iXBRL tags, including exten-  sions to the ESEF taxonomy and the anchoring thereof to elements in the  taxonomy, for all financial information required to be tagged using judge-  ment where necessary;  ⢠Ensuring consistency between iXBRL tagged data and the Consolidated  Financial Statements presented in human readable format; and  ⢠For such internal control as Management determines necessary to enable  the preparation of an annual report that is compliant with the ESEF Regula-  tion.  Our responsibility is to obtain reasonable assurance on whether the annual  report is prepared, in all material respects, in compliance with the ESEF Regu-  lation based on the evidence we have obtained, and to issue a report that  includes our opinion. The nature, timing and extent of procedures selected  depend on the auditorâs judgement, including the assessment of the risks of  material departures from the requirements set out in the ESEF Regulation,  whether due to fraud or error. The procedures include:  ⢠Testing whether the annual report is prepared in XHTML format;  ⢠Obtaining an understanding of the companyâs iXBRL tagging process and of  internal control over the tagging process;  ⢠Evaluating the completeness of the iXBRL tagging of the Consolidated  Financial Statements including notes;  ⢠Evaluating the appropriateness of the companyâs use of iXBRL elements  selected from the ESEF taxonomy and the creation of extension elements  where no suitable element in the ESEF taxonomy has been identified;  ⢠Evaluating the use of anchoring of extension elements to elements in the  ESEF taxonomy; and  ⢠Reconciling the iXBRL tagged data with the audited Consolidated Financial  Statements.  In our opinion, the annual report of Dampskibsselskabet NORDEN A/S for the  financial year 1 January â 31 December 2024 with the file name "norden-2024-  12-31-en.zip" is prepared, in all material respects, in compliance with the ESEF  Regulation.  </arr:AuditorsReportOnXbrlTagging>
<arr:SignatureOfAuditorsPlace contextRef="ctx2" id="fact5834" xml:lang="en">Copenhagen</arr:SignatureOfAuditorsPlace>
<arr:SignatureOfAuditorsDate contextRef="ctx2" id="fact5835">2025-02-06</arr:SignatureOfAuditorsDate>
<cmn:NameOfAuditFirm contextRef="ctx38" id="fact6208" xml:lang="en">EY Godkendt Revisionspartnerselskab</cmn:NameOfAuditFirm>
<cmn:IdentificationNumberCvrOfAuditFirm contextRef="ctx38" id="fact6209">30700228</cmn:IdentificationNumberCvrOfAuditFirm>
<cmn:NameAndSurnameOfAuditor contextRef="ctx38" id="fact6210" xml:lang="en">Mikkel Sthyr</cmn:NameAndSurnameOfAuditor>
<cmn:NameAndSurnameOfAuditor contextRef="ctx39" id="fact6214" xml:lang="en">Morten Weinreich Larsen</cmn:NameAndSurnameOfAuditor>
<cmn:DescriptionOfAuditor contextRef="ctx39" id="fact6215" xml:lang="en">State Authorised Public Accountant</cmn:DescriptionOfAuditor>
<cmn:IdentificationNumberOfAuditor contextRef="ctx39" id="fact6217" xml:lang="en">mne42791</cmn:IdentificationNumberOfAuditor>
<cmn:DescriptionOfAuditor contextRef="ctx38" id="fact6211" xml:lang="en">State Authorised Public Accountant</cmn:DescriptionOfAuditor>
<cmn:IdentificationNumberOfAuditor contextRef="ctx38" id="fact6213" xml:lang="en">mne26693</cmn:IdentificationNumberOfAuditor>
<arr:AuditorsReportOnSubstainabilityReport contextRef="ctx2" id="fact5837" xml:lang="en">INDEPENDENT AUDITOR'S ASSURANCE REPORT ON Â SELECTED ESG PERFORMANCE DATA Â </arr:AuditorsReportOnSubstainabilityReport>
<arr:AddresseeOfAuditorsReportOnSubstainabilityReports contextRef="ctx2" id="fact5839" xml:lang="en">To the stakeholders of Dampskibsselskabet NORDEN A/S Â </arr:AddresseeOfAuditorsReportOnSubstainabilityReports>
