Assets

Type	Time	Amount	Unit
ifrs-full:Assets	2024-12-31	87697000000	usd
ifrs-full:Assets	2023-12-31	82578000000	usd

Revenue

Type	Start date	End date	Amount	Unit
ifrs-full:Revenue	2024-01-01	2024-12-31	55482000000	usd
ifrs-full:Revenue	2023-01-01	2023-12-31	51065000000	usd

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   <mrv:SustainabilityReport contextRef="ctx-1" id="s9__8__5-1" xml:lang="en">BUSINESS MODELOur business and  how we create valueA.P. Moller - Maersk is a purpose-driven company. The increasing complexity in global supply chains drives the need for integrated logistics. We aim to fulfil that need by responsibly delivering  better, simpler and more reliable outcomes for our customers. Operational excellence is achieved through the enablers of ESG, Technology and People. Customer and operational synergies are unleashed from the integrated  businesses of Ocean, Logistics &amp; Services and Terminals. See page 18.What we depend onPurpose-driven people and our cultureOur talented, diverse team of 100,000+ employees across around 170 nationalities.Our brandFor over a century, we have built partnerships with customers, enabling them to prosper  by facilitating global trade.Natural resourcesOur business relies on natural resources  such as steel for our assets and fossil fuels  and biomass for conventional and green fuels.Stakeholder relationships  and partnershipsWe rely on constructive relationships  with  customers, suppliers, employees  and  authorities as well as other key stakeholders.Assets and end-to-end delivery networkOur assets, supplier relationships and logistics expertise ensure resilient supply chains.Financial capitalWe have a strong balance sheet and   are committed to remaining investment  grade-rated.Technology and dataTechnology and data are key to connecting  and simplifying supply chains.Value created forOur customersWe aspire to provide truly integrated logistics for 100,000+ customers’ supply chains, while helping them meet their decarbonisation  commitments.Our peopleWe keep our people safe and engaged while offering equitable and interesting career paths.SocietyBy integrating global logistics, we improve  the flow of goods and materials that sustain people, businesses and economies the world over and contribute to improved quality of  life and prosperity.The planetMaersk is a significant emitter of greenhouse gases and we are committed to realising net-zero emissions by 2040.ShareholdersIn our transformation to become the integrator of container logistics, we continue to innovate and grow shareholder value.ESGSBM-1 §40a i-ii SBM-1 §40e-gESG at the centre of Maersk’s Purpose and ValuesMaersk’s ambitious ESG commitments are an integral part of its busi-ness strategy and a prerequisite for success as the global integrator. Building on over a decade of commitment to sustainability progress, Maersk’s ESG strategy charts an ambitious course, with ESG as core to the company’s Purpose and Values. The strategy encompasses Maersk’s material sustainability impacts, risks and opportunities and is centred around three core commitments – taking leadership in the decarboni-sation of logistics, ensuring that our people thrive at work by providing a safe and inspiring workplace and operating based on responsible business practices. These commitments are delivered across 10 ESG categories, each with defined roadmaps and governance.Differentiating by decarbonising customers’ supply chains Maersk sees the growing strategic importance of ESG and sustainabil-ity amongst its customers, with some having increasingly mature and ambitious commitments. Meeting the customers wherever they are on this journey and helping them achieve their ambitious decarbonisation targets is essential to Maersk’s ESG and business strategies. Customers across all regions and segments, particularly those close to end- consumers such as Fashion &amp; Lifestyle and FMCG, also face increasing expectations from their customers to have low-emission supply chains. Maersk proactively collaborates with customers to shape the products, services and technologies that can support their sustainability ambi-tions. This includes ECO Delivery – Maersk’s emissions-reduced product family for Ocean, Inland and Air freight, and Emissions Dashboard  – enabling customers to view and manage their logistics greenhouse gas emissions across all transportation modes.  The company believes that operating based on responsible business practices, being recognised as an ESG leader in external ratings valued by customers and investors, such as EcoVadis and CDP, is a true differentiator.For more details on ESG strategy and performance, see the sustainability  statement, pages 53-135.Composition and diversity of the Board of DirectorsRef. Indicator  Unit 2024GOV-1 §21aNumber of executive members # 0GOV-1 §21aNumber of non-executive members # 10GOV-1 §21bNumber of employees in the company # 2GOV-1 §21ePercentage of independent Board members % 50GOV-1 §21dPercentage of women % 30GOV-1 §21dPercentage of men % 70When considering Board candidates, the Nomination Committee  takes into account the competences of both the potential candidates and the current Board members with regards to ESG-related matters to ensure that the Board as a whole has a relevant level of expertiseTo leverage knowledge on ESG matters, the Board established an ESG Committee in 2023 to focus on strategic ESG-related topics aligned with the overall ESG strategy, including climate change,  safety, diversity, equity and inclusion and business conductIn addition, the Audit Committee oversees sustainability reporting-related matters related to external reporting e.g. in connection with the discussion of A.P. Moller - Maersk’s CSRD double materiality assessment, which increases the Committee members’ expertise  with regards to material impacts, risks and opportunities related  to sustainability. This includes sustain ability reporting, where work to mature our ESG KPIs was undertaken during 2024 with a focus on improving and implementing controls to support completeness and accuracy of reported ESG data. As 2024 is the first year of CSRD reporting, the control environment is less mature than forour financial reporting.This process also includes sustainability reporting risks, including addressing risks of incompleteness and inaccuracy of reported ESG data by ensuring that clear definitions and procedures are in place and that process maps, risks assessments and internal controls have been implemented.including internal controls that are performed by relevant functions in relation to ESG KPIs.The Board of Direc-tors and Audit Committee receive reports from the Executive Board and Group Internal Audit on compliance with the guidelines, including in relation to ESG reporting.investor.maersk.com/governance/policies-and-chartersGOV-1 §21cQualifications Leadership experience within transportation,  infrastructure and investment-related activities.GOV-1 §21cQualifications International experience in general management, sustainability, procurement and supply chain. Insight from a customer’s perspective in both  shipping and broader logistics space.GOV-1 §21cQualifications Experience within the transport and logistics  sector and listed companies. Technical financial skills, knowledge of global business-to- business technology and customer markets.GOV-1 §21cQualifications International experience as CFO and member  of the board of directors of listed companies  within construction.GOV-1 §21cQualifications Experience as CEO and board member of  private equity and industrial companies and with managing and developing a diverse portfolio of businesses operating in different markets.GOV-1 §21cQualifications Captain in Maersk Line since 2011 and Chief  Officer in Maersk Line from 2004-2011.  Technical, maritime and operational knowledge.GOV-1 §21cQualifications Board experience from international listed  technology, chemical, aerospace, transportation, automotive and innovation companies and from  the financial sector. Management experience  from global, listed IT and electric utility companies. Digital transformation and strategy experience.GOV-1 §21cQualifications Experience as global CEO and board member in listed international companies in IT, consumer goods and chemicals. Strong competencies in  digital transformation, leader ship  development, sustainability and global business trends.GOV-1 §21cQualifications Experience as global CEO and board member  in listed international companies in several IT  sectors, at the senior level in a global leader in  digital information and entertainment services and as a partner in a global private equity firm. Strong competencies in digital transformation, leadership development, sustainability and  global business trends.GOV-1 §21cQualifications Knowledge in ship operation, technical  management, future trends and innovation.GOV-1 §21cQualifications Vincent has held various roles in North America and Copen hagen. In December 2015, Vincent was appointed Chief Commercial Officer in Maersk Line before being appointed as member of the Executive Board as Chief Commercial Officer of Maersk in 2017. In December 2019, Vincent Clerc was appointed CEO of Ocean &amp; Logistics at Maersk.GOV-1 §21cQualifications Before joining Maersk, Patrick was CFO  and member of the Executive Committee in  Clariant AG, Switzerland. Prior to his role as CFO, Patrick held several leadership positions within finance, general management and corporate  development in Clariant in Germany, Mexico,  Singapore, Indonesia and Spain.Sustainability statementGeneral disclosuresEnvironmental disclosuresSocial disclosuresGovernance disclosuresMethanol-capable vessels and the fuels to sail themIn 2024, Maersk took delivery of seven new large dual-fuel methanol vessels, including Antonia Mærsk, shown here in Aarhus, Denmark. She was christened by our customer Vestas, a Danish sustainable energy solution producer. While the vessel technology to decarbonise ocean transport is readily available, the biggest challenge is securing the green fuels for these ships. Maersk signed additional offtake agreements in 2024 and has secured more than half of the projected 2027 demand for its new vessels.ESRS 2Basis of preparationIn 2024, for the first time, A.P. Moller - Maersk (Maersk) has prepared the sustainability  statement in accordance with the EU Corporate Sustainability Reporting Directive (CSRD)  and its underlying European Sustainability Reporting Standards (ESRS). Maersk’s reporting on sustainability and ESG focuses on material sustainability matters and activities and encompasses areas where Maersk may have the largest impact on people and planet through our activities, or where Maersk is exposed to the most significant financial risks or opportunities. The materiality of sustainability matters and topics is determined based on the application of a double materiality assessment (DMA) principle. The results of the DMA have shaped the content of the sustainability statement. Scope and consolidationUnless otherwise stated, the ESG performance data and information included in the sustainability statement are reported based on the same consolidation principles as the financial statements. Thus, the ESG performance data include consolidated data from the parent company, A.P. Møller - Mærsk A/S, and subsidiaries controlled by A.P. Møller - Mærsk A/S. Similarly, unless otherwise stated, our policies apply to all Maersk entities, employees and everyone  working under Maersk’s control. Data is collected per legal entity and per activity, and the figures are consolidated line-by-line. Consolidation of ESG  performance data using financial scope implies that data from the  following assets are included:•  Owned assets that Maersk financially owns and that are  operated by Maersk•  Long-term leased-in assets that Maersk treats as capital assets  and that are treated as such on Maersk’s balance sheet in accordance with IFRS 16• Leased-out assets that Maersk treats as wholly owned  assets in financial accounting and that are treated as such on  Maersk’s balance sheet (i.e. short-term leased-out assets to  third parties).For entities and assets that are under Maersk’s operational control but not consolidated under the parent company and its subsidiaries, the above financial consolidation principles differ. Operational control is defined as the situation where Maersk or one  of its subsidiaries has full authority to introduce and implement its operating policies at the entity (i.e. operationally controlled investees  in e.g. associates, joint ventures or unconsolidated subsidiaries).  Operational control is determined by looking at the contractual arrangements to determine whether Maersk has full authority to  introduce and implement its operating policies.  Data from divestments is included until the divestment date.  Data from Svitzer, which was demerged during 2024, is included  up until the demerger date of 26 April 2024.  This report covers the full upstream and downstream value chain based on the outcome of the DMA.Uncertainties and estimatesPreparation of ESG performance data requires Management to make estimates in some areas, which affect the reported data. Management forms its estimates based on historical experience, independent advice, external data points, in-house specialists and other information believed to be reasonable under the cir-cumstances. Read more about uncertainties and estimates in the accounting policies relating to the ESG performance data. To minimise risks of reporting errors in relation to ESG perfor-mance data, including areas with uncertainty, internal controls and validation processes are established.Page Key accounting estimates  Estimate / Impactand judgementsJudgement91 Categorisation of emissions  Judgementfrom short-term leases between  scope 1 and scope 390 GHG emissions from upstream  Estimatetransportation and distribution  activity estimates108 Waste estimates Estimate124 Average working hours estimate used Estimateto calculate gender pay gap124 Annual total remuneration  Estimateestimates125 Exposure hours estimates used  Estimatewhen preparing the lost time  incident frequencyLevel of potential impact to the reported data:LowMediumHighChanges affecting the ESG performance data in 2024In 2024, Maersk reports for the first time in accordance with the CSRD and the disclosure requirements outlined in the ESRS. Thus, for 2024, we have, in addition to previously reported KPIs, included new ESRS- related datapoints that have been deemed material as part of Maersk’s DMA in the relevant ESG performance data sections of the sustainabil-ity statement. This includes: Environment •  Percentage of scope 1 greenhouse gas (GHG) emissions from  regulated emissions trading schemes•  Renewable energy production•  Maersk top 5 sites at material risk of physical climate change•  Operating expenditures (OPEX) in conjunction with major  incidents and deposits•  Total weight of procured steel Social •  Average number of employees•  Number of employees by gender•  Number of employees by contract type by gender•  Number of employees by contract type by region•  Number of employees by country•  Number of employees who left the company•  Total employee turnover•  Employees by age group•  Gender pay gap•  Annual total remuneration ratio (CEO pay ratio)•  Employees paid below the applicable adequate wage benchmark•  Number of lost time incidentsGovernance•  Number of convictions for violation of anti-corruption and  anti-bribery laws•  Amount of fines for violation of anti-corruption and anti-bribery laws•  Number of legal proceedings outstanding for late paymentsThroughout the sustainability statement, the references used in ESG performance data tables are based on the EFRAG data point list ID’s. In 2024, we report our progress towards validated science-based targets, which are our main climate KPIs and targets towards 2030 and 2040. Consequently, we have discontinued reporting on segment-specific  climate targets, including for Terminals, reduction of absolute scope 1 and 2 emissions by 2030 (2020 baseline), and for Ocean, share of freight transported on green fuels.  In 2024, we have revised our definition of operationally controlled entities and joint ventures. With the introduction of a clear definition for operational control in ESRS, which is based on whether a company has full authority to introduce and implement its operating policies  at the entity as stated in the contractual agreement, Maersk has aligned its definition accordingly, which has resulted in an insignificant adjustment.  We have made a number of other restatements to the 2023 numbers owing to improvement of reporting processes and data quality. Most notably, we made a correction to scope 1 emissions, as refrigerant  emissions had been overstated in 2023. The correction has led to a restatement of scope 1 emissions of 1.7m tonnes CO2e or approximately  a 5% reduction of total scope 1 emissions for 2023. ESRS 2Incorporation by referenceThe table below provides an overview of where information can be found relating to ESRS disclosures that have been incorporated by reference and stated outside of the sustainability statement as part of other sections of this Annual Report or in the Remuneration Report.Disclosure requirements incorporated by referenceDisclosure  Data  Paragraph Pagerequirementpoint(s)Number of executive and non-executive members  GOV-1§21aCorporate governance 47of the Board of DirectorsGOV-1§21b Employee representatives on the Board of Directors Corporate governance 47§21d, GOV-1Diversity of the Board of Directors Corporate governance 47§23a-bGOV-1§21e Percentage of independent Board of Directors members Corporate governance 47§23a-b, GOV-1Information on Board competences,  47§5b, Corporate governanceG1.GOV-1skills and relevant experience50-51§21c, §17Material impacts, risks and opportunities addressed  GOV-2§26cCorporate governance 47by the Board of DirectorsGOV-5§36a-e Information on risk management and controls Corporate governance 48§27, GOV-3§29a-eInformation on sustainability-linked remunerationRemuneration reportE1.GOV-3§13S1-16§97b The annual total remuneration ratio (the CEO pay ratio) Remuneration report§42, SBM-1Business model and value chain Business model 13§42a-b§40a i-ii,  Business strategy and products/services linkage  SBM-1Strategy 1940e-gto sustainability mattersConsolidated financial SBM-1§40b Total revenue by significant sectors147statements, note 2.1Consolidated financial SBM-1§40d-i Revenue derived from fossil fuel activities147statements, note 2.1Disclosure requirements covered by Maersk’s Annual Report 2024The table below provides an overview ESRS datapoints that derive from other  EU legislation and where this information can be found if deemed material.General disclosuresESRS disclosure requirementSection/report PageGeneral disclosuresBP-1General basis for preparation of the sustainability statement Basis of preparation 54BP-2Disclosures in relation to specific circumstances Basis of preparation  55Corporate governance 47The role of the administrative, management and  GOV-1supervisory bodiesESG governance model 64-65Information provided to and sustainability matters addressed  Corporate governance 47GOV-2by the undertaking’s administrative, management and  supervisory bodiesESG governance model 64-65Integration of sustainability-related performance  GOV-3Remuneration reportin incentive schemesGOV-4Statement on due diligence Approach to due diligence 69Risk management and internal controls over sustainability  GOV-5Corporate governance 48reportingBusiness model 13Strategy 19Consolidated financial  147SBM-1Strategy, business model and value chainstatements, note 2.1Social performance data 119Double materiality assessment: 68value chain mappingSBM-2Interests and views of stakeholders Stakeholder engagement 70-74ESG strategy 62-63Material impacts, risks and opportunities and their interac-66-67SBM-3tion with strategy and business model77Double materiality assessment110127 Description of the process to identify and assess material  Double materiality assessment IRO-168impacts, risks and opportunitiesmethodologyDouble materiality assessment 68Disclosure requirements in ESRS covered by the undertaking’s methodologyIRO-2sustainability statementIndex tables 57-59 Environment ESRS disclosure requirementSection/report PageClimate changeIntegration of sustainability-related performance  E1.GOV-3Remuneration reportin incentive schemesE1-1Transition plan for climate change mitigation Climate change 79Climate change 77-88Material impacts, risks and opportunities and their  E1.SBM-3interaction with strategy and business model66-67Double materiality assessment77Description of the processes to identify and assess material  Double materiality assessment E1.IRO-168climate-related impacts, risks and opportunitiesmethodologyE1-2Policies related to climate change mitigation and adaptation Climate change 78-88E1-3Actions and resources in relation to climate change policies Climate change 78-88E1-4Targets related to climate change mitigation and adaptation Climate change 79E1-5Energy consumption and mix Climate change performance data 89-100E1-6Gross scopes 1, 2, 3 and Total GHG emissions Climate change performance data 89-100Embedding the transition  E1-8Internal carbon pricingplan into business strategy81-82and financial planningAnticipated financial effects from material physical and  E1-9Climate change 88transition risks and potential climate-related opportunitiesPollutionDouble materiality assessment 68Description of the processes to identify and assess material  methodologyE2.IRO-1pollution-related impacts, risks and opportunitiesStakeholder engagement 70-74E2-1Policies related to pollution Environment and ecosystems  101-106E2-2Actions and resources related to pollution Environment and ecosystems  101-106E2-3Targets related to pollution Environment and ecosystems  101-106E2-4Pollution of air, water and soil Environmental performance data 107-108Anticipated financial effects from pollution-related impacts, E2-6Environment and ecosystems 107risks and opportunitiesESRS disclosure requirementSection/report PageBiodiversity and ecosystemsDouble materiality assessment Description of processes to identify and assess material  68methodologyE4.IRO-1biodiversity and ecosystem-related impacts, risks and  opportunitiesStakeholder engagement 70-7477Environment and ecosystemsMaterial impacts, risks and opportunities and their  101-106E4.SBM-3interaction with strategy and business modelDouble materiality assessment66-67Transition plan and consideration of biodiversity  E4-1Environment and ecosystems 101-106and ecosystems in strategy and business modelE4-2Policies related to biodiversity and ecosystems Environment and ecosystems 101-106E4-3Actions and resources related to biodiversity and ecosystems Environment and ecosystems 101-106E4-4Targets related to biodiversity and ecosystems Environment and ecosystems 101-106Impact metrics related to biodiversity and ecosystems E4-5Environment and ecosystems 101-106changeResource use and circular economyDouble materiality assessment 68Description of the processes to identify and assess material  methodologyE5.IRO-1resource use and circular economy-related impacts, risks andStakeholder engagement 70-74E5-1Policies related to resource use and circular economy Environment and ecosystems 101-106Actions and resources related to resource use and circular  E5-2Environment and ecosystems 101-106economyE5-3Targets related to resource use and circular economy Environment and ecosystems 101-106E5-4Resource inflows Environmental performance data 107-108E5-5Resource outflows Environmental performance data 107-108 SocialESRS disclosure requirementSection/report PageOwn workforceS1.SBM-2Interests and views of stakeholders Stakeholder engagement 70-74Our workforce 110-113Material impacts, risks and opportunities and their  S1.SBM-366-67interaction with strategy and business modelDouble materiality assessment 110 127Our workforce  111-118S1-1Policies related to own workforceGrievance and remedy 73-74Processes for engaging with own workforce and workers’  S1-2Stakeholder engagement 70-74representatives about impactsProcesses to remediate negative impacts and channels  S1-3Grievance and remedy 70-74for own workforce to raise concernsTaking action on material impacts on own workforce, and  Our workforce  111-118approaches to managing material risks and pursuing material S1-4opportunities related to own workforce and effectiveness  Grievance and remedy 70-74of those actionsTargets related to managing material negative impacts,  S1-5advancing positive impacts and managing material risks  Our workforce  111-118and opportunitiesS1-6Characteristics of the undertaking’s employees Social performance data 119-125S1-9Diversity metrics Social performance data 119-125S1-10Adequate wages Social performance data 119-125S1-14Health and safety metrics Social performance data 119-125S1-16Remuneration metrics (pay gap and total remuneration) Social performance data 119-125S1-17Incidents, complaints and severe human rights impacts Grievance and remedy 73-74ESRS disclosure requirementSection/report PageWorkers in the value chainS2.SBM-2Interests and views of stakeholders Stakeholder engagement 70-74Our workforce 110-113Material impacts, risks and opportunities and their  S2.SBM-366-67interaction with strategy and business modelDouble materiality assessment 110 127Sustainable procurement 130-131S2-1Policies related to value chain workersGrievance and remedy  73-74S2-2Processes for engaging with value chain workers about impacts Stakeholder engagement 70-74Processes to remediate negative impacts and channels  S2-3Grievance and remedy 73-74for value chain workers to raise concernsTaking action on material impacts on value chain workers, Sustainable procurement 130-131and approaches to managing material risks and pursuing  S2-4material opportunities related to value chain workers,  Grievance and remedy 73-74and effectiveness of those actionsTargets related to managing material negative impacts,  S2-5advancing positive impacts and managing material risks  Sustainable procurement 130-131and opportunitiesAffected communitiesS3.SBM-2Interests and views of stakeholders Stakeholder engagement 70-7466-67Material impacts, risks and opportunities and their  S3.SBM-3Double materiality assessment77interaction with strategy and business model127 Grievance and remedy 73-74Approach to human rights 112-113S3-1Policies related to affected communitiesClimate change 78-88Environment and ecosystems 101-106Business ethics 129Processes for engaging with affected communities  S3-2Stakeholder engagement 70-74about impactsProcesses to remediate negative impacts and channels  S3-3Grievance and remedy 73-74for affected communities to raise concernsGrievance and remedy 73-74Taking action on material impacts on affected communities,  Approach to human rights 112-113and approaches to managing material risks and pursuing  S3-4Climate change 78-88material opportunities related to affected communities,  and effectiveness of those actionsEnvironment and ecosystems 101-106Business ethics 129  GovernanceESRS disclosure requirementSection/report PageBusiness conductESG governance model 64-65The role of the administrative, supervisory and  G1.GOV-1management bodiesCorporate governance 47Description of the processes to identify and assess  Double materiality assessment G1.IRO-168material impacts, risks and opportunitiesmethodologyResponsible business conduct 128-132G1-1Business conduct policies and corporate cultureGrievance and remedy 73-74G1-2Management of relationships with suppliers Sustainable procurement 130-131G1-3Prevention and detection of corruption and bribery Business ethics 129G1-4Incidents of corruption or bribery Governance performance data 134G1-5Political influence and lobbying activities Political engagement 71-72G1-6Payment practices Sustainable procurement 130-131Disclosure requirements that derive from other EU legislationThe table below provides an overview ESRS data points that derive from other EU legislation,  cf. ESRS 2 Appendix B and where this information can be found if deemed material.General disclosuresESRS data pointInformation Regulation PageGeneral disclosuresGOV-121 (d) Board’s gender diversity ratio SFDR 47GOV-121 (e)  Percentage of independent Board members SFDR 47GOV-430 Statement on due diligence SFDR 69SBM-140 (d) i Activity in fossil fuel sector SFDR 147Activity in chemical, controversial weapons  SBM-140 (d) ii - 40 (d) ivSFDR N/Aand/or tobacco industry  EnvironmentESRS data pointInformation Regulation PageClimate changeE1-114 Transition plan for climate change mitigation EU Climate Law 79Pillar 3,  E1-116 (f) Exclusion from EU Paris-aligned BenchmarksBenchmark N/AregulationSFDR, Pillar E1-434 (a) - 34 (b) Emission reduction targets3, Benchmark 79regulationE1-537 (a) (c) Energy consumption from fossil and renewable sources SFDR 94E1-537 (b) Energy consumption from nuclear sources SFDR N/AFuel consumption from coal and coal products and  E1-538 (a) (b)SFDR N/Afrom crude oil and petroleum productsE1-538 (c) (d) Fuel consumption from natural gas and other fuel sources SFDR 94Consumption of purchased or acquired electricity,  E1-538 (e) SFDR 94heat, steam or cooling from fossil sourcesEnergy consumption and intensity from activities  E1-540-43SFDR 94in high-climate-impact sectorsESRS data pointInformation Regulation PageSFDR, Pillar 3, E1-648-52 Scope 1, scope 2 and scope 3 emissions89BenchmarkSFDR, Pillar E1-653, 55 GHG emission intensity3, Benchmark 92regulationE1-756 GHG removals and stage EU Climate Law N/AE1-966 Assets at material financial risk Pillar 3 88Carrying amount of real estate assets by energy  E1-967 (c) Pillar 3 Phased inefficiency classesFinancial opportunities (cost savings, market size and Benchmark E1-969Phased inchanges to net revenue) from climate change actionsregulationPollutionE2-428 (a) Emissions to air, water and soil SFDR 107Water and marine resourcesE3-111, 13, 14, 28(c)All disclosures SFDR N/AE3-4(e), 29Biodiversity and ecosystemsActivities in biodiversity-sensitive areas, impacts related  E4.SBM-316 (a) (b) (c) to land degradation, desertification and soil sealing,  SFDR 101-106and operations affecting threatened speciesPolicies on sustainable land or agriculture practices,  E4-224 (b) (c) (d)sustainable oceans and sea practices, and deforestation SFDR 101-106practicesResources use and circularityE5-511, 13, 14 Non-recycled waste SFDR N/AE5-528 (c) (e)  Hazardous waste SFDR 108E5-529 Radioactive waste SFDR N/A SocialESRS data pointInformation Regulation PageOur workforce11 (b) Geographies or commodities with risk of forced labour  SFDR 110S1.SBM-311 (b) Geographies or commodities with risk of child labour SFDR N/AS1-120 (a) General approach to human rights SFDR 112-113S1-120 (b) General approach to engagement with own workforce SFDR 70-74Approach and availability of grievance and remedy  S1-1, S1-320 (c), 32 (c)SFDR 73-74in regards to own workforcePolicies are aligned with internationally recognised  S1-121SFDR 111-118instrumentsPolicies addressing human trafficking, forced labour  112-113  S1-122SFDRand child labour118S1-123 Policies on accident prevention SFDR 116-117SFDR,  S1-1697 (a) - 97 (b) Gender pay gap, annual total remunerationBenchmark 124regulationS1-17103 (a) Incidents of discrimination SFDR 74SFDR,  S1-17104 (a) Severe human rights issues and incidentsBenchmark 74regulationWorkers in the value chain11 (b) Geographies or commodities with risk of forced labour  SFDR 110S2.SBM-311 (b) Geographies or commodities with risk of child labour SFDR N/AHuman rights policy commitments and approach related  S2-117 (a), 19to value chain workers, aligned with internationally  SFDR 112-113recognised standardsS2-117 (b) General approach to engagement with value chain workers SFDR 70-74S2-117 (c)  Approach to remedy for human rights impacts SFDR 73-74Policies explicitly addressing forced labour and child  112-113 S2-118, 19SFDRlabour, aligned with internationally recognised standards118S2-118 Undertaking has a supplier code of conduct SFDR 130-131SFDR,  Severe human rights issues and incidents connected  S2-419, 36Benchmark 74to value chain workersregulationESRS data pointInformation Regulation PageAffected communitiesHuman rights policy commitment to affected  SFDR,  commu nities, whether policies are aligned with S3-116, 17Benchmark 112-113internationally recognised instruments, and general  regulationapproach to human rights of communitiesS3-116 (b) Approach to engagement with affected communities SFDR 70-74Approach to remedy in regard to human rights impacts  S3-116 (c) SFDR 73-74for affected communitiesSevere human rights issues and incidents connected  S3-436SFDR 74to affected communities Consumers and end-usersSFDR,  S4-116 (a) (b) (c),  All disclosuresBenchmark N/AS4-417, 35regulation  GovernanceESRS data pointInformation Regulation PageStatement if no policies exist in regard to anti-corruption  G1-110 (b) (d)SFDR N/Aand bribery and to protection of whistleblowersNumber of convictions and amount of fines for violations  G1-424 (a)SFDR 134of anti-corruption and bribery lawsESRS 2, ESRS - G1ESG strategy  and governanceGeopolitical tensions, a heightened focus on social issues and impacts of climate-related weather events were among the key external trends 2024. In response to increasing regulatory require-ments and further maturing of its strategy, A.P. Moller - Maersk (Maersk) has reviewed and streamlined its ESG priorities.ESG in the light of emerging global trendsGeopolitical tensions continued to reshape trade and logistics in 2024 as the majority of the world’s shipping lines diverted traffic on Asia- Europe trade routes around the Cape of Good Hope in Africa to avoid attacks in the Red Sea. In addition to longer voyages, which directly increase greenhouse gas (GHG) emissions, this situation led to port congestion, cargo delays and a greater reliance on higher-emission transport modes. As geopolitical tension is slowing down the green transition, inflationary pressures and the continued price differential between fossil and green fuels continue to create challenges to our customers’ commitments and their capacity to decarbonise.  A notable climate change impact in 2024, continuing a pattern from previous years, is the sharp increase in the frequency and severity of extreme weather events including record floods, droughts, heatwaves and wildfires. This also poses disruption risks to global supply chains. It is likely that these events will continue in 2025, and therefore climate change remains both a risk and a strategic topic for Maersk. Severe weather has also created a greater need for Maersk to support commu-nities with critical humanitarian aid during 2024.  The increase of geopolitical tensions and armed conflict is also driving a greater focus on societal issues for Maersk and its customers. This has increased the need for a heightened focus on the due diligence processes for human rights, trade controls, sanctions screening and export com-pliance to identify and manage risks when operating in conflict zones. Supply chain digitalisation and increased automation is both a risk and a prerequisite for the integrated logistics strategy. Generative AI is also transforming the industry, highlighting the importance of an ethical use of data and artificial intelligence, where we are trusted in the use of our customers’ and other stakeholders’ data while auto-mating internal processes.   