Assets
| Type | Time | Amount | Unit |
|---|---|---|---|
| ifrs-full:Assets | 2024-12-31 | 8246000000 | vDKK |
| ifrs-full:Assets | 2023-12-31 | 6726000000 | vDKK |
Revenue
| Type | Start date | End date | Amount | Unit |
|---|---|---|---|---|
| ifrs-full:Revenue | 2024-01-01 | 2024-12-31 | 5537000000 | vDKK |
| ifrs-full:Revenue | 2023-01-01 | 2023-12-31 | 4824000000 | vDKK |
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<fsa:AverageNumberOfEmployees contextRef="ctx41" decimals="1" unitRef="pure">2752</fsa:AverageNumberOfEmployees>
<mrv:SustainabilityReport contextRef="ctx1" id="fact1000" xml:lang="en">Employees1  North America: 568  Europe: 2,066, Asia: 178  1 ESRS 2-SBM 1-40(a.iii)  Business and  value chain  ESRS 2-SBM1-42(a,b,c)  Research & development  Resources  2024 results  IPR and  Process  Clinical  Regulatory  discovery  innovations and  trials  processes  formulations  +100 yearsâ profound  200,000  understanding of allergy  additional patients treated  Externally sourced products  in 2024, bringing the total  ~2,800 employees with  number to 2.6 million  diverse talents  Insights from academia,  380 million  patients and partners  Manufacturing  AIT doses produced  (excluding ALK's SCIT bulk  Raw materials,  extracts in the USA)  energy, water, etc.  Standardise  Production  Cultivate  allergen  at 8 sites  allergenic source  extracts  materials  Digital engagement  ~45%  platforms  global market share in AIT  Financial resources  Distribution and sales  ALK present  16 markets  Global  Digital patient  in 46  served by  distribution  mobilisation  markets  partners  Safety, quality, and business ethics compliance  + Introduction to Allergy  ESRS 2-SBM1-40(e)  + The Allergy strategy, launched in June 2024, builds on ALKâs promise  to provide life-changing solutions to the millions of people with allergy.  The strategy is based on four pillars.  ALK will prioritise and focus the commercial activities to  To help more people with allergies, ALK will innovate and  strengthen its global leadership in respiratory allergy. Key  expand its R&D pipeline in a balanced way. ALK will maximise  initiatives include targeted expansion of the respiratory  Innovate  the value of existing core products and diversify the portfolio  tablets to new patient groups and geographies, efforts to  into food allergy, anaphylaxis and other adjacent, allergic  increase prescription depth and breadth, digital mobilisa-  diseases with potential to become new growth levers. The  tion of patients and prescribers, and investments in high-  ambition is to become a market leader in each disease area.  impact markets.  Aspire to  annually help  Focus  5 million people  Optimise  living with  allergy by 2030  To reduce complexity and maintain competitiveness, ALK  will further optimise operations and scale for growth. Initi-  + Activities and targets in the Allergy strategy are under-  atives include streamlining the cost base, reducing struc-  pinned by ALKâs commitment to cultivate the capabilities of  tural complexities, and investing in digital infrastructure.  its people and organisation to foster a strong performance  Cultivate  ALK will continue to focus on high quality, expand produc-  culture through high engagement and conduct business  tion capacity and longer-term explore options to optimise  sustainably by improving access to allergy care and reducing  the manufacturing set-up.  the environmental footprint.  Full paediatric coverage  S4-4  Key initiatives with respect to the current core products were  the targeted expansion of the respiratory tablet portfolio to new  prescribers and patients, particularly children, and new geog-  raphies.  Work intensified in 2024 to secure regulatory approvals to  expand the product indications for the house dust mite (HDM)  tablet and the tree pollen tablet to include young children, after  authorities in Europe and North America accepted ALKâs regula-  tory filings for review. The filings were based on the largest-ever  phase III paediatric trials within the field, which ALK successfully  completed in 2023.  In December 2024, the authorities in 21 European countries  approved the HDM tablet, marketed as ACARIZAX®, for treat-  ment of young children aged five to 11. Initial market introduc-  tions have taken place in ALKâs largest market, Germany, and  other key markets. Subject to approval, the HDM tablet is also  projected to become available for young children in the first half  of 2025 in Canada and the USA, where the tablet is marketed as  ODACTRA®.  The regulatory reviews of the tree tablet ITULAZAX® are  expected to be completed by mid-2025 in Europe and Canada,  allowing this tablet to become available for children and adoles-  cents ahead of the 2025/26 initiation season for pollen tablets.  Regulatory submissions for paediatric use have also been  submitted in other markets, such as Switzerland, the UK, and  Southeast Asia. During the second half of 2025, all five tablets  are expected to be approved for all age groups â children,  adolescents, and adults â in all key markets across the main  respiratory allergies.  Leveraging full paediatric coverage of the tablet portfolio  is anticipated to deliver a material contribution to ALKâs  medium- and long-term growth. ALKâs commercial organ-  isation advanced launch preparations in 2024 with further  initiatives lined up for 2025. Launch activities will focus on all  existing tablet prescribers as well as potential new prescribers  in selected countries â paediatricians, ENT (ear, nose, and  throat) specialists and other medical professionals, treating  the millions of children suffering from uncontrolled respiratory  allergies.  Growing the patient base  S4-4  In Europe, ALK continued its efforts to mobilise eligible patients,  increase prescription depth and breadth among its key  prescribers, and strengthen advocacy for registered, evidence-  based treatment among regulators, payers, and prescribers.  As a result, ALKâs patient base saw double-digit growth, driven  mainly by the tablet portfolio. To further leverage its strongholds  and accelerate sales momentum, ALK increased investments in  high-growth markets, while operations in a few other markets  were downsized until market conditions improve.  NICE review in the UK  S4-4  In the UK, a recent recommendation from the prominent National  Institute for Health and Care Excellence (NICE) has paved the  way for ACARIZAX® to be included in the public National Health  Service system, making it eligible for general reimbursement.  ALK has submitted a similar application for NICE reviews  regarding ITULAZAX®. Currently, the UK is the only major AIT  market in Europe where ALK's tablets are authorised without  adequate public reimbursement.  Expansion outside Europe  S4-4  In Japan â the most important contributor to ALKâs tablet  sales outside Europe â ALK is supporting its partner Torii in  expanding manufacturing capacity for the Japanese cedar  pollen tablet to meet high demand. The upscaled capacity is  expected to become operational in late 2025. Meanwhile, Torii  has initiated clinical development of ALKâs grass pollen allergy  tablet (GRAZAX®) with a view to expanding the current portfolio  comprising CEDARCUREâ¢, the only approved tablet for treat-  ment of Japanese cedar pollen induced allergy, and MITICURE⢠ for treatment of HDM-induced allergy.  In India, ALKâs partner Dr. Reddyâs Laboratories obtained  regulatory approval for ALKâs HDM tablet for treatment of adults  with uncontrolled HDM-induced allergic rhinitis and/or allergic  asthma as well as adolescents with uncontrolled allergic  rhinitis. The tablet, marketed as Sensimune⢠in India, will be  launched in 2025, as soon as an import license is in place.  Efforts to increase market uptake of tablets are also progressing  in the Southeast Asian markets, served by ALKâs partner Abbott,  and in Canada. In 2025, ALKâs product offering in Canada will  be strengthened by the expected approval of tablets for use in  children and the in-licensing of neffy®, as described below.  Expanding  the addressable  markets  ESRS 2-SBM1-40(g);S4-41  ALK addresses markets with a current  value of around DKK 13 billion. The  + Allergy strategy aims at helping more  people with allergies to a better life  by unlocking the potential in existing  markets and expanding into new therapy  areas with high unmet needs.  (Market data below is own estimates, to the greatest extent  possible based on external sources, including IQVIA and other  local market data providers).  The global market for allergy immunotherapy (AIT) treatments  â ALKâs core business â is estimated to be worth around DKK  12 billion, measured in 2024 ex-factory sales. The AIT market  is underpenetrated and geographically concentrated around  Europe, North America, China, and Japan. Since 2019, the AIT  market is estimated to have grown on average by high single  digits, while ALKâs revenue from tablets, injections (SCIT) and  drops has grown by 12% p.a. (CAGR), thus strengthening ALKâs  market position as market leader.  1 Numbers in this section have not been subject to the limited assurance on the  sustainability statement carried out by the independent auditor.  Respiratory Allergy  Anaphylaxis  >50 million  >20 million  People eligible for AIT  People at risk for anaphylaxis in Europe  ~12bn DKK  ~4 million  Estimated AIT market value  Autoinjectors sold in Europe per year  ~45% ALK share  ~1.4bn DKK  of global market  Estimated market value in Europe  Under-treated,  ALK core business  high potential  with high potential  Respiratory  therapy area with  Allergy  the right innovation  Anaphy-  laxis  Food Allergy  New adjacent  Food  therapy areas  Allergy  New  ~200 million  adjacent  therapy  People affected globally  areas  ~8%  Indications with  of children are affected in the USA  high unmet needs and strong  capability fit to ALK  ~2.5 million  children (4-17) with peanut allergy  in the USA and Europe  Therapy area with  high unmet need, close to  core with high potential  Even so, respiratory allergy remains a disease area with signif-  icant under-treatment. At least 50 million people with severe  uncontrolled symptoms would potentially be eligible for AIT  treatment, but only around five million were estimated to receive  AIT in 2024, hereof more than two million with products from  ALKâs AIT portfolio, which spans around 40 different allergies,  excluding US bulk SCIT extracts.  Strong fundamentals  Although it varies considerably across geographies and age  groups, the prevalence of respiratory allergy is on the rise, and  research suggests that this trend will continue. Global warming,  for instance, affects plant and pollen cycles, prolongs pollen  seasons and causes species, such as ragweed, to spread to  new regions. Urbanisation sees more people migrating to cities  where they are exposed to higher levels of air pollution, while  people living in sterile, urban environments do not enjoy the  same protection as people in rural areas, where a wide range of  microbial exposures lowers the risk of allergic sensitisation and  disease.  + Market expansion is a key part of ALKâs Allergy strategy. Efforts  include enlargement of AIT prescriber bases, digital mobilisa-  tion of eligible patients, advocacy for evidence-based medi-  cines, and efforts to expand the reach of the respiratory tablet  portfolio to certain new geographies and new patient groups,  not least by leveraging the up-coming paediatric indications for  the full tablet portfolio. Globally, it is estimated that more than  ten million children, aged five to 11, have uncontrolled respira-  tory allergies and the number is growing.  Significant under-treatment  Anaphylaxis, currently ALKâs second largest disease area, is also  an area with significant under-treatment and high growth poten-  tial. In Europe alone, more than 20 million people are estimated  to be at risk of experiencing severe, acute allergic reactions  (anaphylaxis) after exposure to e.g. specific food, or bee or wasp  stings, but only around 2 million Europeans carry recommended  rescue medication, predominantly adrenaline autoinjectors  (AAIs) such as ALKâs Jext® pen. The number of AAIs sold in Europe  has been growing by 8% p.a. over the last decade.  The recent in-licensing of neffy®, the worldâs first and only nasal  spray for anaphylaxis treatment, allows ALK to cultivate markets  in Europe and Canada â where the combined value of current  AAI sales is estimated at around DKK 1.6bn (2023) â and high-  potential markets in Asia and the Middle East. neffy® is expected  to expand markets because the spray eliminates needle-related  safety concerns, fear and hesitation, as demonstrated by other  emergency medicines going from needles to nasal.  Food allergy on the rise  ALKâs ambition in food allergy is to build a portfolio of treatments  that address unmet medical needs among the ~200 million  people affected worldwide, particularly children. The preva-  Others include diagnostics of allergens,  diagnostics of penicillin allergy, and life  science products  lence of food allergy is increasing, mostly driven by pollution,  urbanisation, and dietary factors associated with cultural/  social behaviours (e.g. obesity, vitamin D deficiency, dietary fat,  etc.)  ALKâs most advanced programme targets peanut allergy, the  most common cause of severe, life-threatening food-related  allergic reactions. The condition often manifests during child-  hood and persists into adulthood for up to 80% of patients. In the  USA, peanut allergy affects up to 1.5 million children and adoles-  cents, while in Europe, around one million children and adoles-  cents are affected. Some reports suggest that the prevalence of  peanut allergy has tripled over the last decade.  ALK targets 5 million patients annually by 2030  Million patients  5 Estimated number of  patients in treatment  4 with ALK products (AIT  3 2.6  and anaphylaxis) and  2.4  2.4  2.0  2.1  AIT products based on  2 allergens from ALK.  1 0 2020 2021 2022 2023 2024  In 2023, a net increase of ~200,000 AIT patients was offset by fewer  Jext® patients due to intermittent supply shortages. 2024 saw  growth in the number of both AIT and Jext® patients.  Revenue by geography  ESRS 2-SBM1-40(a.ii, f)  Growth  Amounts in DKKm  2024  (l.c.)  2023  Europe  3,914  22%  3,216  North America  906  0%  908  Intâl markets  717  4%  700  Revenue  5,537  15%  4,824  Revenue by product line  ESRS 2-SBM1-40(a.i, f)  Growth  Amounts in DKKm  2024  (l.c.)  2023  SLIT-tablets  2,851  24%  2,296  SCIT/ SLIT-drops  2,052  6%  1,939  Other products  634  7%  589  Revenue  5,537  15%  4,824  Board composition  ESRS 2-Gov 1-21(a,b,d,e)  The Board of Directors consists of 11 non-executive members.  Seven of the none-executive members, including the Chair and  the Vice Chair, are up for re-election each year at the Annual  General Meeting. Four members are employee-elected, each  serving a four-year term (the last election was in 2023). No  member of the Board of Management serves on the Board of  Directors.  With two female members on the Board of Directors, ALK  meets its target of having a minimum of two members (29%)  of the underrepresented gender among the non-executive  shareholder-elected members in accordance with section 107d  of the Danish Financial Statements Act. Furthermore, three out of  four employee-elected members are female.  At the Annual General Meeting in 2024, all shareholder-elected  board members were re-elected. The Board of Directors  has a preponderance of independent, shareholder-elected,  Composition of the Board of Directors  ESRS 2-GOV1-21(a, b, d, e)  2024  20231  Number of non-executive members  Number of shareholder-elected members  7 7 Number of employee-elected members  4 4 11  11  Number of executive members  - - Independent members of the Board of Directors  Percentage of independent members in shareholder-elected members  71%  71%  Percentage of independent members in shareholder and employee-elected members  45%  45%  Board gender diversity  Male  Shareholder-elected  5 5 Employee-elected  1 1 Total  6 6 Female  Shareholder-elected  2 2 Employee-elected  3 3 Total  5 5 Ratio of female to male in shareholder and employee-elected members  45%  45%  Percentage of underrepresented gender in shareholder-elected members  29%  29%  Composition of the Executive Leadership Team1 and their direct reportsin management positions  ESRS 2-GOV1-21(a, b, d, e)  2024  2023  Executive Leadership Team and their direct reports in management positions  Number of males  26  25  Number of females  21  18  Total  47  43  Percentage of underrepresented gender  45%  42%  Percentage of females in total workforce  62%  62%  members, as five board members (out of seven) in 2024 may be  considered independent according to the definitions set by the  Danish Committee on Corporate Governance.  All board members are presented on pages 33-34 of this annual  report, while ALKâs Executive Leadership Team is presented on  page 35. Four members of the Executive Leadership Team are  registered with the Danish Business Authority and legally consti-  tute ALKâs Board of Management.  Competency matrix for the Board of Directors  ESRS 2-GOV1-23(a, b); G1-GOV1-5(a, b)  The Board of Directors represents international business expe-  rience from management positions in a variety of industries,  and particular regard is given to the membersâ insight into the  management and globalisation of R&D driven companies. The  Board also has overall expertise in sustainability matters that  are material to ALK and sustainability knowledge is integrated  into board committees and the Board itself. External advice on  specific sustainability topics is obtained, if needed.  To assess whether all of the necessary core competencies are  adequately represented, each shareholder-elected member  of the Board has been asked to identify the primary competen-  cies they bring to the Board, in the context of ALKâs long-term  strategy. Employee-elected members are not part of the compe-  tency assessment. For the Chair and Vice Chair, two additional  competencies, specific to these roles, have been identified.  Highlights of the remuneration report  ESRS 2 â Gov 3; E1-GOV3-13  ALKâs remuneration report for the Board of Directors and the  Board of Management provides an overview of remuneration  components, actual remuneration in 2024, its development over  the past years, and the individual shareholdings of members  of the Board of Directors and Board of Management. All remu-  neration for the Board of Directors and Board of Management  in 2024 followed the principles and framework outlined in ALKâs  remuneration policy. The remuneration report for 2024 will be  presented for an advisory vote at the AGM on 13 March 2025.  The report is prepared in accordance with section 139b of the Danish  Companies Act and is available at https://ir.alk.net/corporate-governance.  Members of the Board of Directors each received a fixed annual  fee, with the Vice Chair and Chair receiving double and triple the  annual fee, respectively. Members also received an additional  fee for serving as member or chair on the Board committees.  The fees for serving on the Board and the Board committees  remained unchanged in 2024.  The remuneration for the Board of Management consisted of  both fixed pay elements (base salary and benefits) and variable  pay elements in the form of short-term incentive (STI) and long-  term incentive (LTI) plans. The programmes reward the attain-  ment of pre-defined financial and non-financial targets linked to  the companyâs strategy. The STI and LTI plans are governed by  ALKâs remuneration policy.  The remuneration policy is submitted for advisory approval at  ALK's Annual General Meeting at least every four years. The  remuneration policy allows for STI and LTI plans to include both  financial and non-financial KPIs, including sustainability-related  targets. The targets linked to the annual STI and LTI plans are  approved each year by ALKâs Board of Directors. In accordance  with the remuneration policy, ALK's Board of Directors does not  participate in short or long-term incentive schemes linked to  company results.  Short-term incentive scheme (STI)  The KPIs for the STI include sustainability targets accounting for  15% of pay to the CEO and 11% for the remainder of the Board  of Management. The sustainability targets reward ALK's Board  of Management for successfully preparing ALK for the CSRD  and EU Taxonomy reporting and for getting science-based CO2  reduction targets approved. This supports ALK's ability to set  additional sustainability targets in the future. The STI plan also  rewards the achievement of gender balance in senior manage-  ment and securing a high level of employee engagement.  Long-term incentive scheme (LTI)  Achievement of the LTI plan for 2022-2024 is linked to the  fulfilment of both financial and sustainability targets with  sustainability-related targets accounting for 10% of the plan  for all members of the Board of Management. This is a grouped  milestone that includes climate-related considerations. The LTI  plan includes a previously established target linked to green-  house gas (GHG) emission reduction, which does not align with  the Science Based Targets initiative (SBTi) target reported  under Disclosure Requirement E1-4. It also includes targets  for increasing the share of the underrepresented gender in  management positions at VP and Senior Director level to 34%  and on increasing the number of patients benefitting from ALKâs  allergy products.  The variable pay elements were settled above target and reflect  strong performance in the financial and non-financial KPIs  defined for the STI and LTI plan. The general increase in base  salary for members of the Board of Management was 3%, in line  with the general increase for ALK employees in Denmark. There  was no increase applied to the base salary for the CEO while the  base salary for the CFO increased above the general level to  align it more closely to market benchmarks.  To support investments in ALKâs new strategy, the Board of  Directors is extending its recommendation that dividend  payments be suspended until ALKâs cash flow further improves.  Accordingly, the Board of Directors will propose to the AGM, that  no dividends should be declared for 2024. The Board of Direc-  tors revisits the dividend policy and ALKâs capital structure on an  ongoing basis.  Up to and including 15 March 2027, the Board of Directors is  authorised to increase the share capital by up to DKK 11,141,196,  with or without pre-emption rights for existing shareholders.  The Board of Directors is authorised for the period until 22 March  2028 to let the company acquire its own B shares for a nominal  value of up to DKK 11,141,196. The consideration for such shares  may not deviate by more than 10% from the official quoted price  of the B shares on the date of acquisition.  Investor Relations  During 2024, ALK representatives participated in many indi-  vidual meetings and briefing calls with analysts and investors as  well as conferences and seminars targeting various audiences.  ALK also hosted a well-attended Capital Markets Day in June  2024 where management presented ALKâs new strategy.  All regulated company announcements are available on ALKâs  corporate website together with reports, presentations,  recordings of telephone conferences, share price information,  analystsâ estimates, and related information. Registered share-  holders are encouraged to sign up on the InvestorPortal.  Competencies2  Specific expertise within management and  sales & marketing in international life science  companies.  Directorships2,3  Ellab, Chair and chair of the Remuneration  Committee  Rodenstock Group, Germany: Member of the  Advisory Board  Candela Medical, USA: Board adviser  Competencies2  Experience in management, financial and  economic expertise, experience in strategy  and communication in international compa-  nies.  Directorships2,3  Ãrsted A/S: Chair and chair of the Nomination  & Remuneration Committee  Falck A/S4: Vice Chair and member of the Remu-  neration and Nomination Committee  H. Lundbeck A/S4: Vice Chair and member of  the Remuneration & Nomination and  Scientific Committees  Nordea Bank Abp, Finland: Vice Chair and  member of the Audit Committee  Competencies2  Global leadership experience and comprehen-  sive understanding of international manage-  ment, finance, IT, and sales & marketing, as  well as insights into building digital commu-  nities.  Directorships2,3  UNION therapeutics A/S: Board member  Tobii Dynavox: Chair  GN Foundation: Chair  Competencies2  Experience in management, finance, and  sales & marketing in international life science  companies, including med-tech and pharma-  ceutical businesses.  Directorships2,3  Biovica International AB, Sweden: Chair and  member of the Audit Committee  H. Lundbeck A/S: Board member and member  of the Audit Committee  The Lundbeck Foundation: Board member and  Chair of the Investment Committee  Vitrolife AB, Sweden: Board member and  member of the Audit Committee  Competencies2  Management and commercial experience from  35 years with global pharmaceutical compa-  nies, including roles at Ascendis Pharma,  Inc., Radius Health, Inc. and Novo Nordisk  Inc., USA. Unique expertise in establishing  and expanding commercial activities in North  America, including product launches.  Directorships2,3  SciBase AB, Stockholm: Chair  Flen Health SA, Luxemburg: Director  2 ESRS 2-GOV1-21(c)  Competencies2  More than 30 years' experience of  global executive R&D leadership  in pharmaceuticals (Astra, Astra-  Zeneca, Almirall) and biotech (ASLAN  Pharmaceuticals, eTheRNA Immuno-  therapies, Galecto Inc.). Experience  in multi therapy area and bringing-  blockbuster therapeutics to market  globally. Served on the Research  Board of AstraZeneca. Participated  in a range of IPOs, acquisitions, and  debt-financing activities.  Directorships2,3  Aqilion AB, Sweden: Chair of the Board  and member of the Remuneration  Committee  Cellevate, Sweden: Director of the  Board  Competencies2  More than 30 years of experience from  the consumer healthcare industry,  including roles in Sanofi, Bayer and  Roche.  Competencies2  Experience in project management of  global drug development projects in  the pharmaceutical industry.  Directorships2,3  The Lundbeck Foundation: Board  member, employee-elected  Competencies2  Expertise in production and release of  ALKâs active pharmaceutical ingre-  dients for sublingual immunotherapy  products.  Competencies2  Experience in the development of new  vaccines, project management of drug  discovery projects, and most recently  governance of data digitalisation and  AI projects.  Competencies2  Experience in HVAC systems, clean-  room testing, utensil washing and  sterilisation for the pharmaceutical  industry.  2 ESRS 2-GOV1-21(c)  ESRS 2  General disclosures  Basis for preparation  ESRS 2-BP1  General basis for preparation of  the sustainability statement  ALK has aligned its reporting with the European Corporate  Sustainability Reporting Directive (CSRD), which is applicable to  ALK from 1 January 2024, and Article 8 of the Taxonomy Regu-  lation (EU) 2020/852. The sustainability statement has been  prepared on a consolidated basis, covering the entire ALK group  and subsidiaries, in line with the financial statements.  The sustainability statement is based on a Double Materiality  Assessment (DMA) covering ALK's own operation as well as its  upstream and downstream value chain. Policies, actions and  targets also cover the value chain when related to its impacts,  risks and opportunities. No information on intellectual property  or know-how has been omitted.  For a detailed description of the scope, methodology and assumptions  behind the DMA process, see ESRS 2 IRO-1 on pages 41-43.  ESRS 2-BP2  Disclosures in relation to specific circumstances  Time horizons  ALK defines the medium-term time horizon as the period ranging  from over 1 to 3 years, and long-term as any timespan beyond  3 years. The time horizons are based on ALKâs Enterprise Risk  Management framework.  Sources of estimation and outcome uncertainty  The use of estimates for metrics, including data from the value  chain, is outlined in the relevant accounting policies.  ALK identified the following estimates, assumptions and judge-  ments as significant for the sustainability statement:  ⢠"Purchased goods & services" (scope 3, category 1) green-  house gas emissions ( see E1-6 on page 54)  ⢠"Water consumption for irrigation" ( see E3-4 on page 60)  ⢠"Gender pay gap" ( see S1-16 on page 78)  ⢠"Number of patients in treatment" ( see S4-5 on page 85).  Incorporation by reference  See appendix "Incorporation by reference" on pages 92-93 IBR for the list  of datapoints incorporated by reference and phased-in, according to ESRS  2-BP2-16.  ESRS 2  Sustainability governance  ESRS 2-GOV1  The role of the administrative, management  and supervisory bodies  ESRS 2-GOV2  Information provided to, and sustainability matters  addressed by the undertakingâs administrative,  management and supervisory bodies  ALK's governance model ensures that sustainability is systemati-  cally managed and integrated into decision-making and business  strategy. It promotes long-term value creation while addressing  societal and environmental challenges. The model defines clear  roles and responsibilities and provides a framework for setting and  monitoring sustainability targets.  Information about the composition, diversity, expertise and business  conduct-related role of the administrative, management and supervisory  bodies, according to ESRS 2-GOV1-21(a, b, d, e), ESRS 2-GOV1-23(a, b) and  G1-GOV1-5(a, b), is incorporated by reference to the section "Corporate  governance" of Corporate matters on pages 28-29.  Information about experience of Board of Directors' members relevant to ALK's  sectors, products and geographic locations, according to ESRS 2-GOV1-21(c),  is incorporated by reference to the section "Board of Directors" of Corporate  matters on pages 33-34.  ALKâs Board of Directors bears the overall responsibility for ALKâs  sustainability strategy including impacts, risks, opportunities  and targets. The Audit Committee oversees sustainability disclo-  sures, processes, controls and assurance, and the Remuneration  Committee oversees sustainability-related remuneration.  The Executive Leadership Team (ELT) is responsible for  approval of all sustainability-related policies and strategy. The  ELT reports to the Board of Directors.  The Sustainability Committee, led by the Executive Vice Pres-  ident for People and Organisation, oversees legal reporting  requirements within sustainability and makes recommenda-  tions to the ELT on matters with strategic impact on the global  organisation. The mandate of the Sustainability Committee is  described in ALKâs sustainability committee charter. In 2024, the  Sustainability Committee focused on ensuring that ALK meets  ESRS and EU Taxonomy reporting requirements. Meeting quar-  terly, the committee will in future also focus on implementing  further due diligence programmes in the value chain and evalu-  ating the effectiveness of policies, actions, metrics, and targets  addressing impacts, risks and opportunities (IROs).  