<arr:StatementOfAuditorsResponsibilitySubstainabilityReport contextRef="ctx2" id="fact5873" xml:lang="en">Auditor's responsibilities  Our responsibility is to express a conclusion based on our examinations on  the presentation of the selected ESG performance data in accordance with  the scope defined above.  We conducted our examinations in accordance with ISAE 3000 Assurance  Engagements Other than Audits or Reviews of Historical Financial Information  and additional requirements under Danish audit regulation to obtain limited  assurance for the purposes of our conclusion.  EY Godkendt Revisionspartnerselskab applies International Standard on  Quality Management 1, ISQM1, which requires the firm to design, implement  and operate a system of quality management including policies or proce-  dures regarding compliance with ethical requirements, professional stand-  ards and applicable legal and regulatory requirements.  We have complied with the independence and other ethical requirements of  the International Ethics Standards Board for Accountants' International Code  of Ethics for Professional Accountants (IESBA Code), which is founded on  fundamental principles of integrity, objectivity, professional competence and  due care, confidentiality and professional behaviour as well as ethical require-  ments applicable in Denmark.  Description of procedures performed  In obtaining limited assurance over the selected ESG performance data on  pages 47, 55 and 82 â 84, our objective was to perform such procedures as to  obtain information and explanations which we consider necessary in order to  provide us with sufficient appropriate evidence to express a conclusion with  limited assurance.  The procedures performed in connection with our examination are less than  those performed in connection with a reasonable assurance engagement.  Consequently, the degree of assurance for our conclusion is substantially less  than the assurance which would be obtained had we performed a reasonable  assurance engagement.  As part of our examinations, we performed the below procedures:  ⢠Interviewed those in charge of the selected ESG performance data to  develop an understanding of the process for the preparation of the Sustain-  ability statement and for carrying out internal control procedures.  ⢠Performed analytical review of the data and trends to identify areas of the  selected ESG performance data with a significant risk of misleading or  unbalanced information or material misstatements and obtained an under-  standing of any explanations provided for significant variances.  ⢠Based on inquiries we evaluated the appropriateness of accounting policies  used, their consistent application and related disclosures in the selected  ESG performance data. This includes the reasonableness of estimates made  by Management.  ⢠Designed and performed further procedures responsive to those risks and  obtained evidence that is sufficient and appropriate to provide a basis for  our conclusion.  ⢠In connection with our procedures, we read the other sustainability infor-  mation in the Sustainability statement of NORDENâs Annual Report and, in  doing so, considered whether the other sustainability information is mate-  rially inconsistent with the selected performance data or our knowledge  obtained in the review or otherwise appear to be materially misstated.  In our opinion, the examinations performed provide a sufficient basis for our  conclusion.  </arr:StatementOfAuditorsResponsibilitySubstainabilityReport>
<arr:IdentificationOfMattersOnWhichAssuranceReportIsProvidedAndDescriptionOfAssuranceEngagementSubstainabilityReport contextRef="ctx2" id="fact5840" xml:lang="en">As agreed, we have performed an examination with a limited assurance,  as defined by the International Standards on Assurance Engagements, on  Dampskibsselskabet NORDEN A/Sâs (âNORDENâ) selected ESG performance  data in the tables âNORDENâs material topics and monitoring indicatorsâ,  âBreakdown of EEOI by vessel and typeâ, âSASB Marine transportation indexâ,  âESRS indexâ, âTotal GHG emissions disaggregated by Scope 1 and 2 and  significant to Scope 3â on pages 47, 55 and 82 â 84 (âthe selected ESG perfor-  mance dataâ) in the Sustainability statement of the Annual Report for the  period 1 January 2024 to 31 December 2024.  