In addition, it is crucial that we keep our workforce in mind in the automation of warehouses and terminals. While increasing accessibil-ity of automation technologies creates opportunities for decarbonis-ing our Logistics &amp; Services and Terminals segments, we also need to invest in upskilling our workforce to maintain and attract critical tal-ents and to ensure safe operations with new technologies.   Worker rights were particularly highlighted in 2024, as dockworker strikes in the US, Canada and the UK, some lasting only a few days, caused knock-on supply chain ripples. Maersk actively works to ensure good and fair working conditions for our workforce and focuses on engaging with our employees or their representatives on complex top-ics such as automation and fair wages.   The current geopolitical tensions and challenges are expected to continue into 2025. Against this complex and uncertain backdrop, Maersk will continue progressing all three of the core commitments of its ESG strategy in 2025. ESG strategy Building on over a decade of commitment to sustainability progress, Maersk’s ESG strategy charts an ambitious course and establishes ESG as core to our Purpose and Values, critical to the success of our inte-grated logistics strategy, and a differentiator in the value we create for our customers.   The strategy encompasses the material sustainability impacts, risks and opportunities for Maersk and is centred around three core commit-ments, each with supporting governance, KPIs and targets. These com-mitments represent issues where Maersk’s position, scale and reach can create the most significant impact, which in turn defines our ambi-tion level in specific ESG categories.   In 2024, we reviewed our ESG priorities to better reflect market and business changes since the 2021 launch of our ESG strategy. The updated strategy with a finetuning of our priorities is informed by the double materiality assessment (DMA) aligned with the EU Corpo-rate Sustainability Reporting Directive (CSRD), our understanding of stakeholder expectations and taking inspiration from globally recog-nised reporting frameworks and ESG benchmarks.  As part of the review and streamlining of our ESG strategy frame-work and priorities, the categories relating to Governance and Sustain-able and Inclusive Trade have been recategorised as an enabler and an outcome, respectively, of our ESG strategy.   The 2024 strategy update sets out a prioritisation of our material ESG categories into three levels, strategic with the highest level of focus, followed by prioritised and foundational. For strategic categories, we set the highest ambition for Maersk’s performance being a differentiator and impact driver. These topics are also tied to executive remuneration as part of the long-term incentive programme. Read more in the Remuneration Report.Our prioritised ESG categories represent areas which are also closely connected to the impact we have on society, the risks to our business and where we have identified a higher degree of responsibility for acting. Together, the strategic and prioritised categories correspond to our strategic ESG targets. Both have high levels of internal governance and reporting processes, with progress on targets tracked and reported to Executive Leadership Team quarterly.Our foundational ESG categories represent topics which are essen-tial to our business and are a license to operate. Progress is governed through the wider corporate governance framework, Commit, and accountability resides with functional teams and executive sponsors.As external measures of progress on our ESG strategy, we engage with select ESG rating providers to help us improve and track perfor-mance across the most material ESG aspects. ESG ratings are also a source of insight on stakeholder expectations, and our submissions are valued by customers and investors. We have prioritised those that are most material to our stakeholders and aligned them with our priorities, including EcoVadis, CDP, MSCI and Sustainalytics.Maersk ESG strategyESG core commitmentsEnvironment We will take leadership in the  decarbonisation of logisticsSocialWe will ensure that people  thrive at work by providing  a safe and inspiring workplaceGovernanceWe operate based on responsible business practicesThree levels of priorityStrategic  categoriesClimate changeSafetyDiversity, equity and inclusionPrioritised  categoriesHuman capitalBusiness ethicsSustainable procurementData ethicsFoundational  categoriesEnvironment and ecosystemsHuman rightsEmployee relations and labour rightsCitizenshipResponsible taxESG governance model Responsibility for ESG and sustainability is anchored with Maersk’s Board of Directors, who endorse the overall ESG strategy.   At the Board level, three committees are responsible for ESG-related aspects as reflected in the committee charters:   The ESG Committee’s primary purpose is to oversee our strategic ESG direction, acting as a sounding board for the Executive Leader-ship Teams (ELT) and supporting the Board of Directors with strategy insights into specific ESG matters. The committee meets quarterly to discuss selected ESG topics throughout the year. The ESG Committee also approves the ESG KPIs that are part of the executive remuneration long-term incentive programme.  The Audit Committee oversees external ESG reporting, data quality and internal controls.  The Remuneration Committee reviews the sustainability- linked  targets, proposed by the ESG Committee as part of the long-term incentive programme for the Executive Leadership Team. Read more in the Remuneration Report.   At the executive level, dedicated sponsors are allocated to Maersk’s material ESG categories. This sponsorship includes driving initiatives forward and accountability to the full ELT and the Board of Directors for the development of and delivering on targets and policies. Respon-sibility for executing on the ESG strategy resides with the dedicated teams within relevant functional areas reporting to the respective ELT sponsors. Risk and Compliance CommitteeThe Risk and Compliance Committee (RCC) is the main executive  governance forum for ESG as well as other key risk and compliance processes and topics across Maersk, including our internal Commit governance framework (description below) and the enterprise risk management (ERM) process. The RCC charter was updated during  2024 with a view to strengthening central governance across the strategic ESG categories (climate, safety and DE&amp;I), anchored with the RCC. To facilitate oversight and support decision making for strategic dilemmas and risks through the year, ESG progress updates are compiled quarterly for strategic and prioritised targets and KPIs and biannually across all ESG categories.  ESG governance in A.P. Moller - Maersk in 2024Board committeesESG relevant •  ESG Committee•   Audit  Committee•   Remuneration   CommitteeBoard of DirectorsEndorses ESG strategyExecutive Leadership TeamDefines ESG strategy and oversees implementationELT committeesESG relevant •  Risk and Compliance Committee•   Investment   CommitteeKey corporate functions (cross-category)Strategy | Corporate sustainability | FinanceFacilitates ESG strategy and oversight, guides and enables category ownersCategory-specific governanceEnvironmentClimate changeRabab Boulos, Chief Operating OfficerEnergy transitionEnvironment and ecosystemsRabab BoulosSafety and resilience    ELT sponsor  Responsible departmentGovernanceBusiness ethicsCaroline PontoppidanComplianceSustainable procurementRabab BoulosAsset strategyResponsible taxPatrick Jany, Chief Financial OfficerTaxCitizenshipCaroline PontoppidanSustainabilityData ethicsNavneet Kapoor, Chief Technology and Information OfficerTechnology SocialHuman capital Susana Elvira, Chief People OfficerPeople functionDiversity, equity and inclusionSusana ElviraPeople functionHuman rightsCaroline Pontoppidan, Chief  Corporate Affairs Officer SustainabilityEmployee relations and rightsSusana ElviraPeople functionSafety and security Rabab BoulosSafety and resilienceThese updates, as well as deep dives into strategic ESG categories and regulatory developments are overseen at the quarterly meetings of the RCC and subsequently, if relevant, discussed with the full ELT.   On an operational level, cross-functional steering committees and working groups facilitate coordination, ensuring that relevant func-tional and business areas are included in strategic decisions and sup-porting implementation across business areas.ESG integration in governance and risk frameworksIn addition to the dedicated ESG governance model outlined  above, ESG topics are also integrated into other internal governance processes, including Commit, Maersk’s governance framework  (see box on the right). ESG is integrated into Commit through the Code of Conduct and  specific Commit rules in relation to health, safety, security and envi-ronment (HSSE), global employee relations, anti-corruption, sustain-able procurement as well as data privacy and data ethics. Each rule has a designated owner in the organisation who is responsible for compliance. Progress oversight on implementation and compliance is performed on an ongoing basis through impact and risk assessment such as self- assessment performed for the Global Employee Relations Rule, com-pliance checks for the Anti-corruption Rule and site inspections for the HSSE Rule. Executive oversight of compliance with Commit is managed through the annual internal assurance process, anchored with the RCC.   In addition, the ERM process also incorporates ESG-related risks as part of the annual risk assessment covering the entire business and overseen by the RCC and the Audit Committee. Managing inorganic changes to the organisationAcquisitions are important to Maersk’s integrated logistics strategy, especially as we look to add capacity and expertise in areas like  project logistics and e-commerce to our global portfolio and local coverage. Although we did not make any acquisitions in 2024, ESG considerations remained an active part of our due diligence processes in evaluating potential opportunities during the year.   To ensure that all inorganic growth targets are aligned with our ESG strategy and commitments, we continue strengthening due diligence processes by incorporating ESG risk assessments more systematically into our mergers and acquisitions (M&amp;A) process. We regularly engage with and perform specific trainings for the M&amp;A teams with a view to further embed ESG priorities and climate change impact assessments into the due diligence and investment decision processes.   In 2024, Maersk completed the demerger of Svitzer. In alignment with our accounting policies, ESG data from Svitzer for 2024 is included until the date of demerger.The three core  elements of CommitMaersk’s internal governance framework Our Commit governance framework sets the  foundation for how we work in Maersk to ensure  compliance with relevant laws, regulations and  responsible business conduct, as well as having  adequate risk mitigation. The framework is  structured around three core elements:Our guiding Core Valueshave been shaped and strengthened since our foundation in 1904. These were updated in 2022 to ensure that they are consistently interpreted, easy to apply and have a strong connection to our Purpose. Read more on Maersk.com.Our Code of Conduct sets global standards for how we engage with  colleagues, customers, suppliers, communities,  authorities and other stakeholders. The Code of Conduct was updated in 2022 to align with  our Purpose and ESG strategy.21 rules of business ethics,  governance and authority are included in the governance framework,  providing detailed internal instructions for all  employees covering high-risk areas. These are  subject to internal controls and an annual  internal assurance process.ESRS 2, ESRS - S1, S2, S3Double materiality  assessment A.P. Moller - Maersk (Maersk)’s ESG strategy and reporting  is grounded in a double materiality assessment (DMA) aligned  with the ESRS requirements.In 2024, we updated our corporate-level DMA. The assessment is approved by the ELT sponsors and endorsed by the Audit Committee.  In the coming years, we will continue working towards further maturing and refining our assessment in line with best practices and new guid-ance across our ESG topics.  The impacts, risks and opportunities (IROs) identified as material to Maersk’s operations and value chain have been mapped against the disclosure requirements listed in the topical European Sustainability Reporting Standards (ESRS) to identify material information for 2024 reporting. For material IROs already covered by a topical standard, we disclose information listed in the ESRS. For additional entity-specific topics, we have applied the minimum disclosure requirements as a foundation for reporting on policies, actions, targets and metrics.  For the index of information covered by this sustainability statement, see pages 57-59.Maersk’s material topicsThe updated DMA assessment has not led to any significant change to our overall ESG categories but did result in changes to the material topics that are part of the ESG categories. For example, where we have previously been tracking and externally reporting on water use in our operations, the more in-depth assessment performed in the DMA showed that water use is important but not material to Maersk.   Our material ESG topics comprise further sub-topics driven by the impacts, risks and opportunities identified. The IROs under each of the topics are unfolded in the Environmental, Social and Governance  sections of this report. This includes 29 individual IROs.  Climate change remains a key material category to Maersk from an impact and financial perspective. We have identified two major climate- related risks: transitional and physical. Climate transition risk has been part of our enterprise risks for several years. For the assess-ment physical impact of climate change to our assets, our double materiality assessment has been informed by an in-depth assessment of the physical impact of climate change to our assets across multiple time horizons.  For environment and ecosystems, in 2024 we conducted an assess-ment of nature-related issues using the Taskforce on Nature-related Financial Disclosures (TNFD) LEAP assessment approach, resulting in  a number of changes from our 2023 assessment including a more granular overview of IROs across our operation and value chain (read more on page 77). Based on the LEAP assessment, we have identified IROs related to five material sub-topics: pollution, ecosystem health and biodiversity, waste management, responsible ship recycling and the sourcing of critical resources.  Environmental topics that are financially material to Maersk are mainly driven by a risk of non-compliance to environmental regulations or related to remediation costs towards environmental incidents. Costs related to such environmental incidents are disclosed in the Environ-ment performance data section.   For social topics, the assessment has confirmed that human capi-tal, diversity, equity and inclusion, employee relations and labour rights and safety and security are material categories to Maersk. Most mate-rial topics under these categories are material from an impact perspec-tive, however, remediation costs and reputational damage is assessed as also being a material risk to Maersk. Additionally, attraction and retention of critical talents have been deemed financially material as  a key enabler to delivering on our business strategy.  While human rights are included as a category in our ESG strategy, they are not called out as standalone IROs in the DMA. This is because human rights issues are integrated across the existing environmental, social and governance topics. The same is the case for impact to affected communities, where impacts on people in local communi-ties can occur across our operations and activities. As an example, greenhouse gases can impact people’s livelihood and wellbeing, and corruption can exacerbate inequalities in societies where we operate. On governance, the assessment also reconfirmed our existing catego-ries on business ethics, sustainable procurement, data and AI ethics and responsible tax. The last two categories are not currently covered by the topical ESRS and are therefore entity- specific. Of the material topics, several risks related to costs of non-compliance to regulations have been deemed material to Maersk, including related to corruption laws, sanctions and transportation of illegal goods. In addition, risks related to data and AI ethics and supplier non-compliance have been assessed as material to our overall strategy.   Of the material risks, none are expected to cause material adjust-ments to carrying amounts of liabilities reported in the financial state-ments in the next annual reporting period.  Recognising our global presence and the nature of our business  as an integrator of global supply chains, this is not an exhaustive list, however, it shows where Maersk may have the largest impacts on  people and planet through our activities, or where Maersk is exposed to the most significant financial risks or opportunities. Many of the topics below the threshold for external reporting are still actively monitored and managed as part of internal processes. As an example, while water use was deemed below the materiality threshold and not covered by our sustainability statement, we continue to actively monitor and work to reduce consumption of water globally, particularly in water-stressed areas. The same is the case for impacts to communities in areas where we operate, where we continue to monitor potential negative impacts and regularly engage with communities as part of e.g. Environmental and Social Impact Assessments (ESIAs), and through local Corporate Social Responsibility (CSR) initiatives under our citizenship programme.OVERVIEW OF MATERIAL TOPICSEnvironment Overview of our material categories and topics  related to EnvironmentClimate change  Climate change mitigationClimate change adaptionEnvironment and ecosystemsPollutionEcosystem health and biodiversityWaste managementResponsible ship recyclingSourcing of critical resourcesSocialOverview of our material categories and topics  related to SocialHuman capital Attracting and retaining critical talentDiversity, equity and inclusionHarassment of vulnerable groupsDiscrimination in the workforceSafety and securitySafety of our workforceExposure to global/local security risksEmployee relations and labour rightsForced labourWorking hours and adequate wagesAdequate housing and sanitationGovernanceOverview of our material categories and topics  related to GovernanceBusiness ethics Legal and regulatory complianceGrievance and remedy Sustainable procurementSupplier relationship managementPayment practicesData and AI ethicsEthical use of data and AIResponsible taxTax governanceDouble materiality assessment  methodologyValue chain mapping As part of the DMA, we assessed material impacts across all operations and the value chain. Outlined in our integrator strategy, Maersk’s busi-ness model spans activities within ocean transportation, terminals and logistics and services to connect and simplify customers’ supply chains. In our upstream value chain, shipyards, fuel suppliers and equipment manufacturers, commercial partners such as freight forwarders and third-party logistics providers, as well as manning agencies provide essential resources and add extended workforce for our operations. Our downstream value chain includes entities and stakeholders involved in ensuring the final delivery of goods and services to end customers, including retailers and manufacturers, freight forwarders and third-party logistics providers, customs and regulatory authorities and port operators, terminals and distribution providers not owned by Maersk. The assessment also extends to the communities that we impact through our operations and workers who are part of our value chain, including our suppliers’ workforces, who are not part of Maersk’s own or contracted workforce, and workers of joint ventures and associates. To assess impacts in our value chain where visibility and data is limited, we use industry-specific analysis, articles, scientific research and shared knowledge from stakeholders etc., as input to identify high risk areas or operations and vulnerable groups.   No IROs were identified for consumers and end-users due to our business model of providing logistics services to customers (business to business) who are not consumers/end-users as defined in the ESRS.Time horizons In the assessment of IROs, we apply the time horizons as per ESRS 1 – short-term being the reporting year and medium-term covering 1-5 years. We have also identified long-term emerging impacts and risks (beyond 5 years). For emerging risks please see Risk management on page 24. In addition, we have identified emerging impacts such as the increased use of water needed for production of biofuels in our value chain.  None of the emerging impacts or risks were deemed material as of this assessment. Acknowledging that materiality is a dynamic process, these emerging impacts or risks are being monitored and tracked as the landscape evolves. Thus, the list of material IROs outlined in the topical sections encompass impacts and risks assessed to have an impact already in the short or medium term. Some of these, such as physical risks of climate change, are also material in the longer term, but since impacts are already apparent, these have been included as either short or medium term IROs.Identification and assessment of material impactsTo assess impact materiality of ESG topics, a specific scoring sheet has been developed and validated by internal subject-matter experts for each of the 10 topical standards in the ESRS. The scoring of impacts is performed for each identified impact and across our value chain, tak-ing into consideration particular stakeholder groups, areas or opera-tions at higher risk of negative impact, informed by our human rights impact assessment. For example, scoring of social impacts has been performed separately for own employees, non-employee workers and workers in the value chain to best capture impact occurrence for differ-ent affected stakeholders in our operations and value chain.  Where available, the scoring utilises existing methodologies and assessments such as Maersk’s most recent human rights impact assessments and relevant internal management systems. For environ-mental impacts, the DMA is informed by a LEAP assessment performed in 2024. As part of this assessment, we identified impacts and depend-encies across our business activities, using various databases and  scientific studies. Read more on pages 101-102.  Severity (based on scale, scope and the irremediable character) is assessed for each IRO using a scale of 1 to 5. For topics where Maersk has potential impacts, the likelihood of such impacts is also assessed with severity and likelihood each being assigned a 50/50 weighting. For human rights-related topics, severity has an assigned higher weighting (75%) compared to likelihood (25%) when determining impact materiality.   A threshold of 3 (out of 5) is applied to capture areas where Maersk has a very significant or critical impact to the environment or people, above which the topic is included in our external reporting. Identification and assessment of material risks and opportunitiesAs part of the DMA, we also assess potential sustainability-related risks that can trigger negative financial or reputational impacts to our business. This includes a consideration of whether the identified impacts and dependencies can also trigger financial risks to Maersk, e.g. reputational damage from impacts on people, or risks from dependencies on access to environmental or human resources.  For climate-related risks, we have assessed our current and future climate-related exposure of assets across different time horizons and climate scenarios. Read more on page 88.  The assessment of risks to Maersk is aligned with our ERM frame-work and is based on an assessment of magnitude (financial and/or reputational costs) and likelihood. This year, we continued the work ini-tiated in 2023 to quantify ESG risks using scenario-based modelling, where feasible. This includes modelling of both inherent and residual risks, where the inherent risk scores are used as part of the DMA. Appli-cation of scenario-based modelling has allowed us to understand the financial risk profile in different scenarios under different assumptions. The risk scores have been assigned based on the scenario, which results in the highest monetary impact. Work to quantify ESG risks will con-tinue as we mature and obtain more solid data as a foundation for the assessment. In addition, we will work towards including modelling of financial opportunities as part of this process going forward.   A quantitative threshold has been set to capture and report on the risks and opportunities with the highest monetary risk exposure. This threshold is lower than that of our ERM process to capture a broader range of potential ESG-related risks to our business.Engaging with key external stakeholders The assessment considers the perspectives of key internal and exter-nal stakeholders, as well as external experts on for example climate, nature, governance and human rights. This year, we mapped our exter-nal stakeholders considering both affected stakeholders and those who are users of the information we publish. Through various engage-ment channels, we continuously collect valuable insights on topics that are important to stakeholders, which inform our assessment of mate-rial impacts and risks and underpin the development of solutions and initiatives in delivering on our ESG commitments and KPIs. During 2025, we will work towards further strengthening our processes for docu-menting and incorporating external stakeholder perspectives into the double materiality process to ensure that stakeholder perspectives are continuously reflected in our ESG priorities. Read more on pages 70-74.ESRS 2Approach to  due diligence Increasing regulatory requirements are broadening the scope of corporate responsibility, extending beyond a company’s own operations to include due diligence and greater transparency across the value chain.The increasing complexity of regulatory requirements is challenging for many companies with global supply chains, and it will be a journey for A.P. Moller - Maersk (Maersk) to further mature our own processes over the coming years to ensure that human rights and environmental considera-tions are fully integrated into our due diligence processes and ESG govern-ance mechanisms. We also recognise the opportunities of further embed-ding due diligence and transparency to support customers across their logistics supply chains and strengthening stakeholders’ trust in our brand.  To continue navigating increased expectations, we support regulatory measures that strengthen requirements for responsible business conduct and contribute to a level playing field globally.  Due diligence in Maersk is integrated into multiple internal processes and programmes to identify, prevent and mitigate negative impacts arising from our operations and value chain. Examples of our human rights and environmental due diligence processes include our supplier management approach, mergers and acquisitions (M&amp;A) processes and requirements embedded in the Commit governance framework.  Our long-standing human rights due diligence approach is founded in our Purpose and Core Values and based on the UN Guiding Principles on Business and Human Rights, which serve as a north star in navigating global trade’s often complex impacts on people. Human rights impacts may occur in dif-ferent business areas, and we take a risk-based approach to our activities and work to strengthen key due diligence processes that allow us to iden-tify and act upon actual and potential human rights risks for rightsholders.   Please see the illustration for more information on specific parts of our processes related to due diligence.1Embed responsible business  conduct in operationsOur guiding documents - the Employee  Code of Conduct and Supplier Code of Conduct, outline our Core Values and policies.See ESG governance2Identify and assess adverse impactsMaterial impacts are identified through the DMA,  informed by, e.g. our corporate human rights assessment, and engagement with external stakeholders. See double materiality assessment See stakeholder engagement 3Cease, prevent or mitigate impactMaterial impacts are managed through our ESG  categories, and through various cross-topical processes and programmes such as supplier management, the Commit governance framework, and M&amp;A processes. See relevant ESG chaptersSee ESG governance4Track implementation and resultsAcross ESG categories, we measure progress and  track performance against our strategic targets.See relevant ESG chaptersInternally, we track progress as part of e.g. quarterly  ESG updates to the Executive Leadership Team, and annual compliance assessment for Commit rules.See ESG governance 5Communicate how impacts are addressedWe communicate progress across ESG categories  as part of the Annual Report, on our website, and  through participation in selected ESG ratings. 6Providing for remediation when appropriateWe are committed to ensuring our stake-holders have access to grievance and remedy.  Access to remedy is a salient human rights issue and focus area for Maersk. See grievance and remedyESRS 2, ESRS S1, S2, S3, E2, E3, E4, E5, G1 Stakeholder  engagementEngagement with key stakeholders provides valuable insights into their perspectives, both from those who might be directly impacted by our activities and those who are users of the  information that A.P. Moller - Maersk (Maersk) publishes.Stakeholder engagement supports us in identifying existing or emerg-ing impacts or risks as part of the double materiality assessment (DMA). Their insights provide valuable input to our ESG programmes, helping us to shape our strategy, targets and decisions towards delivering on ESG commitments and KPIs.  The table on the right shows seven prioritised stakeholder groups. Colleagues and teams across Maersk regularly engage with stakeholder groups through various channels, gathering valuable insights on topics that are important to them. Stakeholder engagement with key exter-nal stakeholders such as own workforce and value chain workers is anchored with the relevant business functions across Maersk, depend-ing on the stakeholder group or topic: labour-rights focused engage-ment is anchored with the Employee Relations and Labour Rights team headed by the Chief People Officer, whereas engagement related to safety is anchored with the Safety and Resilience team headed by the Chief Operating Officer. Management receives regular updates on topics raised by stakeholders and their perspectives. As an example, perspec tives raised by e.g. investors and customers are presented  to the Executive Leadership Team.  We proactively seek stakeholder opinions through, for example, annual employee and supplier surveys, and with customers through  a voice-of-customer process and our annual Strategic Customer Council, as well as dialogues with civil society organisations and unions to gain insights on key industry risks and impacts to workers and communities. Key external stakeholders and how we engage with themStakeholder expectations of Maersk Key engagement channelsHow stakeholder input is usedEmployees, contingent workers and value chain workersMeaningful work, fair treatment  and wages, safe working conditions, a sense of belonging for all, and good development opportunities.•  Daily manager/colleague interactions•  Engagement and inclusion surveys•  Grievance mechanisms•  Engagement with unions and interest groups•  Supplier auditsProvide valuable input to ESG programmes and  shape actions and improvement plans to address any issues.Customers Solutions that can ensure responsible business practices and lower supply chain emissions.•  Regular business interactions and ongoing  supplier assessment •  Strategic Customer Council and customer  satisfaction surveys •  Partnerships and collective action alliancesInforms product development and shapes  solutions. Customer feedback on providing greater value is directly linked to our integrator strategy.Authorities, regulators  and standard settersCompliance with regulation and  industry leadership on the trans-formation to net-zero.•  Engagement with local, national and  international agencies and authorities•  Standard-setter collaboration on topic-specific research, pilots and implementations•   Industry associations, collective action alliances and strategic partnershipsEnsure we adhere to regulations. Help us identify opportunities for collaboration and initiatives across the ESG agenda and to push for regulations towards industry-wide decarbonisation.Suppliers  and business partnersFair and transparent business  opportunities and partnerships  on strategic issues.•  Contract management•   Supplier relationship management framework•   Supplier surveys, workshops and capability- building programmes•   Industry forums and associationsBuild understanding of the effectiveness of  supplier practices and engagement. Enhance value chain visibility, including fair working conditions  and supplier ethical business conduct.Investors and analystsStrategies, plans and actions to  mitigate short and long-term risk  to the business model.•   Regular engagement through e.g. earnings calls, conferences, events, roadshows and meetings, including the Annual General Meeting•   Investor surveys and ESG ratings•   Collective action alliancesHelps us understand how the company is perceived in comparison to other investment opportunities. ESG ratings additionally help identify gaps in ESG management and emerging trends.Local  communities  and natureResponsibility and accountability  towards material issues in areas  of highest impact.•  Environmental and Social Impact Assessments, Corporate Social Responsibility initiatives •   Engagement with community representatives and employees•   Collective action alliances and partnerships•   Scientific  studiesLocal communities help us better understand the needs and constraints of nature where we operate,  informing decisions to invest and procure resources and to mitigate negative impacts in operations and the value chain.Civil society organisationsResponsibility and accountability towards material issues and positive contributions in areas of highest  impact and leverage.•   Bilateral engagement with local, national  and international agencies•   Collective action alliancesAccess to valuable insights, expertise and best  practices which help us identify potential risks or opportunities and shape ambitions and actions.ESG ratings are also a source of stakeholder expectation insights, and our submissions are valued by customers and investors. We prioritise those that are most material to our stakeholders and align with our pri-orities, including EcoVadis, CDP, MSCI and Sustainalytics. We actively use these questionnaires to identify gaps in current processes or ambitions and thus inform action plans across ESG topics.   