The Corporate Finance Department is responsible for  accounting policies, internal controls, frameworks and guide-  lines for data processes and controls.  The Sustainability Department is responsible for the sustaina-  bility strategy implementation, ensuring compliance with legal  reporting requirements, and reporting to internal and external  stakeholders.  The corporate functions are responsible for day-to-day execution  of strategic activities as well as collection of sustainability data.  ALK's IROs are integral to the company strategy. Risks identified in  the DMA are incorporated into the ERM process. However, as DMA  risks are gross risks and ERM includes risk mitigation, the meth-  odologies cannot be fully aligned. The Risk Committee, chaired  by the Chief Finance Officer, informs the Board of Directors about  ERM risks.  ESRS 2-GOV3  Integration of sustainability-related  performance in incentive schemes  Information about the integration of sustainability-related performance in  incentive schemes, according to ESRS 2-GOV3 and E1-GOV3-13, is incor-  porated by reference to the section "Corporate governance" of Corporate  matters on page 30.  ESRS 2-GOV5  Risk management and internal controls  over sustainability reporting  The Sustainability Department is responsible for preparing the  sustainability statement, overseeing the DMA process, and  advising on data collection. The Corporate Finance Department  collaborates closely on numeric data collection. Data is gath-  ered quarterly for ongoing progress tracking and verification,  with all information stored centrally.  Key challenges in creating unified sustainability disclosures  across various business units and locations include human  error and data misalignment. To minimise reporting errors,  internal controls and standard operating procedures for critical  metrics have been established based on a risk assessment, and  a four-eye principle is applied. The Sustainability Committee,  the ELT and the Audit Committee receive quarterly updates on  progress on the sustainability statement. All data comply with  the principles outlined by the ESRS.  ESRS 2-GOV4  Statement on due diligence  The statement on due diligence, according to ESRS 2-GOV4-32, is incor-  porated by reference to the appendix "Core elements of due diligence" on  pages 94-95.  ESRS 2  Stakeholder engagement  ESRS 2-SBM1  Strategy, business model and value chain  Information about ALK's key elements of general strategy, significant  groups of products and services and significant markets and customer  groups, according to ESRS 2-SBM1-40(a.i, a.ii, f) is incorporated by refer-  ence to the section "Sales and market trends" of Financial performance on  page 19.  Description of sustainability-related goals in terms of significant groups  of products and services, customer categories, geographical areas and  relationships with stakeholders, according to ESRS 2-SBM1-40(e) is incor-  + porated by reference to the section "Introduction to Allergy " of Business  and strategy on page 9.  Strategy elements that relate to or impact sustainability matters, including  the main challenges ahead, critical solutions and projects to be put in place,  according to ESRS 2-SBM1-40(g) are incorporated by reference to the  section "Expanding the addressable markets" of Business and strategy on  pages 16-17.  Headcount of employees by geographical areas, according to ESRS  2-SBM1-40(a.iii) is incorporated by reference to the section "ALK at a  glance" of the Introduction on page 5.  The business model, according to ESRS 2-SBM1-42(a,b,c) is incorporated  by reference to the section "Business model" of the Introduction on page 6.  ESRS 2-SBM2  Interests and views of stakeholders  Key stakeholders  How engagement is organised  Purpose of engagement  Examples of outcomes  Employees  ⢠Engagement survey  ⢠Strategic alignment  ⢠Human resources strategy  ⢠Employee-elected board members ⢠Understanding employees'  ⢠Improvement action plans  ⢠Workersâ councils perceptions and experiences  ⢠Training programmes  ⢠Employee development dialogues ⢠Defining training needs  ⢠Employee information  ⢠Employee meetings  Consumers and  ⢠Various digital media platforms  ⢠Creating awareness around  ⢠Improved awareness among  general public  ⢠Consumer websites, apps, email  allergies, symptoms, impact  consumers relating to allergies  flows, etc.  on quality of life and treatment  including symptoms, impact on  options, etc.  quality of life, treatment options, etc.  Healthcare  ⢠Scientific webinars and symposia, ⢠Awareness of allergy, including  ⢠Increased adoption and usage of  professionals  scientific publications, clinical  burden of disease and bene-  evidence-based disease modifying  trial data sharing, etc.  fit-risk of available allergy treat-  allergy treatments  ment strategies  ⢠Correct identification and diag-  nosis of people with allergy  ⢠Clinical practice optimisation  Suppliers and contract ⢠Contract negotiations  ⢠Compliance with ALK's Third-  ⢠Reliable long-term partnerships  manufacturers  ⢠Third-party Code of Conduct  party Code of Conduct  ⢠Adherence to ALKâs business  implementation  ⢠Commitment to Science-Based  conduct standards and collabora-  ⢠Supplier meetings and corre-  Targets initiative  tive decarbonisation progression  spondence  Investors and  ⢠Interim and annual reports,  ⢠Enhancing transparency  ⢠Strong reputation  shareholders  company announcements,  ⢠Understanding expectations to  ⢠Access to capital  websites, presentations, meet-  sustainability  ⢠Fair valuation  ings and events  ⢠Attracting responsible investors  ⢠ESG ratings  Regulatory authorities ⢠Continuous interaction  ⢠Compliance with regulations,  ⢠Compliance and market access  safety and efficacy of medicines  Active engagement with stakeholders is a fundamental aspect  of ALKâs sustainability strategy and is integrated in the overall  strategy. The interaction shapes the understanding of material  issues and supports the initiatives outlined in the sustainability  roadmap. Internal engagement occurs across a broad range  of functions including but not limited to finance, legal, environ-  ment, health and safety, procurement, people and organisation,  R&D, commercial and the ELT.  The interests and views of stakeholder groups inform ALK's  + Allergy strategy and business model, including but not limited  to:  ⢠Results from regular engagement with employees through the  workersâ councils and engagement survey, integrated into the  People and Organisation strategy and processes defined in  the Cultivate pillar.  ⢠ALKâs ongoing interaction with representatives of healthcare  professionals, patients and regulatory authorities, informing  the Innovate and Focus pillars.  ⢠Engagement with suppliers and contract manufacturers,  informing the Optimise pillar.  ⢠Engagement with investors and shareholders, handled  though the Capital Markets Day, the Annual General Meeting  and at meetings requested by larger investors on specific  sustainability-related topics.  The stakeholder engagement during the materiality assessment process is  described under ESRS 2-IRO1 on pages 41-43.  ALKâs overall business model has not been amended in response  to engagement with its stakeholders; however, ALKâs strategy  + was updated in 2024 and the Allergy strategy was launched.  The administrative, management and supervisory bodies are  informed about the views and interests of affected stakeholders  through the sustainability strategy updates.  ESRS 2  Materiality assessment process  ESRS 2-IRO1  Description of the process to identify and assess  material impacts, risks and opportunities  In 2024, ALK updated its initial Double Materiality Assessment  (DMA) from 2023 in a shortened review process, focusing on  implementing regulatory changes as well as engaging with  stakeholders to check for significant changes to the business  model or value chain, or new sustainability-related information  gathered throughout the year.  Implementing regulatory changes  Finalised European Sustainability Reporting Standards (ESRS)  standards and European Financial Reporting Advisory Group  (EFRAG) guidance published since 2023 led to adjustments  to the DMA baseline. The main adjustments to the DMA 2023  include:  ⢠A revision of initially identified positive impacts: positive  impacts have only been deemed justified if they are business-  model-related or if ALK performed well beyond standards.  ⢠An update of the DMA workbook to ensure ESRS-aligned  scoring, based on the finalised sustainability matter list of the  ESRS in inherent (gross) format.  ⢠A greater focus on capturing value-chain-related impacts,  risks and opportunities.  Identifying sustainability matters  The initial phase focused on evaluating ALK's activities and  business relationships, value chain and affected stakeholders,  in order to identify relevant sustainability matters, as outlined  in ESRS 1-AR16. ALK has used internal documents and repre-  sentative internal resources as sources to identify sustaina-  bility matters. As far as possible, datapoints were triangulated  across sources.  Parts of ALKâs value chain were covered more extensively due  to their large potential impact and the nature of ALKâs business.  External sources have been used to provide input on Environ-  ment, Social and Governance (ESG) issues with a heightened  risk of adverse impacts. Furthermore, Sustainability Accounting  Standards Board (SASB) publications for the biotech and  pharmaceuticals sector were reviewed to ensure an industry-  specific viewpoint focussing especially on the potential adverse  impacts on the end-users.  Stakeholder engagement  For the DMA review, ALK engaged with internal subject-matter  experts. These representatives covered the views and inter-  ests of affected stakeholders, including suppliers, end-users,  employees and nature, ensuring that the scope encompassed  the entire organisation. The unique nature of pharmaceuticals  and the extensive regulation of the sector made their integration  significant for ALK.  ALK conducted a human rights risk assessment as part of its  DMA, identifying impacts from a human rights perspective  (including labour rights). Insights were drawn from the engage-  ment survey and consultations with relevant stakeholders. Rele-  vant impacts were translated into corresponding risks or oppor-  tunities and mapped to ALKâs strategic functional roadmaps.  Climate-related impacts,  risks and opportunities  Climate-related impacts, risks and opportuni-  ties (IROs) were considered as part of the DMA  process related to the sustainability topics of  climate change mitigation and climate change  adaptation. However, ALK has not yet under-  taken a climate-related scenario analysis to  inform the identification and assessment of  physical risks and transition risks and oppor-  tunities over the short, medium or long term.  As a result, ALK has not yet included a climate-  related scenario analysis in the resilience  analysis of its strategy and business model.  The scope, methodology and assumptions for green-  house gas emissions are described in detail in the  accounting policies on pages 71-72.  Pollution-related impacts,  risks and opportunities  As part of the DMA process, stakeholder  representatives were consulted to identify  and assess pollution-related impacts. Site-  specific data was collected as a part of the  assessment. All production sites purchase  substances of concern, therefore they are all  deemed material for the pollution-related  impacts ( see accounting policies for list of  the sites on page 71).  Water and marine resources-related  impacts, risks and opportunities  The World Wildlife Fund (WWF) Water Risk  Filter was used to identify material impacts  related to water and marine resources at  ALK's production sites. Potential negative  impacts linked to water-scarce regions  were also identified and assessed using  the Aqueduct Water Risk Atlas tool from the  World Resources Institute (WRI). Internal  stakeholder representatives identified and  assessed impacts, in ALK's own operations  and value chain. ALK has not conducted  consultations directly with affected commu-  nities.  Biodiversity and ecosystem-related  impacts, risks and opportunities  As part of the DMA, a review was conducted  to determine which sites should be included  in the evaluation of potential and actual  biodiversity and ecosystem IROs. This review  focused on filtering sites involved in farming  processes, as they were deemed to have the  most significant potential impact on biodi-  versity. The review concluded that, after  applying this filter, only one site â Post Falls  (USA) â met the criteria. This site met the  materiality threshold and was thus deemed  material in relation to biodiversity impacts.  To identify ALK's actual and potential  impacts on biodiversity and ecosystems,  ALK has conducted an assessment using the  WWF Biodiversity Risk Filter. The analysis  followed the WWF technical guide. No transi-  tion or physical risks, including systemic risks  and opportunities were identified using the  WWF Biodiversity Risk Filter.  Engagement with stakeholder representa-  tives was also used to identify and assess  impacts at the Post Falls site, particularly  from cultivation and collection of allergenic  source materials.  ALK's only material site, Post Falls (USA), is  not located in or near biodiversity-sensitive  areas. ALK has not found it necessary to  implement biodiversity mitigation measures.  Resource use and circular  economy-related impacts, risks  and opportunities  As part of the DMA process, stakeholder  representatives were consulted to identify  and assess impacts related to resource use  and circular economy. Site-specific data was  collected as a part of the assessment. All  production sites generate waste, therefore  they are all deemed material for the related  impacts ( see accounting policies for list of  the sites on page 71).  Business conduct-related impacts,  risks and opportunities  For business-conduct-related IROs, an  industry and geographical perspective was  applied.  Materiality scoring approach  The scoring methodology and criteria used in the DMA were defined in  accordance with the requirements in ESRS 1, applying the principle of  double materiality which comprises:  Impact materiality: Scale, scope, irremedi-  ability, and likelihood of impacts (based on  whether an impact is positive/negative and  actual/potential).  The threshold for human rights-related  impacts was lowered based on ESRS 1-45  requirements.  Financial materiality: Financial magni-  tude of risk/opportunity, likelihood, and the  nature of the financial effect.  The threshold applied for the financial effect  scale is consistent with the materiality  threshold in ALK's Enterprise Risk Manage-  ment (ERM) framework.  Internal stakeholders who identified the risks  and opportunities assessed their magnitude  and likelihood to the best of their knowledge.  All IROs were assessed and scored at a gross  level. A sustainability matter was deemed  material if at least one IRO was above the  threshold, indicating either impact materi-  ality or financial materiality, or both. Non-  material sustainability matters were those  where no IRO was identified and/or all IROs  were found to fall below these thresholds.  The IROs and their scoring were evaluated  and finalised at a workshop with the stake-  holder representatives.  In the initial 2023 DMA, some topics were  easily deemed material, based on ALKâs  industry and business model. ALK focused  its efforts on assessing the materiality of  matters with greater scoring uncertainty.  Special attention was given to sustainability  matters with no identified IRO to ensure that  no significant IROs were overlooked and  the assessment accurately reflected ALKâs  business.  The 2024 DMA result was presented and  approved by the ELT, the Audit Committee  and the Board of Directors.  Decision-making and internal controls  In the DMA, there were three key decision points:  Key decision point  Decision making  Internal control procedures  Identification of  The identification was  ⢠Check that all sustainability matters were covered by internal stakeholders.  internal stakeholders  carried out by ALKâs  ⢠Check that all sustainability matters had identified IROs throughout the stakeholder  sustainability director  engagement process. If none were identified, a sanity check with key stakeholders  was performed, to see that this was sensible in light of the nature of the business.  Appropriateness of  ALKâs sustainability  ⢠Financial materiality threshold was set based on ERM thresholds.  thresholds  director and senior  ⢠Impact materiality threshold was set based on key human rights-related considera-  management  tions and following the ESRS methodology.  ⢠Thresholds were revisited in 2024 at a workshop held by senior management to  reflect on the fit of the complete DMA result to key stakeholder considerations.  Scoring of IROs  Scoring of IROs was  ⢠Scoring included a description of rationality for each IRO.  conducted by internal  ⢠Scoring was based on ESRS guidelines with a consistent method.  stakeholders  ⢠ERM information was utilised where relevant.  The process to identify, assess and manage sustainability  impacts and risk including the use of tools is separated from the  overall risk management process. Some members of the Risk  Committee are also members of the Sustainability Committee to  ensure that sustainability risks are also reflected in the ERM risk  overview where relevant.  Future steps: integration, monitoring, and review  The process was guided by ALK's sustainability-related due  diligence, including internal policy reviews, the whistleblower  channel, and ERM. The DMA assesses risks and opportunities in  relation to sustainability matters from a sustainability perspec-  tive and assesses the gross risk from these. ALKâs ERM process  is separated from the DMA process and includes risk mitigation  in the scoring. ALK will review the DMA on an annual basis,  considering trends, business context, key supplier changes, and  regulations. This shortened review will be conducted annually  unless significant changes in the business model, value chain, or  methodology are detected.  Output from the materiality assessment  The results of ALKâs 2024 DMA can be seen below. There were  no changes in materiality at the topical level compared to the  previous reporting year; however, some sub-topics were moved  from double material to financial or impact materiality, while  others became non-material after the 2024 DMA review.  In total, 178 IROs were identified and evaluated during the DMA.  Of those, 97 impacts were identified, of which 30 were deemed  material. 81 risks and opportunities were identified, of which  8 were deemed material. The IROs were consolidated and  mapped to 22 material sustainability matters. Once completed,  validated and approved, all material disclosure requirements  and datapoints were further assessed to determine the final  scope of reporting disclosures.  ESRS 2  Material impacts, risks  and opportunities  ESRS 2-SBM3  Material impacts, risks and opportunities and  their interaction with strategy and business model  The material IROs identified during the DMA are described  and presented below and alongside the topical standards:  Material impacts, risks  Location in  Time  the value chain  horizon  and opportunities  IRO  E1 â Climate change  Emissions from own operations  ALK generates greenhouse gas (GHG) emissions Actual  â â â â through its direct operations (scope 1) and  negative  purchased energy (scope 2). These emissions  impact  contribute to climate change.  Use of refrigerants contributing to  climate change  ALK uses refrigerants to cool raw materials,  Actual  â â â â pharmaceuticals and production areas. If  negative  released, these refrigerants are GHGs that  impact  contribute to climate change.  Value chain emissions  ALK's value chain generates GHG emissions  Actual  â â â â â from purchased goods and services, capital  negative  goods, upstream and downstream transporta-  impact  tion & distribution, and business travel. These  emissions contribute to climate change.  Climate change and respiratory health1  Climate change threatens respiratory health by  Oppor-  â â extending pollen seasons, increasing airborne  tunity  allergens and promoting mould growth. This  represents a market opportunity for ALK.  Location in  Time  the value chain  horizon  IRO  E2 â Pollution  Usage of REACH substances in production  ALK uses chemicals regulated by the Registra-  Actual  â â â â tion, Evaluation, Authorisation, and Restriction  negative  of Chemicals (REACH) Regulation, including  impact  Substances of Concern with potential environ-  mental and health impacts.  E3 â Water and marine resources  Water consumption in production facilities  The consumption of water in production facilities Actual  â â â â can contribute to local water scarcity, impacting negative  availability and increasing water costs for  impact  surrounding communities. Reduced water avail-  ability may also impact local ecosystems and  agriculture, and increase wildfire risks.  Usage of water in operations in water-  scarce regions  ALKâs Madrid (Spain) production site operates  Potential  â â â â in a high-water stress area. Climate change  negative  and periodic droughts could further constrain  impact  water resources, potentially affecting the local  population.  1 "Climate change and respiratory health" has been identified as an opportunity in both E1 Climate change and S4 Consumers and end-users.  Material impacts, risks  Location in  Time  the value chain  horizon  and opportunities  IRO  E4 â Biodiversity and ecosystems  Hornets and wasps eliminated for venom  harvesting  Wasp and hornet nests are removed to collect  Actual  â â â â venom for the active pharmaceutical ingredients negative  in ALKâs medicinal products. Wasps and hornets impact  are eliminated during the harvesting process.  E5 â Resource use and circular economy  Use of non-recycled paper, single-use  aluminium and single-use plastic  The use of single-use plastic, aluminium bottles  Actual  â â â â and non-recycled paper in production have  negative  environmental impacts during manufacturing  impact  and disposal.  Pharmaceutical standards on products leaving minimal  leeway for circularity in product design  The pharmaceutical industry is highly regu-  Actual  â â â â lated, requiring high standards for quality and  negative  sterility, which results in plastic waste and  impact  limited possibilities for circularity.  Location in  Time  the value chain  horizon  IRO  Operational waste partly disposed in land-  fills  Some of ALKâs operational waste goes to land-  Actual  â â â fills. The impact varies depending on local  negative  waste management infrastructure and regional  impact  regulations. Limited recycling facilities in some  areas hinder material recovery.  End of life of products  In some countries, limited recycling infrastruc-  Actual  â â â â ture for end-of-life of medical products hinders  negative  the recovery of reusable materials and recy-  impact  clable packaging.  Material impacts, risks  Location in  Time  the value chain  horizon  and opportunities  IRO  S1 â Own workforce  Decline in employee competencies due to  inadequate skill upgrading  The skills of ALK employees decline over time as  Potential  â â â â business develops and new competences are  negative  required. Individual development plans linked to impact  job content and performance goals are required  to promote continuous learning and skill-  building, enhancing the ability for employees to  meet job expectations and maintaining employ-  ability.  Employee retention, attraction and  development challenges  ALK relies on the retention and attraction of  Risk  â â skilled employees to stay competitive and  achieve its business strategy. The health-  care industry in general faces persistent high  demand for skilled labour in key locations.  Injuries due to workplace accidents in  farming and production  Employees working in farming and production  Actual  â â are at increased risk of workplace accidents.  negative  Workplace accidents can cause physical harm,  impact  affect mental well-being, and impact employee  morale and productivity.  Location in  Time  the value chain  horizon  IRO  S2 â Workers in the value chain  Health- and safety-related incidents  involving workers in the value chain  Workers across the value chain can encounter  Potential  â â â â â health and safety incidents, especially workers  negative  exposed to hazardous substances, transporta-  impact  tion workers, and workers handling hazardous  waste.  Material impacts, risks  Location in  the value chain  horizon  and opportunities  IRO  S4 â Consumers and end-users  Allergy treatment  ALKâs allergy treatments significantly improve  Actual  â â â â patients' quality of life and personal well-  positive  being by addressing a wide range of allergies,  impact  including potentially life-threatening conditions  like anaphylaxis and insect venom reactions.  Barriers to access  Allergy treatment must be prescribed by a  Actual  â â â â healthcare professional, and is often not prior-  negative  itized by healthcare systems, creating barriers  impact  for patients. Treatments are typically affordable  through public or private insurance, but high  costs can limit access for uninsured or low-in-  come individuals.  Patient safety  Allergy treatments are effective in most cases  Actual  â â â â but not all. If treatment is ineffective, limited  negative  alternatives leave individuals without potential  impact  benefits, directly impacting their well-being and  safety.  Climate change and respiratory health1  Climate change threatens respiratory health by  Oppor-  â â extending pollen seasons, increasing airborne  tunity  allergens, and promoting mould growth. This  represents a market opportunity for ALK.  Location in  Time  the value chain  horizon  IRO  G1 â Business Conduct  Animal welfare  ALK conducts animal testing to ensure its medi-  Actual  â â â â cines are safe and effective, using animals only  negative  when alternative models are insufficient. Regular impact  experiments involve allergen injections on mice  in internal R&D facilities. The negative impacts  include injections, captivity and euthanasia.  Potential bribery of healthcare  professionals  The pharmaceutical industry, including ALK,  Risk  â â faces bribery and corruption risks, especially  in interactions with healthcare professionals.  The main risk is potential bribery to boost sales  which could lead to significant legal, reputa-  tional, and financial repercussions.  ESRS 2-IRO2  Disclosure Requirements in ESRS covered by the undertakingâs sustainability statement  Thresholds used for the DMA process are described in ESRS 2-IRO1 on page 42.  The content index of ESRS disclosure requirements and the list of datapoints that derive from other EU legislation,  according to ESRS 2-IRO2-56, are incorporated by reference to the appendices "Content index of ESRS disclosure  requirements", on pages 96-98, and "List of datapoints that derive from other EU legislation", on pages 99-105.  E1 Climate change  Strategy  E1-1  Transition plan for climate change mitigation  In January 2024, the Science Based Targets initiative (SBTi)  validated and approved ALK's absolute CO2 reduction targets.  The targets align with the latest climate science to achieve the  Paris Agreement goals, limiting global warming to 1.5°C. While  changes to ALK's business model will not be necessary, specific  actions will be implemented following different decarbonisation  levers.  Decarbonisation levers  ALK's transition plan is focused on reducing carbon emissions  from its own operations. This is achieved through the following  levers:  ⢠Transitioning towards renewable energy,  ⢠Electrifying boilers and the company vehicle fleet,  ⢠Substituting refrigerant chemicals in coolers,  ⢠Implementing energy efficiency measures.  Further details on decarbonisation levers and climate change mitigation  actions undertaken in 2024 are provided in E1-3 on page 51.  ALK recognises the presence of certain locked-in emissions and  has considered them during target setting and reduction action  planning. These emissions do not jeopardise the attainment of  the greenhouse gas (GHG) emission reduction targets.  Embedded in strategy  The transition plan is embedded in ALK's strategy and funded  through the annual business and financial planning process. It  has been approved by ALKâs Investment Portfolio and Sustain-  ability committees. The transition plan requires investments,  which are aligned with ALK's financial planning. In particular,  the electrification of boilers demands CapEx investments, and is  reported as a taxonomy-eligible activity.  ALK has not claimed alignment of its economic activities with  delegated regulations on climate adaptation or mitigation under  the Taxonomy Regulation ( see "EU taxonomy" on page 67).  However, efforts will be made to align activities where possible.  ALK is not excluded from EU Paris-Aligned Benchmarks.  ALK's commitment to reducing its GHG emissions is strength-  ened by sustainability-related incentives in the remuneration  schemes for the Executive Leadership Team. This incentivising  of executives results in a more urgent drive for decarbonisa-  tion-related processes.  ALK's short-term and long-term incentive schemes are presented in  detail in the "Corporate governance" section of Corporate matters  on page 30.  ESRS E1  Location in  Time  the value chain  horizon  Impacts, risks and  opportunities  E1 Climate change  IRO  Emissions from own operations  Actual negative impact  â â â â Use of refrigerants contributing to climate change  Actual negative impact  â â â â Value chain emissions  Actual negative impact  â â â â â Climate change and respiratory health  Opportunity  â â E1-SBM3  Material impacts, risks and opportunities and their  interaction with strategy and business model  ALK has not undertaken a climate-related scenario analysis or  a resilience analysis. The materiality assessment described in  ESRS 2-IRO1 on pages 41-43 identified the following climate  change impacts. No material climate-related physical risks or  climate-related transition risks were identified during the mate-  riality assessment.  Impact  Emissions from own operations  ALK impacts the environment through the emission of GHG.  These emissions result from ALK's direct operations (Scope 1)  and purchased energy (Scope 2). In particular, ALKâs energy  consumption is partially based on non-renewable sources,  including natural gas.  This negative impact is located within ALK's own operations  and occurs over the short, medium and long term. ALK has  committed to a science-based target to reduce its GHG emis-  sions by 42% by 2030. As part of its GHG emission reduction  plan, ALK is taking steps to transition to renewable energy and  to improve energy use.  