In preparing the selected ESG performance data, NORDEN applied the  ESG accounting policies described on pages 69 â 74. The selected ESG  performance data needs to be read and understood together with the ESG  accounting policies, which Management is solely responsible for selecting  and applying. The absence of an established practice on which to derive,  evaluate, and measure the selected ESG performance data allows for  different, but acceptable, measurement techniques and can affect compara-  bility between entities and over time.  Other than as described in the preceding paragraph, which sets out the  scope of our engagement, we did not perform assurance procedures on the  remaining information included in the Annual Report and accordingly, we do  not express an opinion on this information.  Management's responsibilities  NORDENSâs Management is responsible for selecting the ESG accounting  policies, and for presenting the ESG performance data in accordance with the  ESG accounting policies, in all material respects. This responsibility includes  establishing and maintaining internal controls, maintaining adequate records,  and making estimates that are relevant to the preparation of the ESG perfor-  mance data, such that it is free from material misstatement, whether due to  fraud or error.  </arr:IdentificationOfMattersOnWhichAssuranceReportIsProvidedAndDescriptionOfAssuranceEngagementSubstainabilityReport>
<arr:EmphasisOfMatterSubstainabilityReport contextRef="ctx2" id="fact5934" xml:lang="en">Conclusion  Based on our examinations and the evidence obtained, nothing has come to  our attention that causes us to believe that the selected ESG performance  data presented in the tables âNORDENâs material topics and monitoring  indicatorsâ, âBreakdown of EEOI by vessel and typeâ, âSASB Marine transporta-  tion indexâ, âESRS indexâ, âTotal GHG emissions disaggregated by Scope 1 and  2 and significant to Scope 3â on pages 47, 55 and 82 â 84 (âthe selected ESG  performance dataâ) in the Sustainability statement of Dampskibsselskabet  NORDEN A/Sâs Annual Report for the period 1 January 2024 to 31 December  2024 has not been prepared, in all material respects, in accordance with ESG  accounting policies described on pages 69 â 74.  </arr:EmphasisOfMatterSubstainabilityReport>
<arr:SignatureOfAuditorsDate contextRef="ctx2" id="fact5836">2025-02-06</arr:SignatureOfAuditorsDate>
<cmn:NameOfAuditFirm contextRef="ctx41" id="fact6231" xml:lang="en">EY Godkendt Revisionspartnerselskab</cmn:NameOfAuditFirm>
<cmn:NameOfAuditFirm contextRef="ctx40" id="fact6225" xml:lang="en">EY Godkendt Revisionspartnerselskab</cmn:NameOfAuditFirm>
<cmn:NameOfAuditFirm contextRef="ctx39" id="fact6218" xml:lang="en">EY Godkendt Revisionspartnerselskab</cmn:NameOfAuditFirm>
<cmn:IdentificationNumberCvrOfAuditFirm contextRef="ctx41" id="fact6230">30700228</cmn:IdentificationNumberCvrOfAuditFirm>
<cmn:IdentificationNumberCvrOfAuditFirm contextRef="ctx40" id="fact6224">30700228</cmn:IdentificationNumberCvrOfAuditFirm>
<cmn:IdentificationNumberCvrOfAuditFirm contextRef="ctx39" id="fact6219">30700228</cmn:IdentificationNumberCvrOfAuditFirm>
<cmn:NameAndSurnameOfAuditor contextRef="ctx40" id="fact6220" xml:lang="en">Mikkel Sthyr</cmn:NameAndSurnameOfAuditor>
<cmn:NameAndSurnameOfAuditor contextRef="ctx41" id="fact6226" xml:lang="en">Lars Fermann</cmn:NameAndSurnameOfAuditor>
<cmn:DescriptionOfAuditor contextRef="ctx41" id="fact6227" xml:lang="en">State Authorised Public Accountant</cmn:DescriptionOfAuditor>
<cmn:IdentificationNumberOfAuditor contextRef="ctx41" id="fact6229" xml:lang="en">mne45879</cmn:IdentificationNumberOfAuditor>
<cmn:DescriptionOfAuditor contextRef="ctx40" id="fact6221" xml:lang="en">State Authorised Public Accountant</cmn:DescriptionOfAuditor>
<cmn:IdentificationNumberOfAuditor contextRef="ctx40" id="fact6223" xml:lang="en">mne26693</cmn:IdentificationNumberOfAuditor>
</xbrli:xbrl>