We proactively engage in cross-industry partnerships and coalitions to set standards, develop solutions and drive common agendas across the ESG agenda such as the UN Global Compact, Smart Freight Centre, SteelZero initiative, the World Business Council for Sustainable Develop-ment, and the Zero Emission Port Alliance. Such proactive engagement is core to our ESG strategy, and in recent years we have seen significant growth in engagement requests.   We welcome perspectives raised by stakeholders, and have regular dialogues on topics raised by customers, civil society organisations and investors, etc. These perspectives provide valuable insight into how our ambitions and decisions are received, and enable us to engage in con-structive dialogue with our stakeholders.  During 2024, we worked to strengthen the format for directly col-lecting and incorporating external stakeholder perspectives into the double materiality process, ensuring that these perspectives are con-tinuously reflected in our ESG priorities. This work began with an in-depth mapping of the current approach to engagement, to assess whether it effectively captures our stakeholders’ perspectives. Based on this mapping, we identified a need for a more structured approach to the collection and documentation of the input received from our stakeholders, ensuring that we leverage existing channels to raise the right questions and document the inputs received.  We regularly perform more targeted engagement towards specific groups or on specific topics. For example, we conducted an Inclusion Survey in 2024 to gain perspectives from vulnerable or underrepre-sented groups in our workforce on potential negative impacts related to diversity, equity and inclusion. In 2025, we will continue this work with the aim of conducting more in-depth engagements on specific ESG topics to help shape future ambitions. In 2024, we also held high-level talks with the International Transport Workers’ Federation, to discuss collaboration opportunities for 2025, focused on contracted labour. The collaboration will focus on two key topics: future of work and diversity, equity and inclusion.Engagement with local communities Our operations can impact people in local communities and their nat-ural surroundings, highlighting a responsibility to proactively engage with communities or their representatives. This engagement is crucial as a license to operate and to understand the needs and conditions in the areas, informing decisions to invest and make meaningful contri-butions to the societies where we operate.  As part of new infrastructure projects, landside projects are reviewed under the Environmental and Social Impact Assessment (ESIA) screening process to understand the environmental and social sensitivities of new projects and existing operations. The ESIA process is based on legal requirements and international standards around conducting such assessments. It provides location-specific context on environmental and social impacts and is the first step towards man-aging the impacts of our operations and growth projects. For each ESIA screening, the scope of the project is reviewed against ten envi-ronmental criteria using global and regional data sources.  Local and indigenous knowledge, as well as nature-based solu-tions and restoration initiatives, have yet to be widely incorporated into broader commitments and actions addressing biodiversity and ecosystems. Currently, they are confined to specific local projects. For example, APM Terminals supports a local conservation initiative in the Monarch Butterfly Biosphere Reserve in Mexico, where scientists observed a significant decrease in the eastern migratory populations in 2024, as habitat loss remains a significant threat. Local and indig-enous knowledge is essential for this project as it provides practical insights into local ecosystems and effective conservation methods used by local communities.Political engagement and  responsible lobbyingMaersk is actively involved in shaping policy and regulatory discussions at both global and regional levels to accelerate the decarbonisation of the maritime and logistics industries. Decarbonising our operations is a core ESG commitment and to achieve our targets, we are dependent on the implementation of supporting regulation. We work actively with political engagement and lobbying as opportunities to support our climate ambitions and to positively impact the industry’s transition to net-zero.   Maersk’s climate policy outreach is conducted in line with the goals of the Paris Agreement. At the International Maritime Organization (IMO) level, Maersk is actively working for the adoption of ambitious, proportional and enforceable mid-term measures, including a green-house gas (GHG) price and a global fuel standard or a combination hereof. Moreover, Maersk calls for any IMO measure to take into con-sideration just and equitable transition and secure that the collection of revenue benefits developing nations in their energy transition.  2025 marks a crucial milestone for the IMO, as a global carbon pricing mechanism and a global fuel standard are expected to be approved. These initiatives are essential for closing the cost gap between fossil and green fuels, to drive the shipping industry’s energy transition and to align with Maersk’s broader goal of achieving net-zero emissions by 2040.  Maersk actively participated in key global meetings during the year, including for example the New York Climate Week and COP29, emphasising the need for stronger global commitments to maritime decarbonisation. Maersk’s CEO, Vincent Clerc, was one of over 100 CEOs and senior executives to call on world leaders ahead of COP29 to enact policies that support the scaling-up of green fuel production and renewable energy infrastructure, while ensuring a just and equi-table transition.   At the EU level, Maersk has called for the full implementation of the ‘Fit for 55’ legislative package, which includes the EU Emissions Trading System (ETS) and the FuelEU Maritime Regulation. Maersk has pushed for the inclusion of container terminals in the ETS and advocated for an end-date for fossil fuel-only newbuild vessels. These measures aim to bridge the cost gap between green and fossil fuels and accelerate the energy transition across the shipping sector.   On landside transportation, Maersk is working for robust EU regula-tion to promote electrification of road transportation.  Maersk adheres to policies and procedures to ensure responsible lobbying. The company is part of the EU Transparency Register (regis-tration number 680443918500-51), in relation to policies on climate, tax, customs, competition, trade, company law and corporate govern-ance and general industry-related policies. We perform risk-based management integrity screenings of third- parties who interact with government officials on Maersk’s behalf or procure business for Maersk. Additionally, hiring managers may not offer employment, directorships or internships to anyone employed or formerly employed (in the last three years) by the government or being a close relative to such a person without approval from Compliance. This is outlined in our Commit Business Ethics Rule.  In general, Maersk does not provide any financial or in-kind dona-tions to politicians, regulators or political parties. In Denmark, Maersk is a member of large trade associations such as Danish Shipping and Danish Industry, which may allocate political contributions on behalf of their member organisations and sectors. These contributions are determined and distributed directly by the associations. In the US, Maersk has established a Political Action Committee (PAC) where dona-tions are voluntary contributions made by individuals, corporations or unions to support candidates, parties or issues, and are subject to strict limits and reporting requirements to ensure full compliance with federal and state regulations. In 2024, the amount donated through the PAC was USD 15k, and no other financial or in-kind political donations were provided by Maersk.Engaging with customersCustomers are at the centre of our business and ESG strategy, and we actively collaborate with them also on sustainability and ESG issues to shape solutions, enhance our practices and achieve shared goals. The core focus of our engagement with customers relates to decarbonisa-tion. Adapting our solutions to meet the unique decarbonisation needs of different customer segments is key to our customer engagement. For example, customer feedback has led to the development of a blended green and fossil fuel product in ECO Delivery Ocean, through the use of different levels of lower-emission and fossil fuel-based fuels, to meet different customer needs and price sensitivities while still supporting decarbonisation.   Across many segments, customers have an appetite for logistics partners that are at least as ambitious on decarbonisation as them-selves and offer credible solutions to make those ambitions a reality. As an example, Primark ships most of its products by ocean, and through our partnership, Maersk is now moving some of Primark’s ocean cargo on lower-emission fuels such as biodiesel and bio methanol. In addition, the first large dual-fuel methanol vessels joined our fleet  in 2024, and our customers Nissan, Vestas, Nike and Primark joined us as godparents for vessel-naming events, emphasising the importance of partnerships.   Customers’ demand for end-to-end decarbonised logistics has prompted Maersk to develop more inland solutions, including electric trucks and rail options in multiple countries. For example, in the US, Maersk is collaborating with Microsoft and Pepsi, the Smart Freight Centre and other partners to launch a shipper-carrier coalition to accelerate heavy-duty EV deployment, including a long-haul EV testing corridor between California and Texas.  The majority of logistics GHG emissions in some industries (i.e. automotive and chemical companies) come from ocean transporta-tion, whereas others have emission hotspots from their air and inland logistics, i.e. fashion, consumer goods and tech companies. Never-theless, we see a trend of fashion and fast-moving consumer goods leading the engagement of ocean decarbonisation, highlighting their maturity in this field. These segments are closer to end consumers, and their logistics are more visible and therefore more attractive to decarbonise. Cutting air freight GHG emissions is one of the most challenging tasks in decarbonising logistics. Air freight is also a vital and integrated part of many automotive, technology and lifestyle supply chains. Customers in these segments have partnered with us on ECO Delivery Air, using sus-tainable aviation fuel to reduce emissions for their air freight shipments.   Like Maersk, many customers are looking at emissions in their value chains and aim to incorporate ESG metrics as part of their pro-curement processes and science-based target setting. To support these needs, Maersk has developed an emissions dashboard solution.   Maersk’s annual Strategic Customer Council is a key engagement channel and platform for collaborating with our customers’ executive leadership, taking a joint problem-solving approach to decarbonisa-tion at a systemic level, including joint lobbying towards IMO member states to balance the price gap of lower-emission and fossil fuels.  We see a positive trend in the maturity of our customers’ sustain-ability approach – moving from a transactional procurement activity, towards partnerships and collaboration with strategic suppliers. Cus-tomer dialogues in 2024 spanned across several topics of interest for future collaborations, including regulatory engagements, circularity, simplifying the complexity of decarbonisation data visibility and com-parability, challenges to the execution of decarbonisation strategies and the overall resilience of supply chains. CitizenshipMaersk’s corporate citizenship is rooted in meaningful engagement with our partners and communities, and aligned with our Purpose,  Core Values and stakeholder expectations. We assume an active responsibility to support the societies where we operate by partnering with local communities, non-profit organisations and customers on social and environmental causes. Leveraging our global reach, expertise and resources, we aim to co-deliver impactful solutions and achieve shared goals effectively.Donations and social investments Maersk supports select stakeholder initiatives through donations and investments in social and environmental well-being, guided by cor-porate guidelines. Our in-kind and financial support aims to address critical needs connected to five priority causes: disaster relief and preparedness, empowering people to trade, protecting the natural environment and oceans, education and health and safety.  Maersk collaborated with a diverse range of organisations in 2024, supporting local initiatives in over 30 countries. Our efforts are designed to create sustainable and positive change, enhancing community  well- being and contributing to better futures.  2024 was marked by record flooding across many regions. During the year, Maersk supported flood relief efforts in Vietnam, Guatemala, Brazil, Kenya and the US through a mix of delivering water and relief supplies, and by donating essential supplies and relief item storage containers.   Our support of education and training programmes in 2024 included improving educational infrastructure and supporting skills develop-ment and capacity-building activities, from providing technical learning scholarships in Peru to a container library project in Vietnam. Corporate partnershipsMaersk engages in strategic partnerships that demonstrate effective multi-stakeholder cooperation between the private and public sectors. These leverage our expertise and resources to address global challenges connected to our industry, but also enhance our knowledge, capabilities and stakeholder relationships. Partnerships further support our prior-itised causes of disaster response and trade empowerment. Maersk is a member of the United Nations-led Logistics Emergency Teams (LET) along with logistics peers, who join forces to provide pro bono support and consultation services during humanitarian crises and natural dis-asters. Working under UN auspices and in collaboration with other key stakeholders allows us to put our experience, network and assets to the best use and reach those in need in a coordinated and efficient way.  In 2024, the LET actively coordinated regional aid and relief efforts in response to the ongoing conflict and resulting humanitarian emer-gency in Gaza. Maersk established a 5,000 m² logistics hub in Amman, Jordan, which serves as a consolidation centre to assist over 50 UN partner and humanitarian NGOs and governments delivering cargo to Gaza. This in-kind donation is ongoing and will extend through 2025.   Since 2018, Maersk has partnered with the International Trade Cen-tre’s SheTrades initiative to advance women’s economic empowerment through trade. This year’s collaboration focused on fostering sustain-able and inclusive trade practices and advocating for public-private partnerships to promote gender inclusivity. For example, Maersk par-ticipated in a panel at a World Trade Organization - International Trade Centre event aimed at inspiring governments and the private sector to take bolder actions in supporting women’s economic empowerment, particularly around issues impacting the supply chains of women-led businesses in developing countries. We also took part in a webinar series to support women- and youth-led micro, small, and medium- sized enterprises (MSMEs) in building resilient supply chains. This involved sharing knowledge on sustainable business practices, includ-ing human rights considerations and managing increasingly complex ESG due diligence and trade. Engaging our own workforce Our annual internal Go Green campaign was maintained in 2024. It aims to engage colleagues on environmental stewardship topics, raise awareness and create a platform for collective action across Maersk and with the communities where we operate. This year’s theme, ‘Noth-ing goes to waste’, focused on waste management best practices and how they tie into our ESG goals. Employees in over 35 locations partic-ipated in local learning events on waste, recycling and other sustain-ability topics, and a number of local on- and off-site volunteer events took place including trash clean-ups and recycling competitions.Grievance and remedyMaersk fosters a ‘speak up’ up culture where anyone is encouraged to voice concerns. This is enshrined in our Code of Conduct along with a zero-tolerance, non-retaliation policy. Multiple channels are available for employees and other stakeholders to raise concerns. As a key pro-cess anchored in the Commit framework, the whistleblower programme has been available for decades and aims to create a safe and secure environment for anyone to speak up and report violations without fear of retaliation. Whistle blower reporting is independently managed on a third-party platform, and complete confidentiality is maintained along with the option of anonymous reporting. This is supported by effective investigations led by independent, objective and impartial investigators and by ensuring appropriate follow-up action to address violations and implement controls to avoid repetition of undesirable behaviour. The investigators follow a standard investigation procedure, outlined in our misconduct reports and investigation process. This includes comply-ing with local laws and data privacy considerations.   Considering the global nature of our business, the whistleblower site is accessible in all countries where Maersk operates, and phone lines are available in 75 languages. The channel is publicly available on Maersk.com and integral in both our Employee Code of Conduct and Supplier Code of Conduct. It is open to everyone, including employees, suppliers and other external affected stakeholders.   In addition to the whistleblower channel, other internal channels are available for our employees to ask questions or raise concerns – such as direct management or leaders, our Compliance, People or Ombuds functions and an employee assistance programme.  Maersk’s internal Ombuds function acts as a neutral, independent, informal and confidential function providing another voice for employ-ees who do not feel comfortable with other channels. The Ombuds function offers a voluntary safe place for employees to seek guidance, voice concerns or discuss options for any work-related matter.Speaking upWe actively monitor the number of cases raised across stakeholder groups, including from our workforce, workers in the value chain, affected communities and consumers as this gives us an indication of the level of awareness and trust of our whistleblower channel and the strength of our speak up culture. In addition, our 2024 inclusion survey included questions around employees’ trust in the grievance mechanisms available. Several improvement areas were identified and are being addressed through initiatives by the Compliance function.  Periodic campaigns like Speak Up are carried out for all Maersk employees, and training projects are rolled out for investigators. Con-sidering the distinct nature of our seafaring workforce, awareness programmes are ongoing as part of the larger cultural transforma-tion for our crews and prevention of unique risks at sea. In 2024, the Speak Up campaign also focused on warehouse and terminal workers and covered 300 entities.  In 2024, Maersk saw a significant rise in whistleblower reports, receiving 1,387 cases – a 20% increase from the 1,154 cases in 2023. This surge reflects the success of our awareness initiatives and under-scores the critical role of reporting in maintaining transparency and accountability. By encouraging and facilitating whistleblower reports, we ensure that issues are promptly addressed, fostering a culture of integrity and trust within our organisation. 84% of the cases received  in 2024 have been closed. In particular, we have seen an increase in cases related to HR-related matters. As part of this category, two cases of discrimination on protected grounds were substantiated and resulted in respectively disciplinary action and policy/process review, respectively. In 2024, we also started tracking human rights incidents which are inherently severe, including cases related to e.g. forced labour, human trafficking or child labour. No such cases were  recorded for 2024.Ensuring access to remedy Maersk is committed to providing remedy in cases that have caused or contributed to an adverse negative impact, including related to human rights. We continue working towards strengthening processes for pro-viding remedy to affected stakeholders, including our own workforce, workers in the value chain and affected communities.  We collaborate with both judicial and non-judicial mechanisms to provide access to remedy if allegations are reported externally. Where Maersk is directly linked to impacts through our business relationships, we are committed to using our leverage to provide remedy.  Issues raised are addressed and documented and feedback is shared with key stakeholders, including the annual submission of a compre-hensive whistle blower report to the Audit Committee and the Risk and Compliance Committee. This includes key performance measures such as the number of cases reported, number of cases closed, type of cases, case outcome, actions taken and benchmark analysis. For own employees, Maersk ensures a 24-hour availability to the employee assistance programme which offers psychological, legal and financial support to employees.Whistleblower reports Reports received  in 20241,387(1,154)Closed whistleblower reportsClosed cases  in 20241,170(923)ESG COMMITMENTSEnvironment A.P. Moller - Maersk is taking a leading role in decarbonising  logistics and in providing green solutions to assist our customers reach their climate goals.SocialA.P. Moller - Maersk strives to provide a safe and inspiring environ ment for our people to grow, develop and thrive as  a diverse and global team.GovernanceAt A.P. Moller - Maersk, high standards of responsible  business practices are foundational for the services we deliver  to customers and the value we create for the communities  where we operate.EnvironmentA.P. Moller - Maersk (Maersk) is taking a leading role in decarbonising logistics and in providing solutions  to assist our customers reach their climate goals.  Learn more about our progress, including newly validated science-based targets for 2030 and 2040, and how  we minimise our impact on the natural environment.CLIMATE CHANGETargets by 2030•  35% absolute reduction in total  scope 1 emissions•  100% renewable electricity sourcing•  22% absolute reduction in total  scope 3 emissions Net-zero targets  by 2040•  96% absolute reduction in total  scope 1 and 2 emissions •  90% absolute reduction in total  scope 3 emissionsENVIRONMENT AND ECOSYSTEMSOngoing ambition Maersk takes constant care to ensure our  operations and value chain minimise and pre-vent impacts to the environment and to people, and we align our operations with local laws and regulations to ensure compliance with environ-mental requirements. Our overall objective is to do as little harm as possible while safeguarding the environ ment, including protecting the eco-systems and habitats where we operate. PERFORMANCE DATAMATERIAL IMPACTS, RISKS AND OPPORTUNITIES EnvironmentOverview of our material impacts, risks and opportunities related to Environment.Climate changeClimate change mitigation Greenhouse gases emitted from our operations,  suppliers and business partners in the value chainOur operations and value chain activities result in direct and indirect emissions of greenhouse gases (GHG) impacting the environment. Climate change caused by emission of GHGs may also have adverse negative impacts on people’s livelihoods and well-being and on nature/biodiversity.Transition risks related to policies and market demand for decarbonisation of the shipping industryLack of political and market support for decarbonisation of the shipping industry present a reputational risk to Maersk of not being able to transition fast enough to meet our science- based targets.Climate advocacy/lobbying for policy interventions  on energy transition in shipping and logisticsFinancial opportunity related to stricter and more ambitious regulation towards industry- wide decarbonisation and a just and equitable transition to support our decarbonisation com-mitments.Climate change adaptation Financial risks due to physical impacts of climate change to assets and operationsFinancial exposure of our assets towards climate-related  physical risks/hazards and disruption of operations and networks.Environment and ecosystemsPollution Air pollutants from vessels and landside/air transportationAdverse impacts on air quality due to emissions of NOx, SOx, PM, BC, CO and NMVOCs, primarily from our vessels.Pollution from hydrocarbon spills from vessels and  landside operations and from containers lost at seaAdverse impacts to the environment and people related  to hydrocarbon spills to the ocean, aquifers and soil from  vessels and at our land-based facilities, and impacts from  the loss of containers at sea, resulting in the release of  pollutants into the ocean and accompanying costs for  Maersk to clean up polluting materials.Discharged wastewater to the sea (e.g. scrubber, bilge, sewage and grey water)Adverse impacts arising from the discharge of wastewater from vessels, including scrubber water, bilge water, cargo  bilge water, wash water, grey water, treated and untreated sewage and boiler water.Ecosystem health and biodiversity Disturbance of species due to vessel traffic and  underwater radiated noiseVessel speed, underwater noise and disturbances from  concentrated ship traffic can disrupt ecosystems and  species, negatively affecting the development and  reproduction of marine species. These impacts may  lead to biodiversity loss and direct harm to species,  such as whales. Ecosystem degradation and biodiversity loss caused by  land use and habitat disruption resulting from construction and operation of land-based assets The construction and operations of warehouses and  terminals can harm biodiversity and ecosystems, particularly when these are located in biodiversity-sensitive areas.Spread of invasive speciesAdverse impact of vessels transporting organisms  (via biofouling) spread across large areas. The spread of  invasive alien species can lead to the disruption of coastal ecosystems and contribute to the spread of disease.Waste management Waste generation during operationsAdverse impact related to waste generation and disposal  from operations, particularly in locations with inadequate waste management infrastructure.Responsible ship recycling Environmental impacts during decommissioning of vesselsAdverse impacts related to breaking and recycling of own vessels, including waste generation and pollution as well as worker safety. Inability to recycle ships due to regulatory changes or increased number of vessels in the pipeline can also pose a financial risk to Maersk through increased cost of recycling.Sourcing of critical resources Environmental impacts resulting from the steel value chainActual and potential adverse impact from the procurement  of non-recycled steel for production of containers and  vessels. The impacts are related to pollution, water use,  eco system degradation, disturbance of species and potential biodiversity loss.Environmental impacts resulting from the fossil fuel  and biofuel value chainActual and potential adverse impact from the procurement  of fossil-based fuels and biofuels. The impacts are related  to pollution, water use, ecosystem degradation, disturbance  of species and potential biodiversity loss.ESRS – E1, S3 Climate changeIn early 2024, A.P. Moller - Maersk (Maersk) reached an important milestone with validated  science-based targets. A major focus this year has been on further refine the transition  plan and driving the investments and actions needed to take us from where we are today  to where we need to be in 2030 and 2040 to meet those targets.Much like the preceding year, 2024 brought ample evidence that the world is facing a climate emergency, impacting not only the environment and broader nature, but also people’s health and economic prosperity. As an industry leader, we consider it our obligation to take decisive action to reach net-zero greenhouse gas (GHG) emissions across our operations, to the benefit of our customers and society at large, and to our shareholders and our business by mitigating transition risks. This is the core of our environmental commit-ment, ‘we will take leadership in the decarbonisation of logistics’.   2024 was a year marked by headwinds from externalities that had a significant impact on the entire trans-portation and logistics sector including Maersk and our ability to reduce GHG emissions during the year. We remain optimistic about our ability to decarbonise and the path ahead, but we are also realistic that we will face many hurdles along the way in meeting our science-based targets.  Commercial shipping attacks in the Red Sea and Gulf of Aden continued re-routing Asia-Europe trade around the Cape of Good Hope to ensure the safety of people, vessels and cargo. This led to longer voyages, capacity shortages and port congestion, all of which contributed to higher fuel consumption and GHG emissions.  In addition, the year’s overall geopolitical climate – including increased protectionism and election cycles in countries with high GHG emissions – created uncertainty and, in some cases, headwinds for climate action. Rising raw material costs, higher shipping expenses and increasing interest rates further challenged our customers’ decarbonisation action in 2024.   Regulatory debates also continue to impact our sector, as consensus and action on several topics critical to the energy transition remain elusive. While there has been promising regional progress such as Fuel EU Maritime starting in 2025 and the US Inflation Reduction Act, more ambitious and impactful policies are urgently needed at a global level, with the support of the International Maritime Organization (IMO) and its member states. 2025 is a pivotal year for IMO policy setting, and the outcomes of IMO Marine Environment Protection Committee meetings in April and October will have a significant impact on the decarbonisation progress of Maersk, our customers and the industry as a whole in the coming years.   In 2024, we made progress in the areas of our operations that to a greater extent are within our control, while focusing on stakeholder engagement and advocacy for areas with greater external dependencies. These are unfolded in detail in our transition plan.Climate transition planMaersk’s climate transition plan outlines the key levers and scenarios to reach our science-based commitments for 2030 taking into con-sideration key uncertainties and complexities. The plan encompasses GHG emissions from our own operations and value chain, covering our end-to-end logistics customer offerings across ocean, land and air. Our approach is focused on business integration and investments in levers where we have higher control, and stakeholder engagement and lobby-ing for levers more dependent on externalities, including regulatory progress and our customers’ willingness to buy, as well as local stand-ards, technology and infrastructure.   Our transition plan, illustrated on the previous page, encompasses two fundamental decarbonisation drivers – efficiency measures and energy shifts. The first two levers relate to the energy efficiency of our network and assets, which combined represent our biggest reduc - tion potential and areas where we have higher degree of control over actions needed to decarbonise. As we mature on our journey and enhance our assessments, we have seen that the efficiency of our  network and assets can play a much more prominent role in meeting our near-term targets towards 2030. Our focus in the coming years will therefore include a higher emphasis on efficiency measures that can deliver tangible reductions towards our 2030 targets. Efficiency, how-ever, will not in itself take us all the way to our net-zero greenhouse gas target, and fuel shifts will play an important role, in particular from 2030 to 2040. Looking beyond 2030, Maersk will continue to apply key levers related to efficiency measures and energy shifts to deliver our 2040 long-term targets. However, uncertainty remains in regard to e.g. further developments of international policies and standards, developments in the fuel market, and advancement of new technolo-gies, all of which are key dependencies for Maersk to deliver on its long-term targets.  Network efficiency relates to Maersk’s Ocean network  including the Gemini network, and asset efficiency includes our owned and time- chartered vessels and our ongoing fleet renewal plan.  The three energy shift-related levers focus on the transition from fossil fuels to lower emissions energy solutions such as alternative marine fuels or electrified solutions.Aligning our roadmap to the  Science Based Targets initiative pathwayThe Science Based Targets initiative (SBTi) is a widely adopted frame-work for setting corporate climate targets in line with the 2015 Paris Agreement’s pathway limiting global temperature rising to 1.5°C. In 2024, Maersk announced the validation of our climate targets by the SBTi as the first in the shipping industry in alignment with a 1.5°C pathway for 2030 and the 2040 net-zero standard.For the first time, we are this year reporting progress against these targets consisting of absolute reduction targets for scope 1, 2 and 3 emissions across Maersk, with required sub-targets for certain opera-tions and GHG sources – in particular related to ocean activities as we follow the maritime sector framework. The sub-targets for maritime operations cover well-to-wake emissions, including emissions relating to the entire process from fuel production and delivery to the actual combustion onboard the vessels.We continue to internally track and externally report on strategic  KPIs on efficiency in our Ocean business and the commercial uptake of the ECO Delivery Ocean product, as these metrics are indicators towards our intended outcomes and closely tied to operational and financial planning. The SBTi framework poses some challenges which Maersk is raising in external dialogues, including directly with the SBTi, in particular relating to accounting for growth and applying Book &amp; Claim mechanisms. The current methodology allows for recalculation of the baseline if a company grows as a result of acquisitions, but this is not allowed when growth happens organically as a result of growing market share.  