Impact  Use of refrigerants contributing to climate change  ALK uses refrigerants as cooling agents in the storage of raw  materials and pharmaceuticals and for cooling production  areas. While these refrigerants are not ozone-depleting, they  are classified as greenhouse gases (GHGs) and contribute to  climate change if released into the atmosphere. Their role in  supporting operational processes highlights their importance  while also presenting potential environmental risks. This repre-  sents an actual negative impact that occurs in ALK's own opera-  tions over the short, medium and long term, as a result of its own  activities.  Impact  Value chain emissions  ALK's value chain represents 93% of GHG emissions, mostly  due to the manufacture and provision of purchased goods and  services. These emissions stemming from ALK's direct business  relationships contribute to climate change. This negative impact  is located within ALK's upstream and downstream value chain in  the short, medium and long term. ALK has set a science-based  target to ensure that suppliers representing 80% of its scope 3  emissions have science-based targets in place by 2028.  Opportunity  Climate change and respiratory health  Climate change directly threatens respiratory health by  extending pollen seasons, increasing airborne allergens,  promoting mould growth, and altering the distribution and  abundance of allergenic plants. The increased length and  severity of pollen seasons expand the potential market size for  ALK, as more individuals suffer from prolonged and intensified  allergy symptoms.  This long-term potential opportunity for ALK is described further in  S4-SBM3 on page 84.  ESRS E1  Impact, risk and  opportunity management  E1-2  Policies related to climate change  mitigation and adaptation  ALK is in the process of addressing the most  significant categories of GHG emissions,  including all of its scope 1 categories, as  well as purchased goods and services and  business travel in scope 3. As an example,  this translates into local policy updates on  company fleet and business travel.  As a result, ALK has not had the need for estab-  lishing a formal global policy related to climate  change mitigation and adaptation, energy  efficiency or renewable energy deployment.  E1-3  Actions and resources in relation  to climate change policies  ALK has developed a roadmap out to 2030 to  reduce its carbon emissions. While this plan  is not linear, it has been developed through  a mapping exercise and, overtime, takes  account of the projected business growth of  the company. ALK has prioritised investments  in reducing the environmental impact of its  own operations (Scope 1 and 2).  The achieved GHG emission reductions are described  in E1-6 on pages 53-54.  ALK is addressing its climate change impacts and climate-related opportunity through the following  decarbonisation levers and actions:  Transitioning towards  renewable energy  ALK has been purchasing  third-party audited Renew-  able Energy Certificates for  electricity since 2019. These  certificates cover 100% of  ALKâs electricity consumption  at production sites where  direct renewable energy  sourcing is not possible.  Operating expenditure (OpEx)  is allocated on an ongoing  basis to purchase the certifi-  cates. In 2024, this amounted  to DKK 0.5 million ( see  Income statement, on page  107 in the consolidated finan-  cial statements).  Electrifying boilers and  the company vehicle fleet  ALK is also reducing CO2 emissions by  converting production boilers from natural  gas to electricity. The replacement of a boiler  in Hørsholm (Denmark) site was imple-  mented in 2022. In 2024, ALK also initiated  the replacement of a gas boiler in France,  with daily operations expected to commence  by 2026. The last boiler replacement will be  initiated by 2028, with full implementation  planned for 2030.  In 2024, ALK also continued the transition of  the company fleet to electric vehicles, with  an initial focus on the countries in Northern  Europe where the infrastructure is well devel-  oped.  The electrification of boilers requires CapEx  investments, which are accounted for in ALK's  annual budget processes and have been  approved by administrative, management,  and supervisory bodies. In 2024, ALK allo-  cated DKK 4 million in CapEx to support the  implementation of the decarbonisation project  for the boilers in France ( see note 3.2 in the  consolidated financial statements, on page  123). The ability to implement the action does  not depend on specific preconditions.  Substituting refrigerant  chemicals in coolers  Starting in 2023, ALK has  mapped all cooling systems  and refrigerants, creating  a timeline for substitution  based on legal requirements,  equipment lifecycle, and cost  considerations. Any refrig-  erant replacement will priori-  tise options with a lower global  warming potential.  To minimise the environ-  mental risks associated with  refrigerant use, ALK has  initiated a cross departmental  programme to better manage  cooling systems and refrig-  erants. ALK is focusing on  initiatives to improve moni-  toring, reporting, preventive  maintenance and substitution,  while maintaining operational  efficiency.  Implementing energy  efficiency measures  In 2023, ALK initiated energy-  saving measures, including  installing LED lighting and  sensor-controlled lighting  systems, to reduce overall  energy consumption. While  the identification of further  potential initiatives continues,  the immediate large-scale  activities have already been  implemented.  ESRS E1  Metrics and targets  E1-4  Targets related to climate change  mitigation and adaptation  ALK has set two targets related to climate  change mitigation:  ⢠reduce its absolute CO2 emissions by 42%  between 2022 and 2030 in its own operations  (market-based Scope 1 and Scope 2)  ⢠have 80% of its emissions from suppliers  with science-based targets by 2028 (Scope  3).  Those targets were approved by the Science  Based Targets initiative in January 2024, and  are compatible with limiting global warming  to 1.5°C.  In 2022, ALK's scope 1 and 2 (market-based)  accounted for 5,492 tCO2e, with scope 1 repre-  senting 90%. The boundaries of this target  exclude ALK's sales offices, which account for  less than 5% of its total emissions. The rest of  the assumptions and methodologies align with  the GHG emissions reporting disclosed under  E1-6 on page 54.  The different decarbonisation levers are presented  under E1-3 on page 51.  E1-6  Gross Scopes 1, 2, 3 and Total GHG emissions  Science-based targets  Unit  2024  20231  20221  Scope 1+2 (production sites)  Total scope 1+2 (location-based)  Tonnes CO2eq  11,348  11,266  10,814  Total scope 1+2 (market-based)  Tonnes CO2eq  5,384  5,709  5,492  Change in scope 1 & 2 from a 2022 baseline  % -2%  +4%  - Scope 3  Scope 3 emissions from suppliers with  science-based targets  % 37  33  N/A  1 The comparative figures for 2022 and 2023 have been updated to reflect the acquisition of ALK's production site in Plainville  (USA) as well as collecting vehicles in Post Falls (USA). 2022 and 2023 figures are not covered by the Independent Auditorâs  limited assurance report.  Emissions from scope 1 and 2 were 2% lower  than the science-based target baseline (2022:  5,492 tonnes CO2eq).  This reflects a slight decrease in direct energy  consumption, mainly related to the reduc-  tion of natural gas consumption, due to the  replacement of a gas boiler to run on elec-  tricity at Hørsholm (Denmark) production site.  Refrigerants were reduced due to an  increased focus on systematic and preventive  maintenance as well as closing of equipment  where leaks have been identified.  Emissions from company fleet were reduced  compared to 2023. This reflects ALKâs tran-  sition towards electric vehicles, which will be  fully implemented in the coming years.  Scope 2 market-based reflects the purchase  of renewable energy certificates for all sites.  ALKâs ambition to reduce GHG emissions by  42% by 2030 remains unchanged.  Over the coming years, investments in boilers  which run on electricity rather than natural  gas will make a major contribution to the CO2  reduction.  The share of suppliers with science-based  targets increased to 37% (2023: 33) reflecting  ALKâs continued efforts in engaging with its  suppliers to implement CO2 emission targets  compatible with limiting global warming to  1.5°C.  Scopes  Unit  2024  20231  20221  Scope 1  Direct energy consumption  Tonnes CO2eq  3,325  3,207  3,368  Company fleet  Tonnes CO2eq  1,383  1,454  1,355  Refrigerants  Tonnes CO2eq  217  501  235  Total scope 1  Tonnes CO2eq  4,925  5,162  4,958  Scope 2  Location-based  Production sites  Tonnes CO2eq  6,423  6,10 4  5,856  Sales offices  Tonnes CO2eq  297  N/A  N/A  Total scope 2 - location-based  Tonnes CO2eq  6,720  6,104  5,856  Market-based  Production sites  Tonnes CO2eq  459  547  534  Sales offices  Tonnes CO2eq  297  N/A  N/A  Total scope 2 - market-based  Tonnes CO2eq  756  547  534  Scope 3  Cat. 1. Purchased goods & services  Tonnes CO2eq  53,825  41,175  49,096  Cat. 2. Capital goods  Tonnes CO2eq  3,307  3,403  3,974  Cat. 3. Fuel & energy related activities  Tonnes CO2eq  2,985  2,364  2,483  Cat. 4. Upstream transportation & distribution Tonnes CO2eq  5,614  5,471  4,748  Cat. 5. Waste generated in operations  Tonnes CO2eq  89  773  105  Cat. 6. Business travel  Tonnes CO2eq  2,626  4,615  3,995  Cat. 7. Employee commuting  Tonnes CO2eq  5,696  6,153  5,724  Cat. 9. Downstream transportation &  distribution  Tonnes CO2eq  336  74  313  Cat. 12. End of life treatment of sold products Tonnes CO2eq  28  39  37  Total scope 3 Tonnes CO2eq  74,506  64,067  70,475  Scopes  Unit  2024  20231  20221  Total emissions (location-based)  Tonnes CO2eq  86,151  75,333  81,289  Total emissions (market-based)  Tonnes CO2eq  80,187  69,776  75,967  GHG intensity  Tonnes CO2eq/  (scope 1 and 2 market-based)  DKKm  1.0  1.2  1.2  GHG intensity  Tonnes CO2eq/  (total emissions, location-based)  DKKm  15.6  15.6  18.0  GHG intensity  Tonnes CO2eq/  (total emissions, market-based)  DKKm  14.5  14.5  16.8  Net revenue  DKKm  5,537  4,824  4,511  Bundled energy attribute claims  % - N/A  N/A  Unbundled energy attribute claims  % 88%  N/A  N/A  GHG scope 3 calculated using primary data  % 15%  N/A  N/A  1 The comparative figures for 2022 and 2023 have been updated to reflect the acquisition of ALK's production site in Plainville  (USA) as well as collecting vehicles in Post Falls (USA). 2022 and 2023 figures are not covered by the Independent Auditorâs  limited assurance report.  The increase in total scope 3 to 74,506 tonnes (2023: 64,067) is primarily related to the increase of  purchased goods and services as a result of the increased turnover. Business travel decreased to 2,626  tonnes (2023:4,615) reflecting the focus on reduced travelling across all functions implemented end of  2023.  E1-5  Energy consumption and mix  Unit  2024  20231  Energy consumption from fossil sources  Fuel consumption from coal and coal products  MWh  - - Fuel consumption from crude oil and petroleum products  MWh  2,420  2,717  Fuel consumption from natural gas  MWh  14,524  14,232  Fuel consumption from other fuel sources  MWh  - N/A  Consumption of purchased or acquired electricity, heat,  steam, or cooling from fossil sources  MWh  10,148  5,241  MWh  27,092  22,190  Energy consumption from nuclear sources  Energy consumption from nuclear sources  MWh  4,505  4,658  MWh  4,505  4,658  Energy consumption from renewable sources  Fuel consumption for renewable sources  MWh  - - Consumption of purchased or acquired electricity, heat,  steam and cooling from renewable sources  MWh  19,810  23,702  MWh  19,810  23,702  Total energy consumption  MWh  51,407  50,550  Share of renewable sources in total energy consumption  % 39%  47%  Energy intensity associated with activities in  high climate impact sectors  MWh/DKKm  9.3  10.5  1 The comparative figures for 2023 have been updated to reflect the acquisition of ALK's production site in Plainville (USA) as well  as collecting vehicles in Post Falls (USA). 2023 figures are not covered by the Independent Auditorâs limited assurance report.  The share of renewable sources in total energy  consumption decreased due to more accurate  documentation from energy providers.  Since ALK's activities belong to a high climate  impact sector, energy intensity is calculated  on the total revenue. The decrease in intensity  reflects the more efficient use of energy at the  E2 Pollution  ESRS E2  Impacts, risks and  opportunities  E2 Pollution  IRO  Usage of REACH substances in production  Actual negative impact  ESRS 2-SBM3  Material impacts, risks and opportunities and their  interaction with strategy and business model  Impact  Usage of REACH substances in production  ALK uses chemicals that fall within the scope of the Registration,  Evaluation, Authorisation, and Restriction of Chemicals (REACH)  Regulation. Substances of Concern (SoCs) are regulated on  the basis of their potential environmental and health impacts.  Some of these chemicals may also appear on restricted or  phased-out lists, such as the Candidate List of Substances of  Very High Concern (SVHCs), requiring careful management to  ensure compliance with legal requirements. ALK recognises  that the continued usage of such chemicals contributes to their  commercialisation, which can result in broader environmental  consequences if not properly controlled.  The use of REACH substances has a negative actual impact  on the environment, which arises in ALK's own operations on  the short, medium and long term. The production processes  soil.  Location in  Time  the value chain  horizon  â â â â requiring REACH-regulated chemicals reflect the ongoing chal-  lenge of balancing operational needs with regulatory compli-  ance and environmental considerations. ALK has not yet formal-  ised policies or targets on Substances of Concern or Substances  of Very High Concern. However, the company ensures compli-  ance with local regulations and REACH requirements for chem-  ical use and handling in production.  Pollution of air, water, and soil is considered immaterial to  ALK due to the very low levels of pollutants in its operations,  with minimal impact on the environment or human health. The  impacts and risks are deemed immaterial as they do not meet  the threshold, and no risks or opportunities were identified for  ESRS E2  Impact, risk and opportunity  management  E2-1  Policies related to pollution  ALK ensures compliance with local regulations  and REACH requirements for chemical use and  handling in production, and relevant actions  and resources are evaluated and allocated  at the operational level as appropriate. As a  result, ALK has not identified the need for a  centralised global policy related to pollution  that specifically addresses actions within the  mitigation hierarchy related to pollution, such  as pollution avoidance, reduction or restora-  tion efforts where there has been pollution of  air, water and soil.  The use of REACH-regulated chemicals  highlights the shared responsibility among  producers and users to minimise their poten-  tial impact on the environment and look at  possible substitution. ALK acknowledges that  the continued use of such chemicals contrib-  utes to their commercialisation, which can  result in broader environmental consequences  if not carefully managed.  E2-2  Actions and resources  related to pollution  ALK is committed to maintaining compliance  with the REACH regulation and local legisla-  tion and to responsibly manage the chemicals  it uses. Initiatives are directed at ensuring  safe handling, storage, and use of regulated  chemicals on all production sites, with ongoing  updates to data and processes as required by  evolving regulations.  As part of its ongoing initiatives, ALK has  worked in 2024 on mapping and estab-  lishing an overview of purchased quantities  of Substances of Concern (SoCs) and their  subset, Substances of Very High Concern  (SVHCs), in its own operations ( see E2-5  on page 57). This initiative aims to improve  visibility and understanding of the volume and  use of these chemicals within the organisation,  supporting compliance and informed analysis  and decision-making. Since ALK does not yet  have a global policy, it has not taken specific  actions in 2024 to achieve pollution-related  policy objectives.  ESRS E2  Metrics and targets  E2-3  Targets related to pollution  ALK has passed all the latest Local Envi-  ronmental Authoritiesâ requirements and  inspections at all of its sites. However, since  2024 is the first year of global consolidated  reporting of substances of concern, ALK  has not set global targets for preventing  and controlling air pollutants, emissions to  water, soil pollution, substances of concern  and substances of very high concern,  beyond what is determined by local regu-  lations.  Compliance with REACH-regulated chem-  icals standards highlights the challenge  of balancing operational needs with  environmental and regulatory require-  ments. As phase-outs and restrictions  are implemented, ALK remains flexible  to ensure compliance and mitigate risks.  The company is evaluating its approach  and considering future targets to align  with evolving sustainability priorities and  regulatory expectations. ALK will focus on  reducing substances of very high concern  by implementing improvements in the  processes at one of ALKâs material produc-  tion sites.  E2-5  Substances of concern and substances of very high concern  Substances of concern and substances of very high concern  Unit  2024  Substances of concern procured  Tonnes  5.0  Substances of very high concern procured  Tonnes  0.9  E3 Water and marine resources  ESRS E3  Impacts, risks and  opportunities  E3 Water and marine resources  IRO  Water consumption in production facilities  Actual negative impact  Usage of water in operations in water-scarce regions  Potential negative impact  ESRS 2-SBM3  Material impacts, risks and opportunities and their  interaction with strategy and business model  Impact  Water consumption in production facilities  ALKâs production facilities rely on the consumption of water,  which is an important natural resource in many areas.  Water usage can contribute to local water scarcity, poten-  tially impacting availability and increasing water costs for  surrounding communities. Reduced water availability may also  affect the ability of the soil to support vegetation, impacting  local ecosystems and agricultural activities. Prolonged dryness  may also increase the potential for wildfires in certain areas.  This represents an actual negative impact on people and the  environment, occurring in the short, medium and long term. To  mitigate it, ALK monitors water use in its production facilities to  ensure compliance with local legal regulation.  Impact  Location in  Time  the value chain  horizon  â â â â â â â â Usage of water in operations in water-scarce regions  ALKâs production site in Madrid (Spain) operates in an area of  high-water stress. In this water-scarce region, the availability  of water resources is increasingly constrained due to climate  change and periodic droughts. As a pharmaceutical company  ALK is prioritised in terms of water supply; however, the use of  water in operations in such regions has a potential negative  impact on the local population, who might face constraints in  the use of water. This potential impact occurs over the short,  medium and long term. ALKâs water consumption is monitored  to ensure compliance with applicable regulations and minimise  negative impacts on the local water basin.  ESRS E3  Impact, risk and opportunity management  E3-1  Policies related to water  has been on mapping ALK's impacts, risks  In 2024, ALK focused on mapping consumption  and marine resources  and opportunities linked to water and marine  from the installed meters to evaluate opportu-  ALK monitors water use in its production facil-  resources. In the coming years, the company  nities for efficient water use and sustainable  ities to ensure compliance with local waste-  will consider the potential adoption of such a  management. These efforts aim to reduce the  water discharge regulations and to minimise  policy.  environmental impact of water consumption  the impact on local water resources.  while supporting operational needs. As a  E3-2  result, no actions were taken in 2024 in relation  ALK does not have a formal global policy on  Actions and resources related to  to general water use, and specifically to ALK's  water management, treatment, or pollution  water and marine resources  production site in Madrid (Spain). In addition,  beyond local regulations. There are currently  ALK aligns its practices with regulatory  at the time of reporting, no action plan for  no policies in place to guide product and  requirements and environmental considera-  2025 has been developed yet.  service design in addressing water-related  tions, seeking opportunities for efficient water  challenges, nor are there commitments  use and sustainable management. Water  to decrease material water consumption  management is an integral part of ALK's envi-  in regions facing water risks. Addressing  ronmental and health and safety management  the water-related challenges could involve  tasks.  adopting advanced technologies, recycling  wastewater, or optimising processes to mini-  The demand for water as a part of ALK's  mise water use, all in line with the local legal  production processes underscores the need to  authorities and the production of pharma  balance operational requirements with envi-  products.  ronmental sustainability.  As sustainable oceans and seas is not deemed  To ensure operational efficiency and minimise  material, no related policy has been adopted.  consumption, ALK has installed water meters  to monitor and control water usage. This is  ALK has not adopted a policy covering its  particularly important in areas with existing  Madrid (Spain) production site, located in an  water-related challenges.  area of high-water stress. In 2024, the focus  ESRS E3  Metrics and targets  E3-3  Targets related to water  and marine resources  ALK has not set global targets for reducing  water consumption or managing marine  resources and water risk areas beyond local  legal requirements. In 2024, ALK installed  meters at all production sites to monitor water  usage, both in production areas and for irri-  gation. This enables ALK to assess efficiency  and consumption across different processes,  ensuring effective future water use.  E3-4  Water consumption  Water  Unit  2024  20231  Water consumption  Irrigation  m3  312,773  N/A  Domestic water use  m3  92,533  101,413  m3  405,306  N/A 2  Water storage  Water stored  m3  - - Changes in storage  m3  - - Water consumption in areas at material water risk  m3  11,495  10,646  Water reused and recycled  m3  18,624  N/A  Water intensity  m3/DKKm  73.2  N/A  1 2023 figures are not covered by the Independent Auditorâs limited assurance report.  2 In 2023, ALK reported a total water consumption of 128,087 m3, excluding irrigation from leased land, for which data was not  available and could not be retrieved.  E4 Biodiversity and ecosystems  Strategy  E4-1  Transition plan and consideration  of biodiversity and ecosystems in  strategy and business model  The majority of ALK's allergenic source mate-  rials covering pollens, mites and molds are  cultivated and collected. Source material from  insect venom is collected by electro-stimu-  lation (bees) and by a collection of wasp and  hornet nets. The allergen source materials are  purified before further processing to active  pharmaceutical ingredients (APIs) used in  ALK's medicinal products. Systemic sustain-  able agricultural practices are implemented to  minimise ALK's impact on nature, including:  ⢠Diversifying species by planting a variety of  crop types and thereby providing a diverse  range of pollination times for pollinator  species like bees.  ⢠Minimising pesticide and fertiliser inputs by  leveraging Integrated Pest Management  Principles.  ⢠Protective native flora and fauna by estab-  lishing large buffer zones.  ⢠Minimum soil disturbance by implementing  lime application.  As part of the materiality assessment process,  a review of ALK's production sites has been  done, using the WWF Risk Filter to identify and  evaluate potential and actual biodiversity and  ecosystem impacts, risks and opportunities  ( for more details, see E4-IRO1 on page 42).  Post Falls (USA) met the materiality threshold  and was thus deemed material in relation to  biodiversity impacts.  ALK has not yet conducted a comprehensive  resilience analysis of its strategy and business  model in relation to biodiversity and ecosys-  tems. As a result, a transition plan related to  biodiversity and ecosystems has not been  created yet. The analysis of ALKâs material  sites in terms of dependencies and ecolog-  ical status will be performed over the coming  years.  Time  Location in  ESRS E4  the value chain  horizon  Impacts, risks and  opportunities  E4 Biodiversity and ecosystems  IRO  Hornets and wasps eliminated for  Actual negative impact  â â â â venom harvesting  ESRS 2-SBM3  Material impacts, risks and  opportunities and their interaction  with strategy and business model  The materiality assessment process outlined  in ESRS 2 IRO-1, on pages 41-43, did not  identify any material negative impacts with  regard to land degradation, desertification or  soil sealing. However, the following material  impact on the state of species was identified:  Impact  Hornets and wasps eliminated  for venom harvesting  ALK collaborates with local communities near  Post Falls (USA) production site to remove  wasp and hornet nests and collect venom for  the API in its medicinal products. The wasps  and hornets are eliminated as part of the  harvesting process. Removing wasp and  hornet nets is part of pest control programs in  areas in densely populated areas.  This site is not located close to a biodiversity-  sensitive area and thereby not negatively  affecting such areas. Moreover, wasps and  hornets are not threatened species.  The venom harvesting process represents an  actual negative impact on the local popula-  tion size of wasps and hornets. This impact is  directly due to ALK's activities and occurs in  ALK's own operation in the short, medium and  long term.  The list and description of material sites is further  developed in E4-1 on page 61.  ESRS E4  Impact, risk and  opportunity management  E4-2  Policies related to biodiversity  and ecosystems  ALK adheres to national legislation and regu-  latory demands, as described in procedures  part of ALK's Quality Management System  covering the part of the supply chain ALK  controls. ALK has performed several initiatives  over the years to support biodiversity at its  material site in Post Falls (USA). As ALK has not  yet performed a biodiversity-related resil-  ience analysis, ALK does not currently have  a formal policy relating to biodiversity and  ecosystems.  Specifically, the company has not adopted  a policy addressing its material impacts or  dependencies, or their social consequences.  There are also no policies on responsible  production, sourcing, or consumption from  ecosystems, nor on the traceability of prod-  ucts, components, and raw materials. ALK  does not have a biodiversity and ecosystem  protection policy covering operational sites  owned, leased, or managed in or near a biodi-  versity sensitive area. ALK has no policy on  sustainable land and agriculture, sustainable  oceans and seas or deforestation.  E4-3  Actions and resources related to  biodiversity and ecosystems  In 2024, the focus has been on mapping ALK's  impacts, risks and opportunities relating to  biodiversity and ecosystems. No new actions  have been taken in 2024 on this matter beyond  what is already implemented as part of daily  management. In particular, no biodiversity  offsets have been used, and local and indige-  nous knowledge and nature-based solutions  have not been considered.  ESRS E4  Metrics and targets  E4-4  Targets related to biodiversity and ecosystems  ALK is to conduct a deeper analysis of its biodiversity impacts  in the coming years with inspiration from the Task Force on  Nature-related Disclosure framework. As this analysis is still to  be performed, ALK has not yet set targets related to biodiversity  and ecosystems. In particular, no ecological thresholds and  allocations of impacts were applied, and no biodiversity offsets  have been used. The Kunming-Montreal Global Biodiversity  Framework, the EU Biodiversity Strategy for 2030 and other  biodiversity and ecosystem-related national policies and legis-  lation have not been used.  E5 Resource use and circular economy  ESRS E5  Location in  Time  the value chain  horizon  Impacts, risks and  opportunities  E5 Resource use and circular economy  IRO  Use of non-recycled paper, single-use aluminium and  Actual negative impact  â â â â single-use plastic  Pharmaceutical standards on products leaving minimal leeway  Actual negative impact  â â â â for circularity in product design  Operational waste partly disposed in landfills  Actual negative impact  â â â End of life of products  Actual negative impact  â â â â ESRS 2-SBM3  Material impacts, risks and opportunities and their  interaction with strategy and business model  Impact  Use of non-recycled paper, single-use  aluminium and single-use plastic  ALK's operations require the use of single-use plastics in  production, as well as single-use aluminium bottles for trans-  porting active pharmaceutical ingredients. ALK also uses  non-recycled paper and plastics, which are vital for maintaining  sterility and efficiency in operations.  Those materials have negative environmental impacts during  manufacturing and/or end of life. In particular, manufacturing of  single-use plastics consumes fossil fuels and emits greenhouse  gases, furthering climate change, while plastic waste, often  non-biodegradable, poses long-term environmental risks. Once  disposed of, plastics accumulate in landfills and, in some cases,  enter natural ecosystems, where they can harm wildlife and  pollute water bodies. However, if disposed correctly, plastic is  also to be recognised as an important energy source. Aluminium  is an energy-intensive resource. The environmental effects of  paper production include deforestation, use of large amounts of  energy and water, and air pollution and waste problems.  This actual negative impact occurs in ALK's own operations  on the short, medium and long term. ALK recognises its short-  term operational reliance on these materials and is working to  evaluate opportunities for more sustainable practices, such as  improved recycling efforts.  Impact  Pharmaceutical standards on products leaving  minimal leeway for circularity in product design  The pharmaceutical industry is highly regulated, setting high  standards on the quality and sterility of products. The high  standards, which ALK must comply with, result in plastic waste  and limited options for using circular products. This leads to  environmental impacts from the upstream production of the  materials and increased waste from both production and end-  users.  This results in a negative actual impact on the environment,  which spans the short, medium and long term in its own oper-  ations. ALK is exploring opportunities to transition to more  sustainable packaging, e.g. by introducing recycled paper and  cardboard.  Impact  Operational waste partly disposed in landfills  A portion of ALKâs operational waste is disposed of in land-  fills, leading to potential environmental effects such as odour,  noise, smoke, and water contamination. This impact varies with  local waste management infrastructure, with greater reliance  on landfills in the USA compared to Europe. Limited recycling  infrastructure in some areas hampers the recovery of reusable  materials, and recycling rates depend heavily on local state  regulations.  This actual negative impact occurs within ALKâs own opera-  tions over the short and medium term. Efforts are underway to  enhance waste tracking and explore recycling and reuse oppor-  tunities to reduce landfill dependency.  Impact  End of life of products  The management of ALK products at the end of their lifecycle is  shaped by national and regional differences in waste handling  practices. Limited recycling infrastructure for medicinal prod-  ucts means that, in some regions, some products are ultimately  disposed of in landfill systems. This hinders the recovery of  potentially reusable materials, including recyclable packaging,  and creates uncertainty in disposal outcomes.  This creates an actual negative impact in ALK's downstream  value chain as a result of ALK's own activities. It occurs in the  short, medium and long term.  Although some ALK products include recyclable packaging or  components, the recycling rates for these materials depend  heavily on local country and state regulations. ALK is continuing  to evaluate opportunities to better understand and improve the  handling of waste streams in the product lifecycle.  ESRS E5  Impact, risk and opportunity  management  E5-1  Policies related to resource use and circular economy  Waste is managed at site level, meeting local legal require-  ments. As a result, ALK has not previously had the need for  establishing a formal global policy on resource use and circular  economy. In 2025, ALK plans to introduce a global waste policy  to address landfill waste.  Concerning circular economy, ALK has not adopted global  policies specifically focused on transitioning away from the  extraction of virgin resources. Moreover, ALK does not have  global policies on sustainable sourcing and use of renewable  resources, or on addressing impacts, risks and opportunities in  ALK's upstream and downstream operations.  E5-2  Actions and resources related to  resource use and circular economy  Because ALK has not developed policies yet, no actions were  undertaken in 2024 to achieve resource use and circular  economy-related policy objectives. However, relevant actions  and resources are evaluated and allocated at the operational  level as appropriate to meet local regulatory requirements.  As part of its ongoing initiatives, ALK's focus in 2024 has been on  improving its mapping of waste types and fractions in alignment  with the ESRS. Moreover, ALK has launched initiatives which  focus on developing plans to reduce and eliminate the amount of  waste that is not part of a reuse or recycling programme.  ESRS E5  Metrics and targets  E5-3  Targets related to resource  use and circular economy  The focus in 2024 has been on aligning the  waste reporting with the ESRS to establish a  baseline. As a result, ALK has not currently  set targets related to any layer of the waste  hierarchy for resource inflows and outflows, in  particular on waste, products and materials,  whether mandatory or voluntary. However,  ALK is evaluating its approach and considering  implementing relevant targets in the future to  align with evolving sustainability priorities and  regulatory expectations.  E5-4  Resource inflows  ALK does not currently gather global data on  its material resource inflows but plans to map  this out during 2025 for future reporting.  E5-5  Resource outflows  All of ALK's waste is directed towards recy-  cling, reuse, incineration with energy recovery  and landfill. ALK does not have any waste  managed as âother disposal operationsâ.  Total waste generated amounted to 2,882  tonnes (2023: 1,939). The waste generated  increased by 49% due to improved waste  reporting and the fact that organic materials  are now included in the waste reporting.  86% (2,478 tonnes) of the total waste is non-  hazardous.  81% of the waste was diverted from disposal  (reused or recycled). Within this diverted  waste, 40% (929 tonnes) was directed  towards recycling initiatives and 60% (1,408  tonnes) was prepared for reuse, aligning with  the Waste Framework Directive (Directive  2008/98/EC).  The waste directed to disposal was carefully  managed based on waste treatment types.  Out of the 545 tonnes, 74% (403 tonnes) was  incinerated and 26% (142 tonnes) was sent to  landfill.  ALK does not currently gather global data on  the rate of recycable content but plans to map  this out during 2025 for future reporting.  At ALK, the waste composition can  be separated into two primary waste  streams:  1 Pharmaceutical waste streams,  which include  ⢠chemical waste and medical waste  (residues from APIs, solvents, and  reagents used in production processes)  ⢠product-related material (plastics,  metals, glass, and transportation  boxes).  2 Agricultural waste streams, which  come from ALK's source materials  used in the allergen production,  and include  ⢠mite media (residual materials  from the cultivation and extraction  of allergenic source materials)  ⢠organic materials (plant-based  or biological substances such as  hay and wood trimmings).  E5-5  Resource outflows  Waste generated diverted from disposal  Unit  2024  20231  Preparation for reuse  Hazardous  Tonnes  24  N/A  Non-hazardous  Tonnes  1,384  N/A  Tonnes  1,408  N/A  Recycling  Hazardous  Tonnes  221  N/A  Non-hazardous  Tonnes  708  N/A  Tonnes  929  N/A  Other recovery operations  Hazardous  Tonnes  - N/A  Non-hazardous  Tonnes  - N/A  Tonnes  - N/A  Total hazardous  Tonnes  245  N/A  Total non-hazardous  Tonnes  2,092  N/A  Total waste generated diverted from disposal  Tonnes  2,337  1,451  1 2023 figures are not covered by the Independent Auditorâs limited assurance report, and are not comparable due to change in  methods and data quality.  Waste generated directed to disposal  Unit  2024  20231  Incineration  Hazardous  Tonnes  158  N/A  Non-hazardous  Tonnes  245  N/A  Tonnes  403  270  Landfill  Hazardous  Tonnes  1 N/A  Non-hazardous  Tonnes  141  N/A  Tonnes  142  218  Other disposal operations  Hazardous  Tonnes  - N/A  Non-hazardous  Tonnes  - N/A  Tonnes  - N/A  Total hazardous  Tonnes  159  N/A  Total non-hazardous  Tonnes  386  N/A  Total waste generated directed to disposal  Tonnes  545  N/A  Total waste  Unit  2024  20231  Waste generated  Hazardous and radioactive  Tonnes  404  N/A  Non-hazardous  Tonnes  2,478  N/A  Tonnes  2,882  1,939  Non-recycled waste  Tonnes  544  N/A  Non-recycled waste  % 19%  N/A  Recycled waste  Tonnes  2,337  N/A  Recycled waste  % 81%  N/A  Accounting policies â Environmental information  The numeric datapoints reported are verified through  internal controls, analysis, benchmarks, and regular  business meetings. External auditors provide limited  assurance on 2024 metrics. The metrics are not vali-  dated by another external body, with the exception of the  science-based target metrics which are approved by the  Science Based Targets initiative (SBTi). N/A is used when  data was not available at the time of the reporting and  could not be retrieved.  Scope  Environmental data covers ALKâs production sites  in the USA (Post Falls and related farms, Port Wash-  ington, Oklahoma City, Luther and Plainville), Denmark  (Hørsholm), Spain (Madrid), and France (Vandeuil and  Varennes). Sales offices located across the globe are  excluded from reporting on energy, pollution, water,  substance of concerns and waste data due to the low  materiality of their environmental footprint.  From 2024 onwards, in accordance with ESRS require-  ments, data from sales offices are included in green-  house gas (GHG) emission reporting ( E1-6 on page  54). However, the reduction target for scope 1 and 2  remains focused primarily on production sites, as vali-  dated by SBTi.  Climate Change  E1-5  Energy consumption and mix  Energy consumption for operations is measured as  consumption of power, heat and fuel. "Fuel consump-  tion from crude oil and petroleum products" consists  of diesel, gas oil and propane. Energy consumption is  based on meter readings and/or invoices at individual  production sites. Numbers are reported in KWh and  converted to MWh.  Some invoice service periods do not align with calendar  months; however, they are one month long, determining  reporting periods. While the majority of the data is  derived from actual data, some estimations are applied  to a minor portion of the fuel consumption data:  ⢠Fuel consumption from diesel backup generators:  Diesel consumption under "fuel consumption from  crude oil and petroleum products" is primarily based  on estimates. These generators contribute only a  minor portion of the overall fuel consumption from  crude oil and petroleum products.  ⢠Fuel consumption estimation for collecting vehi-  cles: For some collecting vehicles at USA production  sites, where odometers are aged or damaged and  mileage data cannot be documented, fuel consump-  tion is estimated.  Electricity production is sourced 100% from renew-  able power, primarily through Renewable Electricity  Certificates (REC). The share of renewable power used  at production sites is reported according to the market-  based method of the GHG Protocol scope 2 Guideline.  The conversion factors for measuring units are sourced  from well-established and authoritative references.  The use of conversion factors for measuring units are  consistent across multiple sites and contexts, ensuring  reliability and uniformity in reporting and calculations.  E1-6  Gross Scopes 1, 2, 3 and Total GHG emissions  GHG emissions are prepared in accordance with the GHG  Protocol, using the operational control approach.  GHG emissions are reported in metric tonnes of carbon  dioxide equivalent according to global warming poten-  tial values published by the Intergovernmental Panel  on Climate Change (IPCC) based on a 100-year time  horizon. All greenhouse gases are included.  When available and recent, source and supplier-specific  emission factors or local grid emission factors are used.  This methodology ensures accurate emission factors by  reflecting local energy mixes and regional character-  istics, leading to reliable and relevant emission calcu-  lations. When such data are unavailable or outdated,  general emission factors are utilized. The specific data-  bases used in these instances are disclosed below.  Scope 1 emissions  Reported scope 1 emissions comprise direct energy  consumption (including emissions from collecting vehi-  cles), company fleet and refrigerants.  Direct energy consumption  GHG emission from direct energy consumption is calcu-  lated using the fuel consumption reported in  E1-5 on  page 55. This includes diesel, gas oil, natural gas and  propane.  When local emission factors are unavailable, general  CO2 emission factors from UK Government GHG Conver-  sions Factors and Environmental Protection Agency  (EPA) GHG Emissions Factors are used. These authori-  tative sources provide comprehensive data covering a  wide range of activities and energy sources, ensuring  that the Global Environment, Health and Safety (EHS)  function has access to extensive data suitable for all ESG  calculations.  Emissions from collecting vehicles are reported under  direct energy consumption. Collecting vehicles are  leased or owned company vehicles used for collecting  source materials. Emissions are based on mileage and  emission factors for diesel and gas oil are updated  according to EPA annual emissions factors.  Company fleet  Company fleet emissions are based on either actual  mileage or contracted annual mileage. Average  passenger vehicle emission factors are taken from  UK Department for Environment, Food & Rural Affairs  (DEFRA). Data for December is estimated based on  average monthly consumption in the reporting year.  Refrigerants  Emissions from refrigerants listed in the GHG Protocol  are included in scope 1. Associated CO2e emissions,  resulting from the leakage of refrigerants from cooling  systems, are calculated based on refrigerant quantities  and their respective global warming potential. Emission  factors used for reporting are based on annual data  from the UK Government Conversion Factors for GHG  reporting.  Scope 2 emissions  Scope 2 emissions comprise CO2e emissions from  purchased electricity and heat (district heating), as  disclosed in  E1-5 on page 55.  Scope 2 location-based emissions are calculated based  on average energy generation emission factors for  defined locations, while scope 2 market-based emis-  sions are calculated based on emissions calculated  from specific energy purchase contracts and therefore  consider renewable energy purchase certificates.  When local emission factors are unavailable, general  CO2 emission factors from UK Government GHG Conver-  sions Factors and EPA GHG Emissions Factors are used.  These authoritative sources provide comprehensive  data covering a wide range of activities and energy  sources, ensuring that Global EHS has access to exten-  sive data suitable for all ESG calculations.  ALK does not have bundled certificates. All electricity  consumption is covered by 100% unbundled renewable  energy certificates, while none of its district heating  consumption is covered by unbundled certificates.  Sales offices  GHG emissions from sales offices are estimated based  on office area (square meters). Emission factors are  specific to each country, and the energy use factor is a  worldwide average for offices.  Scope 3 emissions  All scope 3 emissions are calculated based on data  covering January-December 2024, except category  3, 4 and 12. The months of November and December  are estimated based on average consumption in the  reporting year.  Scope 3 categories 8, 10, 11, 13, 14, and 15 from the GHG  Protocol are excluded as they are not relevant to the  company's operations.  Purchased goods and services (Category 1)  (significant estimate): Calculated using spend-based  emission factors from the Comprehensive Environmental  Data Archive (CEDA). The use of estimates for this data-  point is considered significant.  Capital goods (Category 2): Calculated using spend-  based emission factors from CEDA for upstream emis-  sions of industrial machinery owned and operated by  ALK.  Fuel and energy related activities  (Category 3): Calculated for upstream transmission  & distribution losses of fuels, electricity and district  heating consumed by ALK which are not included in  scope 1 and scope 2, by using emission factors from  DEFRA.  Upstream transportation and distribution (Category  4): Calculated using a mix of spend-based emission  factors from CEDA and primary emissions from certain  distribution providers. Well-to-tank emission factors are  provided by DEFRA.  Waste generated in operations (Category 5): Calcu-  lated using emission factors from DEFRA dependent on  material type, treatment type, material location and  material weight.  Business travel (Category 6): Calculated using well-to-  wheel flight emissions from DEFRA with primary activity  data from service providers.  Employee commuting (Category 7): Estimated using  Quantis emission factors based on the average number  of full-time equivalent employees in the reporting year,  with well-to-tank emission factors from DEFRA.  Downstream transportation and distribution (Cate-  gory 9): Calculated using spend-based emission factors  from CEDA on trunk transportation.  End-of-life treatment of sold products (Category 12):  Estimated for materials used in products using DEFRA  emission factors for material type, country of distribu-  tion, assumed treatment type and weight.  E1-3  Actions and resources in relation to climate change  policies  Scope 1+2 reduction target  GHG emission reduction targets follow SBTi guidelines,  encompassing all production sites. Emissions from sales  offices are excluded, as they account for less than 5%  of scope 1 and 2 GHG emissions. Future developments,  such as changes in sales volumes, have been consid-  ered when setting the targets. The achieved reduction  is calculated against a 2022 baseline for scope 1 and 2  emissions from production sites, ensuring consistency in  the scope over the years.  Scope 3 emissions from suppliers with science-  based targets  This metric quantifies scope 3 emissions from suppliers  with SBTi targets, including those with commitments.  To determine this, suppliers responsible for more than  80% of GHG emissions (covering purchased goods and  services, capital goods, upstream transportation and  distribution, business travel and downstream trans-  portation and distribution) are identified based on the  highest spend and emissions data for 2024.  These suppliers are verified through the SBTi dashboard  to confirm which have approved targets. The Supplier  Tracker List is used to document suppliers with approved  targets.  After verification, the emissions from these suppliers  are aggregated and compared to the total emissions in  these categories. This methodology ensures accurate  and transparent reporting aligned with standard ESG  accounting principles.  Pollution  ALK follows the EUâs Corporate Sustainability Reporting  Directive (CSRD) and its definition of "Substances of  Concern" (SoCs) and subset category âSubstances of  Very High Concernâ (SVHCs). All production sites and  Research and Development report on purchased quan-  tities of SoCs and SVHCs. All SoCs and SVHCs arise from  purchased quantities.  At production sites, which include Product Supply and  Research and Development, comprehensive lists of  SoC chemicals are created by using the internal chem-  ical management system. SoC chemicals are labelled  with one or more Hazard-statements (H-statements),  according to the Classification, Labelling and Packaging  of chemicals (CLP Regulation) in EU. For production sites  in the USA, where H-statements are not available, GHS  hazard statements (defined by OSHA) are translated into  H-statements to determine which chemicals are SoCs or  SVHCs.  Purchased quantities are based on invoices or delivery  notes from vendors, reported in local unit of measures  and converted to metric tons for disclosure.  Water and marine resources  (incl. significant estimate for irrigation)  At production sites, water is categorised into water for  domestic use (drinking water, sanitary water, and water  for production) and water for irrigation, which is used  for cultivating source materials. For irrigation, the use of  estimates is considered significant.  Water consumption is reported in m3 based on meter  readings and/or invoices at individual production sites.  When meter readings or invoices are unavailable, esti-  mation-based water consumption is used to calculate  water consumption:  ⢠Water irrigation for leased land at Post Falls (USA)  production site is estimated based on land area. The  water consumption intensity factor (water consump-  tion per acre) is calculated by the landowner using  data from their records and their knowledge of the  land, crops, and soil. For one of the leased land, water  irrigation consumption is calculated using data from  a specific area at Post Falls (USA) production site  and then applied to that leased land for reporting  purposes.  ⢠Water usage at leased facilities in Plainville and Port  Washington (USA) production sites is estimated  based on square footage occupied by ALK, as stated  in the leasing contract, relative to the total square  footage of the building. Using these numbers, an esti-  mation for water consumption is calculated.  Currently, there is only one leased land in the USA where  water reuse occurs, overseen of the DEQ (Department  of Environmental Quality). This area is part of a water  reclamation program. The landowner provides water  consumption values for ALK crops once a year based on  meter reading.  Production sites located in areas at water risk are  identified using the "Water Scarcity" dimension of the  WWF Water Risk Filter. Madrid (Spain) production site  is the only site classified as being in a water risk area.  Additionally, areas of high-water stress are defined as  areas were the percentage of total water withdrawn is  higher than 40%, as determined by the "Water stress"  dimension of Aqueduct Water Risk Atlas tool of the World  Resources Institute (WRI). Madrid (Spain) production  site is also the sole site identified in a high-water stress  area.  Resource use and circular economy  Waste is generally reported and classified at site level  based on invoices received from waste vendor recipi-  ents. Waste for production sites is converted from local  unit into metric tons in total. Some estimates are used to  calculate waste:  ⢠General solid waste at Luther and Plainville (USA)  production sites is estimated based on the pickup  cycles reported by the waste vendor for each quarter.  ⢠For the leased location at 2 Channel at Port Wash-  ington (USA) production site, general solid waste is  not managed internally. Estimation is therefore based  on the average number of garbage bags collected  per day.  ⢠For some USA production sites and Madrid (Spain)  production site, certain types of waste are estimated  based on the number of pickups reported by the waste  vendor. These estimates are either supported by  actual waste weight measurements collected over a  defined period and applied as fixed standards for the  waste type, or, when actual weights are unavailable,  derived using conversion factors published by govern-  mental authorities.  The actual weights of containers or dumpsters are meas-  ured at local production sites over a defined period.  By default, waste is reported in accordance with the  waste hierarchy of EU waste polices and legislation,  which is described in the EU waste framework directive  (Directive 2008/98/EC).  For production sites in Europe, when there is a difference  between EU and national legislation, ALK follows the  national legislation. Waste types are categorised by  the respective waste vendor according to the national  legislation.  For production sites in the USA, estimation-based waste  is calculated using conversion factors published by the  US EPA.  Intensity calculations  Net revenue amounts are derived from ALK group's  total revenue of the consolidated financial statements  (note 2.1 on page 114).  Intensity calculations are reported as unit / annual  revenue in million DKK. GHG intensity is calculated using  total emissions (scope 1, 2 and 3) on location-based and  market-based methods.  All revenue falls under NACE Section C: Manufacturing,  Division 21: manufacturing of basic pharmaceutical  products and pharmaceutical preparations according  to Commission Delegated Regulation (EU) 2022/1288.  Manufacturing is a high climate impact sector.  S1 Own workforce  ESRS S1  Equal treatment and opportunities  ESRS 2-SBM3  Material impacts, risks and opportunities and their  interaction with strategy and business model  Location in  Time  the value chain  horizon  Impacts, risks and  opportunities  S1 Own workforce  IRO  Decline in employee competencies due to inadequate skill upgrading Potential negative impact  â â â â Employee retention, attraction and development challenges  Risk  â â As a global leader in allergy treatment within the pharmaceu-  tical industry, ALK recognises that its workforce is its most  valuable asset. ALK's strategy is designed to support their well-  being, professional growth and inclusivity, ensuring that ALK  attracts and retains key competences across its operations.  In the materiality assessment, ALK identified the following mate-  rial impact and risk:  Impact  Decline in employee competencies due  to inadequate skill upgrading  ALK relies on its employees having the right skills and compe-  tences in order to be able to perform their tasks and support  business growth. If not maintained, the employees' skills will  decline over time, and their ability to meet future business needs  will not be supported. Without adequate development plans,  employees may find it more challenging to meet new job expec-  tations, have limited opportunities for promotion, and experi-  ence a decrease in employability after leaving ALK.  This creates a potential negative impact, which occurs in ALK's  own operations over the short, medium and long term and is  directly linked to ALK's own activities.  Therefore, ALK seeks to foster a culture of continuous learning  and growth for its workforce. As part of the Global People  Performance Process, all employees are required to have  a personal development plan. These plans are linked to job  content and performance goals and are updated annually. This  process is exclusive to ALK employees and does not extend to  non-employees.  Risk  Employee retention, attraction and  development challenges  ALK operates in a highly competitive labour environment within  the pharmaceutical industry, especially at its Danish, Chinese,  and USA East Coast sites. With a revenue growth strategy of 10%,  paying competitive salaries and ensuring continuous learning  and skills development is critical for ALK to meet its strategic  targets. Salaries below relevant market levels as well as insuf-  ficient learning and development opportunities can negatively  impact employee retention and reduce the overall attractiveness  of ALK as a workplace. This may hinder the company's ability to  attract new employees and retain existing ones.  This risk is focused on ALK's own operations and could lead to a  shortage of necessary competencies needed to support busi-  ness growth in the short, medium, and long term.  To mitigate this risk, ALKâs reward philosophy and salary  processes aim to ensure competitive wage levels and empha-  sises continuous skill enhancement across all business areas,  through learning and development opportunities.  S1-1  Policies related to own workforce  ALK endorses the UN Guiding Principles on Business and Human  Rights and is a signatory to the UN Global Compact. These  commitments are integrated into ALK's Code of Conduct, which  applies to all employees.  ALK's Code of Conduct explicitly prohibits employees from  condoning or engaging in any form of child or forced labour. The  policy does not specifically mention human trafficking, as this is  not a high-risk topic within ALK's industry.  The Code of Conduct is presented in detail in G1-1 on page 88.  S1-2  Processes for engaging with own workforce  and workersâ representatives about impacts  ALKâs commitment to fostering a culture of open communica-  tion, engagement and collaboration is anchored in two key  processes: the workersâ councils and the employee engagement  survey. This engagement has informed the material impacts and  opportunities around development plans and learning opportu-  nities, as well as health and safety matters.  Workersâ councils  Formalised workersâ councils are established at all European  sites where legally required. These councils serve as dedicated  forums where both employees and management can address  and resolve a spectrum of issues, ranging from the company's  competitiveness to employee engagement. In the USA and  China, dialogues are facilitated through the People & Organisa-  tion departments.  Workersâ council meetings are held several times a year.  Engagement varies according to topic and can take the form of  information-sharing, consultation or co-determination. Involve-  ment of workers' councils in decision-making follows local legal  principles for engagement.  Engagement survey  Direct engagement with all employees is driven by the annual  global employee engagement survey, which provides a direct  avenue for expressing satisfaction and offering feedback.  This year's participation rate remained high at 95% (2023:  95%), reflecting the Executive Leadership Team's commitment  to valuing employee feedback and taking action. The overall  engagement score was 8.3 (2023: 8.4), positioning ALK in the  top 5% against the international healthcare benchmark.  The Executive Vice President of People and Organisation is  responsible for ensuring that the engagement with employees  happens and informs the Executive Leadership Team (ELT) of  the results and actions taken.  S1-4  Taking action on material impacts on own workforce,  and approaches to managing material risks and  pursuing material opportunities related to own  workforce, and effectiveness of those actions  Development plans at ALK depend on an employee's life-  cycle stage (new hire, experienced professional, or resigned  employee). These plans are linked to job content and perfor-  mance goals, updated annually between March and October.  The process is tracked through the human resources system,  with a completion rate of 93% for 2024 ( see S1-13 on page 78).  ALK follows the 70-20-10 learning principle: 70% on-the-job  training, 20% peer learning, and 10% training/classroom  learning. ALK does not currently have a process to assess the  quality of development plans, so it is not possible to document  the exact linkage between development actions and individual  performance.  ALK plans to review and improve the development plan process  in 2025 by providing clearer guidance and enhanced training  for both employees and leaders. ALK also aims to enhance its  D&I strategy to include other diversity parameters, such as  geography. ALK intends to update its talent approach to ensure  that the right talents are identified, targeted, and developed in  alignment with the overall strategy.  To address the continuous development of its leaders, ALK  continued the rollout of the Leading with Impact programme for  186 leaders across the organisation. ALK will continue to focus  on leadership development by addressing critical leadership  capabilities and creating scalable training solutions for leaders  worldwide.  ALK has a dedicated team within Global People and Organ-  isation that manages global development programmes for  employees. In addition, leaders and employees are responsible  for ensuring that own skills meet current and future job require-  ments.  S1-5  Targets related to managing material negative  impacts, advancing positive impacts, and  managing material risks and opportunities  As part of the CSRD implementation, ALK has prioritised the  establishment of baseline data for its reporting before initi-  ating the target-setting process. As a result, ALK has not yet set  targets to address its material impacts and opportunities within  its own workforce or engaged with employees or their repre-  sentatives specifically on this matter. The need for additional  targets will be reviewed in 2025.  