Maersk’s view is that further nuances should be introduced in the treatment of organic growth in methodologies by distinguishing between increased market activity owing to market growth versus the capture of market share with no increase in market activity. This is because the capture of market share by a company will result in the decrease in market share for another if market activity is unchanged, leading to marginal effects on GHG emissions emitted into the  atmosphere for the same activity depending on individual efficiencies of companies.SBTi currently lacks recognition for Book and Claim/market-based mechanisms. In a rapidly evolving market with exponential demand for green fuels, we see a need to rapidly address the lack of guidance and consideration of such mechanisms. Regulatory frameworks already use this to operationalise fuel policy (e.g. the Renewable Fuel Standard in the US), and it is widely used and accepted in regulated and voluntary electricity markets, such as the EU, US and India. SBTi has started a call for evidence in 2023/2024 and we look forward to more clear guidance on this topic in 2025.To meet our net-zero target by 2040, we plan to neutralise unabated emissions. According to our transition plan, we expect to have 6.2m tonnes of residual GHG emissions annually by 2040 that we will need to neutralise in accordance with SBTi Net-Zero criteria. The SBTi Corpo-rate Net-Zero Standard is currently undergoing revision. While we await clearer guidance on beyond value chain mitigation and the neutralisa-tion of residual emissions, we continue to evaluate opportunities for the use of carbon credits and Natural Climate Solutions (NCS). While electrification of owned assets has a relatively lower contri-bution to the transition plan, it is the core lever to reducing scope 1 emissions in our logistics and terminal operations, as well as scope 2 emissions when renewable electricity is available from local grids. In Logistics &amp; Services and APM Terminals businesses, we have direct control over the electrification of sites and owned assets; however, we need to work across a fragmented landscape with different tech-nologies, infrastructure, partners and policies that often require site or country-specific roadmaps.   The electrification of non-owned assets includes all of our landside transportation solutions, but in particular vehicles of third-party truck-ing partners. Our ability to decarbonise is highly dependent on the readiness of local grids to support increased electrification demand and their degree of renewable integration.  Lastly, the fuel shift lever has a prime focus on reducing scope 1 emissions from our vessels. The shift to alternative marine fuels like biodiesel, green methanol and biomethane is especially dependent on externalities which are currently slowing the scaling of infrastructure and capacity. Most notably, global regulations are needed through the IMO for green fuel standards, fossil fuel phase-out timelines and the implementation of effective mid-term measures to close the signifi-cant cost gap between fossil fuels and green fuels.   In 2025, the IMO aims to reach agreements on these topics. The outcomes of those decisions will significantly impact the industry, our customers’ ability to pay for decarbonisation and the pace of the energy transition. Our transition plan considers three possible scenarios of ascending ambition, pessimistic, base case and optimistic, each with different implications for green fuel scaling and demand and therefore a corresponding need to adapt our transition plan.  The levers and the current actions supporting our progress are unfolded in the respective sections of this chapter, with greater details on our impacts, risks and opportunities.  Unallocated opportunities pertain to emission reduction measures that rely on consensus in international policies and standards such as SBTi for their successful implementation. Maersk endeavours to con-tinue engaging with policymakers and standard setters in 2025 to unlock unallocated opportunities for our climate transition plan. Embedding the transition plan into business strategy  and financial planningReaching our climate ambitions is core to our ESG strategy and part of the annual business planning process. As such, the required capital and operational expenditures (CAPEX and OPEX) to pursue our climate targets and roadmap is allocated as part of the business strategy and financial planning for the relevant business segments, e.g. the financ-ing of our new fleet of green methanol dual-fuel vessels, ongoing fleet renewal activities and investments in battery-electric container handling equipment. For more information about CAPEX and OPEX allocated to the transition plan, please see the respective sections on the decar-bonisation levers.   Progress towards our strategic KPIs is reviewed quarterly by the Executive Leadership Team (ELT) and the Board of Directors. Respon-sibility for the transition plan and execution resides with the Chief Operating Officer as outlined in our ESG governance model. The ELT and the Board of Directors are involved in discussions around current and upcoming key trends and market developments, progress against  our science-based targets and the potential impact of different IMO agreement scenarios to further integrate our energy transition into business planning.  Since 2021, Maersk has had in place an internal shadow price of  USD 75 per tonne of GHG for investment decisions. The price was deter-mined in 2021 based on an analysis of the existing abatement costs and expectations towards future carbon taxes. This internal price is not applied to actual emissions but is used for projections to ensure that future regulations and carbon costs are considered in all investment committee decisions.  Our Green Finance Framework is essential to ensuring that our  transition plan is properly funded. The Framework allows Maersk to  use a variety of financial instruments to fund projects that deliver  positive impact to the environment and progress towards our targets.  The Framework aligns closely with the EU Taxonomy, covering catego-ries such as new build vessels, retrofitted vessels, warehouses, termi-nals and electrified equipment, and it includes both CAPEX and OPEX. Read more on the 2024 Green Finance Framework. In addition to sup-porting our transition and business plans, the Framework also builds investor trust through its alignment with recognised criteria by show-ing our commitment to sustainable investments.EU Taxonomy reportingThe EU Taxonomy is a classification system for which economic activ-ities can be considered environmentally sustainable. It is a corner-stone of the EU’s sustainable finance framework and an  important market transparency tool, defining criteria for economic  activities that are aligned with a trajectory of net-zero GHG emissions by 2050 and broader environmental goals beyond climate. Since 2021, Maersk has provided EU Taxonomy reporting, and from 2024, Maersk is required to disclose its EU Taxonomy reporting as part of CSRD reporting in relation to our climate transition plan. As a transport  and logistics company, we are engaged in the activities under the  EU Taxonomy that are listed on this page.  The full overview of the results of Maersk’s taxonomy screening  for 2024, which can be found on pages 96-100, confirms that the company has a significant opportunity to substantially  contribute towards climate change mitigation. Although taxonomy-aligned  activities continue to increase, Maersk is still in the early stages of  its journey to decarbonise the end-to-end value chain. We therefore, see a high share of eligible revenue, CAPEX and OPEX, but a signifi-cantly lower share of revenue, CAPEX and OPEX, related to taxonomy- aligned activities. As aligned assets come into operation, we see  a modest, gradual increase of taxonomy-aligned revenue and a con-tinued, steady increase in the taxonomy-aligned CAPEX in line with our decarbonisation strategy and transition plan going forward.Activities included in Maersk's EU Taxonomy reporting Ocean6.10   Sea and coastal freight water transportAligned revenue in the Ocean segment is related to 40 conventional vessels as  well as our first eight dual-fuel vessels that meet the technical screening  criteria. Aligned CAPEX relates to 1) capital expenses in relation to existing vessels;  and 2) milestone payments for the ordered dual-fuel vessels incurred during  the year. Aligned OPEX is the repair and maintenance expenditures in relation  to aligned vessels incurred during the year.6.12 Retrofitting of sea and coastal freight and passenger water transportAligned CAPEX represents efforts to improve our existing fleet with regards  to efficiency and dual-fuel capabilities.Logistics &amp; Services 6.2 Freight rail transport6.6  Freight transport services by road 6.19 Passenger and freight air transportFreight transport by rail, road and air are anchored within Maersk’s Logistics &amp;  Services segment. Only freight done by electrified assets is considered aligned  in relation to rail and road transport. Non-eligible activities within the Logistics &amp; Services segment relate to supply chain management and e-commerce.Terminals 6.16  Infrastructure enabling low-carbon water transportAligned revenue, CAPEX and OPEX in the Terminals segment represents efforts to decarbonise port infrastructure, supporting ocean-based transportation, and are linked to electrical equipment used to operate the terminals, including cranes, trucks and lifts, charging stations as well as onsite renewable electricity installations. Non-eligible activities relate to terminal concession rights and operational software.Cross segments7.7 Acquisition and ownership of buildings7.6 Installation, maintenance and repair of renewable energy technologiesAligned CAPEX represents investments into on-site renewable electricity  installations across all business segments7.4 Installation, maintenance and repair of charging stationsAligned CAPEX represents investments into charging stations across  all business segmentsEfficiency-driven decarbonisationThe first and most impactful component of our transition plan towards 2030 is the efficiency of our Ocean network and assets, which directly reduces fuel consumption. Efficiency of the  network addresses the operational excellence of our Ocean network including our new Gemini network in 2025. Efficiency of assets in the network relates to the design, technology and composition of the global fleet of 700+ owned and time- chartered vessels.The Energy Efficiency Operational Indicator (EEOI) is a key measure of efficiency in Ocean operations. The EEOI is an expression of emissions of CO2e per unit of transport work (tonne cargo times nautical mile). In 2024, we improved the EEOI to 11.1 gCO2e/t nm, compared to 11.7 in 2023, marking a record low for the second consecutive year.  In 2024, the EEOI benefited from increased transport volumes due to the Red Sea situation, as higher capacity utilisation enhanced the energy efficiency of our vessel operations. Our science-based target commitments, however, focus on reducing our absolute scope 1 emis-sions, not on energy efficiency per transported container, and longer voyages and faster sailings in 2024 resulted in a net increase of abso-lute greenhouse gas (GHG) emissions of 8%, compared to 2023.  Maersk's Fleet Management and Technology policy statement, anchored in our Code of Conduct, outlines our commitments to reduce negative impacts to the environment and society from our fleet, includ-ing environmental commitments such as improving energy efficiency and preserving ecological balance and biodioverisy as well as commit-ments around health and safety, fair employment practices and human rights and business ethics. Network efficiencyOptimising sailing speed and routing, while taking factors such as ves-sel safety and environmental protection into consideration, allows us to meet customer delivery promises while optimising fuel consumption and thereby reducing GHG emissions. In addition, network efficiency will have the largest contribution to scope 1 emission reductions in our transition plan towards 2030.   Network efficiency is supported by StarConnect, Maersk’s AI-powered fleet energy efficiency platform that processes 2.5bn data points annually from more than 700 vessels. This advanced system uses machine learning to forecast and optimise fuel consumption and safety, taking into account environmental conditions including ocean currents and weather.  Along with optimising our current network efficiency, significant planning efforts in 2024 went into the Gemini Cooperation with Hapag --Lloyd, which went live on 1 February 2025. The new East-West trade network is built on a fundamentally different design and includes 29 ocean mainliner services and an extensive network of interregional shuttle services making transhipments to strategically selected hubs (ports). Gemini will use leaner, single operator mainliner loops and have almost half the number of port calls per service rotation compared to today. This means that the average number of stops a container makes between origin and final destination  will decrease significantly.  In addition to increased reliability and speed, Gemini will also improve network utilisation and fuel efficiencies. Gemini opened for bookings in December 2024; we will deepen our understanding of how the network supports our science-based targets and customers’ decar-bonisation journeys under actual operating conditions starting in 2025. Asset efficiencyAsset efficiency includes the overall design, technology and composition of our fleet, including a mix of owned and time-chartered vessels, and the operational flexibility this provides in reducing GHG emissions while also meeting network demand. Our fleet renewal strategy is also a key factor as Maersk works at a pace of roughly 160k TEU a year to ensure a gradual and continuous upgrade of our shipping capacity to new fuels.   In 2024, Maersk made significant progress in decarbonising its fleet by deploying seven large dual-fuel green methanol vessels, with addi-tional orders in the pipeline (see figure on page 85). These investments reinforce Maersk’s commitment to advancing sustainable shipping and driving the maritime industry’s energy transition.  Alongside the fleet renewal, Maersk continued implementing new and improved propellers and bulbous bows as well as retrofits and is also working with shore power enablement to reduce the need for vessels to consume fuels while in port. The establishment of a robust global regulatory framework this year by the International Maritime Organization (IMO) remains critical to a successful energy transition.  To increase asset efficiency in terms of investing in new, dual-fuel vessels as well as retrofitting our existing fleet, Maersk has invested USD 1.2bn in 2024, out of which USD 1.2bn is EU Taxonomy aligned under activity 6.10 and 6.12 (read more on page 97). Until 2030, we expect to invest an additional USD 10.9bn into new and existing assets. Energy shift-driven decarbonisationThe second fundamental part of our transition plan is a shift  to powering our business activities using energy with a lower  climate impact. In our Ocean business, this includes switching to new fuels like biodiesel, green methanol and liquefied bio-methane, and our approach to securing these fuels, as the mar-ket mature and scale across multiple pathways. In Logistics  &amp; Services and Terminals, it includes the electrification of  previously fossil fuel-powered trucks, warehouse vehicles and terminal container handling equipment. It also includes the  use of renewable electricity to reduce scope 2 emissions.Fuel shifts Our shift away from fossil fuels, contributing to reducing Ocean emis-sions across 700 owned and time-chartered vessels, is particularly influenced by externalities. This includes customers’ willingness to cover part of the cost gap between conventional and green fuels, which in turn is dependent on regulators setting industry standards and cre-ating supportive policies. In addition, we are dependent on innovation and external investments to scale green fuel production, infrastruc-ture and renewable electricity to responsibly produce green fuel. As our transition plan matures, we see network and asset efficiency levers playing a greater role in reaching our science-based targets, as outlined on the previous pages. A.P. Moller - Maersk (Maersk) therefore now anticipates a need for between 10-20% green fuels by 2030 to reach our Ocean targets (depending on growth), which de-risks our plan compared to the 25% green fuels expectation communicated in 2021.    Maersk’s actions relating to shifting to green fuels are twofold: In areas where we have higher control and influence, such as our fleet renewal and green fuel offtake agreements, we have a strong executional focus. For areas with significant external dependencies, such as customer willingness and industry-level policy, we take a strong engagement and advocacy focus.   Shifting to green fuels is a balancing act between various, sometimes conflicting demands, including market viability, customer requirements, current and emerging regulations and our own science- based targets. We follow a diversified, fuel-agnostic portfolio strategy to ensure we can cut emissions now and over the mid-term as multiple pathways to net-zero emissions mature and, in the case of fossil fuels, start to wind down.Securing green fuels for current and future operationsMaersk’s long-term commitments to green fuels, including methanol, biomethane and the biodiesel, currently used in our ECO Delivery Ocean offering, help us to reduce greenhouse gas (GHG) emissions and to meet customer demands today. They also send important demand signals to the industry, which incentivises more production scaling. We also continue exploring promising future green energy sources such as ammonia.   Successfully transitioning to green fuels is not, however, limited to securing fuel supplies and investing in vessels that can sail on them. It also requires increasing the industry’s knowledge on how to safely operate low-emissions transport, establishing the needed policies, procedures and permitting, and developing the infrastructure required for a global transformation to net-zero supply chains.  Maersk progressed along its methanol fuel pathway with the launch of seven large dual-fuel methanol vessels during 2024. This included six name-giving events in various strategic cities, including Aarhus, Singapore and Los Angeles. These name-giving events are important opportunities to engage with our customers, regulators, employees and business partners in welcoming the additions to our fleet and celebrating progress in the industry’s green transition.    Maersk has 11 large (16,000-17,000 TEU capacity) dual-fuel vessels scheduled for delivery in 2025 as well as six smaller (9,000 TEU) dual-fuel vessels coming in 2026-2027. In November, we successfully took delivery of the Maersk Halifax – the world’s first retrofitted dual-fuel methanol vessel.  To secure green methanol for these vessels, we have made important offtake agreements, including an October 2024 long-term bio methanol offtake agreement with LONGi Green Energy Technology Co., Ltd. Maersk’s requirements for green fuelsOur approach to green fuels is guided  by requirements across three pillars. 1) All green fuels must be certified by a third party to  ensure credibility and have a proof of sustainability.2) We look at lifecycle GHG savings; all fuels must meet  the minimum reductions of the EU Renewable Energy Directive which is 65% for biofuels and 70% for e-fuels compared to referenced fossil fuel. 3) Maersk only accepts second-generation feedstocks  such as wastes and residues, i.e. we do not accept any first-generation food and feed crops. In addition to climate impacts, when assessing the life-cycle impact of new fuels, we consider a broad range of environmental indicators such as biodiversity, ecosystems, resources and materials depletion, human health and eco-toxicity, air and water quality. We use lifecycle assessment and also consider indirect effects of fuel use such as indi-rect land use and other marginal effects to avoid shifting the burden of GHG emissions and impacts from one stake-holder to another.Our lifecycle analysis of prioritised current and possible future green fuels for ocean shipping is governed by  three policies, which are available online:Maersk green fuel requirements Maersk biofuel sustainability requirements Maersk methanol sustainability requirements Maersk’s combined methanol offtake agreements now meet more  than 50% of the expected dual-fuel methanol fleet demand in 2027.  In 2024, Maersk sourced green fuels valued at above USD 250m towards our ECO Delivery solutions sold to customers. Until 2030, we anticipate spendings in the range of USD 2-8bn on green fuels depend-ing on growth, outcomes of the IMO and other uncertainties that will impact our transition plan towards 2030. As OPEX for fuels is not included in the scope of the OPEX KPI under the EU Taxonomy, these expenses are not included in Maersk’s EU Taxonomy reporting.  Maersk is taking steps to diversify its fuel pathways, with our energy transition plan and fleet renewal strategy built around an expectation for a multi-fuel future. In August 2024, we announced our intention to add 50-60 newbuild dual-fuel vessels to our fleet as part of our on-going fleet renewal programme. In December, Maersk executed on the fleet renewal plan, with the ordering of 20 owned vessels for our fleet. With these orders, Maersk concluded the intended owned newbuilding orders announced in the August update of the fleet renewal plan.In addition to these new dual fuel vessels, our fleet renewal plan also includes retrofitting existing vessels. This year, Halifax became the industry's first retrofitted dual-fuel methanol vessel.  Time-chartered vessels represent approx. half our fleet of 700+  vessels and are also part of these renewal orders to support scope 1 emissions reduction targets from subcontracted ocean shipping.  These vessels will be a combination of dual-fuel methanol and dual-fuel liquified methane vessels.    Bio and e-methanol are likely to be the most competitive and  scalable pathways to decarbonisation in this decade. Liquefied bio and e-methane also meet Maersk’s green fuel requirements for emission reductions, and we are now engaging the market to seek a scalable sup-ply of these fuels. At the same time, there is a risk of methane slippage linked to the production of methane that impacts upstream scope 3 value chain GHG emissions. Therefore, more focus is needed on feedstock pro-curement and upstream processing. Methane slip is also a risk on vessels, and Maersk is committed to using engine types with the lowest methane slip. We also continue to explore other promising fuel pathways like ammonia, which is scalable but poses safety concerns due to its toxicity.   Maersk is further engaging with ports in many regions to establish safe methanol bunkering procedures and permitting, building on pro-gress in 2023 from early adopters such as Singapore and Rotterdam.  Maersk's own dual-fuel  vessel investments2023Laura Mærsk, the world’s  first methanol-capable  container vessel2,100 container capacity20247 large vessels113,000 total container capacity202511 large vessels168,000 total container capacity2026-20276 vessels54,000 total container capacity2028-203020 vessels 300,000 total container capacityIn 2025, Maersk will continue defining a roadmap for the right asset mix to move, store, blend and bunker new fuels like methanol, and the right policy support to get those fuels onto our vessels.Fuels for air transportationCustomer demand for integrated supply chains that include air freight remains high, especially for cargo of high value or with demanding delivery schedules. Yet reducing airfreight GHG emissions is one of the most challenging tasks in decarbonising logistics due to the high abatement costs of sustainable aviation fuel (SAF) and the lack of  production or distribution scalability.   Whereas there are effective short-term solutions to decarbonise ocean and landside operations, air cargo presents a long-term chal-lenge due to its significant dependency on technology developments and industry and government-level regulation.   In 2024, we added two new Boeing 777Fs to our fleet, one of the most fuel-efficient freighters available today, especially for long- haul operations. Regulatory and customer impacts on our fuel transitionThe regulatory landscape and its impact on our customers’ transport choices has a profound importance for our ability to shift to green fuels. 2024 saw the inclusion of shipping in the EU Emissions Trading System (ETS), a market-based mechanism designed to reduce European Economic Area emissions. An even stronger driver in the coming years will be the new FuelEU Maritime legislation, which comes into force in January 2025 and introduces increasingly stricter limits on GHG inten-sity for ships calling on European ports. It favourably includes a well-to-wake approach which Maersk already uses and advocates for, as well as looking beyond carbon to include other GHG such as methane and nitrous oxide.   At the same time, FuelEU Maritime is complex, with numerous unresolved issues around definitions, compliance and financial mech-anisms that require resolution. Implementing a regional standard for fuels which are purchased and consumed in international trade cre-ates challenges and inconsistencies. Maersk therefore advocates for a global industry standard through the IMO to create a level playing field for all nations. The IMO Carbon Intensity Indicator (CII) is to be reviewed by 2026. Depending on the outcome of this review, the CII could also have an impact on the energy transition towards 2030.  Closing the price gap between fossil fuels and green fuels is one of the most critical IMO policy needs. The IMO’s Marine Environment Protection Committee MEPC 83 meeting in April 2025 will be crucial for refining and approving mid-term measures, including marine fuel standards and a pricing mechanism, which will be formally adopted at an extraordinary MEPC session in October 2025. Maersk actively sup-ports effective mid-term measures and works towards measures that secure a multi-fuel future for shipping, and a just and equitable transi-tion for all countries.   The ambition level and regulatory clarity of these agreements will have an impact on the pace and scale of the global shipping industry’s energy transition, as well as Maersk’s fuel strategy. In a pessimistic scenario, a low ambition level of IMO regulations would result in a patchwork of regional and country regulations that would make decar-bonisation compliance more complex, maintain the cost gap between green and fossil fuels and decrease financial investments needed for scaling due to their higher risk.   In a more optimistic scenario for an IMO agreement with high ambition and regulatory clarity, effective finance mechanisms would be enacted that result in green and fossil fuels reaching price parity. This would make green fuels the obvious choice for shipping cus-tomers and the need for additional funding of the green fuel transi-tion would go down. This would also derisk and further catalyse fur-ther capacity and infrastructure investments to accelerate the green energy transition.   Between these two extremes is a ‘base case’ scenario which would secure some supportive measures but with less ambition and clarity of the  optimistic scenario. This could create the need for shipping cus-tomers to cover additional costs in the medium term, so the industry’s transition speed would be affected by a lower willingness to pay in the market . The biggest question under this scenario therefore is whether it will be sufficient to drive the industry to commit and act on reducing GHG emissions in time.  The outcomes of the eventual IMO agreement will naturally have a significant impact on our customers’ capacity to act on commitments for decarbonisation. Many Maersk customers, including almost 60% of our top 200 custom-ers, share our recognition of the urgency of acting on climate change and have set or com mitted to science- based targets. At the same time, they had to navigate higher raw materials, fuel and freight costs and higher interest rates, all in 2024, as well as prioritising resilience in the face of many global supply chain disruptions and uncertainties.  As the affordability of decarbonisation is challenged, this may lead some companies to pull back on their SBTi commitments. Under pessi-mistic or base case IMO scenarios, the business case for companies to increase the maturity of their decarbonisation commitments will be more difficult.   In 2024, absolute volume rate increases for Maersk ECO Delivery product offerings were lower than previous years, under high fuel price pressures. However, we optimistically see continued customer interest in building long-term volume commitments in ECO Delivery Ocean, the most mature of our ECO Delivery products.Electrification of owned assetsElectrification of owned assets, while being a relatively low contributor to the transition plan, is a vital decarbonisation lever for APM Terminals and Logistics &amp; Services. It includes replacing diesel terminal container handling equipment with electric versions, connecting existing and newbuild warehouses and terminals with renewable electricity and adding supportive infrastructure to these sites such as EV charging stations for electric equipment and vehicles.  These ambitions are highly dependent on local renewable electricity capacity, grid reliability and market, for example, our ability to enter into power purchasing agreements with state-owned utilities. Therefore, in less mature renewable electricity markets, our approach focuses on advocacy and engagement with local officials to drive policy change and infrastructure investments, as well as joint planning with govern-ments and utility companies to upgrade grids.Electrification of terminalsFor APM Terminals, shifting from fossil-fuelled equipment in our ports to battery-electric container handling equipment is the main lever for reducing scope 1 GHG emissions. During 2024, we rolled out such equipment in Egypt, Jordan and Spain as part of our USD 60m electrification pilot programme.   In 2023, APM Terminals and DP World jointly announced the Zero Emission Port Alliance (ZEPA), an industry-wide strategic coalition aim-ing to accelerate the adoption of battery-electric container handling equipment in ports. In December 2024, ZEPA published its first annual findings. It expects demand to rapidly accelerate in the coming years but notes the need for standardisation to ensure widespread adoption as well as the importance of grid and infrastructure updates to support increased terminal power demand.  While some electric equipment prices have fallen and reached cost parity with fossil fuel alternatives from a total cost of ownership per-spective, many electric container handling equipment categories still have a large price gap to diesel-powered alternatives. This is largely driven by a lack of scale or standardisation – for example the wide divergence in battery sizes, charging infrastructure and software for battery-electric equipment.   To meet science-based scope 1 targets, APM Terminals is commit-ted to electrifying assets at the time of their scheduled replacement. This transition is expected to require an overall CAPEX of USD 1.1bn to 1.2bn until 2030, which includes investments in battery-electric con-tainer handling equipment and infrastructure needed for electrifica-tion. Investments into the electrification of Terminals is included in Maersk’s EU Taxonomy reporting of CAPEX, amounting to USD 513m in 2024. Read more on page 97.  Despite higher initial investments, the long-term operational ben-efits from electrification are expected to offset a portion of the cost. These savings come from reduced diesel consumption and the posi-tive financial impact of long-term power purchase agreements (PPAs) and onsite solar projects. Ultimately, the investment in the electrifi-cation of our assets will support both sustainability objectives and financial performance.  For scope 2 emissions, the ambition is to transition to 100% renew-able energy by 2030. In 2024, approx. 45% of APM Terminals’ electricity was powered through renewable sources. These initiatives have resulted in more than 8% reduction in absolute scope 1 and 2 emissions in our Terminals in 2024 compared to our 2022 baseline.   Our USD 2bn investments in two newbuild terminals in Suape, Brazil, and Rijeka, Croatia, and the expansion of the MV II terminal in the Nether lands include all the infrastructure that is needed for electrified operations, which will run on renewable electricity. The investment includes infrastructure for charging of battery- electric equipment and solar panels.  In addition to the improvements in air quality that electrified con-tainer handling equipment provides for local communities, APM Termi-nals also focuses on the social impact to our workforce and communi-ties. This includes upskilling opportunities for our workforce to operate battery electric equipment, and a more pleasant work environment with reduced noise and odours, and lower equipment vibrations.Electrification of our warehousesIn warehouse operations, we focused in 2024 on energy efficiency retro fits, upskilling our frontline teams in energy management at our 500+ facilities and on building a data foundation to provide emission visibility to customers at a warehouse level. We also continue to ensure that all newbuild facilities are green building certified to the highest efficiency standards. In June 2024, Maersk opened a BREEAM Excellent certified warehouse in Taulov Dry Port, Denmark. The warehouse has zero direct emissions from operations and all indoor and outdoor equipment is electrified.  Certified buildings and electrification of equipment in our warehouses are important levers to Maersk and part of our Green Finance Frame-work, which also saw allocation to green bonds issued earlier in 2024.Energy shifts of business partnersLandside logistics are often the largest source of GHG emissions in our customers’ supply chains, and there is strong demand for both land-side decarbonisation solutions and integrated logistics solutions across ocean, land and air. In addition, it represents a large share of scope 3 emission reductions in our transition plan. Our emission reduction solu-tions currently rely on a mix of EVs and transitional fuels like bio fuels, as well as modal shift to more efficient transport modes within our landside network such as rail. Our aim is to provide emission visibility while offering lower emission solutions across inland modes.  Maersk owns some landside transport assets, such as our fleet of 100+ Volvo VNR electric trucks in North America. However, most of our landside logistics services are delivered through third party partner-ships with trucking companies across our operational footprint. There-fore, our ability to decarbonise landside logistics depends on their will-ingness and ability to invest in replacing fossil fuel powered road vehicles such as heavy and light delivery trucks with EVs. It also depends on local energy providers and infrastructure to ensure sufficient power grid capacity, reliability and charging station availability.   Maersk’s ECO Delivery Inland product is our main offering for truck, rail and barge logistics decarbonisation, together with the Emissions Studio product, which offers increased visibility over transportation emissions. Improving ECO Delivery Inland availability and scalability are key focus areas for 2025, as both are key customer value drivers.   