S1-6  Characteristics of the undertakingâs employees  Employees' characteristics  Unit  2024  20231  Employees' characteristics  Unit  2024  20231  Number of employees per country  Number of non-guaranteed hours employees  China  # 175  164  Male  # 15  14  Denmark  # 942  983  Female  # 20  23  France  # 357  379  Chooses not to self identify  # - - Germany  # 137  142  # 35  37  Poland  # 96  101  Spain  # 364  373  Employee turnover  # 463  316  USA  # 547  533  Employee turnover  % 17%  12%  Other  # 194  214  1 2023 figures are not covered by the Independent Auditorâs limited assurance report.  # 2,812  2,889  Number of permanent employees  ALK employs 2,812 employees (2023: 2,889), out of which 2,574 are permanently employed (2023:  Male  # 970  990  2,638). The employee turnover was 17% in 2024 (2023:12%), out of which 283 employees left voluntarily  Female  # 1,601  1,645  and 180 involuntarily. The decrease in number of employees and the increase in employee turnover  Chooses not to self identify  # 3 3 reflects the organisational adjustments relating to the implementation of the Allergy strategy.  + # 2,574  2,638  The most representative number, disclosed in the consolidated financial statements, corresponding to the total  Number of temporary employees  number of employees is the full-time equivalent employees (FTEs) (note 2.4 on page 116).  Male  # 95  95  Female  # 142  156  Chooses not to self identify  # 1 - # 238  251  Total male  # 1,065  1,085  Total female  # 1,743  1,801  Total chooses not to self identify  # 4 3 Total number of employees  # 2,812  2,889  S1-13  Training and skills development metrics  Training and skills development  Unit  2024  Participation in performance and  career reviews  Male  % 91%  Female  % 94%  Chooses not to self identify  % 100%  Number of performance reviews per  employee per year  # 1 Total participation to performance  and career reviews  % 93%  S1-16  Remuneration metrics  (pay gap and total remuneration)  Remuneration metrics  Unit  2024  20231  CEO annual  compensation ratio  Times  33  30  Gender pay gap  % 17%  16%  1 2023 figures are not covered by the Independent Auditorâs limited assurance  report.  The gender pay gap reflects the disparity in representation, as ALK  currently has a higher proportion of men than women in senior lead-  ership positions. ALK is continuously working on ensuring gender  equality in leadership positions.  ESRS S1  Health and safety  ESRS 2-SBM3  Material impacts, risks and opportunities and their  interaction with strategy and business model  Location in  Time  the value chain  horizon  Impacts, risks and opportunities  S1 Own workforce  IRO  Injuries due to workplace accidents in farming and production  Actual negative impact  â â Impact  Injuries due to workplace accidents  in farming and production  Health and safety management is an essential part of ALKâs  operations, especially in production and farming activities  where employees may face workplace risks. Based on engage-  ment with internal stakeholders representing affected stake-  holder groups, ALK has developed an understanding of how  people working in particular activities may produce specific  negative impacts.  Workplace accidents during production and farming may result  in injuries to members of ALKâs workforce. These injuries can  cause physical harm, impact mental well-being, and raise  concerns about workplace safety. Such incidents may also  affect employee morale and productivity.  This creates an actual negative impact on ALK's own workforce,  which is related to individual incidents and occurs annually in the  short term. To prevent accidents and mitigate their effects, ALK  conducts risk assessments, implements safety protocols, and  adheres to national and Occupational Safety and Health Admin-  istration (OSHA) standards for injury recording and compliance.  S1-1  Policies related to own workforce  ALK adheres to national legislation and regulatory requirements  in all countries of operation. ALK follows local legislation to  ensure compliance with health and safety requirements. In the  USA, ALK complies with OSHA standards. Safety procedures are  implemented at production facilities to mitigate risks identified  through assessments and ensure a safer working environment.  As a result, ALK has not previously identified the need for a  global Environmental, Health, and Safety (EHS) policy or a  global management system.  S1-3  Processes to remediate negative impacts and  channels for own workforce to raise concerns  ALK emphasises the importance of engaging workers in health  and safety practices to foster shared responsibility and work-  place safety.  To prevent injuries, ALK conducts risk assessments across  all its production sites. These assessments identify potential  hazards, implement appropriate measures to reduce risks and  evaluate the effectiveness of existing safety measures. Workers  contribute to those risk assessments by providing input on  hazards and by helping to develop site-specific safety meas-  ures.  Workplace injuries are also recorded and monitored. For USA  operations, ALK adheres to OSHA standards for tracking and  reporting injuries. This data provides insights into workplace  safety trends and helps ensure that operations comply with  applicable legal frameworks.  Employees are encouraged to report unsafe conditions or  hazards, which are promptly reviewed and addressed to  improve workplace safety. Regular training ensures that  workers understand health and safety procedures and risks  relevant to their tasks.  All employees can also raise concerns through the whistleblower platform  ALK Alertline, which is described in detail in G1 on page 89.  S1-4  Taking action on material impacts on own workforce,  and approaches to managing material risks and  pursuing material opportunities related to own  workforce, and effectiveness of those actions  ALK has a continuous focus on maintaining health and safety for  its employees and is actively engaged in projects focused on  improving material risk and work force exposure. This engage-  ment has ensured that ALK employeesâ exposure to chemicals/  substances is minimised/reduced. Tracking of yearly training  ensures that ALK employees have the necessary competences  to perform safe work processes.  S1-14  Health and safety metrics  Health and safety  Unit  2024  20231  Work-related accidents  # 112  106  Work-related accidents  rate  1.5  0.8  Fatalities as a result of  work-related incident  # - - Employees covered by  health & safety manage-  ment system  % 74%  N/A  1 2023 figures are not covered by the Independent Auditorâs limited assurance  report.  ALK had 6 accidents with lost time absence ordinated by a  medical professional in 2024 (2023:3). This resulted in an acci-  dent rate of 1.5.  S1-17  Incidents, complaints and severe  human rights impacts  See G1 on page 90.  S2 Workers in the value chain  ESRS 2-SBM3  Material impacts, risks and opportunities and their  interaction with strategy and business model  Location in  Time  the value chain  horizon  Impacts, risks and opportunities  S2 Workers in the value chain  IRO  Health and safety related incidents of workers in the value chain  Potential negative impact  â â â â â The materiality assessment identified the impacts seen below  related to workers in ALK's value chain. Those impacts originate  from ALKâs strategy and business model and are integrated into  ALKâs work with its suppliers. While ALK has identified its high-  level material impacts on value chain workers, a more detailed  understanding is still to be developed, to identify specific activ-  ities where workers may be at a greater risk of harm. However,  the majority of ALKâs suppliers are EU-based where the level of  law enforcement is generally high and the risk of child labour  low.  Impact  Health- and safety-related incidents  involving workers in the value chain  As an international pharmaceutical company specialising in  products based on allergenic source materials, ALK relies  upon business partners and suppliers across its value chain to  produce and distribute its products. Health and safety manage-  ment is integral to the success of both ALK and its suppliers.  Health and safety incidents can result in a range of negative  consequences for individuals and can potentially happen in all  parts of the value chain.  The most significant groups of supplier employees who could be  materially impacted are:  ⢠Workers in upstream production units. They could be  exposed to hazardous substances, including chemicals  used in the manufacture of pharmaceutical ingredients and  consumables. Key risks in this area include chemical expo-  sure, operational hazards and ergonomic risks.  ⢠Workers involved in downstream transportation. They  face the risk of vehicle accidents, which can result in serious  injuries or fatalities. These include risks during loading and  unloading as well as during transit.  ⢠Workers handling hazardous waste. They can encounter  harmful chemicals that pose significant health risks, including  chemical burns, respiratory issues and toxic exposure.  The potential negative impact is concentrated in ALK's upstream  and downstream supply chain and may occur in the short,  medium and long term as individual incidents. To address this  impact and prevent harm to workers in its value chain, ALK has  policies and procedures in place to ensure that its business  partners and suppliers uphold high safety standards. Moreover,  ALK seeks to establish long-term partnerships with its suppliers,  which offer them financial stability and allow them to allocate  resources toward ensuring job security for their workers.  S2-1  Policies related to value chain workers  ALKâs Third-Party Code of Conduct outlines the standards of  behaviour that ALK expects from all third parties globally when  it comes to business conduct and treatment of employees. The  Third-Party Code of Conduct is aligned with the Ten Principles of  the United Nations Global Compact and follows the UN Guiding  Principles on Business and Human Rights, as well as applicable  laws, regulations, standards and labour agreements.  Key areas covered include health and safety, animal welfare,  anti-corruption, environmental practices, working conditions,  human rights (including child and forced labour, anti-discrimi-  nation and fair pay), interaction with healthcare professionals  and patient organisations. The policy does not specifically  mention human trafficking.  Any violations of the standards set out in the ALK Third-Party  Code of Conduct can be reported through the whistleblower  platform.  The Third-Party Code of Conduct is an integral part of ALK's GxP  (good practice) supplier agreements. All new suppliers must  commit to the Code as a pre-requisite for collaboration with  ALK. The Chief Finance Officer is the most senior-level executive  accountable for the implementation of ALKâs Third-Party Code of  Conduct.  In addition to the Third-Party Code of Conduct covering human  rights impacts, ALK also adheres to the UK Modern Slavery Act  and publishes an annual statement of compliance.  S2-2  Processes for engaging with value  chain workers about impacts  While ALK does not currently have a formal process in place  to engage with value chain workers about impacts, ALK is  committed to developing robust engagement strategies that  will enhance communication and strengthen its connection  with value chain workers in the future. ALK is actively working  to establish processes for engaging with value chain workers  in 2025. The Senior Vice President of Global Procurement is  responsible for the supplier engagement.  S2-3  Processes to remediate negative impacts and  channels for value chain workers to raise concerns  Value chain workers can raise their concerns through the whis-  tleblower platform ALK Alertline. No complaints involving such  workers were substantiated in 2024. ALK does not have struc-  tures or processes to assess whether value chain workers are  aware of and trust ALK Alertline.  ALK Alertline is described in detail in G1 on page 89.  S2-4  Taking action on material impacts on value  chain workers, and approaches to managing  material risks and pursuing material  opportunities related to value chain workers,  and effectiveness of those actions  Supplier relationships  ALK prioritises collaboration with reputable suppliers who  adhere to high standards in their labour practices, reducing  the likelihood of serious working conditions-related issues.  By establishing long-term contracts with these suppliers, ALK  ensures financial stability, which fosters a commitment to high  labour standards and responsible working conditions. These  agreements provide suppliers with reliable revenue streams,  enabling them to invest in infrastructure, training and safety  initiatives. Financial stability is fundamental for business  development, and it enables suppliers to allocate resources to  product development and job security for workers.  As a result, long-term contracts with suppliers both strengthen  supply chain resilience and promote the well-being of workers,  contributing to a sustainable and ethical operational environ-  ment.  Risk assessment and monitoring  To address supplier risk, ALK continued its collaboration with  an external supplier evaluation platform to identify environ-  mental, labour and human rights, and procurement risks. From  this initial risk assessment, ALK continues to conduct high-level  assessments to identify whether further engagement may  potentially be required.  The potential negative impact that ALK might cause is monitored  through its business relationships. If there is a potential case,  appropriate actions are taken accordingly.  No severe human rights issues and incidents connected to ALKâs  upstream and downstream value chain were reported in 2024  ( see G1-1 for more information on page 90).  Monitoring and continuous improvement  The sustainable procurement manager is a newly established  role with responsibility for oversight and management of the  sustainable procurement programme globally in ALK.  While ALK has not identified any material actual negative  impacts, ALK will continue to evaluate its suppliers from a  sustainability perspective and take action accordingly. To  properly track the effectiveness of remedy actions for workers  in the value chain in the future, ALK is seeking to implement a  comprehensive monitoring system that includes regular assess-  ments and feedback mechanisms to measure outcomes related  to worker welfare and satisfaction over time.  ALK is committed to enhancing its due diligence processes by  2025, with a focus on continuous improvement and compliance  with emerging reporting standards.  S2-5  Targets related to managing material negative  impacts, advancing positive impacts, and  managing material risks and opportunities  ALK will be updating its responsible supply chain strategy in  2025 and considering the need for specific targets to manage  health- and safety-related impacts on workers in the value  chain. As of 2024, ALK has therefore not yet identified the need  for targets related to workers in the supply chain or for engaging  with workers in the value chain or their representatives.  S4 Consumers and end-users  S4-SBM3  Material impacts, risks and opportunities and their  interaction with strategy and business model  Location in  Time  the value chain  horizon  Impacts, risks and opportunities  S4 Consumers and end-users  IRO  Allergy treatment  Actual positive impact  â â â â Barriers to access  Actual negative impact  â â â â Patient safety  Actual negative impact  â â â â Climate change and respiratory health  Opportunity  â â Allergy is the most common type of chronic disease globally and  it has a profound impact on peopleâs lives. For more than 100  years, ALK has been at the forefront of long-term allergy treat-  ment. ALK is dedicated to offering a wide range of treatments,  products and services to meet the unique needs of people living  with allergy, their families and doctors.  The materiality assessment identified the following material  impacts and opportunities related to customers and end-users.  The materially impacted consumers and end-users are health-  care professionals and patients.  Based on engagement with internal stakeholders representing  affected stakeholder groups, ALK has developed an under-  standing of how particular products may create specific nega-  tive impacts.  Impact  Allergy treatment  ALK products are available worldwide, reaching individuals  with diverse ethnic backgrounds, in some cases starting from  childhood. ALK offers solutions and products for people affected  by allergy and aims to treat a wide range of allergies. Within  ALK's portfolio, sublingual immunotherapy tablets offer acces-  sible long-term allergy treatment, which can be administered at  home, unlike injections which require regular visits to a doctor.  Moreover, tablets do not require up-dosing or refrigeration and  are available for five of the most common respiratory allergies.  ALKâs products therefore seek to enhance the health and well-  being of patients regardless of their ethnicity, gender, or age.  ALK's portfolio includes treatment options for a variety of  allergens, some of which can be potentially life-threatening  (e.g. anaphylaxis, venom immunotherapy). An adrenaline  autoinjector is indicated in the emergency treatment of severe  acute allergic reactions (anaphylaxis) to insect stings or bites,  foods, drugs and other allergens as well as idiopathic or exer-  cise anaphylaxis. Similarly, ALKâs venom immunotherapy can  help patients who are highly allergic to stings from insects.  For both cases, ALK enhances the personal safety of its end-  users by providing effective treatment options and can turn a  life-threatening condition into a non-life-threatening issue. For  other allergies like house dust mites and grass and tree pollen,  the treatment improves the quality of life of the patient.  These actual positive impacts are concentrated in ALK's down-  stream value chain, occur in the short, medium and long term  and are linked to ALK's own activities.  Impact  Barriers to access  ALK is committed to providing more effective help to a greater  number of people with allergies and implements its allergy  care principles globally to ensure broad access. However, ALK  products need to be prescribed by a healthcare professional.  Currently, allergy treatment is not necessarily considered a  priority topic by all healthcare systems, leading to a barrier to  access to allergy care for the patient. This can have a consider-  able negative impact on patients who are unlikely to receive ALK  medicines from an allergy specialist.  ALK aims to price its treatments fairly and competitively, and  affordability for patients is often supported by public and/or  private health insurance and reimbursement schemes offered  by authorities. However, without access to public health provi-  sions or insurance, some patient groups who could benefit from  allergy treatment may not be able to afford it.  In markets such as the USA with private healthcare, hospital  doctors and general practitioners are paid based on the  services provided, leading them to favour giving injections over  prescribing tablets. The structure of the healthcare system  can therefore disincentivise doctors to prescribe the cheaper  allergy tablets and favour potentially suboptimal and more  expensive treatments such as injections.  The barriers to treatment access represent systemic actual  negative impacts. They occur in ALKâs downstream value chain  and recur every year. ALK is indirectly impacting the patients.  Impact  Patient safety  Allergy treatments are effective in most cases but not all. If the  treatment proves ineffective, alternative options are limited,  leaving individuals without the potential life-changing benefits  of ALK products. This creates an actual negative impact, which  directly compromises the well-being and safety of individuals  relying on those treatments.  The impact is concentrated in ALK's downstream value chain,  arises from ALK's own activities as individual and isolated  events, and occurs in the short, medium and long term.  Opportunity  Climate change and respiratory health  Climate change directly threatens respiratory health by  extending pollen seasons, increasing airborne allergens, and  altering the distribution and abundance of allergenic plants.  Global warming also leads to higher humidity, creating favour-  able conditions for mould growth and potentially higher allergen  exposure. Addressing climate change is thus an environmental  imperative with significant social and public health dimensions.  Climate-induced species migration introduces new types of  pollen and allergens to regions that were previously unaffected,  presenting new market opportunities for ALK through emerging  allergies. The increased length and severity of pollen seasons  expand the potential market size for ALK, as more individuals  have prolonged and intensified allergy symptoms. Spikes in  allergen concentrations can also trigger reactions in a larger  segment of the population by exceeding their individual toler-  ance levels.  This potential opportunity is concentrated in ALK's own opera-  tions, it would not be related to specific groups of consumers or  end-users, and is expected to happen over the long term. ALK  has indirect control over this opportunity which would benefit  its own operations. Specific financial effects have not yet been  identified.  S4-1  Policies related to consumers and end-users  ALKâs Access to Medicines Policy sets out the companyâs ambi-  tion to reach more patients. The policy focuses on three key  principles: improving quality of life through better treatment  options and earlier diagnosis, supporting healthcare systems  with training and education on allergy care, and forming part-  nerships for broader access. The policy is continually reviewed  by the ELT to ensure alignment with the overall strategy of the  ALK Group. Reporting is done through ALK's website and annual  report, ensuring transparency and accountability.  The oversight, accountability and responsibility for the imple-  mentation of ALK's Access to Medicines Policy rests with the  Board of Directors, which has delegated this responsibility to  the ELT.  The policy covers both people with allergy and healthcare  professionals and relates to material impacts related to access  treatment and access barriers.  The pharmaceutical industry is heavily regulated, with human  rights topics like the right to health and informed consent in clin-  ical trials already embedded in legislation. Therefore, ALK does  not have specific consumer policies aligned with the UN Guiding  Principles of Business and Human Rights.  External stakeholders with a business-related connection to  ALK can report potential human rights impacts through the  Alertline ( see G1 on page 89).  S4-2  Processes for engaging with consumers  and end-users about impacts  See ESRS 2-SBM2 on pages 39-40.  S4-3  Processes to remediate negative  impacts and channels for consumers  and end-users to raise concerns  ALK works closely with doctors, pharmacists, and other health-  care professionals to ensure they have the necessary informa-  tion to advice patients.  Furthermore, ALKâs digital universe empowers people to proac-  tively manage their allergies by offering information and guid-  ance on how to avoid or alleviate symptoms and seek treatment.  In addition to reaching patients through its digital platforms,  ALK engages systematically in educational activities, training  and dialogue with healthcare professionals to elevate the  standard of care in allergy diagnosis and treatment. Much of  the engagement is done digitally to enable ALK to reach more  healthcare professionals within a shorter time and reduce  the climate impact of travelling to physical meetings. ALKâs  approach to engaging with healthcare professionals also  encompasses collaboration with patient organisations across  the globe to raise awareness around patient care and product  safety.  In the ongoing efforts to develop innovative, effective treat-  ments for allergies, ALK conducts clinical trials in close collabo-  ration with authorities, healthcare professionals, scientists and,  most critically, patients. ALK upholds safety, privacy, ethics and  respect through every phase of the clinical trials and adheres  to the Principles for Responsible Clinical Trial Data Sharing from  the European Federation of Pharmaceutical Industries and  Associations (EFPIA) and the Pharmaceutical Research and  Manufactures of America (PhRMA). In this way, ALK ensures that  clinical trial data is used responsibly and transparently, safe-  guarding patient privacy and respecting the integrity of national  regulatory systems that protect proprietary information.  Rigorous industry regulations ensure that safety data from  any source, including clinical trials, healthcare professionals  or patients, is collected and analysed systematically by ALK's  global pharmacovigilance team. This ensures that the safety  profile of the products is optimised for the benefit of the patient  and that the relevant authorities can be made aware of any  safety issue in order to facilitate immediate action.  Patients are informed of how they can contact ALK to report  potential side effects in the leaflets for all products.  External stakeholders with a work-related connection to ALK  can raise their concerns through the whistleblower platform ALK  Alertline, which is described in detail in G1 on page 89.  S4-4  Taking action on material impacts on  consumers and end- users, and approaches to  managing material risks and pursuing material  opportunities related to consumers and end-  users, and effectiveness of those actions  Helping more people with allergies is at the core of ALKâs  + Allergy strategy. ALK will prioritise and focus its commercial  activities to strengthen its global leadership in respiratory aller-  gies including targeted expansion of the sublingual immuno-  therapy tablets to new patient groups and geographies, digital  mobilisation and investments in high impact markets.  Information about actions taken, planned and underway to address  material impacts and opportunities, according to S4-4, is incorporated  + by reference to the sections "Strategy progress: Review of Allergy imple-  mentation", on pages 10-11, and "Expanding the addressable markets" of  Business and strategy, on pages 16-17.  S4-5  Targets related to managing material negative  impacts, advancing positive impacts, and  managing material risks and opportunities  ALK aims to help 5 million allergy patients by 2030 to advance its  positive impact and opportunity. The target covers ALKâs down-  stream activities in the countries where ALK operates  ( see "ALK at a glance" on page 5).  In 2024, ALK reached an estimated 2.6 million patients in treat-  ment, as a result of its commercial activities.  Although ALK has previously had the need to establish specific  external targets, it will assess the potential necessity for addi-  tional targets related to access barriers and patient safety in  2025.  ALK has not engaged directly with patients or their represent-  atives on the target setting, but information has been obtained  indirectly through market insights.  Accounting policies â Social information  The numeric datapoints reported are verified through  internal controls, analysis, benchmarks, and regular  business meetings. External auditors provide limited  assurance on 2024 metrics, but they are not validated by  another external body. N/A is used when data was not  available at the time of the reporting and could not be  retrieved.  Own workforce  Workforce is defined as all ALK employees who are on  payroll as of 31 December 2024, both full-time and part-  time, as well as active and non-active. The numbers are  reported in headcount as of end of reporting period.  S1-6  Characteristics of the undertakingâs employees  Permanent employees are determined as employees  whose employment contract is without a specified  end-date. Temporary employees are determined as  employees whose employment contract is with specified  end-date. Non-guaranteed hours employees are deter-  mined as employees employed by ALK without a guar-  antee of a minimum or fixed number of working hours.  The employee may need to make themselves available  for work as required, but ALK is not contractually obli-  gated to offer the employee a minimum or fixed number  of working hours per day, week, or month.  For any employee-related metrics, headcount meas-  ures are used. The measures are extracted from the HR  systems. The numbers are reported in headcount as of  end of reporting period.  For reporting by gender, the following descriptions are  used: âMaleâ, âFemaleâ, and âEmployee chooses not to  self-identify'.  For breaking down per countries, countries with less  than 50 employees are classified as âother countriesâ.  When reporting by geographical areas, regions are  broken down into North America (USA, Canada), Asia  (China, Russia, Jordan, Turkey), and Europe (Denmark,  France, Spain, Germany, Poland, Netherlands, Sweden,  Slovakia, United Kingdom, Austria, Switzerland, Norway,  Italy, Belgium, Czech Republic, Finland, Ireland).  Employee turnover  Employee turnover is defined by the number of  employees leaving ALK during the period. The turnover  is a total of voluntary and involuntary terminations.  The employee turnover ratio is calculated by dividing  the number of employees who left ALK by the average  number of employees in the reporting year. The  employees included in the calculation are all permanent  employees and inactive employees on garden leave.  Due to local regulations, temporary employees located  in Poland and China are also included, as a temporary  contract is required before transitioning to permanent  status.  S1-16  Remuneration metrics  Gender pay gap (significant estimate)  Gender pay gap is defined as the difference of average  base pay levels between male and female employees,  relative to the average annual pay of male employees.  Average gross annualised earnings are used in this  calculation due to limited data availability for hourly pay  levels. The use of estimates for this datapoint is consid-  ered significant.  CEO annual compensation ratio  CEO annual compensation is determined by the annual  total compensation of the CEO against the median annual  total compensation for all full-time active (permanent  and temporary) employees, excluding the CEO. Annual  total compensation includes salary, bonus, allowances,  pension, and all one-time payments over the course of  a year.  S1-13  Training and skills development metrics  A regular performance review is defined as a review  based on criteria known to the employee and his or her  superior undertaken with the knowledge of the employee  at least once per year. The review can include an evalua-  tion by the employeeâs direct superior, peers, or a wider  range of employees.  Employee engagement  Participation rate and engagement score are collected  from a survey conducted by a third party.  