We have already started EV-powered truck operations with partners in Spain, China, Sweden, Denmark, UK, Thailand and Brazil, with more in development. We are also working on ECO Delivery Inland for rail, with pilots for barges underway.  To address investment barriers for our suppliers, our focus is on cost reduction through scaling and demand certainty for both EV manufac-turers and grid owners, encouraging them to invest and scale, which will further drive down costs for our customers.Physical climate risks exposure The past decade has been the warmest on record globally with 2024 becoming the first year to exceed 1.5°C above pre-industrial levels, cou-pled with increased frequency and intensity of extreme weather events.   In 2022, in collaboration with external consultants, we performed an in-depth assessment of the physical impact of climate change on Maersk’s business. 107 assets were selected for analysis, including ter-minals, warehouses, data centres and third-party operated property. The assets were mapped against prevailing climate hazards such as heatwaves, flooding, windstorms, water stress etc, and modelled across multiple time horizons and climate scenarios. Estimated loss values were determined based on losses to impacted assets (property damage and disruption costs) but excludes the resulting effect on the network.  The illustration to the right shows our top five assets at risk by 2050 in a “middle of the road” SSP2-4.5 scenario (+2.5°C by 2100), represent-ing a future based on stated policies. In the assessment, we have also considered risks under SSP5-8.5 (+3.0°C by 2100) and SSP1-1.9 (+2°C by 2100) scenarios, with the former showing a higher level of extreme climate impacts, and the latter where risks are mitigated. Most of the financial impact from weather disruption and damage is concentrated around the five terminals presented to the right. The financial impact is driven by their exposure to temperate windstorms, coastal flood, drought/water stress, heatwave, and hurricane and storm.  As a response to the physical risk to our assets, all our majority owned terminals and large warehouse locations are part of a loss pre-vention programme entailing an assessment of climate change related exposure. In addition, we conduct risk engineering reports for selected exposed assets that inform mitigative actions at site level. For example, in APM Terminals Maasvlakte we have implemented actions such as elevating critical electrical infrastructure above ground level to miti-gate impacts of flooding and tying down equipment to be able to with-stand storms and floods. We have currently not developed a corporate policy or overall measurable targets, but we continue to assess the need for mitigative actions at site level.SSP2-4.5 SCENARIO BY 2050 Top 5 assets exposed  to physical climate risksAPM Terminals Maasvlakte IIRotterdam, the NetherlandsEstimated total annual revenue loss and asset damage in 205049.9 mKey climate risks •  Coastal flood•  Temperate windstormAPM Terminals  Pier 400Los Angeles, USAEstimated total annual revenue loss and asset damage in 2050Key climate risks•  Drought/water stressAPM Terminals ElizabethNew Jersey, USAEstimated total annual revenue loss and asset damage in 2050Key climate risks•  Temperate windstorm•  Heatwave•  Hurricane and storm surgeThe Suez Canal Container Terminal Suez Canal, EgyptEstimated total annual revenue loss and asset damage in 2050Key climate risks•  Temperate windstorm•  Heatwave•  Drought/water stressAqaba Container TerminalAqaba, JordanEstimated total annual revenue loss and asset damage in 2050Key climate risks•  Temperate windstorm•  HeatwavePerformance dataGross scopes 1, 2, 3 and total GHG emissions EFRAG IDRetrospective Milestones and target yearsE1-6_01E1-6_02E1-6_04E1-6_07E1-6_08E1-6_09E1-6_10E1-6_11Base Com-2024 % 2024 2025 2030 2040 Annual % E1-6_12E1-6_13E1-6_14E1-6_27year para tive /2023target/MDR-T_13(2022)(2023)1Base yearScope 1 GHG emissionsGross scope 1 GHG emissions  96% 232,404(1,000 tonnes CO22e) 34,41633,939 5% N/A 35%(S1 &amp; S2) 4%Percentage of scope 1 GHG emissions from regulated emission trading schemes (%) - - 16% - N/A N/A N/A -Scope 2 GHG emissionsGross location-based scope 2  2375GHG emissions (1,000 tonnes CO22e) 441431 15% N/AGross market-based scope 2  96% 2335GHG emissions (1,000 tonnes CO22e) 421356 6% N/A 100%(S1 &amp; S2) 13%Significant scope 3 GHG emissions Total gross indirect (scope 3)  GHG emissions (1,000 tonnes CO2e) 47,980 44,938 49,232 10% N/A 22% 90% 3%1) Purchased goods and services 3,248 5,728 5,383 -6% N/A N/A N/A N/A2) Capital goods 1,502 1,065 2,520 137% N/A N/A N/A N/A3) Fuel and energy-related activities  (not included in scope 1 or scope 2) 5,949 5,653 6,036 7% N/A N/A N/A N/A4)  Upstream  transportation  and distribution 26,574 20,465 23,759 16% N/A N/A N/A N/A5) Waste generated in operations 9 4 3 -25% N/A N/A N/A N/A6) Business traveling 156 141 134 -5% N/A N/A N/A N/A7) Employee commuting 21 25 20 -20% N/A N/A N/A N/A8) Upstream leased assets 121 130 624 380% N/A N/A N/A N/A11) Use of sold products 8,799 10,428 9,699 -7% N/A N/A N/A N/A12) End-of-life treatment of sold products 313 391 298 -24% N/A N/A N/A N/A13) Downstream leased assets 531 155 178 15% N/A N/A N/A N/A15) Investments 757 753 578 -23% N/A N/A N/A N/ATotal GHG emissions (1,000 tonnes CO2e)277,717Total GHG emissions (location-based) 82,83783,602 8% N/A N/A N/A N/A277,677Total GHG emissions (market-based) 82,81783,528 8% N/A N/A N/A N/A1  Not covered by the Independent Auditor’s limited assurance report.2  Numbers restated due to improved reporting processes.For 2024, Maersk’s total emissions increased by 8% compared to 2023. This was mainly driven by an increase of 5% in scope 1 emissions and an increase of 10% in scope 3 emissions. The increases in both scope 1 and scope 3 to a large extend relate to increased emissions from the additional fuel consumption needed for  the extended re-routing around the Cape of Good Hope, caused by the Red Sea situation, from both our own vessels and chartered vessels, and from vessel-sharing agreements and supply chain partners.  ACCOUNTING POLICIES Scope and consolidationThe consolidation of greenhouse gas (GHG) emissions data is based on the financial consolidation approach and stated in accordance with the GHG Protocol: direct emissions from owned and long-term leased-in assets as defined by IFRS 16 (scope 1), indirect emissions from purchased electricity and district heating (scope 2), and value chain emissions (scope 3), which also includes emissions related to leased out assets as defined by IFRS 16. For more information, see the sustainability statement basis of preparation.Emissions reporting for entities under operationsIn 2024, it has been assessed that Maersk does not have operationally controlled investees in e.g. associates, joint ventures, or unconsolidated subsidiaries. This implies that the scope and treatment of entities under financial control and operation control do not differ for 2024. Thus, no separate disclosures are provided for Maersk’s GHG emissions, including operationally controlled inves-tees in e.g. associates, joint ventures, or unconsolidated subsidiaries. Maersk is annually reviewing its contractual arrangements in line with CSRD requirements.Emission conversions and calculationsGHG emissions are calculated using conversion factors for energy consumption and other GHG gases. Primary schemes used for activity-based calculations are Sixth Assessment Report (AR6, 2022), European Monitoring and Evaluation Programme/European Economic Area (EMEP/EEA air pollutants database, 2023), International Energy Agency (IEA, 2024), Global Logistics Emissions Council (GLEC) framework, (updated 2023), and Depart-ment for Environment, Food and Rural Affairs (UK) (2024). The Comprehensive Environmental Data Archive 6 (CEDA 6) (2022) is used for spend-based estimates. Relevant spend is adjusted to 2018 levels using the latest data from Oxford Economics (Q3 2024) to ensure compara-bility with the base year of the spend-based emissions factors. The principles for choosing among the schemes for default conversion factors are:•   The most recent and internationally recognised  schemes are preferred•  Specific industry schemes can be included when  not in conflict with the above. Gross scope 1 GHG emissionsGross scope 1 GHG emissions is the sum of all UNFCCC/Kyoto gases converted to CO₂ equivalents. UNFCCC/Kyoto gases comprise: CO₂, CH₄ and N₂O, which are calculated based on amount of direct energy (i.e. the fuels stated un-der ‘Energy consumption’) that are consumed/combusted, and HFCs, PFCs, SF₆ and NF₃, which are based on direct consumption at entities/vessels controlled by Maersk.Percentage of scope 1 GHG emissions from regulated emission trading schemesPercentage of scope 1 GHG emissions from regulated emission trading schemes is the share of Maersk’s gross scope 1 GHG emissions covered by the EU ETS.Gross location-based scope 2 GHG emissionsGross location-based scope 2 GHG emissions is the CO₂ equivalents’ converted sum of CO₂, CH₄ and N₂O, calcu-lated based on consumed electricity and district heating bought from a third party and using location-based IEA emission factors.Gross market-based scope 2 emissionsGross market-based scope 2 GHG emissions is the CO₂ equivalents’ converted sum of CO₂, CH₄ and N₂O, calcu-lated based on consumed electricity and district heating bought from a third party and using country-specific market-based factors for EU countries and the US and IEA factors for other countries. In markets where Maersk pro-cures renewable electricity, this is used as part calculating the gross market-based scope GHG emissions, provided appropriate EAC documentation is available.Significant scope 3 GHG emissionsValue chain GHG emissions (scope 3 GHG) are the CO₂ equivalents’ converted sum of CO₂, CH₄ and N₂O from Maersk’s value chain activities. Of the 15 scope 3 cate-gories in the GHG Protocol, 12 categories are currently determined as applicable to Maersk’s business model and activities. The excluded categories are: •  Category 9 – downstream transportation and  distribution, since we do not produce products  that we need transportation for.•  Category 10 – processing of sold products, since  our business model is transport and logistics services for our customers’ goods. •  Category 14 – franchises, since we do not have  franchises. Thus, value chain GHG emissions comprise of emissions relating to: •  Category 1 – purchased goods and services, which are reported based on financial data and includes goods for our operations. •  Category 2 – capital goods, which is reported based  on life cycle assessments and reported capital expend-iture. This category covers capital investments such as new asset purchases, retrofit of vessels and dry docking. We include the full scope 3 impact in the year of investment. •  Category 3 – fuel and energy-related activities,  which is reported based on actual fuel procured and consumed. •  Category 4 – upstream transportation and distribution, which is reported based on transportation data re-corded in operational systems. The resulting emissions are estimated following the Global Logistics Emissions Council (GLEC) methodology per transport type. For supporting logistics-related activities like towage ser-vices, financial data is multiplied by relevant emission factors. •  Category 5 – waste generated in operations, which is reported based on amounts and types of waste. •  Category 6 – business travel, which is reported based on activity-data for our direct air travel and procure-ment data for other business travel related activities. •  Category 7 – employee commuting, which is reported based on employee headcounts per location, estimated commuting distance and transportation modes.•  Category 8 – upstream leased assets, which is a spend-based estimate of emissions from leased assets that is not reported in scope 1 and 2. •  Category 11 – use of sold products, is based on activity data for fossil fuels distributed by Maersk to third par-ties, estimated fuel use of liners calling APM Terminals, and estimated emissions from the use of refrigerated containers produced by Maersk Container Industry. •  Category 12 – end-of-life treatment of sold products, which is reported based on activity data for end of life and retreatment of sold new and second-hand reefers.•  Category 13 – downstream leased assets, which is re-ported based on fuel consumption from vessels, tugs and planes leased to third parties. •  Category 15 – investments, emissions are calculated  to the extent of the equity share in non-controlled  joint ventures and associates using financial data and corresponding factors. Total gross scope 3 emissions  is the emissions related to the 12 significant scope 3  categories outlined above.Total GHG emissionsTotal GHG emissions have been stated as both the sum of scope 1, scope 2 – location-based and scope 3 emissions as well as scope 1, scope 2 – market-based and scope 3 emissions.Annual % target /base yearThe annual % target/base year is the percent average annual emission reduction per year required to meet Maersk’s 2030 target. The annual % target/base year  is calculated using the following formula:  emissions in target year 1 -     emissions in target base year   target year – base year Uncertainties and estimatesGHG emissions from upstream transportation and dis-tribution activities are modelled using the EcoTransIT World (ETW) online tool. In cases, where Maersk does not have access to information of the actual fuel con-sumption and/or route information of third-party trans-portation activities, we use the ETW and its worldwide transportation route network and vehicle model data set to estimate the emissions from such activities. Maersk uses actual activity data from its transport management systems for the GHG modelling in ETW. The actual data from Maersk’s systems that are used for the modelling are:•  Origin and destination details.•  Carrier mode to be considered for segregation of  transport mode. Presently it can contain ocean,  air, trucks, rail and vans.•  Carrier actual weight.The share of Maersk’s total scope 3 emissions for 2024 that have been modelled using the ETW tool is 28.44%.Progress towards Maersk’s 2030 and 2040 targetsRetrospective Milestones and target yearsBase 2023 2024 % 2024/ % 2024/ 2030 2040 Annual % EFRAG IDyear (1,000 (1,000 2023Base yeartarget/MDR-T_13(2022)tonnes tonnes Base year1 (1,000 CO22e)COe)tonnes CO2e)Scope 12Absolute reduction in total  34,416 32,40433,939 5% -1% 35% 96% 4%scope 1 emissionsScope 22421 335356 6% -15% 100% 100% 13%Renewable electricity sourcingScope 3Absolute reduction in total  47,980 44,938 49,232 10% 3% 22% 90% 3%scope 3 emissionsMaritime operationsAbsolute reduction in scope 1 and scope 3 well-to-wake emissions from 38,134 35,884 38,079 6% 0% 35% 96% N/Aown container shipping operationsAbsolute reduction in scope 3 well-to-wake emissions from subcontracted 11,725 8,531 10,921 28% -7% 17% 97% N/Acontainer shipping operationsOther operationsAbsolute reduction in scope 1  and scope 2 emissions from all  1,937 1,697 1,667 -2% -14% 42%other sourcesAbsolute reduction in scope 3 Fuel  and energy-related activities and  15,143 12,983 13,069 1% -14% 25%Upstream transportation90%3N/AAbsolute reduction in scope 3 emissions  from Use of sold products covering  6,450 7,932 8,105 2% 26% 42%distributed fossil fuelsAbsolute reduction in scope 3 emissions 49,006 10,314 11,331 10% 26% -from all other sources1  Not covered by the Independent Auditor’s limited assurance report.2  Numbers restated due to improved reporting processes. 3  Maersk has validated targets to reduce emissions from other operations than maritime operations by 90% in 2040. In addition, Maersk has near-term (2030) sub-targets in relation to other operations than maritime operations that relate to significant emissions categories, which support the delivery of the overall 90% reduction target for 2040. This is in line with the SBTi Net-Zero Standard, accounting for the ongoing updates in global frameworks regarding the applicability of market instruments in meeting net-zero emissions targets.4  Outside the near-term (2030) target boundary. Work to reduce the scope 3 emissions from all other sources in other operations will be performed in the 2030 to 2040 time period.For 2024, our absolute scope 1, scope 2 and scope 3 emissions increased by 5%, 6%, and 10%, respectively, compared to 2023, and thus trending in the wrong direction. The absolute emissions were significantly  negatively impacted by the re-routing of vessels around the Cape of Good Hope, which resulted in longer distances and increased fuel consumption throughout 2024. Compared to Maersk’s baseline in 2022, we have reduced our absolute scope 1 emissions by 1% and scope 2 emissions by 15%. Our scope 3 emissions have increased by 3% in the same period. In addition to the impacts of the re-routing, we took delivery of more dual-fuel vessels during 2024 compared to previous years. This has also increased our scope 3 emissions.  ACCOUNTING POLICIES Main targets Absolute reduction in total scope 1 emissionsThe absolute reduction in total scope 1 emissions is stated as a percentage reduction of scope 1 in the reporting year (2024) compared to the base year (2022) and previous year.Absolute reduction in scope 2 emissionsThe absolute reduction in scope 2 emissions is stated as the percentage reduction of scope 2 (market-based) in the reporting year (2024) compared to the base year (2022)and previous year.Absolute reduction in total scope 3 emissionsThe absolute reduction in total scope 3 emissions is stated as a percentage reduction of scope 3 in the reporting year (2024) compared to the base year (2022) and previous year.Uncertainties and estimatesWhen preparing the reporting of emissions related to short-term charter vessels, Management applies judge-ment in the categorisation of such emissions as to whether they should be categorised as own (scope 1) or value chain (scope 3 category 4 upstream transportation and distri-bution) emissions. For 2024, we have included emissions from short-term charter vessels in scope 3. This is a change compared to previous years, where emissions from short-term charter vessels have been included in scope 1. Recat-egorisation of emissions between scopes for comparison years before application of ESRS has not been done.  Total emissions reported for all years are complete.  Had we restated comparative numbers to align with the approach for classification of emissions from short-term charters applied for 2024, Maersk’s scope 1 emissions would have increased by 11% in 2024, while Maersk’s scope 3 emissions would have increased by 6% compared to 2023. Equally, Maersk’s absolute reduction in scope 1 and scope 3 well-to-wake emissions from own container shipping operations, would have increased to 11% in 2024 compared to 2023.Sub-targets – Marine operations Absolute reduction in scope 1 and scope 3 well-to-wake emissions from own container shipping operationsThe absolute reduction in scope 1 and scope 3 well-to-wake emissions from own container shipping operations  is stated as the percentage reduction of scope 1 and scope 3 well-to-wake emissions from own container  shipping operations in the reporting year (2024)  compared to the base year (2022) and previous year.Absolute reduction in scope 3 well-to-wake emissions from subcontracted container shipping operationsThe absolute reduction in scope 3 well-to-wake emissions from subcontracted container shipping operations is stated as the percentage reduction of scope 3 well-to-wake emissions from subcontracted container shipping operations in the reporting year (2024) compared to the base year (2022) and previous year.Sub-targets – Other operations Absolute reduction in scope 1 and scope 2 emissions from all other sourcesThe absolute reduction in scope 1 and scope 2 emis-sions from all other sources is stated as the percentage reduc tion of scope 1 and scope 2 emissions for all other (non-maritime) operations, including emissions from ter-minals, landside logistics and air freight operations in the reporting year (2024) compared to the base year (2022).Absolute reduction in scope 3 Fuel and energy- related activities and upstream transportationThe absolute reduction in scope 3 Fuel and energy- related activities and Upstream transportation emissions is stated as the percentage reduction of scope 3 Fuel and energy related activities (Category 3) and Upstream transportation (Category 4) for all other (non-maritime) operations in the reporting year (2024) compared to the base year (2022) and previous year.Absolute reduction in scope 3 emissions from the use of sold products covering distributed fossil fuelsThe absolute reduction in scope 3 Use of sold products covering distributed fossil fuels is stated as the percentage reduction of scope 3 Use of sold products (Category 11)  relating to distributed fossil fuels in the reporting year (2024) compared to the base year (2022) and previous year.Absolute reduction in scope 3 emissions from all other sourcesAbsolute reduction in scope 3 emissions from all  other sources is stated as the percentage reduction  of scope 3 emissions for all other (non-maritime) oper-ations in the reporting year (2024) compared to the base year (2022) and previous year.Annual % target/base yearThe annual % target/base year is the percent average annual emission reduction per year required to meet Maersk’s 2030 target. The annual % target/base year is calculated using the following formula:  emissions in target year 1 -     emissions in target base year   target year – base year How Maersk ensures consistency of GHG emission  reduction targets with GHG inventory boundariesMaersk has validated near-term and net-zero climate targets by Science Based Targets initiative (SBTi), a widely recognised global standard for corporate target setting. Maersk’s climate inventory follows the require-ments of the Greenhouse Gas Protocol, covering all greenhouse gas emissions. Maersk’s climate inventory follows the financial control approach for target setting, which translates to a 100% inclusion of emissions from activities by subsidiaries and an equity share of emissions for joint ventures and asso-ciates included under scope 3.15 Investments.  Maersk currently has near-term and net-zero climate targets for scope 1, 2, and 3, and complementary sub targets in line with the requirements of SBTi’s maritime sector decarbonisation guidance. Maersk’s near-term target covers &gt;95% of scope 1 and 2 and &gt;66% of scope 3; the net-zero coverage is &gt;95% and &gt;90% respectively. These thresholds are in line with SBTi requirements. The emissions reduction targets are gross targets, meaning that GHG removals, carbon credits or avoided emissions are not currently considered as means of achieving the GHG emission reductions.  Maersk ensures its climate targets are relevant and follow the latest climate standards by means of a recal-culation policy of climate inventories and targets. The recalculation policy is publicly available and follows the latest requirements of the Greenhouse Gas Protocol and Science Based Targets initiative (SBTi), outlining the types of changes and thresholds that trigger a recalculation and restatement of previously reported greenhouse gas emis-sions. Please see the Maersk recalculation policy. Maersk endeavours to ensure consistency, accuracy, completeness and comparability in public reporting of emissions and  externally committed greenhouse gas reduction targets.GHG emission intensityEFRAG IDIndicator Unit 2024E1-6_30GHG emission intensity (location-based) 1,000 tonnes CO₂e/USDm 1.51E1-6_31GHG emission intensity (market-based) 1,000 tonnes CO₂e/USDm 1.51The GHG emission intensity for 2024 is 1.51k CO2e/USDm both when calculating based on location- and  market-based scope 2 emissions.  ACCOUNTING POLICIES GHG emission intensityGHG emission intensity is the GHG emissions expressed per unit of revenue (million) – based on total GHG emissions (sum of reported scope 1, scope 2 – location- based and scope 3 emissions) and revenue as stated in the income statement of the consolidated financial statements.Efficiency in OceanEFRAG IDIndicator Unit 2024 2023111202220212020Entity  specificEnergy efficiency operational indicator (EEOI) Intensity 11.1 11.7 13.0 13.0 12.21  Not covered by the Independent Auditor’s limited assurance report.In 2024, Maersk continued increasing the energy efficiency of our fleet, despite the negative impact on fuel consumption of the network diversion around the Cape of Good Hope. The Red Sea situation has resulted in longer routes and increased fuel consumption. To address these challenges, Maersk has continuously focused on network optimisation and maintained a relentless focus on vessel utilisation within our operations, resulting in year-on-year improvement in our efficiency in CO2 emitted per tonne mile. Maersk has also continued to invest in and expand proven initiatives, increasing the adaption of Star-Connect and successfully rolling out new features. Efficiency retrofits in both owned and time-chartered vessels have also continued, with shore power enablement and the first large container vessel conversion to the dual-fuel methanol engine of Maersk Halifax.The use of second-generation biodiesel remains an important lever and has been complemented by the steady increase in biomethanol, with the delivery of seven dual-fuel methanol vessels.These initiatives have delivered efficiencies at a scale to significantly reduce the impact of increased fuel consumption caused by longer routes and has enabled us to continue driving down the EEOI, achieving a record of 11.1, down from 11.7 in 2023.   ACCOUNTING POLICIES Energy efficiency operational indicator (EEOI)The energy efficiency operational indicator (EEOI) covers container vessels under Maersk’s operation. EEOI is  defined by IMO in MEPC.1/Circ.684 and is calculated as gCO₂/(Tonne cargo x Nm). In practice, we calculate EEOI  on voyage level and aggregate it in the following way:(g CO222 voy 'n' + g CO voy 'n' + g CO voy 'n')((Tonne cargo x Nm)voy 'n' + (Tonne cargo x Nm)voy 'n' + (Tonne cargo x Nm)voy 'n')The data sources are:•   g CO₂ – Based on fuel consumption, from departure voyage 1, to departure voyage 2, multiplied with  relevant CO₂ factor (3.114 for HFO, 3.206 for MDO and  0 for biofuels).•   Tonne cargo – Calculated via draft and displacement tables, subtracting vessel weight and ballast water  and fuel stock.•   Nm – GPS distance from departure voyage 'n',  to departure voyage 'n'.Biogenic emissionsEFRAG IDIndicator Unit 2024E1-6_17Biogenic emissions not included in scope 1 1,000 tonnes CO2e 828For 2024, Maersk recorded 828k tonnes CO2e biogenic emissions not included in its scope 1 inventory.  Biogenic emissions are primarily related to the combustion of biofuels in Maersk’s Ocean operations.  ACCOUNTING POLICIES Biogenic emissions not included in scope 1Biogenic CO2 emissions result from the combustion or biodegradation of biomass. Biomass is defined as any material or fuel produced by biological processes of  living organisms, including organic non-fossil material  of biological origin (such as plant material), biofuels (such as liquid fuels produced from biomass feedstocks), biogenic gas (such as landfill gas) and biogenic waste (such as municipal solid waste from biogenic sources).  In Maersk’s current inventory, the calculation of biogenic CO2 is limited to the combustion of fuels based on bio-genic feedstock in Maersk’s scope 1 GHG emissions. This may expand based on evolving international standards detailing the treatment of biogenic emissions in corpo-rate inventories.Energy consumptionEFRAG IDIndicator Unit 2024 202312022E1-5_012Total energy consumption GWh 121,008 116,272 124,0702E1-5_19E1-5_022Fossil energy consumption GWh 117,664 113,831 121,7342E1-5_112Fuel oils  GWh 116,789 112,971120,7612E1-5_122Gas fuels GWh 101 106752E1-5_13Other fuels GWh 14 14 62E1-5_142Electricity and heating from fossil fuel sources GWh 760 7408932E1-5_052Renewable energy consumption GWh 3,344 2,4412,3362E1-5_07Renewable electricity GWh 303 231 2302E1-5_063Green fuels GWh 3,034 2,2042,1063E1-5_08Self-generated non-fuel renewable energy GWh 7 6 01  Not covered by the Independent Auditor’s limited assurance report.2  Numbers restated due to improved reporting processes.3  Previously reported numbers for green fuels have been restated as a result of an improved reporting practice. In previous years, the amount of green fuels was based on invoiced amounts. With the roll-out of StarConnect to the entire fleet, the actual amount of green fuels consumed on the vessels are now collected and used for reporting. The numbers for consumption of green fuels have been restated accordingly. For 2024, the total energy consumption increased by 4% compared to 2023. The increase was mainly related to an increase in fuel oils consumption related to the Red Sea situation and re-routing of vessels around the Cape of Good Hope. While relatively smaller, the consumption of renewable energy increased by 37% in 2024 compared to 2023. The increase was mainly driven by an increase in green fuels consump-tion and more terminals procuring renewable electricity.  ACCOUNTING POLICIES Scope and consolidationEnergy consumption data is collected per legal entity per energy type, and the figures are consolidated line by line. To ensure completeness in reported data from our offices within legal entities, office standards have been developed, which can be used for offices with no production or ware-houses. The office standards define average consumption values per FTE and are only used if other more accurate information is not available. Total energy consumptionTotal energy consumption is the sum of fossil energy  consumption and renewable energy consumption.Fossil energy consumptionFossil energy consumption encompasses all fossil-based energy consumption that is consumed/combusted at Maersk controlled entities/vessels. Fossil energy con-sumption includes the following: •   Fuel oil, including heavy fuel oil, marine diesel oil,  gasoline, diesel and kerosene•   Gas fuels, including liquified petroleum gas (LPG),  liquefied natural gas (LNG) and natural gas•  Other fuels, including heating oil and cylinder oil•  Electricity and heatingRenewable energy consumptionRenewable energy consumption encompasses all renew able energy consumption, including renewable electricity, heating and green fuels that are consumed at Maersk-controlled entities/vessels. Renewable electricity includes electricity from solar panels, wind turbines and batteries, covering on-site self-generated and purchased renewable electricity from the grid. Green fuels include biofuels and green methanol. Thus, renewable energy consumption is reported as:•   Renewable  electricity•   Green  fuels•   Self-generated non-fuel renewable energyEnergy intensity and mixEFRAG IDIndicator Unit 2024 202312022E1-5_18Energy intensity GWh/USDm 2.18 2.28 1.52E1-5_09Share of renewable energy consumption % 3 2 2E1-5_15Share of fossil fuel sources in energy consumption % 97 98 981  Not covered by the Independent Auditor’s limited assurance report.For 2024, the energy intensity was 2.18 GWh/USDm, a decrease from 2.28 compared to 2023. This was driven by a relatively higher increase in revenue compared to energy consumption for the year. We recorded a minor increase in the share of renewable energy consumption from 2023 to 2024, however 97% of Maersk’s total energy consumption was derived from fossil fuel sources in 2024.  ACCOUNTING POLICIES Energy intensity (based on revenue)Energy intensity is the total energy consumption in high climate impacts sectors per unit of revenue (USDm),  as stated in the income statement of the consolidated  financial statements. All of Maersk's energy con-sumption is considered as related to high climate  impact sectors. Share of renewable energy consumptionThe share of renewable energy is the percentage of total energy consumption that is derived from renewable energy sources.Share of fossil fuel sources in energy consumption The share of fossil fuel sources in energy consumption is the percentage of total energy consumption that is derived from fossil-based energy sourcesRenewable energy productionEFRAG IDIndicator Unit 2024E1-5_17Renewable energy production GWh 9Maersk’s renewable energy production is related to on-site solar installations that produce electricity and/or heating, which is used on-site. Electrification of assets and investments in on-site renewable energy installations are part of Maersk’s transitions.   ACCOUNTING POLICIES Renewable energy productionRenewable energy production is the total amount  of renewable energy produced in Maersk’s operations during the reporting year. The total reported production comprises of the consumption, storage and sale of  renewable electricity to the grid.1 Environment  and ecosystemsA.P. Moller - Maersk (Maersk) is committed to carrying out its business activities  safely and securely with minimal impact to the environment. This includes the responsible use of natural resources such as land, water and natural materials for our operations,  and managing risks to biodiversity and ecosystems as well as specific activities in our value chain, namely responsible ship recycling and sourcing of critical resources. Since the adoption of the United Nations Kunming-Montreal Global Biodiversity Framework, we have seen new standards and initiatives emerging to guide corporate actions and disclosures related to nature and biodiversity. In 2024, Maersk performed an initial assessment using the LEAP (Locate, Evaluate, Assess and Prepare) framework created by the Taskforce on Nature-related Financial Disclosures (TNFD) to identify and assess our main nature-related issues, aiming to strengthen the foundation for environmental initiatives across our global operations and align commitments and actions with global standards.   Environmental and ecosystem management spans a range of topics handled by different functions and business segments, each supported by dedicated teams responsible for regulatory compliance and initia-tives of varying scope. These efforts include initiatives such as the newly established landside environmental roadmap (see page 103), global standards such as our environmental and social impact assessment proce-dure, and other health, safety, security and environment (HSSE) procedures across our landside, terminal and ocean operations, often addressing multiple interconnected environmental topics. There are further significant synergies between our activities to drive energy transition, ensure social responsibility and mitigating nature-related impacts, not least related to responsible ship recycling and the sourcing of critical resources, including steel and fuels.   