S1-14  Health and safety metrics  Work-related incidents are reported to Global Environ-  ment, Health and Safety. Work-related accidents are  defined as unplanned events that result in injury, with or  without absence. The number of accidents is reported  per site on a monthly basis. The rate of work-related  accidents is calculated as Lost Time Injury Frequency  Rate (LTIFR). It measures the number of accidents with  absence multiplied by million, divided by total working  hours during a single financial year. A lost-time injury is  a work-related injury that results in time lost from work  ordered by a medical professional person.  Fatalities are the number of employees who lost their  lives as a result of a work-related incident.  Consumers and end-users  Number of patients in treatment (significant estimate)  Due to the absence of comprehensive data sources across  all markets, it is not possible to directly and specifically  measure the number of patients treated with ALK prod-  ucts. Patient numbers are estimated using various data  sources, an in-house Patient Model and insurance claims  data, while applying several assumptions, which leads to  a certain level of uncertainty. The use of estimates for this  datapoint is considered significant.  When a more precise method is not available, units sold  ex-factory are converted to treatment years per patient  using a treatment years conversion factor. This estima-  tion is adjusted based on market and patient research  from various countries, applying an adherence rate and  a co-administration rate across products and coun-  tries to prevent e.g. double counting patients receiving  multiple types of allergy immunotherapy treatments  (AIT) simultaneously.  When available, more precise methods are tailored to  specific product groups as follows:  For SLIT-drops in most markets, anonymized data and  unique patients counted based on prescription data are  used.  For SLIT-tablets in most markets, data is based on  the in-house Patient Model. The Patient Model uses  in-market units sales data and where possible new  patient data to convert to patients in treatment. Actual  in-market sales and patient data are used for two-thirds  of the year, while the remaining portion is forecasted. A  co-administration rate is applied to tablet patients.  In North America, ALK sells bulk allergen extracts to  healthcare professionals who prepare the allergy shots  using various and unspecified dosing schedules. To esti-  mate the number of patients receiving AIT, a commercial  claims database is used. Extrapolation of the patient  number to USA population is done using the ratio of  database coverage to the total USA population. To obtain  the number of patients on AIT, an estimated market  share is applied. Given that commercial claims data have  a 14-16-month time lag, the extrapolation to the current  year is done by applying a discounted revenue growth  from the time of data extraction to the current year.  For the Auto Adrenaline Injector (AAI), following official  recommendations, the number of sold pens is divided by  2 to reflect the assumption that each patient carries two  pens at a time.  Governance  information  G1 Business conduct  ESRS G1  Location in  Time  the value chain  horizon  Impacts, risks and  opportunities  G1 Business conduct  IRO  Animal welfare  Actual negative impact  â â â â Potential bribery of healthcare professionals  Risk  â â Information about Corporate governance can be found on page 28.  ESRS G1  Animal Welfare  ESRS 2-SBM3  Material impacts, risks and opportunities and their  interaction with strategy and business model  Impact  Animal welfare  When developing new treatments, ALK conducts tests on animals  to ensure that patients receive safe and effective medicines.  ALK only uses animals for research purposes when alternative  models do not provide the data necessary to evaluate the treat-  ment. ALK conducts regular experiments on animals through  allergen injections on mice in its own internal R&D facilities.  Within ALK's own operations, the negative impact on the animals  is from the injections, and also from keeping them in captivity  and euthanising them after the experiments are finished. This  impact occurs over the short, medium and long term.  To mitigate this impact, ALK selects professional, well-  recognised and accredited suppliers, adhering to the guidelines  from the Federation of European Laboratory Animal Science  Associations (FELASA).  G1-1  Business conduct policies and corporate culture  Animal welfare  ALK ensures compliance with local regulations related to animal  welfare. As a result, ALK has not previously identified the need  for a centralised global policy on animal welfare. However, it is in  the process of developing a global animal welfare policy sched-  uled for implementation by 2025, which will be approved by the  governance bodies.  ESRS G1  Corruption and bribery  ESRS 2-SBM3  Material impacts, risks and  opportunities and their interaction  with strategy and business model  Risk  Potential bribery of healthcare  professionals  The pharmaceutical industry faces risks  associated with bribery and corruption,  particularly in the context of employeesâ  interactions with healthcare professionals  (HCPs). The main risk of corrupt behaviour for  ALK concerns potential bribery of healthcare  professionals, i.e., using improper influence  over HCPs to increase ALKâs sales and cash  f low.  An incident of such corrupt behaviour could  have significant legal, reputational and finan-  cial repercussions. This risk arises in ALKâs  downstream value chain over the short term.  There are no current financial effects, nor any  significant risk of material adjustment for next  year. This risk is mitigated through the regular  training of all employees on ALKâs Code of  Conduct.  G1-1  Business conduct policies  and corporate culture  Code of Conduct  ALK's approach to business conduct is  grounded in a comprehensive framework  of policies centred on its Code of Conduct.  The Code of Conduct, applicable to all ALK  employees, sets the tone for business integrity  and ALKâs ethical principles. It affirms ALK's  commitment to upholding human rights, safe-  guarding confidential business information,  and promoting zero-tolerance for corruption  and fraud. The Executive Leadership Team  (ELT) is responsible for oversight of the Code of  Conduct.  ALK has not developed specific global policies  on business conduct training, as the ALK Policy  for Anti-Corruption already includes a general  commitment to train employees, and business  conduct training is administered in practice  ( see "Training and awareness" on page 90).  ALKâs Code of Conduct is complemented  by additional policies on business conduct  matters, which also apply to all ALK employees  and are publicly accessible on the ALK  website.  Whistleblowing Policy  The Code of Conduct is supplemented by  specific policies, such as the Whistleblowing  Policy, which defines the organisation and  processes in place to ensure that ethical  concerns are treated seriously and appro-  priately; it includes the standards for inves-  tigating such cases and protecting whistle-  blowers. The policy includes a non-retaliation  commitment to protect any employee or stake-  holder who raises a concern in good faith.  The ALK Audit Committee has the overall  responsibility for the Whistleblowing Policy,  and for reviewing the effectiveness of actions  taken in response to concerns raised under the  policy. The Corporate Affairs & Legal depart-  ment has day-to-day operational responsi-  bility for the policy.  Policy for Anti-Corruption  With regard to the risk of potential bribery of  healthcare professionals, the ALK Policy for  Anti-Corruption addresses compliance with  general anti-bribery and anti-corruption  legislation, as well as industry-specific stand-  ards covering interactions with healthcare  professionals. It is consistent with the United  Nations Convention against Corruption.  The Board of Directors is responsible for  ensuring that the policy complies with appli-  cable laws, while managers are responsible  for implementing the policy at all levels.  Third-Party Code of Conduct  In parallel with this, expectations for business  partners are outlined in the Third-Party Code  of Conduct, which applies to ALKâs upstream  and downstream value chain. ALKâs Whistle-  blowing Policy also applies to external stake-  holders.  Details on the Third-Party Code of Conduct are  provided in S2-1 on pages 81-82.  ESRS G1  Channels to raise concerns  ALK Alertline  ALK has established a whistleblowing system:  ALK Alertline, which is accessible to internal  and external stakeholders. The company's  own workforce, value chain workers and other  external stakeholders with a work-related  connection to ALK can use the ALK Alertline  to raise and report serious and sensitive  concerns, including reasonable suspicions  of breaches of ALKâs Code of Conduct, anti-  corruption laws, and laws within the scope of  the EU Whistleblower Protection Directive.  ALK Alertline is confidential and offers the  option of anonymous reporting, as a protec-  tive measure against retaliation. Available by  phone or online in eight languages, ALK Alert-  line is accessible via ALK's intranet and on its  public websites.  Reports are entered directly into an inde-  pendent companyâs secure server. Corporate  Affairs & Legal manages the access, and  the reports are made available only to pre-  appointed individuals within ALK who are  responsible for evaluating reports.  The monitoring and tracking of registered reports are  described below under G1-3 on page 89.  The non-retaliation commitment is specified under  G1-1 on page 88.  ALK assesses awareness and trust in the  processes for raising concerns by including  questions in the annual engagement  survey about employees' confidence in ALK  addressing serious misconduct and the impor-  tance managers place on employee well-  being.  In addition to ALK Alertline, employees  are encouraged to speak up and raise any  concerns through ordinary management  channels. ALK launched manager training  in 2024 on how to recognise and respond to  whistleblower reports. This training includes  a section stressing reporter protections,  including against retaliation.  ESRS G1  Whistleblowing and anti-corruption system  Incidents of bribery and corruption  Unit  2024  Convictions for violation of anti-corruption and bribery laws  # - Fines for corruption and bribery convictions  DKKm  - G1-3  Prevention and detection of  corruption and bribery  G1-4  Incidents of corruption or bribery  ALK takes a zero-tolerance approach to  corruption and bribery. In addition to ALK  Alertline, financial control systems act to  prevent and detect any corruption and  bribery events.  Should an allegation of corruption or  bribery be made through ALK Alertline,  the ensuing investigation is governed by  ALKâs Compliance Investigations Process.  Each case is overseen by an investigation  supervisor. This may be the Vice President,  Corporate Affairs & Legal or their designee,  usually within the Legal or Compliance func-  tions. Where appropriate due to specific  allegations in a report, an investigation  supervisor independent from the chain of  management will oversee the case: either  external legal counsel, or the Chair of the  Audit Committee.  The Chair of the Audit Committee is noti-  fied of reports concerning corruption and  is responsible for deciding whether to  approve case recommendations. Corpo-  rate Affairs & Legal also updates the Audit  Committee on an annual basis on all ALK  Alertline activities for the past year.  In 2024, ALK had no convictions or related  fines for violations of anti-corruption and  anti-bribery laws.  ESRS G1  Training and awareness  Code of Conduct training  Unit  2024  Functions-at-risk Code of Conduct training completion  % 99%  G1-3  Prevention and detection of corruption  and bribery  G1-4  Incidents of corruption or bribery  Training and awareness activities are  essential for fostering a culture of integrity  and creating a common understanding of  what is expected from ALKâs employees.  All new hires are required to confirm that  they agree to act in accordance with the  Code of Conduct. Online training on the Code  of Conduct is also rolled out annually for all  employees. It includes all ELT members and  ALK employee representatives serving on the  Board of Directors.  The training covers relevant business conduct  topics including anti-corruption, ALK Alertline,  communications, promotion & social media,  competition law, conflicts of interest, political  contributions, human rights, interaction with  healthcare professionals, IT security, patient  safety, and data privacy.  Employees who interact directly with health-  care professionals have been identified as  being at higher risk with regard to corruption  and bribery. In ALK, these are to be found in  commercial operations and medical affairs  functions. Among ALK employees in such  functions, 99% completed the global Code of  Conduct e-learning course in 2024. Additional  targeted training is offered at local level to  these employees in these functions, to cover  specific compliance matters such as promo-  tional activities and interactions with health-  care professionals. As 2024 is the first year of  reporting of functions-at-risk, ALK does not  have a specific target on completion rate of  functions-at-risk Code of Conduct training.  S1-17  Incidents, complaints and severe human rights impacts  ALK Alertline and human rights incidents  Unit  2024  ALK Alertline  Work-related discrimination reports registered on Alertline  # 1 Reports of other work-related complaints  # 3 Amount of fines, penalties and compensation for damages as  a result of work-related complaints  DKKm  - Severe human rights incidents  Severe human rights incidents  # - Amount of fines, penalties, and compensation for damages  for severe human rights incidents  DKKm  - In 2024, ALK was not liable for any fines,  penalties, or compensation for damages as  a result of work-related Alertline reports or  severe human rights incidents. Therefore, no  related amounts have been accounted for in  the financial statements.  Accounting policies â Governance information  The numeric datapoints reported are verified through  internal controls, analysis, benchmarks, and regular  business meetings. External auditors provide limited  assurance on 2024 metrics, but they are not validated by  another external body.  Business conduct  S1-17  Incidents, complaints and severe human rights  impacts  ALK Alertline is the companyâs whistleblower system,  which can be used to report serious and sensitive  concerns - including serious offenses against persons  such as discrimination.  Work-related complaints and reports refer to allegations  registered on Alertline which involve ALKâs own work-  force. Severe human rights incidents refer to substanti-  ated incidents of human rights violations pertaining to  ALKâs own workforce.  Fines, penalties and compensation for damages are âas  a resultâ of allegations and complaints only when such  allegations and complaints are substantiated and undis-  puted. They are reported in the reporting year when they  are imposed and final (i.e., the amount is no longer under  appeal or in dispute).  G1-4  Corruption and bribery  Bribery can take the form of money, gifts, loans, fees,  hospitality, services, discounts, the award of a contract  or any other advantage or benefit, and it comprises any  financial or other inducement or reward for an action  which is illegal, unethical, a breach of trust or improper  in any way. Corruption is defined as abuse of entrusted  power by someone for personal gain.  For purposes of the reporting, convictions in scope are  final decisions or acts by courts of law, which constitute  criminal convictions under applicable local law in the  jurisdiction where the decision or act takes place. As  required by the ESRS, only convictions where ALK or its  employees are directly involved are considered within  scope. Fines relating to such convictions are reported in  the reporting year when they are imposed and final (i.e.,  no longer under appeal or in dispute).  G1-3  Prevention and detection of corruption and bribery  âPercent of functions at risk covered by training  programsâ refers to the percentage of Code of Conduct  e-learning completion for employees in commercial  operations or medical affairs. The Code of Conduct  e-learning course was rolled out between March and  May 2024.  Incorporation by reference  The table below provides an overview of information incorporated by reference as part of other  sections of this annual report, by stating the datapoint code beneath the relevant header, which  remains applicable until the next header of the same level. When the datapoint applies to a  specific part of a section, the datapoint code is cited in a footnote.  Disclosure  Requirement Disclosure Requirement  Disclosed  Disclosed  code  name  Datapoint code  in section  on page  ESRS 2-BP2  Disclosures in relation to  ESRS 2-BP2-16  Incorporation  92-93  specific circumstances  by reference  ESRS 2-GOV1 The role of the  ESRS 2-GOV1-21a  Corporate  28-29  administrative,  governance  management and  ESRS 2-GOV1-21b  Corporate  28-29  supervisory bodies  governance  ESRS 2-GOV1-21c  Board of Direc- 33-34  tors  ESRS 2-GOV1-21d  Corporate  28-29  governance  ESRS 2-GOV1-21e  Corporate  28-29  governance  ESRS 2-GOV1-23  Corporate  29  governance  ESRS 2-GOV1-23a  Corporate  29  governance  ESRS 2-GOV1-23b  Corporate  29  governance  ESRS 2-GOV3 Integration of sustainability- All data points  Corporate  30  related performance in  governance  incentive schemes  ESRS 2-GOV4 Statement on due diligence  ESRS 2-GOV4-32  Core elements 94-95  of due diligence  Disclosure  Requirement Disclosure Requirement  Disclosed  Disclosed  code name  Datapoint code  in section  on page  ESRS 2-SBM1 Strategy, business model  ESRS 2-SBM1-40  Sales and  19  and value chain  market trends  ESRS 2-SBM1-40a.i Sales and  19  market trends  ESRS 2-SBM1-40a.ii Sales and  19  market trends  ESRS 2-SBM1-40a.iii ALK at a glance  5 ESRS 2-SBM1-40e  Introduction to  9 + Allergy  ESRS 2-SBM1-40f  Sales and  19  market trends  ESRS 2-SBM1-40g  Expanding the 16-17  addressable  markets  ESRS 2-SBM1-42  Business model  6 ESRS 2-SBM1-42a  Business model  6 ESRS 2-SBM1-42b  Business model  6 ESRS 2-SBM1-42c  Business model  6 ESRS 2-IRO2 Disclosure Requirements  ESRS 2-IRO2-56  Content index of 96-105  in ESRS covered by  ESRS disclosure  the undertakingâs  requirements;  sustainability statement  List of data-  points that  derive from  other EU legis-  lation  E1-GOV3  Integration of sustainability- E1-GOV3-13  Corporate  30  related performance in  governance  incentive schemes  E1-3  Actions and resources in  E1-3-29c.i  Income state-  107; 123  relation to climate change  ment  policies  Disclosure  Requirement Disclosure Requirement  Disclosed  Disclosed  code  name  Datapoint code  in section  on page  S1-6  Characteristics of the  S1-6-50f  Staff costs  116  undertakingâs employees  S4-4  Taking action on material  All data points  Strategy  10 -11; 16-17  impacts on consumers and  progress;  end- users, and approaches  Expanding the  to managing material risks  addressable  and pursuing material  markets  opportunities related to  consumers and end-users,  and effectiveness of those  actions  G1-GOV1  The role of the adminis-  G1-GOV1-5a  Corporate  29  trative, management and  governance  supervisory bodies  G1-GOV1-5b  Corporate  29  governance  Phased-in Disclosure Requirements  Disclosure  Requirement /  Datapoint code  Disclosure Requirement / Datapoint name  ESRS 2-SBM3-48e  Anticipated financial effects  E1-9  Anticipated financial effects from material physical and transition risks  and potential climate-related opportunities  S1-7  Characteristics of non-employees in the undertakingâs own workforce  S1-13-83b  Average training time per employee and by gender  S1-14-88d  Cases of work-related illness  S1-14-88e  Lost time due to work-related injuries, fatalities and illness  Core elements of due diligence  The table below maps the core elements of ALK's due diligence process, cross-referencing the impacts  on people and the environment with the relevant disclosures in the sustainability statement.  ESRS 2-GOV4  Statement on due diligence  Does the disclosure  Core elements of  Pages in the sustainability  relate to people and/or  Due Diligence  statement  the environment?  a) Embedding due diligence  ESRS 2 GOV-2, pages 37-38  People and environment  in governance, strategy and  ESRS 2 GOV-3, pages 38  People and environment  business model  ESRS 2 SBM-3, pages 44-48  People and environment  ESRS 2 SBM-3-E1, page 50  Environment  ESRS 2 SBM-3-E2, page 56  ESRS 2 SBM-3-E3, page 58  ESRS 2 SBM-3-E4, page 61  ESRS 2 SBM-3-E5, pages 63-64  ESRS 2 SBM-3-S1, pages 74-75; 79  People  ESRS 2 SBM-3-S2, page 81  ESRS 2 SBM-3-S4, pages 83-84  ESRS 2 SBM-3-G1, pages 87-88  People and environment  Does the disclosure  Core elements of  Pages in the sustainability  relate to people and/or  Due Diligence  statement  the environment?  b) Engaging with affected  ESRS 2 GOV-2, pages 37-38  People and environment  stakeholders in all key steps of  ESRS 2 SBM-2, pages 39-40  People and environment  the due diligence  ESRS 2 IRO-1, pages 41-43  People and environment  ESRS 2 MDR-P:  Environment  E1-2, page 51  E2-1, page 57  E3-1, page 59  E4-2, page 62  E5-1, page 64  ESRS 2 MDR- P:  People  S1-1, pages 75; 79  S2-1, pages 81-82  S4-1, page 84  S1-2, pages 75-76  People  S2-2, page 82  Does the disclosure  Core elements of  Pages in the sustainability  relate to people and/or  Due Diligence  statement  the environment?  c) Identifying and assessing  ESRS 2 IRO-1, pages 41-43  People and environment  adverse impacts  ESRS 2 SBM-3, pages 44-48  People and environment  ESRS 2 SBM-3-E1, page 50  Environment  ESRS 2 SBM-3-E2, page 56  ESRS 2 SBM-3-E3, page 58  ESRS 2 SBM-3-E4, page 61  ESRS 2 SBM-3-E5, pages 63-64  ESRS 2 SBM-3-S1, pages 74-75; 79  People  ESRS 2 SBM-3-S2, page 81  ESRS 2 SBM-3-S4, pages 83-84  ESRS 2 SBM-3-G1, pages 87-88  People and environment  d) Taking actions to address  ESRS 2 MDR-A:  Environment  those adverse impacts  E1-3, page 51  E2-2, page 57  E3-2, page 59  E4-3, page 62  E5-2, page 64  ESRS 2 MDR-A:  People  S1-4, pages 76; 80  S2-4, page 82  S4-4, page 85  E1-1, page 49  Environment  E4-1, page 61  G1-1, pages 87-88  People and environment  G1-3, pages 89-90  Does the disclosure  Core elements of  Pages in the sustainability  relate to people and/or  Due Diligence  statement  the environment?  e) Tracking effectiveness of  ESRS 2 MDR-M:  Environment  these efforts and communi-  E1-5, page 55  cating  E1-6, pages 53-54  E2-5, page 57  E3-4, page 60  E5-4, page 65  E5-5, pages 65-66  ESRS 2 MDR-M:  People  S1-13, page 78  S1-14, page 80  S1-16, page 78  S1-17, pages 80; 90  G1-4, pages 89-90  People and environment  E1-4, page 52  Environment  E2-3, page 57  E3-3, page 60  E4-4, page 62  E5-3, page 65  S1-5, page 76  People  S2-5, page 82  S4-5, page 85  Content index of ESRS disclosure requirements  The table below presents the disclosure requirements from ESRS 2 and the nine topical standards relevant to  ALK and indicates where to find information related to each specific requirement.  ESRS 2-IRO2  Disclosure Requirements in ESRS covered by the undertakingâs sustainability statement  List of material Disclosure Requirements  Page number  ESRS 2  General Disclosures  BP-1  General basis for preparation of the sustainability statement  36  BP-2  Disclosures in relation to specific circumstances  36; 54; 60; 78; 85;  92-93  GOV-1  The role of the administrative, management and supervisory  28-29; 33-34;  bodies  37-38  GOV-2  Information provided to and sustainability matters addressed by  37-38  the undertakingâs administrative, management and supervisory  bodies  GOV-3  Integration of sustainability-related performance in incentive  30; 38  schemes  GOV-4  Statement on due diligence  38; 94-95  GOV-5  Risk management and internal controls over sustainability  38  reporting  SBM-1  Strategy, business model and value chain  5; 6; 9; 16-17; 19;  39  SBM-2  Interests and views of stakeholders  39-40 ; 41-43  SBM-3  Material impacts, risks and opportunities and their interaction with  44-48; 50; 56; 58;  strategy and business model  61; 63; 74-75; 79;  81; 83-84; 87-88  IRO-1  Description of the processes to identify and assess material  41-43  impacts, risks and opportunities  IRO-2  Disclosure Requirements in ESRS covered by the undertakingâs  42; 48; 96-105  sustainability statement  List of material Disclosure Requirements  Page number  E1  Climate change  ESRS 2  Integration of sustainability-related performance in incentive  30  GOV-3-E1 schemes  E1-1  Transition plan for climate change mitigation  30; 49; 51  ESRS 2  Material impacts, risks and opportunities and their interaction with  50; 84  SBM-3-E1 strategy and business model  ESRS 2  Description of the processes to identify and assess material  41  IRO-1-E1  climate-related impacts, risks and opportunities  E1-2  Policies related to climate change mitigation and adaptation  51  E1-3  Actions and resources in relation to climate change policies  51; 53-54; 107; 123  E1-4  Targets related to climate change mitigation and adaptation  51-52  E1-5  Energy consumption and mix  55  E1-6  Gross Scopes 1, 2, 3 and Total GHG emissions  53-54  E2 Pollution  ESRS 2  Material impacts, risks and opportunities and their interaction with  56  SBM-3-E2 strategy and business model  ESRS 2  Description of the processes to identify and assess material  41  IRO-1-E2 pollution-related impacts, risks and opportunities  E2-1  Policies related to pollution  57  E2-2  Actions and resources related to pollution  57  E2-3  Targets related to pollution  57  E2-5  Substances of concern and substances of very high concern  57  List of material Disclosure Requirements  Page number  E3  Water and marine resources  ESRS 2  Material impacts, risks and opportunities and their interaction with  58  SBM-3-E3 strategy and business model  ESRS 2  Description of the processes to identify and assess material water  42  IRO-1-E3  and marine resources-related impacts, risks and opportunities  E3-1  Policies related to water and marine resources  59  E3-2  Actions and resources related to water and marine resources  59  E3-3  Targets related to water and marine resources  60  E3-4  Water consumption  60  E4  Biodiversity and ecosystems  E4-1  Transition plan and consideration of biodiversity and ecosystems in  61  strategy and business model  ESRS 2  Material impacts, risks and opportunities and their interaction with  61  SBM-3-E4 strategy and business model  ESRS 2  Description of processes to identify and assess material biodi-  42  IRO-1-E4  versity and ecosystem-related impacts, risks dependencies and  opportunities  E4-2  Policies related to biodiversity and ecosystems  62  E4-3  Actions and resources related to biodiversity and ecosystems  62  E4-4  Targets related to biodiversity and ecosystems  62  List of material Disclosure Requirements  Page number  E5  Resource use and circular economy  ESRS 2  Material impacts, risks and opportunities and their interaction with  63  SBM-3-E5 strategy and business model  ESRS 2  Description of the processes to identify and assess material  42-43  IRO-1-E5 resource use and circular economy-related impacts, risks and  opportunities  E5-1  Policies related to resource use and circular economy  64  E5-2  Actions and resources related to resource use and circular  64  economy  E5-3  Targets related to resource use and circular economy  65  E5-4  Resource inflows  65  E5-5  Resource outflows  65 -66  S1  Own workforce  ESRS 2  Interests and views of stakeholders  39-40  SBM-2-S1  ESRS 2  Material impacts, risks and opportunities and their interaction with  74-75; 79  SBM-3-S1 strategy and business model  S1-1  Policies related to own workforce  75; 79; 88  S1-2  Processes for engaging with own workforce and workers' repre-  75-76  sentatives about impacts  S1-3  Processes to remediate negative impacts and channels for own  79-80; 88-89  workforce to raise concerns  List of material Disclosure Requirements  Page number  S1-4  Taking action on material impacts on own workforce, and  80  approaches to mitigating material risks and pursuing material  opportunities related to own workforce, and effectiveness of those  actions  S1-5  Targets related to managing material negative impacts, advancing  76  positive impacts, and managing material risks and opportunities  S1-6  Characteristics of the undertakingâs employees  77; 116  S1-13  Training and skills development metrics  78  S1-14  Health and safety metrics  80  S1-16  Remuneration metrics (pay gap and total remuneration)  78  S1-17  Incidents, complaints and severe human rights impacts  80; 90  S2  Workers in the value chain  ESRS 2  Interests and views of stakeholders  39-40  SBM-2-S2  ESRS 2  Material impacts, risks and opportunities and their interaction with  81  SBM-3-S2 strategy and business model  S2-1  Policies related to value chain workers  81-82  S2-2  Processes for engaging with value chain workers about impacts  82  S2-3  Processes to remediate negative impacts and channels for value  82; 88-89  chain workers to raise concerns  S2-4  Taking action on material impacts on value chain workers, and  82; 90  approaches to managing material risks and pursuing material  opportunities related to value chain workers, and effectiveness of  those actions  S2-5  Targets related to managing material negative impacts, advancing  82  positive impacts, and managing material risks and opportunities  List of material Disclosure Requirements  Page number  S4 Consumers and End-users  ESRS 2  Interests and views of stakeholders  39-40  SBM-2-S4  ESRS 2  Material impacts, risks and opportunities and their interaction with  83-84  SBM-3-S4 strategy and business model  S4-1  Policies related to consumers and end-users  84; 88-89  S4-2  Processes for engaging with consumers and end-users about  39-40; 84  impacts  S4-3  Processes to remediate negative impacts and channels for  85; 88-89  consumers and end-users to raise concerns  S4-4  Taking action on material impacts on consumers and end-users,  10 -11; 16-17; 85  and approaches to managing material risks and pursuing material  opportunities related to consumers and end-users, and effective-  ness of those actions  S4-5  Targets related to managing material negative impacts, advancing  85  positive impacts, and managing material risks and opportunities  G1  Business Conduct  ESRS 2  Material impacts, risks and opportunities and their interaction with  87-88  SBM-3-G1 strategy and business model  ESRS 2  The role of the administrative, management and supervisory  29  GOV-1-G1 bodies  ESRS 2  Description of the processes to identify and assess material  42  IRO-1-G1 impacts, risks and opportunities  G1-1  Business conduct policies and corporate culture  81-82; 87-88; 90  G1-3  Prevention and detection of corruption and bribery  89-90  G1-4  Incidents of corruption or bribery  89-90  List of datapoints that derive from other EU legislation  The table below includes all the ESRS datapoints that derive from other EU legislation and indicates where the information can be found if deemed material.  