The LEAP assessment helped inform our double materiality assessment (DMA) (see page 66), enabling us to identify and understand key impacts to the environment, both actual and potential. As part of the DMA, we also identified material financial risks to our business related to hydrocarbon spills, lost containers and challenges associated with ship recycling. When it comes to physical and transition risks, more broadly related to nature and systemic risks of ecosystem collapse, an emerging risk looking beyond five years is  an increased dependency on water in our supply chain for production of e-fuels. Additionally, we foresee transition risks driven by increased regulatory focus on ocean health, particularly in biodiversity- sensitive areas, and stricter regulations concerning for example, the use of scrubbers. Such emerging risks are being monitored and tracked as the landscape evolves. The material environmental and ecosystem impacts, risks and oppor-tunities in our own operations, identified as part of the 2024 DMA, centre around pollution, ecosystem health and biodiversity and waste management. We have further identified specific material activities in our value chain, including responsible ship recycling and the sourcing of critical resources, including steel and fuels.   These topics are explained in the sections below with regard to policies and approaches, actions and targets, with pollution, waste and ecosystem health and biodiversity combined in one section as these issues share a common approach and policies across Maersk operations. Maersk’s environment and ecosystems policy architecture document outlines all key commitments and principles as a compre-hensive overview to employees and other stakeholders of efforts to avoid and minimise nature-related impacts, dependencies and risks across all five topics. The document is supported by internal business and issue-specific standards, requirements and policies, and is made available to relevant stakeholders via our intranet.  Suppliers are required to adhere to the environmental standards outlined in our Supplier Code of Conduct. This includes demonstrating a commitment towards environmental protection by striving to mini-mise environmental impacts and, where material, proactively contribute positively to shared environmental ambitions.ESRS – E2, E4, E5, S3Environmental impacts  from our operationsAs a global logistics company operating across ocean, land  and air, we recognise our responsibility to manage impacts  from our daily activities in terms of pollution, ecosystem  health and biodiversity and waste management. We are committed to avoiding and reducing pollution to air, land and sea across our operations. Maersk also strives to protect habitats and biodiversity, and actively participates in restoring ocean and land health in critical habitats. Waste management focuses on the need to reduce our waste footprint across our operations and to contribute to  a circular economy. Across these topics, Maersk takes constant care  to ensure our operations minimise and prevent impacts to the environ-ment and people, and we align our operations with local laws and  regulations to ensure compliance with environmental requirements.Approach and policiesMaersk’s Environment &amp; Ecosystems Policy Architecture is a cross-topic document that guides our employees on minimising our mate-rial impacts by adhering to the principles set out by our environmental management systems and global policies, including on pollution, eco-systems health and biodiversity and waste management.Approach to pollution Maersk continues to address pollution impacts by adhering to our management framework and guidelines for preventing and respond-ing to pollution across our daily land and sea operations. This includes air quality management measures, chemical handling protocols, spill prevention standards and detailed emergency response manuals.  Maersk collaborates with key industry stakeholders to tackle air pollution impacts, such as the Alliance for Clean Air. Through this partnership, we aim to reduce air pollution across the value chain  by looking into innovative solutions, increasing transparency in reporting, and investigating target setting methodologies. In our Ocean business, pollution is regulated through the International Convention for the Prevention of Pollution from Ships (MARPOL) and International Maritime Organization (IMO) regulations. Maersk uses a combination of low sulfur fuel oil and open-loop scrubbers to comply with mandatory IMO 2020 sulfur emission regulations. Open-loop scrubbers reduce sulfur oxide (SOx) emissions into the air, however, they transfer effluents to the marine environment, which may increase sea-water acidity. Maersk recognises the ongoing environmental challenges that open-loop scrubbers present, and we continue working together with the World Shipping Council and the IMO to find industry-level solutions to this complex challenge.   Pollution risks from container losses at sea are directly attributed to severe weather and sea conditions. Maersk takes a technology-based approach to managing this risk through innovative new container lash-ing techniques, the installation of larger bilge keels to enhance stability and advanced weather and rolling monitoring solutions.Approach to ecosystem health and biodiversityEnvironmental and social impact assessments are performed for all new Logistics &amp; Services and APM Terminals projects, to proactively identify environmental risks and impacts, extending beyond biodiver-sity and ecosystem concerns. We use defined screening criteria, includ-ing global and regional data sources, to predict and mitigate biodiver-sity and ecosystems risks and assess community impacts. Our work going forward will include integrating a more structured approach to consult with affected communities as part of environment and social screenings and assessments.   In marine contexts, we adhere to relevant standards and regula-tions, strive to minimise disturbances to marine wildlife, and continue to enhance our understanding of impacts and risks to ocean health through research projects and collaborative engagements with civil society and academics. Maersk does not currently use biodiversity off-sets as a way to address our impacts.   We have a zero-tolerance policy towards transporting illegal wild-life and timber (available on Maersk.com), zero tolerance for transport-ing any products of shark and whale origin, and we are committed to enforcing stringent internal controls to prevent the misdeclaration and unauthorised transboundary movement of hazardous waste including plastic scrap, battery waste and industrial waste. Approach to waste management Maersk’s waste management requirements establish critical con-trols to reduce risks associated with waste generation and disposal, and guidance to fulfil these requirements to minimise environmental impact. We ensure compliance with environmental requirements by aligning our practices with local laws and regulations.  In our Ocean operations, Maersk fully complies with MARPOL Annex V regulations for waste and garbage management and maintains a strict zero-dumping policy. In line with these regulations, we are dedicated to reducing overall waste generation and have set a clear goal to minimise plastic waste across our fleet.Targets and progressIn relation to pollution, Maersk does not have measurable targets in place. However, we strive to prevent spills through operational controls and monitor and respond immediately to mitigate impacts of spills. In 32024, Maersk had no significant (above 10 m) hydrocarbon spills. We also strive to avoid the loss of any containers at sea. In 2024, five con-tainers were lost overboard from the time-chartered vessel Celsius Brickell near the port of Mombasa, Kenya. The containers were all empty and the incident resulted in no pollution or injuries.   At present, Maersk also does not have group-wide targets specifi-cally addressing waste management or ecosystem health and biodiver-sity. However, we continuously monitor our performance across both landside and ocean operations to gain a clearer understanding of our impacts. With regard to waste, we are currently working to enhance the granularity of data on waste generation and disposal across both land and sea, including establishing accurate baselines. This groundwork will position us to set meaningful commitments for the future.Key actions In 2024, Maersk finalised a landside environmental roadmap to define a strategy and critical focus areas for 2024-2026. This includes develop-ing a stronger set of digital tools for tracking compliance and increasing incident and spills reporting, which will drive future transparency and target-setting. Updated environmental and social screening guidance will align our growth opportunities with corporate policy and ambitions.  Maersk also made a significant USD 2m investment to improve HSSE performance, as part of our final integration process across 220+ warehouse sites. These projects include installation of spill kits, updated waste containers and signage, water infrastructure improve-ments, refrigerant retrofits and environmental site assessments. Actions addressing pollution impacts•  To mitigate the risk of lost containers at sea and improve safety on our vessels, in 2024, Maersk introduced a heavy weather monitoring and alert technology solution that allows shore-based support teams to provide real-time notifications to vessels at risk of encountering extreme weather. Maersk also introduced a parametric roll risk man-agement solution that enables crews to optimise route planning by incorporating real-time weather forecasts, thereby avoiding adverse seas that could cause dangerous rolling conditions. •  Maersk actively engages with the TopTier Joint Industry Project to scientifically address lost containers at sea and conducted our own technical research and model testing to identify the key contributing factors for container loss. We shared these findings through the IMO. Actions addressing ecosystem health and biodiversity impacts•  As part of the LEAP assessment, in 2024, we identified critical busi-ness segments across our operations and value chain, analysing impact drivers and dependencies in relation to specific business activities and their potential effect on nature and ecosystem ser-vices. To evaluate our presence in biodiversity-sensitive areas, we utilised data from the World Databases of Protected Areas and Key Biodiversity Areas. Initial findings based on the geolocations of our sites per 31 October 2024, indicate that 48 terminals, 471 inland logistics facilities, and 269 offices are in potential biodiversity-sen-sitive sites. Further analysis in coming years will confirm whether these sites and assets negatively impact such areas or significantly depend on local ecosystem services. Our objective for the coming 1-2 years is to further refine our understanding of these links, ena-bling prioritisation, target-setting and action plans as well as over-all transition planning and resilience analysis. Ocean transporta-tion was excluded from the 2024 analysis, as our vessel navigation platforms do not currently include sensitivity layers enabling the assessment. We expect to be able to include impacts from vessels into the analysis in the coming years. •  Maersk complies with international conventions to perform pest control and as of 2024, we reached the target of 100% of our vessels having ballast water treatment systems installed, well in line with the deadline set by the Ballast Water Management Convention.•  We are improving our StarConnect AI-powered fleet energy efficiency platform to include capabilities to monitor our presence in marine protected areas and particularly sensitive sea areas, as well as adding additional whale zones based on updates to the World Shipping Council (WSC) Whale Chart. Implementation of this data will take place in 2025. •  Maersk actively engaged with regulators, state entities, shipping asso-ciations and NGOs in the development of revised guidelines on Under-water Radiated Noise (URN) Management, in line with IMO guidelines. This includes participation in awareness campaigns and workshops across the industry, URN measurements of fleet vessels to develop a baseline and conduct data analysis, and development of an action plan based on the guidelines. Actions addressing waste impacts•  In 2024, Maersk started a pilot for a fleet-wide solution to create better visibility into different waste categories and landing and dis-posal requirements. When fully implemented, it will provide full tracking of garbage landed at end destinations and enable precise reporting for waste regulatory requirements.•  A global waste assessment was completed across Logistics &amp; Services and APM Terminals in 2024, developing a baseline understanding of waste generation and management across our organisation. In Logistics &amp; Services, an updated global waste standard, paired with compliance tools and updated training, will enable the setting of future targets around waste management and landfill diversion.•  Maersk continued its employee and community engagement around offshore and landside waste management through its annual Go Green Week in June 2024. The week included virtual and onsite events in all operational regions to raise environmental awareness and intro-duce colleagues and external stakeholders to waste management best practices. •  Maersk continued its recycled mooring rope pilot with C-Loop. In 2024 we had the first landing of recycled ropes in Europe, and exploration continues on several promising repurposing or recycling solutions with the hope of scaling more in 2025. ESRS – E5Responsible ship recyclingAs a responsible ship owner, Maersk’s ambition is to ensure  safe and responsible recycling of our vessels at end-of-life,  benefiting workers, the environment, responsible yards and shipowners. Globally, there is an urgent need for financially  viable, responsible recycling practices to meet the growing demand for large vessel recycling. By leveraging these retiring assets, the shipping industry can also contribute to decarbon-ising the global steel value chain. As an industry leader and a  significant owner of steel assets, we recognise our responsibility to drive positive impact.Approach and policiesMaersk’s responsible ship recycling standards outline stringent require-ments to ensure that ship recycling processes are conducted safely and responsibly. These standards are established to prevent, reduce, min-imise and, to the extent practicable, eliminate accidents, injuries and other adverse impacts on human health and the environment caused by ship recycling operations.   Maersk actively collaborates with stakeholders to foster a sup-portive regulatory environment, addressing the critical capacity  challenges required to meet growing demands for responsible ship recycling. Advocating for effective policies to accelerate responsible  ship recycling remains a key priority for Maersk, and we are positive about new 2024 regulations, which should clear the way for more EU-flagged vessels to be recycled at approved facilities outside  of the EU.   We also work to create global opportunities for responsible post-Panamax ship recycling, where recycling capacity shortfalls  can only be addressed through global consensus on the approval  of more yards with appropriate safety and environmental standards. This global consensus should be based on the rules of the IMO’s  Hong Kong Convention for the Safe and Environmentally Sound  Recycling of Ships.  Our CSR projects in the Alang, India area continue to make a  meaningful contributions in the lives of the ship recycling workers.  The mobile health unit (MHU) project provides complementary  health care access, addressing skin and muscular-skeletal ailments, diabetes and oral cancer screening and providing health training. Targets and progressMaersk actively monitors the effectiveness of its policies and actions towards our qualitative target to increase global capacity for the responsible recycling of post-Panamax vessels.Key actions •  Maersk successfully completed the recycling of Maersk Patras in May 2024 at Alang, India, and Jeppesen Maersk and Alexander Maersk at Aliaga, Turkey, in October 2024 with zero safety or  environmental incidents. •  To create further global opportunities for recycling post-Panamax vessels, Maersk signed a memorandum of understanding in July 2024 with Kingdom of Bahrain ministries that aims to develop  local post-Panamax recycling capacity and lower steel ecosystem GHG emissions through government and industry collaboration. •  As part of our commitment to the broader development of the Alang area, the mobile health unit in Alang provided 15,000  out- patient department services in 2024.Alang impact assessmentWe continue monitoring the impact of Maersk’s ship  recycling activities in Alang, India. The data below covers  the period 2017-2024, during which 17 vessels were respon-sibly recycled at six yards, engaging more than 1,200  workers. Please see the full assessment on maersk.com17vessels responsibly recycled OUR ENGAGEMENT125+Audits performed, including 45+ Lloyd’s Register audits,  40+ environmental tests and 40+ Maersk Sustainable  Procurement audits3,250+ Man days of supervision 5,440+Health and safety trainingsTHE IMPACTZeroSpills and hazardous materials incidentsZero Fatalities ZeroLost time injuriesESRS – E5Sourcing of critical resourcesEffective resource management and reducing the impact of our sourcing activities across the value chain are foundational to our ESG priorities. We strive to use resources efficiently across the company, with a focus on avoiding and reducing impacts throughout the upstream supply chain, particularly  for critical resources which Maersk is dependent on such  as steel and fuels.Approach and policiesMaersk’s policies relevant for sourcing of steel and green fuel are outlined in the Environment &amp; Ecosystems Policy Architecture. They include our specific green fuel sustainability requirements and our approach to deepening our understanding of the steel value chain and mitigating its negative impacts.  Shipbuilding and large infrastructure projects across our operations rely heavily on steel, a material associated with significant environmen-tal impacts. Maersk is committed to increasing the use of lower GHG emissions steel by collaborating with key industry stake holders. One particular challenge in developing an ecosystem around lower emis-sions steel is the lack of standards across the value chain. Maersk is working with the Climate Group (under the SteelZero initiative) and industry partners to develop criteria for responsible steel sourcing practices and to create alignment around low GHG emissions steel standards and certifications.  As part of our energy transition, we are shifting from fossil fuels towards the use of green fuels. To ensure these fuels are sourced and assessed responsibly, Maersk has established environmental sourcing requirements for biofuels and methanol across all company operations. Read more under climate change.Targets and progressBeyond GHG emissions, we do not currently have targets to address  the wider environmental impacts from the steel and fuel value chains. Key actions•  As part of our commitment through the SteelZero initiative to  transition to using 50% lower emission steel by 2030 and set-ting a clear pathway to using 100% net-zero steel by 2040, in 2024, Maersk continued the collaboration with the Climate Group to define environmental standards for lower emission steel.•  As part of our science-based climate targets, we are committed  to adhering to our green fuel standards to ensure responsible sourcing throughout the transition. In new offtake agreements with Goldwind and LONGi, we are in continued dialogue with production partners to ensure alignment with our green fuel requirements in the development and production phases of the agreements. Performance dataEnvironmental incidentsEFRAG IDIndicator Unit 2024 2023111202220212020E2-4_033Hydrocarbon spills &gt; 10 mNumber 0 0 0 2 2E2-4_03Containers lost at sea Number 5 52 118 - -Operating expenditures (OPEX)  E2-6_04in conjunction with major incidents USDm 2 - - - -and deposits1  Not covered by the Independent Auditor’s limited assurance report.3During 2024, we recorded no oil spills above 10 m, making 2024 the third consecutive year without  a significant oil spill from our operations. In February 2024, we lost five empty containers following  a vessel collision near Mombasa, Kenya. No pollution or people injuries were caused from the incident  but both vessels suffered damage. The number of containers lost at sea has decreased over the last three years, indicating that our efforts to improve the handling of containers are working. The operational expenditures incurred during 2024 in relation to major environmental incidents are linked to the clean-up and salvage operation undertaken following the loss of 46 containers in the North Sea in December 2023. The operational expenditures relate to the additional costs that are not covered by insurance.  ACCOUNTING POLICIES 3Hydrocarbon spills &gt; 10 mSpills are reported as the number of uncontained hydro-3carbon liquids spills greater than 10 m, resulting from any unintended, irreversible release associated with current operations.Containers lost at seaContainers lost at sea is based on the recorded number of containers (independent of size) lost at sea during the year. This includes containers lost at sea from own and time-chartered vessels, but does not include containers falling overboard in ports and other cases where  containers will be picked up. Operating expenditures (OPEX) in conjunction with  major incidents and depositsThe operational expenditures (OPEX) related to major environmental incidents include the clean-up and salvage operation costs that are not covered by insurance in con-3junction with significant oil spills (&gt; 10 m) and containers lost at sea from Maersk-owned vessels incurred during the financial year. Air pollutantsEFRAG IDIndicator Unit 2024 2023111202220212020E2-4_02SOx1,000 tonnes 97 90 100 107 102E2-4_02NOx1,000 tonnes 704 672 611 887 825E2-4_02NMVOCs 1,000 tonnes 16 16 27 - -E2-4_02CO 1,000 tonnes 80 77 55 - -E2-4_02PM10 1,000 tonnes 58 49 51 - -E2-4_02PM2.5 1,000 tonnes 40 38 43 - -E2-4_02Black Carbon 1,000 tonnes 3 3 3 - -1  Not covered by the Independent Auditor’s limited assurance report.For 2024, Maersk’s air pollutant emissions increased as a result of and generally in line with the increased fuel oils consumption caused by the extended distance linked to the Red Sea situation and re-routing of vessels around the Cape of Good Hope throughout 2024. Black Carbon emissions remained on par with 2023, which was a result of a general higher engine load contributing to more efficient combustion.  ACCOUNTING POLICIES Air pollutionAir pollution is the amount of air pollutants emitted in relation to Maersk’s operations, besides GHG emissions. The air pollutants included are SOx, NOx, Non-Methane Volatile Organic Compounds (NMVOCs), carbon monoxide (CO), Particulate Matter (PM10 and PM2.5, and Black Carbon (BC)). By default, PM10 also includes smaller par-ticles (hereunder PM2.5 and BC), which are also reported separately because these fractions of particulate matters have differing impacts on environment and health than the coarser fractions. Air pollutants have been prepared and stated based on the first version of the Stockholm Environment Institute’s (SEI) reporting guide, except for BC and PM10 reporting from the fleet of Maersk, which is based on the methods outlined by IMO in MEPC 75/7/15 as our data availability allows for IMO’s more accurate assessment. In case of scrubber use, SOx pollutants are reported based on Clean Cargo guidelines, where SOx output is assumed to be  maximum for the operating area in which the vessel spends 80% of time.Waste generatedEFRAG IDIndicator Unit 2024 2023111202220212020E5-5_072Waste 1,000 tonnes 556 517553 357 289E5-5_15– Hazardous waste 1,000 tonnes 236 218  229 216 188E5-5_102– Non-hazardous waste 1,000 tonnes 320 299324 141 1011  Not covered by the Independent Auditor’s limited assurance report.2  Restated from 533k tonnes and 315k tonnes for ‘waste’, and ‘non-hazardous waste’, respectively, due to the application of an incorrect unit conversion from a reporting entity in 2023.For 2024, Maersk recorded an increase of approximately 8% in total waste generated across its operations compared to 2023. The increase is mainly driven by an increased number of vessels in Maersk’s operations.  ACCOUNTING POLICIES WasteWaste is reported as the sum of all waste types generated, with further bifurcation in hazardous and non-hazardous waste types. Non-hazardous waste primarily consists of municipal and industrial waste, such as food waste, pal-lets, cardboard, general trash and metal and wood scrap.Uncertainties and estimatesWaste data is reported by entities and is based on a  combination of actual numbers and estimates.  For land-based operations, waste data is sourced from billing and accounting systems or from the procurement/supply management department. For some offices and minor sites, where it is challenging to obtain actual waste data, estimates based on FTE counts are used to ensure completeness in waste reporting.  For waste from vessel, conversion factors for all MAR-POL Annex V garbage categories have been developed and used on the actual waste generated by 10 vessels within three different vessel size groups (sample of 30 vessels in total). The average waste generated by vessels within each of vessel size groups has been used to extrapolate waste numbers for the entire fleet.Resource inflowsEFRAG IDIndicator Unit 2024E5-4_02Total weight of steel consumed Tonnes 73,394 Maersk procures and uses steel for manufacturing containers. In addition, significant amounts of steel  are used by suppliers and partners in the value chain to produce vessels, cranes and other heavy assets that Maersk uses in its operation. We only report on the weight of the steel we directly procure and  use to manufacture containers.  ACCOUNTING POLICIES Total weight of steel consumedTotal weight of steel consumed is the weight of steel used for producing containers during the year. The weight is calculated based on the number of containers produced and the bill of materials related to those containers. SocialA.P. Moller - Maersk (Maersk) strives to provide a safe and inspiring environment for our people to grow, develop and thrive as a diverse and global team. Our actions are guided by our Purpose and Core Values, international standards and the expectations of our key stakeholders.HUMAN CAPITALTarget by 2025 Employee engagement survey score  in the 75th percentile of global normSAFETY AND SECURITYTarget by 2024 (recurring)100% of learning teams completed  following high potential incidentsDIVERSITY, EQUITY AND INCLUSIONTargets by 2025 •  &gt;40% women in management •  &gt;30% diverse nationality (non-OECD)  of executives EMPLOYEE RELATIONS AND LABOUR RIGHTSTarget by 2024 (recurring)100% of employees (in scope) trained  in employee relations and labour rights PERFORMANCE DATAMATERIAL IMPACTS, RISKS AND OPPORTUNITIES SocialOverview of Maersk’s material impacts, risks and opportunities related to SocialHuman capitalAttracting and retaining critical talent Inability to retain and attract the right workforce for key critical capabilitiesInability to retain and attract key critical capabilities could impact the ambition to deliver on the integrator strategy.Diversity, equity and inclusionHarassment of vulnerable groups Risk of harassment creating an unsafe working environment for underrepresented or vulnerable groups in our workforceUnderrepresented and vulnerable groups are at increased risk of harassment and violence. This can take place in office environments, warehouses or on ships, the risk being higher for frontline workers and in highly male- dominated environ-ments. This can pose a financial risk to Maersk in terms of costs of remediation and reputational damage.Discrimination in the workforce Risk of discrimination based on ethnicity, gender,  nationality or disabilitiesPotential discrimination within our workforce, based on ethnicity and nationality given a large global workforce and the variety of office environments, and on the basis of gender in traditionally male-dominated parts of the business. Under-represented and vulnerable groups (such as persons with  disabilities) may also be at increased risk of discrimination.Safety and securitySafety of our workforce Risks of work-related injuries, life-altering incidents  and fatalitiesRisks of work-related injuries, life-altering incidents and  fatalities for workers given the nature of the transport and logistics sectors. This can pose a financial risk to Maersk in terms of costs of remediation and reputational damage.Exposure to global/local security risks Exposure to global/local security risksGlobal and local geopolitical instability and conflicts result  in security risks where criminals, terrorists and/or others  with ill intent expose our employees to health and safety  risks, e.g. piracy and terrorism. Financially, this can cause  disruptions to our operations, which may also impact our  ability to decarbonise, and costs related to safety incidents.Employee relations and labour rightsForced labour Forced labour such as debt bondage and withholding  of passportsRisk of debt bondage and withholding of passports for  contracted workforce and value chain workers. This risk  is higher for large infrastructure projects with a migrant workforce.Working hours and adequate wages Excessive hours worked for contracted frontline workersImpacts related to working hours and overtime for  contracted frontline workers, such as truck drivers,  seafarers and migrant workers.Ensuring that workers are paid an adequate wageIn some supplier categories, there is a potential risk of  inadequate wages being paid for contracted labour. Adequate housing and sanitation Adequate housing and sanitation facilities for own and contracted workforceFor contracted workers and in the broader value chain,  on-site housing is provided to workers at e.g. terminal  constructions, warehousing, shipyards and shipbreaking  yards. These spaces can potentially be substandard,  crowded and not adequately hygienic – aggravated in  some contexts by the lack of gender segregation.Our workforceThe people of A.P. Moller - Maersk (Maersk) are the foundation of our success and the ones  who deliver on our customer promises, including Environmental, Social and Governance  commitments. Our ambition is to ensure that our people thrive at work by providing a safe  and inspiring workplace. This is driven by efforts within human capital, diversity, equity and  inclusion (DE&amp;I), safety and security and employee relations and labour rights, and  underpinned by a commitment to respecting human rights.We employ 100,000+ people across almost 130 countries in the world. Our team includes office-based professionals and technology experts who develop and bring Ocean, Logistics &amp; Services and Terminals offerings to life. We also employ frontline workers who fulfil our customers’ logistics needs, such as ware-house staff, truck drivers, terminal operators and aircraft maintenance teams, as well as the 12,000+ dedicated sea faring colleagues sailing our vessels.   In addition to own employees, we also rely on a large extended workforce of third-party contracted labour (non-employee workers) who are not directly employed by Maersk, but work on our premises with us and for us in our customers’ value chain, especially in Logistics &amp; Services and Terminals. Our business model also includes impacts and risks to workers in our value chain. These include workers on chartered/leased assets and workers of our suppliers that are not part of our contracted workforce.   The complexity of our operations and workforce, combined with diverse local labour regulations, stand-ards and practices across our global footprint, creates potential people-related impacts and risks. Whether our people have office-based or frontline roles, or whether they are employees or contracted labour in the value chain, we strive to safeguard fair and safe working conditions and the ability to make meaningful con-tributions through growth and learning. Doing this requires active management of several impacts and risks.  An inability to retain and attract employees could impact Maersk’s ambition to deliver on our integrated logistics business model, especially for specialised experts in technology and logistics.   Given the nature of the transport and logistics sectors, Maersk employees and non-employee workers under our duty of care are exposed to health and safety risks, including work-related injuries, life-altering incidents and fatalities. Maersk’s broad footprint also exposes our assets and employees to security risks, especially with the current increase in geopolitical instability such as the Red Sea situation.  Our workforce may be exposed to the risk of harassment, discrimination or violence that could create a physically or psychologically unsafe working environment. This risk is especially higher for underrepresented or vulnerable groups in our workforce.Our people100,000+ employees170+ nationalitiesTOP 6 EMPLOYEE NATIONALITIES%21Indian%12Chinese%9Filipino%9U.S American%3Brazilian%3DanishWe actively manage the risks and impacts of our operations on labour rights. Frontline employees and contracted workers face risks related to excessive working hours and overtime. Contracted workers might also face demands to work excessive hours, or risks of forced labour where workers may face restrictions on their freedom of movement due to the retention of their passports. Ensuring that workers are paid an adequate wage is also a labour rights risk, as is securing adequate housing and sanitation facilities for own and contracted workers. Both risks are gen-erally higher for contracted workers and are present in all high-risk supplier categories. Across all of Maersk’s workforce risk categories, there is also a risk of limited visibility across the value chain, especially tier 2 or 3 suppliers and parts of the downstream value chain.Maersk’s People strategyOur People strategy outlines the people principles which are our north star for all people practices and policies. It includes employee attrac-tion, development and engagement activities to ensure workforce con-tinuity and stability, while unleashing employees’ energy, focus and commitment to executing our strategy.The priorities of Maersk’s People strategy for 2024, a multi-year effort launched in 2021, are:•  Enable teams that collaborate, to deliver with passion towards goals, maximise individual and team results and pursue continuous learning and growth.•  Lead with intent, embodying our leadership commitments.•  Scale frontline capability to drive growth, create competitive  advantage and great workplaces for all.