Benchmark Regulation  EU Climate Law  Material /  Disclosure Requirement and related datapoint  SFDR reference  Pillar 3 reference  reference  reference  Not material  Page number  ESRS 2 GOV-1  Indicator number 13  Commission Delegated  Material  28-29  Board's gender diversity paragraph 21 (d)  of Table #1 of Annex 1  Regulation (EU)  2020/1816, Annex II  ESRS 2 GOV-1  Delegated Regulation  Material  28-29  Percentage of board members who are independent  (EU) 2020/1816, Annex II  paragraph 21 (e)  ESRS 2 GOV-4  Indicator number 10  Material  94-95  Statement on due diligence paragraph 30  Table #3 of Annex 1  ESRS 2 SBM-1  Indicators number 4  Article 449a Regulation (EU) No 575/2013;  Delegated Regulation  Not material  Involvement in activities related to fossil fuel  Table #1 of Annex 1  Commission Implementing Regulation (EU)  (EU) 2020/1816, Annex II  activities paragraph 40 (d) i  2022/2453  Table 1: Qualitative information on  Environmental risk and Table 2: Qualitative  information on Social risk  ESRS 2 SBM-1  Indicator number 9  Delegated Regulation  Not material  Involvement in activities related to chemical  Table #2 of Annex 1  (EU) 2020/1816, Annex II  production paragraph 40 (d) ii  ESRS 2 SBM-1  Indicator number 14  Delegated Regulation  Not material  Involvement in activities related to controversial  Table #1 of Annex 1  (EU) 2020/1818,  weapons paragraph 40 (d) iii  Article 12(1) Delegated  Regulation (EU)  2020/1816, Annex II  ESRS 2 SBM-1  Delegated Regulation  Not material  Involvement in activities related to cultivation and  (EU) 2020/1818,  production of tobacco paragraph 40 (d) iv  Article 12(1) Delegated  Regulation (EU)  2020/1816, Annex II  Benchmark Regulation  EU Climate Law  Material /  Disclosure Requirement and related datapoint  SFDR reference  Pillar 3 reference  reference  reference  Not material  Page number  ESRS E1-1  Regulation  Material  49  Transition plan to reach climate neutrality by 2050  (EU) 2021/1119,  paragraph 14  Article 2(1)  ESRS E1-1  Article 449a Regulation (EU) No 575/2013;  Delegated Regulation  Material  49  Undertakings excluded from Paris-aligned  Commission Implementing Regulation  (EU) 2020/1818,  Benchmarks paragraph 16 (g)  (EU) 2022/2453  Article12.1 (d) to (g), and  Template 1: Banking book-Climate Change  Article 12.2  transition risk: Credit quality of exposures  by sector, emissions and residual maturity  ESRS E1-4  Indicator number 4  Article 449a Regulation (EU) No 575/2013;  Delegated Regulation  Material  51-52  GHG emission reduction targets paragraph 34  Table #2 of Annex 1  Commission Implementing Regulation  (EU) 2020/1818,  (EU) 2022/2453  Article 6  Template 3: Banking book â Climate  change transition risk: alignment metrics  ESRS E1-5  Indicator number 5  Material  55  Energy consumption from fossil sources  Table #1 and  disaggregated by sources (only high climate impact  Indicator n. 5  sectors) paragraph 38  Table #2 of Annex 1  ESRS E1-5  Indicator number 5  Material  55  Energy consumption and mix paragraph 37  Table #1 of Annex 1  ESRS E1-5  Indicator number 6  Material  55  Energy intensity associated with activities in high  Table #1 of Annex 1  climate impact sectors paragraphs 40 to 43  ESRS E1-6  Indicators number 1  Article 449a; Regulation (EU) No 575/2013;  Delegated Regulation  Material  54  Gross Scope 1, 2, 3 and Total GHG emissions  and 2 Table #1 of  Commission Implementing Regulation  (EU) 2020/1818,  paragraph 44  Annex 1  (EU) 2022/2453  Article 5(1), 6 and 8(1)  Template 1: Banking book â Climate change  transition risk: Credit quality of exposures  by sector, emissions and residual maturity  ESRS E1-6  Indicators number 3  Article 449a Regulation (EU) No 575/2013;  Delegated Regulation  Material  54  Gross GHG emissions intensity paragraphs 53 to 55  Table #1 of Annex 1  Commission Implementing Regulation  (EU) 2020/1818,  (EU) 2022/2453  Article 8(1)  Template 3: Banking book â Climate  change transition risk: alignment metrics  Benchmark Regulation  EU Climate Law  Material /  Disclosure Requirement and related datapoint  SFDR reference  Pillar 3 reference  reference  reference  Not material  Page number  ESRS E1-7  Regulation  Not material  GHG removals and carbon credits paragraph 56  (EU) 2021/1119,  Article 2(1)  ESRS E1-9  Delegated Regulation  Phase-in  Exposure of the benchmark portfolio to climate-  (EU) 2020/1818, Annex II  related physical risks paragraph 66  Delegated Regulation  (EU) 2020/1816, Annex II  ESRS E1-9  Article 449a Regulation (EU) No 575/2013;  Phase-in  Disaggregation of monetary amounts by acute and  Commission Implementing Regulation  chronic physical risk paragraph 66 (a)  (EU) 2022/2453  ESRS E1-9  paragraphs 46  Location of significant assets at material physical risk  and 47; Template 5: Banking book  paragraph 66 (c).  - Climate change physical risk: Exposures  subject to physical risk.  ESRS E1-9  Article 449a Regulation (EU) No 575/2013;  Phase-in  Breakdown of the carrying value of its real estate  Commission Implementing Regulation  assets by energy-efficiency classes paragraph 67  (EU) 2022/2453  (c).  paragraph 34; Template 2:Banking book  -Climate change transition risk: Loans  collateralised by immovable property  - Energy efficiency of the collateral  ESRS E1-9  Delegated Regulation  Phase-in  Degree of exposure of the portfolio to climate- related  (EU) 2020/1818,  opportunities paragraph 69  Annex II  ESRS E2-4  Indicator number 8  Not material  Amount of each pollutant listed in Annex II of the  Table #1 of Annex 1  E-PRTR Regulation (European Pollutant Release and  Indicator number 2  Transfer Register) emitted to air, water and soil,  Table #2 of Annex 1  paragraph 28  Indicator number 1  Table #2 of Annex 1  Indicator number 3  Table #2 of Annex 1  Benchmark Regulation  EU Climate Law  Material /  Disclosure Requirement and related datapoint  SFDR reference  Pillar 3 reference  reference  reference  Not material  Page number  ESRS E3-1  Indicator number 7  Material  59  Water and marine resources paragraph 9  Table #2 of Annex 1  ESRS E3-1  Indicator number 8  Not material  Dedicated policy paragraph 13  Table 2 of Annex 1  ESRS E3-1  Indicator number 12  Material  59  Sustainable oceans and seas paragraph 14  Table #2 of Annex 1  ESRS E3-4  Indicator number 6.2  Material  60  Total water recycled and reused paragraph 28 (c)  Table #2 of Annex 1  ESRS E3-4  Indicator number 6.1  Material  60  Total water consumption in m3 per net revenue on own  Table #2 of Annex 1  operations paragraph 29  ESRS 2- SBM 3 - E4  Indicator number 7  Material  61  paragraph 16 (a) i  Table #1 of Annex 1  ESRS 2- SBM 3 - E4  Indicator number 10  Material  61  paragraph 16 (b)  Table #2 of Annex 1  ESRS 2- SBM 3 - E4  Indicator number 14  Material  61  paragraph 16 (c)  Table #2 of Annex 1  ESRS E4-2  Indicator number 11  Material  62  Sustainable oceans / seas practices or policies  Table #2 of Annex 1  paragraph 24 (c)  ESRS E4-2  Indicator number 12  Material  62  Sustainable oceans / seas practices or policies  Table #2 of Annex 1  paragraph 24 (c)  ESRS E4-2  Indicator number 15  Material  62  Policies to address deforestation paragraph 24 (d)  Table #2 of Annex 1  ESRS E5-5  Indicator number 13  Material  65-66  Non-recycled waste paragraph 37 (d)  Table #2 of Annex 1  ESRS E5-5  Indicator number 9  Material  65-66  Hazardous waste and radioactive waste  Table #1 of Annex 1  paragraph 39  ESRS 2- SBM3 - S1  Indicator number 13  Not material  Risk of incidents of forced labour paragraph 14 (f)  Table #3 of Annex I  ESRS 2- SBM3 - S1  Indicator number 12  Not material  Risk of incidents of child labour paragraph 14 (g)  Table #3 of Annex I  Benchmark Regulation  EU Climate Law  Material /  Disclosure Requirement and related datapoint  SFDR reference  Pillar 3 reference  reference  reference  Not material  Page number  ESRS S1-1  Indicator number 9  Material  75  Human rights policy commitments paragraph 20  Table #3 and  Indicator number 11  Table #1 of Annex I  ESRS S1-1  Delegated Regulation (EU) 2020/1816,  Material  75  Due diligence policies on issues addressed by the  Annex II  fundamental International Labor Organisation  Conventions 1 to 8, paragraph 21  ESRS S1-1  Indicator number 11  Material  75  processes and measures for preventing trafficking in  Table #3 of Annex I  human beings paragraph 22  ESRS S1-1  Indicator number 1  Material  79  workplace accident prevention policy or  Table #3 of Annex I  management system paragraph 23  ESRS S1-3  Indicator number 5  Material  88-89  grievance/complaints handling mechanisms  Table #3 of Annex I  paragraph 32 (c)  ESRS S1-14  Indicator number 2  Delegated Regulation  Material  80  Number of fatalities and number and rate of work-  Table #3 of Annex I  (EU) 2020/1816,  related accidents paragraph 88 (b) and (c)  Annex II  ESRS S1-14  Indicator number 3  Phase-in  Number of days lost to injuries, accidents, fatalities or  Table #3 of Annex I  illness paragraph 88 (e)  ESRS S1-16  Indicator number 12  Delegated Regulation  Material  78  Unadjusted gender pay gap paragraph 97 (a)  Table #1 of Annex I  (EU) 2020/1816,  Annex II  ESRS S1-16  Indicator number 8  Material  78  Excessive CEO pay ratio paragraph 97 (b)  Table #3 of Annex I  ESRS S1-17  Indicator number 7  Material  90  Incidents of discrimination paragraph 103 (a)  Table #3 of Annex I  ESRS S1-17  Indicator number 10  Delegated Regulation  Material  90  Non-respect of UNGPs on Business and Human Rights  Table #1 and  (EU) 2020/1816, Annex II  and OECD paragraph 104 (a)  Indicator n. 14 Table  Delegated Regulation  #3 of Annex I  (EU) 2020/1818 Art 12 (1)  Benchmark Regulation  EU Climate Law  Material /  Disclosure Requirement and related datapoint  SFDR reference  Pillar 3 reference  reference  reference  Not material  Page number  ESRS 2- SBM3 â S2  Indicators number 12  Material  81  Significant risk of child labour or forced labour in the  and n. 13 Table #3 of  value chain paragraph 11 (b)  Annex I  ESRS S2-1  Indicator number 9  Material  81-82  Human rights policy commitments paragraph 17  Table #3 and  Indicator n. 11 Table  #1 of Annex 1  ESRS S2-1  Indicator number 11  Material  81-82  Policies related to value chain workers paragraph 18  and n. 4 Table #3 of  Annex 1  ESRS S2-1  Indicator number 10  Delegated Regulation  Material  81-82  Non-respect of UNGPs on Business and Human Rights  Table #1 of Annex 1  (EU) 2020/1816,  principles and OECD guidelines paragraph 19  Annex II  Delegated Regulation  (EU) 2020/1818, Art 12 (1)  ESRS S2-1  Delegated Regulation  Material  81-82  Due diligence policies on issues addressed by the  (EU) 2020/1816,  fundamental International Labor Organisation  Annex II  Conventions 1 to 8, paragraph 19  ESRS S2-4  Indicator number 14  Material  82; 90  Human rights issues and incidents connected to its  Table #3 of Annex 1  upstream and downstream value chain paragraph 36  ESRS S3-1  Indicator number 9  Not material  Human rights policy commitments paragraph 16  Table #3 of Annex  1 and Indicator  number 11 Table #1 of  Annex 1  ESRS S3-1  Indicator number 10  Delegated Regulation  Not material  non-respect of UNGPs on Business and Human  Table #1 Annex 1  (EU) 2020/1816,  Rights, ILO principles or and OECD guidelines  Annex II  paragraph 17  Delegated Regulation  (EU) 2020/1818, Art 12 (1)  ESRS S3-4  Indicator number 14  Not material  Human rights issues and incidents paragraph 36  Table #3 of Annex 1  Benchmark Regulation  EU Climate Law  Material /  Disclosure Requirement and related datapoint  SFDR reference  Pillar 3 reference  reference  reference  Not material  Page number  ESRS S4-1  Indicator number 9  Material  84  Policies related to consumers and end-users  Table #3 and  paragraph 16  Indicator number 11  Table #1 of Annex 1  ESRS S4-1  Indicator number 10  Delegated Regulation  Material  84  Non-respect of UNGPs on Business and Human Rights  Table #1 of Annex 1  (EU) 2020/1816,  and OECD guidelines paragraph 17  Annex II  Delegated Regulation  (EU) 2020/1818, Art 12 (1)  ESRS S4-4  Indicator number 14  Not material  Human rights issues and incidents paragraph 35  Table #3 of Annex 1  ESRS G1-1  Indicator number 15  Not material  United Nations Convention against Corruption  Table #3 of Annex 1  paragraph 10 (b)  ESRS G1-1  Indicator number 6  Not material  Protection of whistle- blowers paragraph 10 (d)  Table #3 of Annex 1  ESRS G1-4  Indicator number 17  Delegated Regulation  Material  89  Fines for violation of anti- corruption and anti-bribery  Table #3 of Annex 1  (EU) 2020/1816,  laws paragraph 24 (a)  Annex II)  ESRS G1-4  Indicator number 16  Material  89  Standards of anti- corruption and anti- bribery  Table #3 of Annex 1  paragraph 24 (b)  </mrv:SustainabilityReport>
<mrv:StatementOfPolicyForDataEthics contextRef="ctx1" id="fact7869" xml:lang="en">Data ethics  ALK processes data from clinical trials,  research and development, employees,  customer interactions, and pharmacov-  igilance. Recognising the importance of  responsibly managing stakeholder data,  ALK adheres to its publicly communicated  data ethics policy. This policy ensures strict  compliance with privacy regulations and  best practices to safeguard data confiden-  tiality, integrity, and availability.  ALK maintains transparency about how  data is collected, processed, and used.  Data is only used to expand scientific and  medical understanding, ensure patient  safety, improve products and services, and  deliver appropriate treatments. The Board  of Directors regularly assesses this policy,  which applies to all ALK employees. Rele-  vant business units manage day-to-day  data ethics, integrating these principles  into their operations. This report complies  with section 99d of the Danish Financial  Statements Act.  </mrv:StatementOfPolicyForDataEthics>
<mrv:StatementOfTheDiversityPolicies contextRef="ctx1" id="fact7895" xml:lang="en">Disclosures stemming from other legislation  or generally accepted sustainability  reporting pronouncements  The sustainability statement has been prepared in compliance  with Section 99a of the Danish Financial Statements Act, in  accordance with the ESRS. Information prepared in compliance  with Section 107d of the Danish Financial Statements Act has  been included in the management review as well as in S1-1 on  page 75.  In addition to the Code of Conduct, which addresses harass-  ment, ALK has adopted a Diversity & Inclusion (D&I) Policy which  aims to eliminate discrimination and promote equal treatment  and opportunities for all employees. It sets out ALK's ambition  to create an inclusive work environment that fosters a sense of  belonging where different perspectives, abilities, talents and  experiences are able to contribute equally. The policy applies  to all ALK employees. The most senior level accountable for  implementing the policy is the ALK Sustainability Committee,  which receives quarterly reports from ALKâs sustainability  department on company-wide diversity performance. The ALK  D&I policy specifies that the following grounds for discrimination  are unacceptable: age, gender, race, ethnicity, religion, sexual  orientation, disability or and other characteristics including  work and life perspectives. The policy does not include specific  commitments for inclusion of people from particularly at-risk or  vulnerable groups.  ALK tracks employeesâ perceptions of diversity and inclusion  and their sense of psychological safety via the annual employee  engagement survey. In 2024, the overall perception of D&I in  ALK was 8.4, which is 0.2 points above the industry benchmark.  Other initiatives to promote diversity and inclusion include  training leaders on unconscious bias and incorporating D&I  topics into talent development programmes.  </mrv:StatementOfTheDiversityPolicies>
<mrv:DescriptionofTheTaxonomyRegulation contextRef="ctx1" id="fact7931" xml:lang="en">E3-4  Water consumption  In 2024, ALK's overall water consumption was  405,306 m3. This year, ALK included the irri-  gation for all leased land for ALK source mate-  rials, and installed meters to measure exact  consumption. The domestic water use was  92,533 m3 (2023: 101,413).  The consumption of water at Madrid (Spain)  was 11,495 m3 (2023: 10,646). Madrid (Spain)  production site is located in the Tagus river  basin, which has a low water quality and  quantity.  ALK reused 18,624 m3 of water for irrigation  purposes on the land where crops are culti-  vated to produce allergenic source materials.  Water used in ALKâs production processes  must meet strict regulatory standards for  quality and sterility, particularly in pharma-  ceutical manufacturing. These requirements  make water reuse or recycling complex and  may require advanced treatment systems to  ensure compliance, which are not currently  in place. As some allergenic source materials  come from leased land, implementing long-  term infrastructure, such as water recycling  systems, may not always be feasible or  aligned with the terms of the leasing agree-  ments.  ALK does not currently have water storage  facilities. The production processes at ALKâs  production sites generally rely on a direct and  consistent supply of water from municipal or  other external sources, reducing the imme-  diate need for on-site water storage. Since  water is not extensively reused or recycled,  the requirement for storage infrastructure is  limited.  The focus on investments in initiatives with  immediate and significant environmental  impacts has over the past year taken prece-  dence over the development of water storage  systems. In regions where water availability  is generally stable or sourced directly from  external providers, water storage may not  be deemed essential. For example, in areas  where water supply networks are reliable,  on-site storage systems may not add signifi-  cantly to operational efficiency.  EU Taxonomy  Under Article 8(1) of the Taxonomy regulation  (EU) 2020/852 and further detailed in Annex I of  the Disclosure Delegated Act (EU) 2021/2178,  ALK is obligated to report on the sustainability  profile of its Turnover, Capital Expenditure  (CapEx), and Operating Expenditure (OpEx).  This process involves evaluating ALK's economic  activities against those enumerated in the  delegated legislation of the EU Taxonomy (i.e.  eligibility assessment), identifying ALK's eligible  Turnover, CapEx, and OpEx, and finally assessing  compliance with the Substantial Contribution  Criteria (i.e. alignment assessment).The findings  from both the eligibility and alignment assess-  ments are encapsulated in key performance indi-  cators (KPIs) for Turnover, OpEx, and CapEx.  For a full overview of our taxonomy-eligible activites,  see the tables on pages 68-70.  Eligibility and alignment  In 2024, ALK has identified 98.0% turnover (2023:  97.8%), 18.7% CapEx (2023: 70.5%), and 57.9%  OpEx (2023: 47.4%) eligibility. Key changes from  2023 results from error identification in last year  reporting for CapEx and OpEx KPIs.  ALK has not claimed EU taxonomy alignment for  any eligible activities as it cannot be documented.  A climate risk assessment is planned for 2025.  Turnover  ALK has identified the following eligible turnover  activities:  ⢠PPC 1.2, manufacture of medicinal products: A  large portion of ALK's turnover stems from the  production of allergy immunotherapy treatments  as well as adrenaline pens (97.9% of turnover).  ⢠PPC 1.1, manufacture of active pharmaceutical  ingredients (API) or active substances: A minor  portion of ALKâs turnover is related to manufac-  ture of allergen extracts for use in the diagnosis  of specific allergies, for instance in skin prick  tests (0.1% of turnover).  CapEx  ALK has identified the following eligible CapEx  activities:  ⢠PPC 1.2, manufacture of medicinal products:  Capital expenditures related to the manufac-  turing of allergy immunotherapy treatments and  adrenaline pens (12.8% of CapEx).  ⢠CCM 7.5, Installation, maintenance and repair of  instruments and devices for measuring, regula-  tion and controlling energy performance of build-  ings: In 2024, ALK continued to install metering  equipment in Denmark to monitor water and elec-  tricity consumption (0.1% of CapEx).  ⢠CCM 7.6, Installation, maintenance and repair  of renewable energy technologies: Related to  the installation of an electrified boiler in France  replacing a boiler running on natural gas (0.3%  of CapEx).  ⢠CCM 7.7, Acquisition and ownership of buildings:  Projects related to investments and mainte-  nance of ALKâs buildings (5.5% of CapEx).  OpEx  ALK has identified the following eligible OpEx  activities:  ⢠PPC 1.2, manufacture of medicinal products:  OpEx relate to the manufacturing of allergy  immunotherapy treatments and adrenaline  pens (52.7% of OpEx).  ⢠CCM 6.5, transport by motorbikes, passenger  cars and light commercial vehicles: Leased  vehicles (5.2% of OpEx).  Annex XII of the Consolidated Complementary Delegated Act  All amounts in the tables below are presented in mEUR  Template 1 Nuclear and fossil gas related activities  Turnover  CapEX  Row  OpEx  Nuclear energy related activities  1.  The undertaking carries out, funds or has exposures to research,  NO  development, demonstration and deployment of innovative electricity generation facilities that  produce energy from 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  NO  nuclear installations to produce electricity or process heat, including for the purposes 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 installa-  NO  tions that produce electricity or process heat, including for the purposes of district heating or indus-  trial 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  NO  generation facilities that produce electricity using fossil gaseous fuels.  5.  The undertaking carries out, funds or has exposures to construction, refurbishment, and operation  NO  of combined heat/cool and power generation facilities using fossil gaseous fuels.  6.  The undertaking carries out, funds or has exposures to construction, refurbishment and operation of NO  heat generation facilities that produce heat/cool using fossil gaseous fuels.  Taxonomy turnover  Proportion of turnover from products or services associated with Taxonomy-aligned economic activities â disclosure covering year 2024  DNSH criteria  Financial year 2024  2024  Substantial Contribution Criteria  ('Does Not Significantly Harm')  Proportion  of Taxonomy  Propor-  Climate  Climate  Climate  aligned  tion of  Change  Change  Climate  Change  (A.1.) or eligible Category  Category  turnover,  Mitiga-  Adapta-  Circular  Bio-  Change  Adapta-  Circular  Bio-  Minimum  (A.2.) turnover,  enabling  transitional  Economic activities  Code  Turnover year N  tion  tion  Water  Pollution  Economy diversity Mitigation tion  Water  Pollution  Economy diversity Safeguards  year 2023  activity  activity  (1)  (2)  (3)  (4)  (5)  (6)  (7)  (8)  (9)  (10)  (11)  (12)  (13)  (14)  (15)  (16)  (17)  (18)  (19)  (20)  DKKm  % 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. Environmentally sustainable activities  (Taxonomy-aligned)  Turnover of environmentally sustainable activities (Taxonomy-aligned) (A.1)  0 0.0%  0.0%  0.0%  0.0%  0.0%  0.0%  0.0%  N N N N N N N 0.0%  Of which Enabling  0 0.0%  0.0%  0.0%  0.0%  0.0%  0.0%  0.0%  N N N N N N N 0.0%  E Of which Transitional  0 0.0%  0.0%  N N N N N N N 0.0%  T A.2 Taxonomy-eligible but not environmentally sustainable activities  (not Taxonomy-aligned activities)  EL;N/EL  EL;N/EL  EL;N/EL  EL;N/EL  EL;N/EL  EL;N/EL  Manufacture of active pharmaceutical ingredients (API) or active substance  PPC 1.1  7 0.1%  N/EL  N/EL  N/EL  EL  N/EL  N/EL  0.4%  Manufacturing of Medicinal products  PPC 1.2  5,418  97.9 %  N/EL  N/EL  N/EL  EL  N/EL  N/EL  97.4%  Turnover of Taxonomy-eligible but not environmentally sustainable activities  (not Taxonomy-aligned activities) (A.2)  5,425  98.0%  0.0%  0.0%  0.0%  98.0%  0.0%  0.0%  97.8%  A. Turnover of Taxonomy eligible activities (A1 + A2)  5,425  98.0%  0.0%  0.0%  0.0%  98.0%  0.0%  0.0%  97.8%  B. Taxonomy-non-eligible activities  Turnover of Taxonomy-non-eligible activities  112  2.0%  Total  5,537  100.0%  Taxonomy CapEx  Proportion of CapEx from products or services associated with Taxonomy-aligned economic activities â disclosure covering year 2024  DNSH criteria  Financial year 2024  2024  Substantial Contribution Criteria  ('Does Not Significantly Harm')  Proportion  of Taxonomy  Climate  Climate  Climate  aligned  Proportion Change  Change  Climate  Change  (A.1.) or eligible  of CapEx, Mitiga-  Adapta-  Circular  Biodiver- Change  Adapta-  Circular  Bio-  Minimum  (A.2.) CapEx,  Category  Category transi-  Economic activities  Code  CapEx  year N  tion  tion  Water  Pollution  Economy sity  Mitigation tion  Water  Pollution  Economy diversity Safeguards  year 2023  enabling activity tional activity  (1)  (2)  (3)  (4)  (5)  (6)  (7)  (8)  (9)  (10)  (11)  (12)  (13)  (14)  (15)  (16)  (17)  (18)  (19)  (20)  DKKm  % 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. Environmentally sustainable activities  (Taxonomy-aligned)  CapEx of environmentally sustainable activities (Taxonomy-aligned) (A.1)  0 0.0%  0.0%  0.0%  0.0%  0.0%  0.0%  0.0%  N N N N N N N 0.0%  Of which Enabling  0 0.0%  0.0%  0.0%  0.0%  0.0%  0.0%  0.0%  N N N N N N N 0.0%  E Of which Transitional  0 0.0%  0.0%  N N N N N N N 0.0%  T A.2 Taxonomy-eligible but not environmentally sustainable activities  (not Taxonomy-aligned activities)  EL;N/EL  EL;N/EL  EL;N/EL  EL;N/EL  EL;N/EL  EL;N/EL  Manufacturing of Medicinal products  PPC 1.2  167  12.8%  N/EL  N/EL  N/EL  EL  N/EL  N/EL  69.0%  Installation, maintenance and repair of energy efficiency equipment (CapEx C)  CC M 7. 3  0 0.0%  EL  N/EL  N/EL  N/EL  N/EL  N/EL  0.7%  Installation, maintenance and repair of instruments and devices for measuring,  regulation and controlling energy performance of buildings  CC M 7. 5  1 0.1%  EL  N/EL  N/EL  N/EL  N/EL  N/EL  0.8%  Installation, maintenance and repair of renewable energy technologies  CC M 7.6  4 0.3%  EL  N/EL  N/EL  N/EL  N/EL  N/EL  0.0%  Acquisition and ownership of buildings  CC M 7.7  71  5.5%  EL  N/EL  N/EL  N/EL  N/EL  N/EL  0.0%  CapEx of Taxonomy-eligible but not environmentally sustainable activities  (not Taxonomy-aligned activities) (A.2)  243  18.7%  5.9%  0.0%  0.0%  12.8%  0.0%  0.0%  70.5%  A. CapEx of Taxonomy eligible activities (A1 + A2)  243  18.7%  5.9%  0.0%  0.0%  12.8%  0.0%  0.0%  70.5%  B. Taxonomy-non-eligible activities  CapEx of Taxonomy-non-eligible activities  1,060  81.3%  Total  1,303  100.0%  Taxonomy OpEx  Proportion of OpEx from products or services associated with Taxonomy-aligned economic activities â disclosure covering year 2024  DNSH criteria  Financial year 2024  2024  Substantial Contribution Criteria  ('Does Not Significantly Harm')  Proportion  of Taxonomy  Climate  Climate  Climate  aligned  Proportion Change  Change  Climate  Change  (A.1.) or eligible  of OpEx,  Mitiga-  Adapta-  Circular  Bio-  Change  Adapta-  Circular  Biodiver- Minimum  (A.2.) OpEx,  Category  Category transi-  Economic activities  Code  OpEx  year N  tion  tion  Water  Pollution  Economy diversity Mitigation tion  Water  Pollution  Economy sity  Safeguards  year 2023  enabling activity tional activity  (1)  (2)  (3)  (4)  (5)  (6)  (7)  (8)  (9)  (10)  (11)  (12)  (13)  (14)  (15)  (16)  (17)  (18)  (19)  (20)  DKKm  % 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. Environmentally sustainable activities  (Taxonomy-aligned)  OpEx of environmentally sustainable activities (Taxonomy-aligned) (A.1)  0 0.0%  0.0%  0.0%  0.0%  0.0%  0.0%  0.0%  N N N N N N N 0.0%  Of which Enabling  0 0.0%  0.0%  0.0%  0.0%  0.0%  0.0%  0.0%  N N N N N N N 0.0%  E Of which Transitional  0 0.0%  0.0%  N N N N N N N 0.0%  T A.2 Taxonomy-eligible but not environmentally sustainable activities  (not Taxonomy-aligned activities)  EL;N/EL  EL;N/EL  EL;N/EL  EL;N/EL  EL;N/EL  EL;N/EL  Manufacturing of Medicinal products  PPC 1.2  172  52.7%  N/EL  N/EL  N/EL  EL  N/EL  N/EL  46.9%  Transport by motorbikes, passenger cars and light commercial vehicles (OpEx C)  CCM 6.5  17  5.2%  EL  N/EL  N/EL  N/EL  N/EL  N/EL  0.5%  OpEx of Taxonomy-eligible but not environmentally sustainable activities (not Taxono-  my-aligned activities) (A.2)  189  57.9%  5.2%  0.0%  0.0%  52.7%  0.0%  0.0%  47.4%  A. OpEx of Taxonomy eligible activities (A1 + A2)  189  57.9%  5.2%  0.0%  0.0%  52.7%  0.0%  0.0%  47.4%  B. Taxonomy-non-eligible activities  OpEx of Taxonomy-non-eligible activities  138  42.1%  Total  327  100.0%  EU Taxonomy  The turnover, OpEx and CapEx numerators are deter-  mined from ALKâs assessment of the relevant economic  activities within all six environmental objectives.  The turnover denominator is derived from ALK groupâs  total revenue of the consolidated financial statements  ( see note 2.1 on page 114). The Turnover KPI is defined  as Taxonomy-eligible Turnover divided by total Turnover.  The CapEx denominator is derived from the ALK groupâs  total annual investments in property, plant and equip-  ment as well as intangible assets, excluding short term  leases and non-capitalised ROU assets based on Danish  GAAP, as stated in the consolidated financial statements  ( see notes 3.1 - 3.3 on pages 121-126). Goodwill  is not included in CapEx. The CapEx KPI is defined as  Taxonomy-eligible CapEx divided by total CapEx.  The OpEx denominator covers direct non-capitalised  costs that primarily relate to repair and maintenance,  car expenses that are short term leased, tests and costs  relating to the servicing of group assets that are neces-  sary to ensure the continued and effective functioning  of such assets. The OpEx KPI is defined as Taxonomy  eligible OpEx divided by total OpEx.  For the CapEx and OpEx allocations, the relevant  purchases and measures, as well as the primary related  economic activity, are identified. Thereby, it is ensured  that no CapEx or OpEx is double counted.  </mrv:DescriptionofTheTaxonomyRegulation>
<sob:StatementByExecutiveAndSupervisoryBoards contextRef="ctx1" id="fact8852" xml:lang="en">Statement by Management  on the annual report  The Board of Directors and the Board of Management have today  considered and adopted the annual report of ALK-Abelló A/S for the  financial year 1 January to 31 December 2024.  The consolidated financial statements have been prepared in  accordance with IFRS accounting standards as adopted by the EU  and further requirements in the Danish Financial Statements Act.  The parent company financial statements have been prepared in  accordance with the Danish Financial Statements Act. Manage-  ment's review has been 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 position at 31 December 2024 of the group and the parent  company and of the results of the group and parent company opera-  tions and consolidated cash flows for the financial year 1 January to  31 December 2024.  In our opinion, Managementâs review includes a true and fair  account of the development in the operations and financial circum-  stances 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.  Additionally, the Sustainability Statement, which is part of Manage-  mentâs review, has been prepared, in all material respects, in  accordance with paragraph 99 a of the Danish Financial Statements  Act. This includes compliance with the European Sustainability  Reporting Standards (ESRS) including that the process undertaken  by Management to identify the reported information (the âProcessâ)  is in accordance with the description set out in section âDescrip-  tion of the process to identify and assess material impacts, risks  and opportunitiesâ. Furthermore, disclosures in subsection âEU  Taxonomyâ in the environmental section of the Sustainability State-  ment are, in all material respects, in accordance with Article 8 of EU  Regulation 2020/852 (the âTaxonomy Regulationâ).  The year 2024 marks the initial implementation of paragraph 99 a  of the Danish Financial Statements Act concerning compliance with  ESRS. As such, more clear guidance and practice are anticipated in  various areas, which are expected to be issued in the coming years.  Furthermore, the Sustainability Statement includes forward-looking  statements based on disclosed assumptions about events that  may occur in the future and possible future actions by the Group.  Actual outcomes are likely to be different since anticipated events  frequently do not occur as expected.  In our opinion, the annual report of ALK-Abelló A/S for the financial  year 1 January to 31 December 2024 with the file name alk-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.  </sob:StatementByExecutiveAndSupervisoryBoards>
<sob:PlaceOfSignatureOfStatement contextRef="ctx1" id="fact8908" xml:lang="en">Hørsholm</sob:PlaceOfSignatureOfStatement>
<sob:DateOfApprovalOfAnnualReport contextRef="ctx1" id="fact8909">2025-02-19</sob:DateOfApprovalOfAnnualReport>
<cmn:NameAndSurnameOfMemberOfExecutiveBoard contextRef="ctx24" id="fact9854" xml:lang="en">Peter Halling</cmn:NameAndSurnameOfMemberOfExecutiveBoard>
<cmn:TitleOfMemberOfExecutiveBoard contextRef="ctx24" id="fact9855" xml:lang="en">President & CEO</cmn:TitleOfMemberOfExecutiveBoard>
<cmn:NameAndSurnameOfMemberOfExecutiveBoard contextRef="ctx25" id="fact9856" xml:lang="en">Claus Steensen Sølje</cmn:NameAndSurnameOfMemberOfExecutiveBoard>
<cmn:TitleOfMemberOfExecutiveBoard contextRef="ctx25" id="fact9857" xml:lang="en">Executive Vice President & CFO</cmn:TitleOfMemberOfExecutiveBoard>
<cmn:NameAndSurnameOfMemberOfExecutiveBoard contextRef="ctx26" id="fact9859" xml:lang="en">Søren Niegel</cmn:NameAndSurnameOfMemberOfExecutiveBoard>
<cmn:TitleOfMemberOfExecutiveBoard contextRef="ctx26" id="fact9860" xml:lang="en">Executive Vice President, Commercial Operations</cmn:TitleOfMemberOfExecutiveBoard>
<cmn:NameAndSurnameOfMemberOfExecutiveBoard contextRef="ctx27" id="fact9862" xml:lang="en">Henriette Mersebach</cmn:NameAndSurnameOfMemberOfExecutiveBoard>
<cmn:TitleOfMemberOfExecutiveBoard contextRef="ctx27" id="fact9863" xml:lang="en">Executive Vice President, Research & Development</cmn:TitleOfMemberOfExecutiveBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx28" id="fact9865" xml:lang="en">Anders Hedegaard</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx32" id="fact9870" xml:lang="en">Lene Skole</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx28" id="fact9866" xml:lang="en">Chair</cmn:TitleOfMemberOfSupervisoryBoard>
<cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx32" id="fact9871" xml:lang="en">Vice Chair</cmn:TitleOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx29" id="fact9867" xml:lang="en">Gitte Aabo</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx33" id="fact9872" xml:lang="en">Lars Holmqvist</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx34" id="fact9873" xml:lang="en">Alan Main</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx36" id="fact9875" xml:lang="en">Jesper Høiland</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx37" id="fact9876" xml:lang="en">Katja Barnkob</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx38" id="fact9877" xml:lang="en">Johan Smedsrud</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx30" id="fact9868" xml:lang="en">Bertil Lindmark</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx31" id="fact9869" xml:lang="en">Nanna Rassov Carlson</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx35" id="fact9874" xml:lang="en">Lise Lund Mærkedahl</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
<arr:IndependentAuditorsReportsAudit contextRef="ctx1" id="fact8910" xml:lang="en">Independent Auditorâs Reports  </arr:IndependentAuditorsReportsAudit>
<arr:KeyAuditMattersAudit contextRef="ctx1" id="fact8983" xml:lang="en">Key audit matters  Key audit matters are those matters that, in our professional judgement, were of most signif-  icance in our audit of the Financial Statements for 2024. These matters were addressed in  the context of our audit of the Financial Statements as a whole, and in forming our opinion  thereon, and we do not provide a separate opinion on these matters.  Key audit matter  Revenue recognition and related  sales deductions  The Group sells products in certain markets  subject to various rebate and discount  arrangements and mandated price adjust-  ments schemes. These arrangements  and schemes result in deductions to gross  revenue in arriving at net revenue and in  accruals for estimated sales deductions.  We focused on these areas as accounting  for rebates, discounts and mandated price  adjustments is complex and requires a  high degree of estimation by Management.  This includes the estimation uncertainty  regarding accruals for estimated sales  deductions.  We refer to note 2.1 in the consolidated  financial statements.  How our audit addressed  the key audit matter  We discussed the policies for revenue recog-  nition, including accounting for rebates,  discounts and mandated price adjustments  with Management.  We performed risk assessment procedures  to obtain an understanding of the IT systems,  business processes and relevant controls for  revenue recognition and related sales deduc-  tions. We assessed whether the controls were  designed and implemented to effectively  address the risk of material misstatement.  We evaluated and challenged the assump-  tions and estimates, including methods, data  and assumptions used for calculating rebates,  discounts and mandated price adjustments  and accruals for sales deductions.  We assessed the appropriateness of the  related disclosure provided in the consoli-  dated financial statements.  </arr:KeyAuditMattersAudit>
<arr:AddresseeOfAuditorsReportOnAuditedFinancialStatements contextRef="ctx1" id="fact8911" xml:lang="en">To the shareholders of ALK-Abelló A/S  </arr:AddresseeOfAuditorsReportOnAuditedFinancialStatements>
<arr:AuditorsReportOnFinancialStatements contextRef="ctx1" id="fact8912" xml:lang="en">Report on the audit of  the Financial Statements  </arr:AuditorsReportOnFinancialStatements>
<arr:DescriptionOfQualificationsOfAuditedFinancialStatements contextRef="ctx1" id="fact8946" xml:lang="en">Basis for opinion  We conducted our audit in accordance with Inter-  national Standards on Auditing (ISAs) and the  additional requirements applicable in Denmark.  Our responsibilities under those standards and  requirements are further described in the Auditorâs  responsibilities for the audit of the Financial State-  ments 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 Account-  antsâ International Code of Ethics for Professional  Accountants (IESBA Code) and the additional ethical  requirements applicable in Denmark. We have also  fulfilled our other ethical responsibilities in accord-  ance with these requirements and the IESBA Code.  To the best of our knowledge and belief, prohibited  non-audit services referred to in Article 5(1) of  Regulation (EU) No 537/2014 were not provided.  Appointment  We were first appointed auditors of ALK-Abelló A/S  on 11 March 2020 for the financial year 2020. We  have been reappointed annually by shareholder  resolution for a total period of uninterrupted engage-  ment of 5 years including the financial year 2024.  </arr:DescriptionOfQualificationsOfAuditedFinancialStatements>
<arr:OpinionOnAuditedFinancialStatements contextRef="ctx1" id="fact8914" xml:lang="en">Our opinion  In our opinion, the Consolidated Financial State-  ments give a true and fair view of the Groupâs  financial position at 31 December 2024 and of the  results of the Groupâs operations and cash flows for  the financial year 1 January to 31 December 2024  in accordance with IFRS Accounting Standards as  adopted by the EU and further requirements in the  Danish Financial Statements Act.  Moreover, in our opinion, the Parent Company  Financial Statements give a true and fair view  of the Parent Companyâs financial position at  31 December 2024 and of the results of the Parent  Companyâs operations for the financial year  1 January to 31 December 2024 in accordance with  the Danish Financial Statements Act.  Our opinion is consistent with our Auditorâs Long-  form Report to the Audit Committee and the Board  of Directors.  What we have audited  The Consolidated Financial Statements (pp 106-145)  and the Parent Company Financial Statements (pp  146-156) of ALK-Abelló A/S for the financial year  1 January to 31 December 2024 comprise income  statement, balance sheet, statement of changes  in equity and notes, including material accounting  policy information for the Group as well as for the  Parent Company, and statement of comprehensive  income and cash flow statement for the Group.  Collectively referred to as the âFinancial Statementsâ.  </arr:OpinionOnAuditedFinancialStatements>
<arr:StatementOnManagementsReviewAuditorsReportOnAuditedFinancialStatements contextRef="ctx1" id="fact9032" xml:lang="en">Statement on Managementâs Review  Management is responsible for Managementâs  Review (pp 1-105 and 164).  Our opinion on the Financial Statements does not  cover Managementâs Review, and we do not as  part of the audit express any form of assurance  conclusion thereon.  In connection with our audit of the Financial  Statements, our responsibility is to read Manage-  mentâs Review and, in doing so, consider whether  Managementâs Review is materially inconsistent  with the Financial Statements or our knowledge  obtained in the audit, or otherwise appears to be  materially misstated.  Moreover, we considered whether Manage-  mentâs Review includes the disclosures required  by the Danish Financial Statements Act. This does  not include the requirements in paragraph 99 a  related to the Sustainability Statement covered by  the separate auditorâs limited assurance report  hereon.  Based on the work we have performed, in our  view, Managementâs Review is in accordance  with the Consolidated Financial Statements  and the Parent Company Financial Statements  and has been prepared in accordance with the  requirements of the Danish Financial Statements  Act, except for the requirements in paragraph  99 a related to the Sustainability Statement, cf.  above. We did not identify any material misstate-  ment in Managementâs Review.  </arr:StatementOnManagementsReviewAuditorsReportOnAuditedFinancialStatements>
<arr:StatementOfAuditorsResponsibilityForAuditAndAuditPerformed contextRef="ctx1" id="fact9087" xml:lang="en">Auditorâs responsibilities for the audit of  the Financial Statements  Our objectives are to obtain reasonable assur-  ance about whether the Financial Statements  as a whole are free from material misstate-  ment, whether due to fraud or error, and to  issue an auditorâs 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 the addi-  tional 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, individually  or in the aggregate, they could reasonably be  expected to influence the economic decisions of  users taken on the basis of these Financial State-  ments.  As part of an audit in accordance with ISAs  and the additional requirements applicable in  Denmark, we exercise professional judgement  and maintain professional scepticism throughout  the audit. We also:  ⢠Identify and assess the risks of material  misstatement of the Financial Statements,  whether due to fraud or error, design and  perform audit procedures responsive to those  risks, and obtain audit evidence that is suffi-  cient 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 omis-  sions, misrepresentations, or the override of  internal control.  ⢠Obtain an understanding of internal control  relevant to the audit in order to design audit  procedures that are appropriate in the circum-  stances, but not for the purpose of expressing  an opinion on the effectiveness of the Groupâs  and the Parent Companyâs internal control.  ⢠Evaluate the appropriateness of accounting  policies used and the reasonableness of  accounting estimates and related disclosures  made by Management.  ⢠Conclude on the appropriateness of Manage-  mentâs use of the going concern basis of  accounting and based on the audit evidence  obtained, whether a material uncertainty  exists related to events or conditions that  may cast significant doubt on the Groupâs and  the Parent Companyâs ability to continue as a  going concern. If we conclude that a material  uncertainty exists, we are required to draw  attention in our auditorâs 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  auditorâs report. However, future events or  conditions may cause the Group or the Parent  Company to cease to continue as a going  concern.  ⢠Evaluate the overall presentation, structure  and content of the Financial Statements,  including the disclosures, and whether the  Financial Statements 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 Consol-  idated 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 signifi-  cant audit findings, including any significant defi-  ciencies in internal control that we identify during  our audit.  We also provide those charged with governance  with a statement that we have complied with rele-  vant ethical requirements regarding independ-  ence, and to communicate with them all relation-  ships and other matters that may reasonably be  thought to bear on our independence and, where  applicable, actions taken to eliminate threats or  safeguards applied.  From the matters communicated with those  charged with governance, we determine those  matters that were of most significance in the  audit of the Financial Statements of the current  period and are therefore the key audit matters.  We describe these matters in our auditorâs report  unless law or regulation precludes public disclo-  sure about the matter.  </arr:StatementOfAuditorsResponsibilityForAuditAndAuditPerformed>
<arr:StatementOfExecutiveAndSupervisoryBoardsResponsibilityForFinancialStatements contextRef="ctx1" id="fact9063" xml:lang="en">Managementâs 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 further  requirements in 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 Financial  Statements Act, and for such internal control as  Management determines is necessary to enable  the preparation of financial statements that are  free from material misstatement, whether due to  fraud or error.  In preparing the Financial Statements, Manage-  ment is responsible for assessing the Groupâs  and the Parent Companyâs ability to continue as a  going concern, disclosing, as applicable, matters  related to going concern and using the going  concern basis of accounting unless Management  either intends to liquidate the Group or the Parent  Company or to cease operations, or has no real-  istic alternative but to do so.  </arr:StatementOfExecutiveAndSupervisoryBoardsResponsibilityForFinancialStatements>
<arr:AuditorsReportOnXbrlTagging contextRef="ctx1" id="fact9202" xml:lang="en">Report on compliance with  the ESEF Regulation  As part of our audit of the Financial Statements  we performed procedures to express an opinion  on whether the annual report of ALK-Abelló A/S  for the financial year 1 January to 31 December  2024 with the filename alk-2024-12-31-en.zip is  prepared, in all material respects, in compliance  with the Commission Delegated Regulation (EU)  2019/815 on the European Single Electronic  Format (ESEF Regulation) which includes require-  ments related to the preparation of the annual  report in XHTML format and iXBRL tagging of the  Consolidated Financial Statements including  notes.  Management is responsible for preparing an  annual report that complies with the ESEF Regu-  lation. This responsibility includes:  ⢠The preparing of the annual report in XHTML  format;  ⢠The selection and application of appropriate  iXBRL tags, including extensions to the ESEF  taxonomy and the anchoring thereof to  elements in the taxonomy, for all financial infor-  mation required to be tagged using judgement  where necessary;  ⢠Ensuring consistency between iXBRL tagged  data and the Consolidated Financial State-  ments presented in human-readable format;  and  ⢠For such internal control as Management  determines necessary to enable the prepara-  tion of an annual report that is compliant with  the ESEF Regulation.  Our responsibility is to obtain reasonable assur-  ance on whether the annual report is prepared,  in all material respects, in compliance with the  ESEF Regulation based on the evidence we have  obtained, and to issue a report that includes  our opinion. The nature, timing and extent of  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 State-  ments including notes;  ⢠Evaluating the appropriateness of the compa-  nyâs 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  including notes.  In our opinion, the annual report of ALK-Abelló  A/S for the financial year 1 January to 31  December 2024 with the file name alk-2024-12-  31-en.zip is prepared, in all material respects, in  compliance with the ESEF Regulation.  </arr:AuditorsReportOnXbrlTagging>
<arr:SignatureOfAuditorsPlace contextRef="ctx1" id="fact9291" xml:lang="en">Hellerup</arr:SignatureOfAuditorsPlace>
<arr:SignatureOfAuditorsDate contextRef="ctx1" id="fact9292">2025-02-19</arr:SignatureOfAuditorsDate>
<cmn:NameOfAuditFirm contextRef="ctx43" id="fact9898" xml:lang="en">PricewaterhouseCoopers Statsautoriseret Revisionspartnerselskab</cmn:NameOfAuditFirm>
<cmn:NameOfAuditFirm contextRef="ctx42" id="fact9888" xml:lang="en">PricewaterhouseCoopers Statsautoriseret Revisionspartnerselskab</cmn:NameOfAuditFirm>
<cmn:IdentificationNumberCvrOfAuditFirm contextRef="ctx43" id="fact9897">33771231</cmn:IdentificationNumberCvrOfAuditFirm>
<cmn:IdentificationNumberCvrOfAuditFirm contextRef="ctx42" id="fact9890">33771231</cmn:IdentificationNumberCvrOfAuditFirm>
<cmn:NameAndSurnameOfAuditor contextRef="ctx42" id="fact9891" xml:lang="en">Lars Baungaard</cmn:NameAndSurnameOfAuditor>
<cmn:DescriptionOfAuditor contextRef="ctx42" id="fact9892" xml:lang="en">State Authorised Public Accountant</cmn:DescriptionOfAuditor>
<cmn:IdentificationNumberOfAuditor contextRef="ctx42" id="fact9893" xml:lang="en">mne23331</cmn:IdentificationNumberOfAuditor>
<cmn:NameAndSurnameOfAuditor contextRef="ctx43" id="fact9894" xml:lang="en">Kim Tromholt</cmn:NameAndSurnameOfAuditor>
<cmn:DescriptionOfAuditor contextRef="ctx43" id="fact9895" xml:lang="en">State Authorised Public Accountant</cmn:DescriptionOfAuditor>
<cmn:IdentificationNumberOfAuditor contextRef="ctx43" id="fact9896" xml:lang="en">mne33251</cmn:IdentificationNumberOfAuditor>
<arr:AuditorsReportOnSubstainabilityReport contextRef="ctx1" id="fact9293" xml:lang="en">Independent auditorâs limited assurance report on  the Sustainability Statement  To the stakeholders of ALK-Abelló A/S  Basis for conclusion  Our firm applies International Standard on  ⢠assessment of the materiality of the identi-  We conducted our limited assurance engagement  Quality Management 1, which requires the firm  fied impacts, risks and opportunities related  Limited assurance conclusion  in accordance with International Standard on  to design, implement and operate a system of  to sustainability matters by selecting and  We have conducted a limited assurance  Assurance Engagements (ISAE) 3000 (Revised),  quality management including policies or proce-  applying appropriate thresholds; and  engagement on the sustainability statement  Assurance engagements other than audits or  dures regarding compliance with ethical require-  of ALK-Abelló A/S (the âGroupâ) included in  reviews of historical financial information (âISAE  ments, professional standards and applicable  ⢠making assumptions that are reasonable in the  Managementâs Review, page 36-105, for the  3000 (Revised)â) and the additional require-  legal and regulatory requirements.  circumstances.  financial year 1 January â 31 December 2024 (the  ments applicable in Denmark.  âSustainability Statementâ).  Managementâs responsibilities for  Management is further responsible for prepa-  The procedures in a limited assurance engage-  the Sustainability Statement  ration of the Sustainability Statement, which  Based on the procedures we have performed  ment vary in nature and timing from, and are  Management is responsible for designing and  includes the information identified by the  and the evidence we have obtained, nothing has  less in extent than for, a reasonable assurance  implementing a process to identify the informa-  Process, in accordance with the Danish Financial  come to our attention that causes us to believe  engagement. Consequently, the level of assur-  tion reported in the Sustainability Statement in  Statements Act paragraph 99 a, including:  that the Sustainability Statement is not prepared,  ance obtained in a limited assurance engage-  accordance with ESRS and for disclosing this  in all material respects, in accordance with the  ment is substantially lower than the assurance  Process as included in section âDescription of the  ⢠compliance with ESRS;  Danish Financial Statements Act paragraph 99 a,  that would have been obtained had a reasonable  process to identify and assess material impacts,  including:  assurance engagement been performed.  risks and opportunitiesâ of the Sustainability  ⢠preparing the disclosures as included in  Statement. This responsibility includes:  subsection âEU Taxonomyâ of the Sustainability  ⢠compliance with the European Sustainability  We believe that the evidence we have obtained  Statement, in compliance with Article 8 of the  Reporting Standards (ESRS), including that the  is sufficient and appropriate to provide a basis  ⢠understanding the context in which the Groupâs  Taxonomy Regulation;  process carried out by Management to identify  for our conclusion. Our responsibilities under this  activities and business relationships take  the information reported in the Sustainability  standard are further described in the Auditorâs  place and developing an understanding of its  ⢠designing, implementing and maintaining  Statement (the âProcessâ) is in accordance  responsibilities for the assurance engagement  affected stakeholders;  such internal control that Management deter-  with the description set out in section âDescrip-  section of our report.  mines is necessary to enable preparation of  tion of the process to identify and assess mate-  ⢠identification of the actual and potential  the Sustainability Statement that is free from  rial impacts, risks and opportunitiesâ; and  Our independence and quality management  impacts (both negative and positive) related  material misstatement, whether due to fraud or  We are independent of the Group in accordance  to sustainability matters, as well as risks and  error; and  ⢠compliance of the disclosures in subsection âEU  with the International Ethics Standards Board  opportunities that affect, or could reasonably  Taxonomyâ within the environmental section  for Accountantsâ International Code of Ethics for  be expected to affect, the Groupâs financial  ⢠the selection and application of appropriate  of the Sustainability Statement with Article 8  Professional Accountants (IESBA Code) and the  position, financial performance, cash flows,  sustainability reporting methods and making  of EU Regulation 2020/852 (the âTaxonomy  additional ethical requirements applicable in  access to finance or cost of capital over the  assumptions and estimates that are reason-  Regulationâ).  Denmark. We have also fulfilled our other ethical  short-, medium-, or long-term;  able in the circumstances.  responsibilities in accordance with these require-  ments and the IESBA Code.  Inherent limitations in preparing the Sustaina-  ⢠Designing and performing procedures to eval-  reviewing the Groupâs internal documentation  bility Statement  uate whether the Process is consistent with the  of its Process; and  In reporting forward-looking information in  Groupâs description of its Process, as disclosed  accordance with ESRS, Management is required  in section âDescription of the process to iden-  ⢠Evaluated whether the evidence obtained  to prepare forward-looking information on the  tify and assess material impacts, risks and  from our procedures about the Process imple-  basis of disclosed assumptions about events  opportunitiesâ of the Sustainability Statement.  mented by the Group was consistent with the  that may occur in the future and possible future  description of the Process set out in section  actions by the Group. Actual outcomes are likely  Our other responsibilities in respect of the  âDescription of the process to identify and  to be different since anticipated events frequently  Sustainability Statement include:  assess material impacts, risks and opportuni-  do not occur as expected.  tiesâ of the Sustainability Statement.  ⢠Identifying where material misstatements are  Auditorâs responsibilities for the assurance  likely to arise, whether due to fraud or error;  In conducting our limited assurance engagement,  engagement  and  with respect to the Sustainability Statement, we:  Our responsibility is to plan and perform the  assurance engagement to obtain limited assur-  ⢠Designing and performing procedures respon-  ⢠Obtained an understanding of the Groupâs  ance about whether the Sustainability Statement  sive to disclosures in the Sustainability State-  reporting processes relevant to the prepara-  is free from material misstatement, whether  ment where material misstatements are likely  tion of its Sustainability Statement, including  due to fraud or error, and to issue a limited  to arise. The risk of not detecting a material  the consolidation processes, by obtaining an  assurance report that includes our conclusion.  misstatement resulting from fraud is higher  understanding of the Groupâs control envi-  Misstatements can arise from fraud or error and  than for one resulting from error, as fraud may  ronment, processes and information systems  are considered material if, individually or in the  involve collusion, forgery, intentional omis-  relevant to the preparation of the Sustaina-  aggregate, they could reasonably be expected to  sions, misrepresentations, or the override of  bility Statement but not evaluating the design  influence decisions of users taken on the basis of  internal control.  of particular control activities, obtaining  the Sustainability Statement as a whole.  evidence about their implementation or testing  Summary of the work performed  their operating effectiveness;  As part of a limited assurance engagement in  A limited assurance engagement involves  accordance with ISAE 3000 (Revised) we exercise  performing procedures to obtain evidence about  ⢠Evaluated whether the information identified  professional judgement and maintain profes-  the Sustainability Statement. The nature, timing  by the Process is included in the Sustainability  sional scepticism throughout the engagement.  and extent of procedures selected depend on  Statement;  professional judgement, including the identifica-  Our responsibilities in respect of the Process  tion of disclosures where material misstatements  ⢠Evaluated whether the structure and the pres-  include:  are likely to arise, whether due to fraud or error,  entation of the Sustainability Statement are in  in the Sustainability Statement.  accordance with ESRS;  ⢠Obtaining an understanding of the Process, but  not for the purpose of providing a conclusion on  In conducting our limited assurance engagement,  ⢠Performed inquiries of relevant personnel and  the effectiveness of the Process, including the  with respect to the Process, we:  analytical procedures on selected information  outcome of the Process;  in the Sustainability Statement;  ⢠Obtained an understanding of the Process by  ⢠Considering whether the information identified  performing inquiries to understand the sources  ⢠Performed limited substantive assurance  addresses the applicable disclosure require-  of the information used by Management; and  procedures on selected information in the  ments of ESRS; and  Sustainability Statement;  ⢠Where applicable, compared disclosures in  the Sustainability Statement with the corre-  sponding disclosures in the Financial State-  ments and Managementâs Review;  ⢠Evaluated the methods, assumptions and data  for developing estimates and forward-looking  information; and  ⢠Obtained an understanding of the Groupâs  process to identify taxonomy-eligible and  taxonomy-aligned economic activities and the  corresponding disclosures in the Sustainability  Statement.  Other matter  The comparative information included in the  Sustainability Statement was not subject to an  assurance engagement. Our conclusion is not  modified in respect of this limitation of scope.  </arr:AuditorsReportOnSubstainabilityReport>
<arr:SignatureOfSubstainabilityAuditorsPlace contextRef="ctx1" id="fact9588" xml:lang="en">Hellerup</arr:SignatureOfSubstainabilityAuditorsPlace>
<arr:SignatureOfSubstainabilityAuditorsDate contextRef="ctx1" id="fact9589">2025-02-19</arr:SignatureOfSubstainabilityAuditorsDate>
<cmn:NameOfAuditFirmSubstainability contextRef="ctx39" id="fact9878" xml:lang="en">PricewaterhouseCoopers Statsautoriseret Revisionspartnerselskab</cmn:NameOfAuditFirmSubstainability>
<cmn:IdentificationNumberCvrOfAuditFirmSubstainability contextRef="ctx39" id="fact9880">33771231</cmn:IdentificationNumberCvrOfAuditFirmSubstainability>
<cmn:NameAndSurnameOfSubstainabilityAuditor contextRef="ctx39" id="fact9881" xml:lang="en">Lars Baungaard</cmn:NameAndSurnameOfSubstainabilityAuditor>
<cmn:DescriptionOfSubstainabilityAuditor contextRef="ctx39" id="fact9882" xml:lang="en">State Authorised Public Accountant</cmn:DescriptionOfSubstainabilityAuditor>
<cmn:fIdentificationNumberOfSubstainabilityAuditor contextRef="ctx39" id="fact9883" xml:lang="en">mne23331</cmn:fIdentificationNumberOfSubstainabilityAuditor>
<cmn:NameAndSurnameOfSubstainabilityAuditor contextRef="ctx40" id="fact9884" xml:lang="en">Kim Tromholt</cmn:NameAndSurnameOfSubstainabilityAuditor>
<cmn:DescriptionOfSubstainabilityAuditor contextRef="ctx40" id="fact9885" xml:lang="en">State Authorised Public Accountant</cmn:DescriptionOfSubstainabilityAuditor>
<cmn:fIdentificationNumberOfSubstainabilityAuditor contextRef="ctx40" id="fact9886" xml:lang="en">mne33251</cmn:fIdentificationNumberOfSubstainabilityAuditor>
</xbrli:xbrl>