•  Drive a culture of empathy, care and compassion which empowers everyone to perform, lead and deliver.Every year, the people priorities, with specific focus areas, are set and communicated to the entire organisation. Employees and Constant Care are both Core Values to Maersk and fully aligned with our People strategy. We carefully monitor and analyse the impact of our People strategy through the biannual employee engagement survey (EES), which helps us shape our programmes and targets. In 2024, we performed a second organisation-wide inclusion survey to gain valuable insights from employees and lessons for improvement on DE&amp;I performance.ESRS S1, ESRS S2, ESRS S3Maersk’s approach to human rightsMany aspects of our business touch on human rights,  including employees’ working conditions, health and safety, how vessels are recycled, how we use digital data and tech-nologies and suppliers’ business practices. Our conduct within our own business and through business relationships can  have a significant impact on people, communities and society, both positive and negative. Human rights perspectives inform and guide several categories in our ESG strategy and  governance approach.Approach to human rightsRecognising the potential for global trade and supply chains to make positive contributions to society and socio-economic development, Maersk is committed to respecting human rights in its own operations and entire value chain. Maersk’s approach to human rights is founded in our Purpose and Core Values and based on a long standing commitment to the UN Guiding Principles (UNGPs) on Business and Human Rights and the OECD Guidelines for Responsible Business Conduct, helping us navigate the often complex impacts of global trade on people. These commitments and this approach are formalised in Maersk’s Human Rights Policy Statement, available on Maersk.com.   Human rights are anchored in Corporate Sustainability, headed by the Chief Corporate Affairs Officer. The department collaborates with several key functions such as Legal, Compliance, Employee Rela-tions, Safety and Resilience, the People function and Sustainable Pro-curement to ensure that human rights considerations are integrated throughout the business and value chain. Maersk’s ambition is to con-tinue aligning our business practices with the UNGP and ensure that human rights considerations are integrated into due diligence pro-cesses and ESG governance mechanisms.   In 2024, a key focus has been to initiate preparations for compli-ance with the EU’s Corporate Sustainability Due Diligence Directive (CSDDD), which will be mandatory for Maersk from 2027. As part of this, we continued engaging and training key functions and human rights issue owners to support and equip them with the knowledge and tools to handle dilemmas in a manner sensitive to potential human rights impacts.   We engage regularly with key stakeholders, such as customers and investors, as well as external experts on human rights topics, as we see increasing regulation and growing expectations from stake-holders. We continued to mature key internal due diligence processes, and we are also addressing emerging risks from new business activi-ties, such as the development of the green fuel supply chain and the continued expansion of logistics operations. As a consequence of increasing geopolitical tensions across the world, we recognise the need for enhancing our approach to human rights risk assessments when operating in conflict-affected areas.   As a global company with a footprint all over the world, we serve all types of customers, both companies and states. In line with our commitment to ensuring responsible business practices aligned with international standards, we perform risk assessments and heightened due diligence on certain transactions, including in relation to armed conflicts and military cargo. This is also to ensure we comply with arms embargoes.   In May 2024, NCP Denmark (the Danish Mediation and Complaints Handling Institution for Responsible Business Conduct) concluded on a case raised against Maersk relating to the operations of the joint venture Douala International Terminal in Cameroon, following a two-and-a-half year investigation process. While the vast majority of raised complaints were dismissed, including complaints related to the specific joint venture, we acknowledge the recommendations by NCP Denmark related to our joint venture framework and promoting responsible business conduct in entities where we do not have full con-trol, as well as exercising due diligence with regards to documentation and follow-up on policy implementation. We have already undertaken updating our joint venture framework, as well as expanded our training for APM Terminals-nominated board members and representatives for joint venture entities.   We actively engaged with NCP Denmark throughout the course of the investigation over two-and-a-half years, with the intent to demon-strate and explain how we implement our commitment to respecting the OECD Guidelines for Multinational Enterprises. We valued the oppor-tunity to reflect upon and review how we implement and document our respect for international standards and have taken a variety of learnings from the process, including codifying initiatives that we had underway into our governance frameworks and due diligence processes, ensuring our commitment and approach to respecting the OECD Guide-lines are unequivocally documented.Maersk’s salient human rights issuesIn 2021, we conducted a corporate-level human rights impact assess-ment founded in the OECD guidelines. The result of this exercise was five prioritised salient human rights issues that we continuously address. This assessment has also informed the 2024 double mate-riality assessment (DMA), reconfirming the materiality of the human rights issues.  These include health and safety in the supply chain, violence and harassment at work, impacts of climate change and decarbonisation (just transition), access to remedy and working conditions in the supply chain. Read more about these issues in the relevant topical sections of this report. ESRS S1Human capitalMaersk’s ability to deliver on customer needs and our business strategy ambitions depends on highly engaged employees and internal capabilities in critical areas. To ensure that we attract and retain the right talent, our aspiration is to create an engaging environment for all colleagues and to be a company where employees can develop and have thriving careers.Policies and approachOur People strategy outlines our vision, core principles and capabilities. It includes engagement as an outcome of excellent leadership, clear direction and workspaces that are inclusive. Therefore, engagement is included in all people practices.  Maersk’s approach to human capital as an ESG priority includes three focus areas: employee engagement, employee attrition and talent development. These speak to our continuous efforts to attract, engage and retain employees and ensure continuity and stability of, and for our workforce.  We work towards minimising negative impacts arising from our oper-ations through careful monitoring and analysis of employee engage-ment and attrition. In particular, our employee engagement survey (EES) provides valuable insights into performance and helps us pinpoint areas of improvement. Both functional and operational leaders receive the results of the EES and are responsible for developing action plans to address survey findings, with the support of dedicated resources in the People function. In response to the survey results, we conduct listening sessions, refine processes and policies as needed and invest continu-ously in leadership and overall capabilities.  Biannual progress updates take place, supplemented by internal cam-paigns on performance management tools and training programmes, as part of the People strategy. Multiple training and development resources are available to employees through our internal talent development (MPACT) framework to maximise talent performance and ensure align-ment and career growth.Targets and progressIn support of our ambition to attract and retain the right talent and create an engaging environment for all colleagues to develop and thrive, we evaluate progress against our strategic target to achieve an EES score in the 75th percentile of Gallup’s global norm. The EES is performed twice a year.  The result of the second EES of 2024 showed an increase in engage-ment to the 65th percentile compared to a 60th percentile score at the end of 2023. Another noteworthy positive trend is that 92% of colleagues consistently participated in both of the 2024 surveys com-pared to 85% in 2023. The survey also highlighted consistent strengths and opportunities compared to the previous two surveys, notably in the areas of recognition and development, attributed to the contin-ued adoption of MPACT and the embedding of a performance culture. These improvements suggest that more leaders are dedicating time to review performance, recognise good work and encourage development.  Along with the EES, we track employee turnover with the aim to  sustain a healthy attrition rate aligned with the industry performers.  In October 2024, the employee turnover rate was 11%.Key actionsIn 2024, we progressed across our People strategy’s main focus areas:•  The MPACT framework continued to strengthen our performance  culture by driving objective setting and performance conversa-tions, with adoption rates reaching 87% and 82% across Maersk, respectively.•  Employee development solutions were strengthened with the launch of the Maersk Academy framework attracting over 750,000 visits, an expanded mentoring solution with 2,400 participants and the introduction of a coaching programme.•  Leadership solutions were consistently promoted to support leaders  in empowering employees in their daily work. Each people leader is expected to create an action plan based on the EES results and lever-age the MPACT talent and development framework alongside other targeted leadership initiatives, including specialised programmes and leadership development solutions. Additionally, we elevated the suc-cession management process to a global level, enhancing visibility for leaders and fostering the growth and development of talent.PercentileEmployee engagement65th(60th percentile)The result of the second employee engagement survey  of 2024 showed an increase in engagement to the 65th  percentile compared to a 60th percentile score at the end of 2023. While this is a solid result, more work is needed  to reach the 75th percentile target by 2025.% headcountWomen in management 35%(35%)1  In 2024, the share of women in managementremained  on par with 2023.1  Excluding seafarers.PercentageTarget nationalities in  executive leadership21%(20%)Through focused efforts, our target nationalities  in executive leadership saw an overall improvement.ESRS S1Diversity, equity and inclusionAt Maersk, we aspire to facilitate diversity of thought and create a more diverse, equitable and inclusive workplace, where  our employees feel able to bring their whole selves to work and contribute to their fullest. This is a Core Value of Maersk and essential to supporting our customers’ evolving logistics  needs and growing our business. By facilitating a culture where  everyone feels respected and is treated fairly, we gain access  to a larger, more diverse pool of talent.Policies and approachTwo main policies anchor our diversity, equity and inclusion (DE&amp;I) approach: a diversity, equity and inclusion policy and an anti-dis-crimination, harassment, bullying and violence policy. These policies are publicly available on Maersk.com and accessible on our internal intranet site along with training materials.   Our diversity, equity and inclusion policy outlines our holistic view on diversity, grounded in our Core Values, as well as our targets and approach to underrepresented groups in our workforce. In 2023, we introduced a diverse abilities policy to provide even stronger support for this specific, underrepresented group. We call disabilities ‘diverse abilities’ to focus on our colleagues’ skills and capabilities, rather than their perceived limitations.  Maersk’s anti-discrimination, harassment, bullying and violence policy articulates that discrimination, harassment, and bullying of employees are not tolerated in any country where we operate. This is further codified in our Commit governance rules, through our Code of Conduct, and in our commitment to the UNGP Global Compact and UNGP on Business and Human Rights. These policies are developed with an inclusion perspective, going beyond minimising harm.  As a core strategic topic for Maersk, DE&amp;I is anchored in the Executive Leadership Team and is driven by a dedicated global diver-sity, equity and inclusion team as well as by employees across the organi sation. Beyond diversity targets, we prioritise inclusion as a catalyst for behav-ioural change, shifting mindsets from passive allyship to active advo-cates. To foster an inclusive culture, we conduct an organisation-wide inclusion survey to guide functional team action plans so we can take a targeted approach to embed equity, bring inclusion to life and con-tinuously measure progress. In addition, we gain valuable insights from our employees and lessons for improvement from feedback during our annual global diversity, equity and inclusion week, diverse abilities week, pride celebration, black history month and other campaigns.   A new employee resource network (ERN) in Oceania brings the total to 42 ERNs, all dedicated to integrating our Global DE&amp;I strategy across regions. Twice a year, the ERNs join forces with the Global  DE&amp;I Team to discuss best practices and collaborate to strengthen collective efforts.Targets and progressTo create a more diverse, equitable and inclusive workplace, we have set a range of strategic targets:  We set a gender diversity target of above 40% women in manage-ment by the end of 2025. In 2024, the number remained on par with 2023 at 35% with continued impact from the 2023 reorganisations. With slower progress due to reorganisations and new hire restrictions,  we took steps to maintain representation – especially at leadership levels – and to improve gender balances in hiring in 2024. These included adding a DE&amp;I statement to all job advertisements, hiring manager trainings, launching a social media advocacy programme and mandating the use of gender language tools.  Taking into account broader diversity aspects, we also set a target of having above 30% of diverse nationalities (non-OECD) of executives. In 2024, the number increased by 1 percentage point, slightly reducing the gap towards our 2025 target. In 2024, we expanded the original scope of our talent sponsorship programme for women in leadership to also include talent of underrepresented racial and ethnic groups.   To address some of the remaining challenges in our diversity targets and the inherent limitations of count-based targets, we introduced a new ‘diversity in teams’ metric, which looks at gender and nationality in our leadership pipeline. In 2024, our score was 58% on gender and 85% on nationality. Measured at the team level, diversity in teams builds systemic equal opportunity across different roles at leadership levels. Following a successful 2024 test, we will roll out team-wide tailored plans in 2025, with targeted actions intended to have greater impact than generic diversity programmes and trainings.Key actionsMaersk progressed in many DE&amp;I engagement initiatives during 2024:•  Our second inclusion survey was launched across 126 countries. The results showed a shared pride in working at Maersk and its overall culture of inclusion. 88% of respondents agreed that Maersk hires from a variety of backgrounds. The results also  highlighted equal opportunity as a focus area for improvement  in 2025.•  Over 5,000 colleagues were identified as having diverse abilities  in the inclusion survey and recorded a positive inclusion experi-ence. A dedicated programme was developed in 2024 to support our colleagues’ and wider teams on hiring and onboarding, in line with our diverse ability policy introduced in 2023.•  Targeted efforts in developing and hiring underrepresented  genders included expanding our talent sponsorship programme  to North America and improving gender balance in our hiring  process through e.g. social media advocacy, inclusive language, DE&amp;I statement in job ads and training of hiring managers.•  In 2024, Maersk reached the important milestone of employing almost 6% of female seafarers across the fleet. According to the International Maritime Organization (IMO), the industry average is 2%. We actively promote gender diversity at sea through special training programmes for young women in select markets, position-ing Maersk as a maritime employer with career opportunities, and collaborating with schools and universities.•  A series of initiatives under our One team together programme  to transform the working culture at sea continued to progress  in 2024, including actively attracting, onboarding, training and developing colleagues at all levels, with a strong focus on exten-sive leadership development for senior officers.ESRS S1Safety and securitySafety and security at work is a basic human right, and Maersk has a duty of care to ensure the health, safety and security of everyone who works with us.Policies and approachOur commitment towards health, safety, security and environment (HSSE) is anchored in our company values and codified in Maersk’s HSSE Policy. The policy, publicly available on Maersk.com, clearly sets our obligation , clearly sets our obligation for healthy, safe, secure and environmentally responsible business practices and applies globally to all Maersk entities, employees and everyone working under Maersk’s supervision. This means that all workers on our sites, including both own employees and contracted workers that work under Maersk’s supervision, are covered by Maersk’s safety management systems. The HSSE Policy is supported by and unfolded in detail in our HSSE Commit Rule and the Maersk HSSE Management Framework. Our Supplier Code of Conduct further set expectations for our suppliers to uphold respon-sible business practices including on safety (see Sustainable Procure-ment pages 130-131).  These commitments are well reflected in our legacy operations. Since embarking on our integrated logistics strategy, Maersk has added hundreds of warehouses and thousands of new logistics colleagues to complement ocean and terminal operations. The speed of this growth, as well as expansion into new locations with diverse practices and safety cultures, has transformed and expanded our HSSE risk profile. To meet this challenge, we are working fast on a global scale to bring the landside asset portfolio up to our global HSSE standards and to build the capacity, capabilities and work culture required to work safely and securely everywhere that we operate. In these efforts, we draw on and benefit from the experience and solid safety culture we have developed over decades in our Ocean and Terminals businesses.   Our efforts are guided by four principles equally anchored in safety theory and operational experience. First, ‘we lead with care’ – leaders engage, listen and respond to what frontline colleagues need to do their work safely. Second, ‘we learn and adapt’ by building capacities to manage serious risks through controls and safeguards that protect people while improving business efficiency, using innovation and safety- by-design principles. Third, we insist that ‘our people are the experts’ – inspiring a culture of learning and engagement by promoting employee voices, elevating engagement and sharing learning across our business. Fourth, we make sure ‘we are resilient’ by planning for and monitoring supply chain disruptions and ensuring we have the backup capabilities for key resources to keep customer cargo moving.   We continuously monitor and manage evolving safety and security risks. For example, the introduction of new dual-fuel capable vessels as part of our energy transition brings new technologies, equipment and fuels that have different safety characteristics. Maersk has robust pro-cedures and training in place to ensure that the crew on these vessels are well equipped for safe operations. In our Terminals business, we are ensuring that the electrification of container-handling equipment is safe and inclusive to frontline terminal colleagues with upskilling and specialised training and procedures in topics like electric battery main-tenance and fire prevention.   As part of our security and business resilience (continuity planning and crisis management) framework, we focus on protecting people, assets, cargo and the Maersk brand. Our threat intelligence team (forecasting) collects, analyses and prioritises security or continuity risks, which are then presented for discussion with the regional security and business resilience managers. This supports informed risk decision- making and mitigation strategies on topics such as people-related risks, cargo theft and severe weather disruptions. Our approach is to leverage technology and data to understand customer and legislative expectations and the local environment, and to standardise controls and risk management.Targets and progressTo support capacity building to manage critical risks and identify improvement areas, we have set strategic targets of ensuring that 100% of learning teams are completed following a high potential incident. In 2024, we conducted focused training towards learning teams across our portfolio, aiming to address all high potential incidents, ending the year at 99% completion. Following a Terminals high potential incident review, Terminals identified traffic management as a key risk and con-ducted a Kaizen activity to drive improvements and standardise prac-tices across terminals.100% of learning teams completed following  a high potential incident (by 2024)99%(2023: 99%)Key actions2024 was marked by heightened geopolitical threats, conflicts and instability. Protecting cargo from security-related disruptions, while ensuring reliable and resilient supply chains is critical to our growth and reputation. We are also moving with speed and resolve to bring every logistics site up to Maersk’s global standards and provide every-one with HSSE responsibilities with the tools, training and support needed to fulfil their roles. In 2024, this included:•  15,000 safety and security Gemba walks conducted across Ocean, Logistics &amp; Services and Terminals operations.•  Completion of a one-time HSSE assessment of 354 logistics sites, closing 95% of the HSSE and business resilience improvement actions, including new safeguards, security equipment and training. The findings also laid the foundation for a capability study to build an HSSE learning academy to upskill our workforce in 2025.•  Launch of a three-year global campaign to help every Maersk ware-house and depot implement our HSSE management framework.•  A new global HSSE assurance team to provide regular validation  of our HSSE performance and improvement journey.•  Successfully managed more than 19 crisis management teams across a variety of crises from the Red Sea situation to vessel fires.•  Reviewed resilience maturity for third-party terminals (+20) linking to the Gemini network. In 2025, we will continue supplier resilience evaluations and assessments with procurement to understand  vulnerabilities and develop improvement plans.•  Development of a global resilience intelligence tool to standardise and better enable site-level business continuity planning.•  Training of 191 employees as business resilience coordinators at  the site level, enabling them to develop and implement business continuity plans.•  New in-house capability to identify security and resilience-related threats, enabling pre-emptive risk mitigation. This included refining our data landscape to ensure internal metrics and external threats are properly identified and assessed as well as improved data aggre gation across Security and Resilience functions.LTIfLost time incident frequency rate1.53(1.14 LTIf)The rise of our lost time incident frequency (LTIf) rate  was driven by increases in lost time incidents (LTIs) in  our Logistics &amp; Services and APM Terminals businesses,  as well as an improved reporting culture. 1  2023 restated from 1.11.NumberFatalities in 20241(4)Regrettably, we had one fatal incident involving a con-tracted colleague in a warehouse in the Philippines on 26 December 2024. While we have seen a significant  reduction in the number of fatalities since 2022, the loss  of a colleague underscores that we still have much work to do on understanding and staying ahead of our risks  and on building the right safety culture. In addition to the fatalities recorded for employees and contractors under Maersk's responsibility, we recorded one fatality involving  a value chain worker on a construction site within our  premises. This individual was employed by the construction company and not working under Maersk's responsibility. ESRS S1Employee relations and labour rightsThe way we treat employees and their representatives is fun-damental to responsible business practices and grounded in respect for internationally recognised labour rights in all of our workplaces. Respect for fundamental labour rights is an essen-tial part of Maersk’s social commitments, which include offering decent, fair and equitable working conditions for all employees. We assess potential risks affecting both own employees and contracted/third-party labour and take proactive and corrective measures to ensure our operations and growth align with our commitments on social responsibility.Policies and approachMaersk has two main employee relations and labour rights policies. The Commit Rule on Global Employees and Labour Relations is appli-cable to own employees, while the Maersk global standards on third-party labour applies to contract/third-party labour.   The Commit Rule, which is part of the broader Maersk Commit gov-ernance framework, describes the fundamental rights of employees and colleagues as foundational to a positive working environment. When it comes to workers of our suppliers, starting with our Supplier Code of Conduct as a base, we further clarify labour expectations  with the global third-party labour standards (please see Sustainable Procurement page 130-131).   These policies are aligned with international standards such as the UN International Labour Organisation core conventions and the UN Global Compact and cover all fundamental labour rights, includ-ing guidelines on forced and child labour, adequate housing and sani-tation, wages and working hours. They are further supported by inter-nal guidelines for flexible working, a global principle of rewards policy, a global employee benefits and rewards policy and other topic-specific policies on e.g. safety and DE&amp;I, which all apply to the working condi-tions for employees of Maersk.  Maersk has three main employee relations and labour rights focus areas. The first is how we manage the risks of violation of employee rights for third-party labour. This is particularly material to our strate-gic business focus of driving growth in the Logistic &amp; Services segment, which depends on third-party relationships, and where we operate in regions with higher risk of violations of employee rights.  The second is technology and business growth – how we secure the ethical use of technologies in our operations to ensure labour standards are respected and implemented as we grow our business. The final focus is on wages – employees should as a minimum be paid an adequate wage. A 2024 assessment of adequate wages across own employees, based on the guidance from the CSRD and available bench-marks, showed that no employees are paid below the applicable ade-quate wage benchmark. We are currently developing a framework for assessing local adequate wage levels for contracted employees.   As part of our human rights due diligence processes, potential negative impacts and risks are monitored on an ongoing basis via joint business reviews, site audits and a biannual self-assessment for com-pliance with the Commit Rule. These processes allow us to identify emerging risks within our operations and develop targeted action plans to mitigate such risks. Targets and progressWe have set the strategic target of training 100% of our in-scope employees on employee relations and labour rights. At the end of 2024, 94% of Maersk employees have completed the mandatory employee and labour relations e-learning. While this is an improve-ment compared to 2023, more work is needed to address challenges  in reaching all employee groups. We maintain the rigour of a 100% target also for 2025, with a particular focus on ensuring that all new employees are trained as part of their onboarding process.100% of employees (in scope) trained in employee  relations and labour rights (by 2024)94%(2023: 90%)Key actions•  During 2024, we broadened the rollout of the global standards on third-party labour through targeted training for leaders, addressing unique risks across APM Terminals and Logistics &amp; Services. APM Terminals achieved 85% compliance, while Logistics &amp; Services reached 42%. To further close identified gaps and achieve full com-pliance in 2025, we have identified a need to further strengthen internal capabilities within employee and labour relations. As a result, APM Terminals created a labour excellence organisation  and regional focus leads were appointed in Maersk’s frontline Logistics &amp; Services.•  We launched a tracking app in 2024 to monitor training progress, supplier performance and compliance risks, providing a consol-idated dashboard across the People function, procurement and operations. This effort is supported by steering committees con-sisting of senior executive management for APM Terminals and Logistics &amp; Services, to oversee progress and to ensure full com-pliance. In 2025, we plan to expand the tracking app use across the business as a single source of truth for documenting compliance. •  In 2024, our Supplier Code of Conduct and Commit Rule were updated to align with the new global standards on third-party labour.•  Maersk’s global labour rights council completed a company-wide labour rights assessment as part of our due diligence, with action plans for 2025 focusing on areas such as working hours and over-time payment.•  We performed an assessment of adequate wages across own employees in 2024, based on the guidance from European Sustain-ability Reporting Standards and available benchmarks. The results showed that none of our employees are paid below the applicable adequate wage benchmark. Performance dataNumber of employeesEFRAG IDNumber of employees  S1-06_01in 2024 (headcount)SBM-1_03SBM-1_04S1-6_09S1-6_10 S1-6_03 Total number of employees 108,1601S1-6_03 Average number of employees 106,6261  Refer also to the most representative average number of employees (FTEs) number in note 2.2 operating costs of the consolidated financial statements. Average number of employees (headcount) is the average number of individual employees during the year while FTEs (as stated in note 2.2 operating costs of the consolidated financial statements) is calculated based on working hours and reported as an average for the full-year.At year-end 2024, Maersk employed 108,160 employees, and the average number of employees during the year was 106,626.  ACCOUNTING POLICIES Total number of employeesTotal number of employees is the headcount of employ-ees with an employment contract with Maersk, who are on payroll regardless of the type of contract at year end. Excluded are employees on garden leave and unpaid leave, contractors and third-party workers. The number  of employees is based on registrations in Maersk’s  HR systems. Average number of employeesThe average number of employees is calculated  as average number of employees (headcount) per  month during the year.Number of employees by genderEFRAG IDGender Number of employees  S1-06_01in 2024 (headcount)S1-06_01Male 70,100S1-06_01 Female 37,459S1-06_01 Other 3S1-06_01 Not disclosed 598At year-end 2024, of the 108,160 employees employed by Maersk, 70,100 were recorded as male, 37,459 were recorded as female, 3 were recorded as other and 598 were recorded as not disclosed.  ACCOUNTING POLICIES Number of employees by genderThe number of employees by gender is the number  of males, females, other and not disclosed in the total  number of employees at 31 December in the reporting year. The gender categorisation is based on registrations in Maersk’s HR systems.Number of employees by contract type by gender2024EFRAG IDFemale Male Other Not  TotaldisclosedS1-6_07Number of employees (headcount) 37,459 70,100 3 598 108,160S1-6_07Number of permanent employees (headcount) 31,039 56,301 3 563 87,906S1-6_07Number of temporary employees (headcount) 6,420 13,799 0 35 20,254S1-6_07Number of non-guaranteed hours employees (headcount) 0 0 0 0 0Maersk does not employ any employees on non-guaranteed hours contracts, and the majority of Maersk’s workforce is on permanent contracts.  ACCOUNTING POLICIES Number of employees (headcount) by contract typeThe number of employees (headcount) by contract type by gender is the number of permanent, temporary and non-guaranteed hours employees in the total number  of employees at 31 December in the reporting year.  The contract type and gender categorisation are based  on registrations in Maersk’s HR systems.Number of employees by countryEFRAG ID Country Number of employees  in 2024 (headcount)S1-6_04India 16,159S1-6_05S1-6_04Denmark 15,820S1-6_05S1-6_04China 11,908S1-6_05S1-6_04USA 11,126S1-6_05For 2024, Maersk had more than 10% of its total workforce employed in each of the countries of India, China and the USA. Denmark has been included in the list as Maersk’s seafarer population is employed by a Danish legal entity and thus has been allocated to Denmark. The seafarer population totals more than 12,000 employees.  ACCOUNTING POLICIES Number of employees by countryThe number of employees by country is the number of employees in countries where Maersk has more than 50 employees, representing at least 10% of the total number of employees at 31 December in the reporting year.  The employees by country specification is based on  registrations in Maersk’s HR systems.Number of employees by contract type by region2024EFRAG IDAsia  Europe Indian subcontinent, Latin  North  PacificMiddle East, AfricaAmericaAmericaS1-6_07 Number of employees  S1-6_08(headcount) 27,015 32,781 23,770 10,526 14,068S1-6_07 Number of permanent employees S1-6_08(headcount) 19,138 21,959 23,400 9,448 13,961S1-6_07 Number of temporary employees S1-6_08(headcount) 7,877 10,822 370 1,078 107S1-6_07 Number of non-guaranteed S1-6_08hours employees (headcount) 0 0 0 0 0At year-end 2024, the share of employees in Maersk’s regions of Asia Pacific, Europe and the Indian  subcontinent - Middle East and Africa were 25%, 30% and 22%, respectively, with the Latin America  and North America regions combined accounting for 22% of the employees in Maersk.  ACCOUNTING POLICIES Number of employees (headcount) by contract typeby regionThe number of employees (headcount) by contract type by region is the number of employees by contract type by region at 31 December in the reporting year. The employee contract type and region specifications are based on registrations in Maersk’s HR systems.Employee attraction and retentionEFRAG IDUnit 2024 2023111202220212020Entity- Employee engagement  specificsurvey score Percentile rank 65 60 67 59 54S1-6_11Number of employees who left the company Number 11,835 - - - -S1-6_12Total employee turnover rate % 11 - - - -1  Not covered by the Independent Auditor’s limited assurance report.In 2024, our employee engagement survey (EES) results improved as engagement scored at the 65th percentile. We have narrowed the gap to our 2025 target (75th percentile). The progress recorded for 2024 is driven by an improvement across all questions included in the EES. For 2024, the employee turnover rate was 11%.  ACCOUNTING POLICIES Employee engagement survey scoreThe employee engagement survey score is calculated as Maersk’s aggregated ranking of employee engagement relative to Maersk’s survey vendors’ global organisational employee engagement norm. Number of employees who left the companyThe number of employees who left the company is the number of employees who left the organisation voluntarily or due to dismissal, retirement or death while employed by Maersk during the year. The number of employees who left during the year is based on registrations in Maersk’s HR systems.Total employee turnover rateThe total employee turnover is calculated based on  the average number of employees and the number of  employees who left the company during the year.Diversity of our workforceEFRAG IDUnit 2024 2023111202220212020S1-9_01Women in leadership  # 340 359 331 233 189S1-9_02(job level 6+)% 27 27 26 22 21Entity- Women in management  # 6,405 6,170 5,459 4,228 3,224specific(job level 4+)% 35 35 33 33 31Entity- Target nationalities in executive specificleadership (job levels 8 and 9) % (headcount) 21 20 16 15 12Entity- Diversity in teams (gender)specific% 58 - - - -Entity- Diversity in teams (nationality)specific% 85 - - - -S1-9_03Employees under 30 years old # 23,909 - - - -% 22 - - - -S1-9_04Employees between 30-50 # 71,946 - - - -years old% 67 - - - -S1-9_05Employee over 50 years old # 12,305 - - - -% 11 - - - -1  Not covered by the Independent Auditor’s limited assurance report.For 2024, the share of women in leadership and the share of women in management are on par with 2023. This is the result of efforts made in 2024 to continue the progress in the face of significant and necessary reorganisations that impacted Maersk’s workforce in late 2023. We also recorded a relatively higher level of gender diversity in teams of leaders in CEO -1 and CEO -2 layers. Through focused efforts, our target nationalities in executive leadership saw an overall improvement. Concerted efforts are required in 2025 to reach the targets of 30% and 40% for women in leadership and management, respectively, and to meet the target of 30% target nationalities.   ACCOUNTING POLICIES Women in leadershipWomen in leadership is the percentage of women at job levels 6, 7, 8 and 9, corresponding to leaders, senior leaders and executives, compared to the total headcount  at the same levels. Seafarers are not included in the  calculation of women in leadership since seafarers  do not have the same job level categories as our other employee groups.Women in managementWomen in management is the percentage of women at job levels 4, 5, 6, 7, 8 and 9, corresponding to managers, senior managers, leaders, senior leaders and executives, compared to the total headcount at the same levels. Sea farers are not included in the calculation of women in management since seafarers do not have the same job level categories as our other employee groups.Target nationalities in executive leadershipTarget nationalities in leadership is the percentage of leaders with non-OECD country nationalities at job levels 8 and 9, corresponding to executives, compared to the total headcount at the same levels.Diversity in teamsDiversity in teams expresses the percentage of leaders with diverse teams based on 1) gender and 2) nationality at year-end. A team is defined as the direct reports to the leader (hierarchical view), excluding executive assistants and other administrative staff. The scope of diversity in teams is leaders at the CEO-1 and CEO-2 layers.  Team diversity is assessed and calculated per leader based on two parameters: gender and nationality. The assessments are binary: either the team is diverse or non-diverse for that parameter. For a team to be consid-ered gender diverse, the percentage of one gender must not surpass 70% of the team headcount, excluding exec-utive assistants and other administrative staff. Similarly, for a team to be considered nationality diverse, the per-centage of one nationality must not surpass 70% of the team headcount, excluding executive assistants and other administrative staff.Employee age diversity The employee age diversity is the number and share of employees that are under 30 years old, between 30 and 50 years old (30 and 50 included), and over 50 years old. Age is defined as the chronological age, i.e. the total period in years a person/employee has existed. Age distri-bution of employees is based on registrations in Maersk’s HR systems.Gender diversity of our seafarers 2024EFRAG IDFemale Male Other Not  % of  disclosedfemalesEntity- Totalspecific719 11,449 0 0 6Entity- Senior officersspecific29 2,373 0 0 1Entity- Junior officersspecific89 2,727 0 0 3Entity- Cadetsspecific372 1,372 0 0 21Entity- Ratingspecific229 4,977 0 0 4In 2024, Maersk reached an important milestone by employing almost 6% of female seafarers across the fleet. According to the IMO, the industry average is 2%. Attracting more female colleagues remains a priority across our key sourcing areas where we continue to build, grow and promote career paths  for women. Key initiatives include special training programmes for young women in select markets, proactively positioning Maersk as maritime employer with career opportunities, and collaborating  with schools and universities.  ACCOUNTING POLICIES Gender diversity of our seafarersGender diversity of our seafarers is the number and share of females within Maersk’s seafarer population at year-end. The gender diversity of seafarers is based on registrations in Maersk’s HR systems. For 2024, we have applied the gender categories of male and female, which is currently in our HR system for seafarers, and all sea farers have a gender category according to this. In 2025, we will work towards including all four gender categories.Employee relations and labour rights trainingEFRAG IDUnit 2024 2023120222021 2020Entity- Employee relations and labour Completion  specificrights trainingrate 94 90 83 - -1  Not covered by the Independent Auditor’s limited assurance report.For 2024, we recorded a 4 percentage point improvement in the completion rate for the employee  relations and labour rights training compared to 2023. We continue to strive for an 100% completion  rate for the employees in scope for the employee relations and labour rights training.  ACCOUNTING POLICIES Employee relations and labour rights trainingEmployee relations and labour rights training is the completion rate of employees in scope for the employee relations and labour rights e-learning out of the total employee population in scope. The employees in scope for the e-learning in 2024 are active office-based Maersk employees. This excludes office-based employees on long-term leave, consultants and employees that have joined Maersk after 31 October in the reporting year. The completion rate is based on registrations in Maersk’s Learning Management system. The employees in scope of the training cover 58% of the total employees in Maersk during 2024.Compensation metricsEFRAG IDUnit 2024S1-16_01Gender pay gap % 5S1-16_02Annual total remuneration ratio ratio 205For 2024, our first company-wide gender pay gap analysis showed a 5% difference of average pay between female and male employees. The annual total remuneration ratio result for 2024 landed at 205. In the coming years, we will continue to refine our approach, which may also impact the outcome of the KPIs.  ACCOUNTING POLICIES Gender pay gapThe gender pay gap is calculated as the difference of average annual total remuneration between female and male employees, expressed as a percentage of the average annual total remuneration of male employees. The annual total remuneration for all own employees is calculated using the fully loaded cost index. Fully loaded cost is calculated per job level and country, and is an esti-mation of the benefits, guaranteed allowances, employer liabilities, on-target short-term incentives, on-target long-term incentives and recognition costs for 2024. The calculation is based on headcount and the estimated an-nual total remuneration at 31 December in the reporting year. Excluded from the calculation are learners, interns, graduates, students, cadets, long-term assignees and inactive employees on unpaid or garden leave.Annual total remuneration ratioThe annual total remuneration ratio is calculated by  comparing the annual total remuneration of the highest paid employee in Maersk with the annual median total remuneration of the rest of the own employees in Maersk. The annual total remuneration for all own employees is calculated using the fully loaded cost index. Fully loaded cost is calculated per job level and country, and is an esti-mation of the benefits, guaranteed allowances, employer liabilities, on-target short-term incentives, on-target long-term incentives and recognition costs for 2024.  The calculation is based on headcount and the estimated annual total remuneration at 31 December in the reporting year. Excluded from the calculation are learners, interns, graduates, students, cadets, long-term assignees and inactive employees on unpaid or garden leave.Uncertainties and estimatesWhen preparing the gender pay gap, employees with annual salaries and part-time salaries are converted to full-time equivalents as part of the calculation method-ology. In order to ensure cross-country comparability, we apply a standard formula to calculate the hourly rate for all employees. The calculation is based on a 40-hour work week or 2,080 hours per year for all employees. This is an estimate since actual and contractual working hours vary from country to country. When preparing the annual total remuneration ratio and the gender pay gap, the fully loaded cost index is used as the basis of calculation. The fully loaded cost includes benefits, guaranteed allowances, employer liabilities, on- target short-term incentives, on-target long-term incen-tives and recognition costs for Maersk’s own employees for 2024. The on-target costs for short and long-term incentives/bonus are estimates as the actual costs are dependent on various factors not fully known at the time of reporting.Employees paid below the applicable adequate wage benchmark for 2024EFRAG IDCountry % of employeesS1-10_03N/A 0For 2024, our assessment shows that we have no employees in any country that are paid below the applicable adequate wage benchmark.  ACCOUNTING POLICIES Percentage of employees paid below the applicable  adequate wage benchmarkThe percentage of employees paid below the applicable adequate wage benchmark is prepared and reported as the percentage of employees in any country where not all Maersk employees are paid an adequate wage, and is based on the total number of employees at 31 December in the reporting year. Adequate wages is determined as: In the European Economic Area (EEA): The minimum wage set in accordance with Directive (EU) 2022/2041 of the European Parliament and of the Council on adequate minimum wages in the European Union. In the period until Directive (EU) 2022/2041 enters into force, where there is no applicable minimum wage determined by legislation or collective bargaining in an EEA country, Maersk uses an adequate wage benchmark from a neighbouring country with a similar socio-eco-nomic status or not lower than a commonly referenced international norm such as 60% of the country’s median wage and 50% of the gross average wage.Outside of the EEA:i.   The wage level established in any existing interna-tional, national or sub-national legislation, official norms or collective agreements, based on an assess-ment of a wage level needed for a decent standard  of living;ii.   If none of the instruments identified in (i) exist, any national or sub-national minimum wage established  by legislation or collective bargaining; oriii.  Living Wage benchmark (typical family law) as provided by Wage Indicator.Excluded from the calculation are learners, interns, graduates, students, cadets, long-term assignees and inactive employees on unpaid or garden leave.Safety and securityEFRAG IDUnit 2024 2023111202220212020S1-14_02Fatalities Number 1 4 9 4 1S1-14_042Lost time incidents (LTIs)Number 493 376 282 270 327S1-14_0523Rate 1.53 1.14Lost time incident frequency (LTIf)0.93 0.93 1.22Entity- Learning teams completed  Completion  specificfollowing a high potential incidentrate 99 99 83 - -1  Not covered by the Independent Auditor’s limited assurance report.2  The Lost time incidents (LTIs) and Lost time incident frequency (LTIf) include both own- and non-employee workers (contracted workers) working under our responsibility.3  Restated from previously reported figure of 1.11 to align with the updated operational control definition as outlined in the sustainability statement basis of preparation. Consequently, two terminals that were previously considered under operational control have been excluded from the reporting for 2023 and 2024. The reported numbers for 2021 and 2020 have not been restated.Regrettably, we had one fatal incident involving a contracted colleague in a warehouse in the Philippines on 26 December 2024. While we have seen a significant reduction in the number of fatalities since 2022, the loss of a colleague underscores that we still have much work to do on understanding and staying ahead of our risks and building the right safety culture.The lost time incident frequency (LTIf) increased to 1.53 compared to 1.14 in 2023. This is driven by increased lost time incidents (LTIs) in Logistics &amp; Services and in APM Terminals. In Logistics &amp; Services, an approximately 50% year-over-year increase in recorded LTIs reflected an improved safety reporting culture, which is expected to be further strengthened in the upcoming years. APM Terminals experienced more inci-dents during vessel lashing, prompting work on standardising best practices in close collaboration with stevedores. Fleet LTIs, mainly involving slips, trips, falls and pinching injuries among newcomers are being addressed through enhanced safety training.For 2024, the share of learning teams completed following a high potential incident remained on par with 2023, standing at a 99% completion rate. We remain committed to reaching 100% of learning teams completed following a high potential incident.  ACCOUNTING POLICIES Scope and consolidation:The consolidation of safety data differs from the finan-cial principles used across the sustainability statement.  Safety data is consolidated using an operational control approach. Operational control is defined as the situation where Maersk or one of its subsidiaries has full authority to introduce and implement its operating poli-cies at the entity, i.e. an operationally controlled investee (such as associates, joint ventures or unconsolidated subsidiaries). In such cases, Maersk is responsible for the health, safety and environmental (HSE) management of the people, processes and facility and is liable to report 100% of the ESG data for the entity in question. Opera-tional control is determined by looking at the contractual arrangements to determine whether Maersk has the full authority to introduce and implement its operating pol-icies at the operation. In 2024, it has been assessed that Maersk does not have operationally controlled investees in e.g. associates, joint ventures, or unconsolidated sub-sidiaries. This implies that the scope and treatment of entities under financial control and operation control do not differ for 2024.  Mobile assets are included when operated by Maersk.For vessels, the International Safety Management Code Document of Compliance must be held by Maersk to be included in the safety data.FatalitiesFatalities is the headcount of work-related accidents leading to the death of the employee regardless of time between injury and death.Lost time incidents (LTIs)A lost time incident is a work-related injury, which re-sults in an individual being unable to return to work and carry out any of his/her duties within 24 hours following the injury, unless caused by delays in getting medical treatment. Excluded from LTIs are suicide or attempted suicide, ‘natural causes’, incidents during the commute to and from the regular place of work and incidents which occur off the ship, but where the consequences appear onboard at a later point in time. Lost time incident frequency (LTIf)Lost time incident frequency is the number of lost time incidents per million exposure hours. LTIs used to calcu-late the LTIf follows the definition for LTIs. Exposure hours are the total number of work hours in which an employee is exposed to work- related hazards and risks. Leave and non-work- related sickness are excluded from exposure hours.Uncertainties and estimatesWhen preparing the lost time incident frequency, the  exposure hours performed by Maersk’s own and non- employees (contractors) are used as the basis for calcu-lating the frequency. Since actual exposure hours are not registered for all employees across Maersk’s operations, Maersk applies estimates where actual exposure hours are not available. The estimates are based on the type of work and employee contracts, e.g. certain number of exposure hours for seafarers aboard a vessel and certain number of exposure hours for office-based employees.Learning teams completed following  a high potential incidentLearning teams completed following a high potential incident is calculated as the share of learning teams completed following a high potential incident has been recorded. The number of high potential incidents and learning teams completed is based on reporting by brands and maintained and quality-assured by the  Group Safety &amp; Resilience team of Maersk. To give the  organisation sufficient time to complete a learning  team and maintain completeness in our reporting, the  reporting period runs from 31 October in the previous year to 31 October in the reporting year, i.e. for 2024 the  reporting period is 1 November 2023 to 31 October 2024.    A high potential incident may be exempted from conducting a learning team in cases where a full-scale investigation has been carried out by internal or external parties, or the involved parties are outside of Maersk's  operational control, or legal circumstances does not  allow us to engage due to a legal investigation, or due  to a recurrence of an incident for which a learning team has been previously completed. GovernanceAt A.P. Moller - Maersk (Maersk), high standards of respon-sible business practices are foundational for the services we deliver to customers and the value we create for the  communities where we operate. BUSINESS ETHICSTarget by 2024 (recurring)100% of employees (in scope) trained  in business ethicsSUSTAINABLE PROCUREMENTTargets by 2024 (recurring)•  100% of suppliers (in scope) committed  to the Supplier Code of Conduct•  &gt;85% of strategic/high-risk suppliers  undergoing ESG assessments•  &gt;80% of high-risk category suppliers with  Improvement Plan successfully closed•  100% procurement staff trained in Sustainable ProcurementDATA AND AI ETHICSTarget by 2024 (recurring)100% of employees (in scope) trained  on data ethicsRESPONSIBLE TAXOngoing ambition Ensure full compliance with tax regulations  in all countries where we operatePERFORMANCE DATAMATERIAL IMPACT, RISK AND OPPORTUNITY GovernanceOverview of Maersk’s material impacts, risks and opportunities related to GovernanceBusiness ethicsLegal and regulatory compliance Impact and risk of cases of noncompliance on anti-corruption laws, international sanctions or transport of illegal goodsThe legal and regulatory landscape in which Maersk operates is complex, and Maersk could be subject to compliance cases in connection with violations of anti-corruption laws, interna-tional sanctions, transportation of illegal goods, competition law and/or data privacy. Corruption can negatively impact  company culture and society, eroding trust and exacerbating inequality in societies.Grievance and remedy Access to grievance and remedy for affected stakeholdersPotential barriers to access grievance mechanisms for our stakeholders (e.g. language, fear of retaliation, psychological or physical barriers) could result in violations of rights and lack of access to remedy. The risk is heightened in the  value chain.Sustainable procurementSupplier relationship management Risks of noncompliance with Maersk’s standards  by our suppliersRisks of suppliers not complying with Maersk’s standards,  including the Supplier Code of Conduct, could lead to Maersk being subject to cases and incidents that negatively impact Maersk’s reputation and trust with customers and/or direct financial costs. Payment practices Ensuring timely and fair payment practices to suppliersPotential impact on suppliers’ working capital and cash flow affecting their financial and operational stability. Especially with regard to late payments for small and medium-sized undertakings.Data and AI ethicsEthical use of data and AI Ethical use of our stakeholders’ data and protection  of individuals’ right to privacyPotential risk of undue influence, mishandling and abuse of data and artificial intelligence can have negative implications to the customers and business partners whose data has been handled unethically. This erodes trust in Maersk as a business partner. Potential violation of employees’ and consumers’ right to privacy if their personal data is not handled responsibly.Responsible taxTax governance Risk of different interpretations and tax controversyTax regulations are complex and differences in interpretation is considered a key risk, with impacts depending on the specific situation.Responsible  business conductA.P. Moller - Maersk (Maersk) is a purpose-driven company operating in a complex  environment that relies on integrated global supply chains. “We operate based on responsible  business practices” is a core commitment of our ESG strategy, underpinning efforts to  ensure compliance with relevant laws, regulations and responsible business conduct,  as well as having adequate risk mitigation.As a global leader in logistics services, Maersk serves 100,000+ customers and operates in almost 130 countries with a complex footprint across our business segments and value chain. We work to ensure that we have the right corporate culture to live up to our Purpose and Core Values. Our approach to this commit-ment is driven by our Commit governance framework and ESG categories on business ethics, sustainable procurement, data ethics and AI and responsible tax.  Corruption undermines social and economic development, destabilises the business environment and adds to the cost of doing business and participating in global trade. Sanctions and export controls have grown exponentially over the last three years, and with growing geopolitical tensions, they are impacting global trade more than ever. Anti-competitive behaviour distorts fair market conditions, impacting global supply chains.   In this dynamic business environment and complex legal and regulatory landscape, it is imperative for Maersk to continuously enhance our compliance programme to adapt to evolving regulatory requirements, market conditions and geopolitical events. Increasing regulation on value chain due diligence, including the EU Corporate Sustainability Due Diligence Directive is also raising the importance of ensuring that Maersk’s suppliers meet our global standards and local laws around business ethics, human and labour rights, working conditions and employment practices and environmental responsibility.   Maersk also sees a sharp rise in contraband, from narcotics to illegal wildlife and timber trafficking, and stolen and counterfeit goods. These criminal activities continue to affect our supply chain and require on going, proactive management to mitigate the risks of threats to people, bribery attempts and opera-tional disruptions that are often associated with contraband trafficking.  Finally, as the digitalisation of supply chains continues to accelerate, including the rapid adoption of generative AI, responsibly managing data from business partners and customers has never been more relevant to maintaining their trust in Maersk. ESRS G1, S3Business ethicsCorruption, sanctions and export controls, competition law  violations and data privacy and ethics are the most material business ethics risks of Maersk. Failing to live up to our business ethics commitment could subject Maersk to legal or reputational risks and negatively impact company culture and societies where we operate. Our policies, approach and governance of business ethics focus on high standards for responsible business practices everywhere we operate, aligned with international requirements and with a heightened focus in jurisdictions with greater exposure to these risks and human rights abuses.Policies and approachThe Maersk Code of Conduct sets global standards for how we engage with colleagues, customers, suppliers, communities, authorities and other stakeholders. As a global company, we take an active responsibil-ity for the society and environment where we operate and are guided by international standards such as the Universal Declaration of Human Rights and the principles of the UN Global Compact. The Code is publicly available on Maersk.com in 17 languages.  The standards in our Code are supported by and explained in more detail in the Commit Business Ethics Rules. These rules are to be adhered to by all employees regardless of business association or geographic location, including contracted staff who act on behalf of Maersk and employees in controlled joint ventures.  Employees are required to take Code of Conduct trainings (onboarding and yearly refreshers). We conduct ongoing campaigns and activities linked to international awareness events such as Business Ethics Day, Anti-Corruption Day and Illegal Wildlife Day. Other commu-nication activities include our Speak-Up and No Retaliation campaign, Sanctions and Export Controls awareness, Dawn Raid Preparedness and Data Privacy Due Diligence Check campaign.  We are committed to investigating allegations of business miscon-duct promptly, independently and objectively. Depending on the type of case, investigations are carried out by independent and objective investigators from relevant teams in Maersk or by external advisors. Protocols are in place for internal investigations and disciplinary actions to ensure a swift and effective response to compliance violations. Cases of non-compliance are reported to the Board of Directors and Executive Leadership Team through the Risk and Compliance Committee.   The Commit Rules covering anti-corruption, sanctions and export controls, competition law violations and data privacy set out the meas-ures to identify, mitigate and manage compliance risks in jurisdictions where we operate. The efforts are carried out through dedicated teams of 70+ compliance professionals and a comprehensive Business Com-pliance Ambassadors’ network. These experts, represented in all regional offices and many high-risk locations, partner with colleagues in the business to detect, assess and mitigate risks.   Maersk is an active and founding member of the Maritime Anti- Corruption Network (MACN), working to eliminate corruption in the maritime and port industries. In 2024, Maersk partnered with MACN and USAID for a two-year project under the headline “Doing Business with Integrity”. This collaboration is part of USAID’s Countering Trans-national Corruption Grand Challenge for Development, which is set to strengthen the fight against transnational maritime sector corruption. Targets and progressWe have set the strategic target that 100% of our employees in scope complete our Code of Conduct training each year. This year, 94% of Maersk employees in scope completed the mandatory Code of Conduct training. Challenges in reaching all employee groups remain, particu-larly due to organisational changes, however, we are working to close this gap to 100% completion in 2025.100% of employees (in scope) trained in the Maersk  Code of Conduct94%(2023: 92%)A risk assessment is performed at least every two years, with the most recent in 2023, to identify high risk areas, functions and busi-ness activities. This is tracked through the percentage of operations covered by a risk assessment on compliance and business ethics targeting 100%.Key actionsAs we continue to advance on our business ethics ambitions, we com-pleted the following key actions in 2024: •  Introduction of the ‘Minerva’ cargo screening platform, to automate compliance and adapt screening processes to evolving trade regula-tions, with an initial focus on sanctions screening.•  Reporting of the bi-annual 2023 risk assessment to business leaders and functional heads and implementation of mitigating measures. A next-generation risk assessment is under development for 2025 deployment, with the goal of anchoring compliance risk owner ship in the appropriate businesses and functions. •  Working with sustainable procurement and vendor data manage-ment to integrate third-party management screening and assess-ment at the process level during vendor onboarding. •  Digitalisation of key compliance approvals and processes to provide insights into operational and compliance risk trends and patterns within the business. •  Completion of 87 compliance spot checks on selected entities and processes, covering critical risks within the areas of anti-corruption, sanctions compliance, competition law and data privacy.ESRS G1, ESRS S1, ESRS S2Sustainable procurementManagement of ESG risks in our supply chain network enhances stakeholder trust in our brand and equips us to meet current and upcoming supply chain due diligence regulations. Maersk’s operations and procurement choices influence the social, envi-ronmental and economic conditions within our industry, global supply chains and the communities we serve. We are continu-ously enhancing the process of embedding ESG as a strategic priority throughout the supplier lifecycle. We promote supplier collaboration and engagement, driving co-development and innovation towards sustainable outcomes.Policies and approachOur updated 2024 Supplier Code of Conduct is aligned with the UN Guiding Principles and OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. It reflects Maersk’s values of ethical conduct, environmental stewardship and social responsibility.   Enforced through the Commit Sustainable Procurement Rule, the Code sets expectations for suppliers to uphold responsible practices in areas such as ethics, human rights, working conditions and environ-mental standards, and in compliance with all applicable laws and reg-ulations. The Code also outlines the expectation for our suppliers to implement the Code or similar requirements with their sub-suppliers. It is communicated through several internal channels and is publicly available on Maersk.com in 12 different languages.   Our approach to sustainable procurement is founded in our com-mitment to proactively manage supply chain risks as our “licence to operate” and to comply with an evolving regulatory landscape, includ-ing the upcoming Corporate Sustainability Due Diligence Directive (CSDDD). ESG due diligence is therefore an integral part of our sup-plier selection process. We also focus on continuously building the capacity of our procurement team and business functions who inter-act with suppliers to fully integrate ESG principles and ensure com-pliance with our standards. Our approach to procurement emphasises ESG integration through three key priorities: value chain decarbonisation, human and labour rights and safety and resilience.  Supporting Maersk’s science-based targets, we focus on reducing scope 3 emissions, targeting key hotspots using data-driven insights and initiatives like supplier maturity assessments and abatement models.   The Sustainable Procurement programme contributes to the effective development, deployment and monitoring of our global standards on third-party labour and safety across our supply chain, to promote fair working conditions. Human rights and labour rights are integrated into our due diligence processes for suppliers. To address emerging risks from new business activities such as the development of green fuel supply chains, we are developing a green fuel sourcing due diligence framework. Site visits and workshops are conducted to raise awareness, with the aim that suppliers adhere to Maersk’s standards in all aspects of their operations. This is supported by dedicated safety superintendents who oversee and conduct periodic on-site safety training sessions.   We promote a speak-up culture and actively monitor whistleblower cases to ensure transparency and accountability on identified value chain issues. Suppliers are required to communicate the Whistleblower channel’s existence, and to ensure that their employees and subcon-tractors are made aware of it. Each reported issue is investigated and, where necessary, appropriate remedies are provided.   Furthermore, we are piloting business resilience requirements with selected suppliers to strengthen Maersk’s business continuity manage-ment framework, identifying learnings and scaling it for global applica-tion across our supplier base.  We recognise that ensuring fair and timely compensation for suppli-ers is part of responsible supplier engagement. Our standard payment terms vary based on the service/spend category. We strive to align pay-ments with these terms and continuously monitor payment practices to ensure compliance and improve supplier’s experience. We are build-ing visibility on supplier-related payment impacts, especially regarding late payments to small and medium-sized businesses through internal processes and tools, minimising the impact of delayed payments by prioritising prompt and equitable payment processes, aligned with local and national requirements. We are also actively engaging with suppliers on effective arbitration on late-payment related issues.PercentSustainable procurement targets100% of suppliers (in scope) committed  to the Supplier Code of Conduct by 2024. &gt;85% of tier 1 high-risk category suppliers  undergoing ESG assessment by 2024. &gt;80% of high-risk category suppliers with  Improvement Plan successfully closed by 2024. 100% procurement staff trained  in Sustainable Procurement by 2024.Targets and progressWe have set an annual target for all of our suppliers in scope to sign and comply with our Supplier Code of Conduct, supported by a mandatory Sustainable Procurement Clause. Currently, 87% have signed the Code. The decrease from 2023 is a result of integration of additional supplier contracts into the compliance framework and improvements to our calculation methods for the KPI.  We evaluate supplier compliance towards our Code across key areas such as anti-corruption, health and safety, labour and human rights and environmental practices. Our evaluation process includes pre-screening, desktop assessments, on-site audits and improvement plans to address identified gaps. During 2024, we digitised our report-ing structure, which resulted in an expanded addressable baseline for the supplier assessment metric, causing a 24 percentage point decrease compared to 2023. To close