Assets

Type	Time	Amount	Unit
ifrs-full:Assets	2024-12-31	39281000000	dkk
ifrs-full:Assets	2023-12-31	34647000000	dkk

Revenue

Type	Start date	End date	Amount	Unit
ifrs-full:Revenue	2024-01-01	2024-12-31	29753000000	dkk
ifrs-full:Revenue	2023-01-01	2023-12-31	27304000000	dkk

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   <mrv:StatementOfPolicyForDataEthics contextRef="ctx-1" id="s8__8__8" xml:lang="en">3. ITSystems breakdown, cyber-attacks and security breachesRisk description:Information technology systems and platforms are essential to daily operations. Disruptions to vital systems can significantly compromise oper-ations and hence customer relations and earnings. Such disruptions could be inadvertent loss of data, cyber-incidents leading to critical system shutdowns, or information security risks related to management of passenger and freight customer data.Mitigation strategies:IT disruption risk is mitigated by prioritisation of cyber security solutions, continuous system monitoring, backup systems, and standard operating procedures to restore system functionality. This includes ongoing updates to standard systems, regular testing of recovery processes, focus on identi-fying and preventing malware, multi-factor authenti-cation, and network segmentation. Both internal and external resources are used to conduct awareness and security tests.Risk assessment:2024 saw an increase in the frequency of cyber attacks and the tools used by cyber criminals continue to become more advanced. The elevated risk was managed through groupwide awareness training, running of frequent tests and attack simulations, and investment in technologies to improve resilience. DFDS also participates in multiple cyber security networks to help increase industry knowledge and awareness. Cyber security risk levels are expected to remain high in 2025.</mrv:StatementOfPolicyForDataEthics>
   <mrv:SustainabilityReport contextRef="ctx-1" id="s8__8__9-1" xml:lang="en">Sustainability statementIntroduction to the Sustainability statementThis year marks a significant step forward in cor-porate sustainability reporting with the implemen-tation of the Corporate Sustainability Reporting Directive (CSRD). For the first time, DFDS has pre-pared its sustainability disclosures in accordance with this new regulatory framework, reflecting our commitment to enhanced transparency and alignment with the latest regulatory requirements.The Sustainability Statement encompasses our CSRD reporting; a comprehensive approach to reporting on environmental, social, and gover-nance (ESG) matters. It goes beyond traditional sustainability reporting by following a structured framework based on the European Sustainability Reporting Standards (ESRS). These standards ensure consistency, comparability, and a holistic perspective on how sustainability is integrated into our governance, strategy, and operations.Unlike previous sustainability disclosures, the CSRD emphasises both our impact on the environ-ment and society and how sustainability factors affect our business performance and resilience. This dual focus, known as the double materiality principle, is central to the directive’s purpose and is reflected throughout this statement. DFDS has adopted a foundational approach, choosing to focus on the mandatory disclosure requirements for the 2024 reporting year. Com-parative figures for prior years are not included, a choice made in order to ensure alignment with the new framework, and establish a consistent and reliable baseline for future reporting. Howev-er, for the EU Taxonomy reporting, comparative figures are included. Moving forward in coming years, we will include comparative data, which will further enhance our disclosures. We have chosen to exclude voluntary or phase-in disclosures in 2024. Looking ahead, we will in-clude the phase-in disclosures when applicable, and where relevant, include voluntary standards. The following pages outline our governance structures, sustainability strategies, and key metrics, providing a clear and detailed account of our approach to managing impacts, risks, and opportunities in the evolving ESG landscape. This section is designed to offer valuable insights for stakeholders seeking a deeper understanding of our sustainability journey and its alignment with global sustainability goals.This section serves as our mandatory statement on sustainability, cf. Section 99a in the Danish Financial Statements Act.Guide to CSRD integration in the statementThis report integrates the Corporate Sustainability Reporting Directive (CSRD) requirements through the European Sustainability Reporting Standards (ESRS) developed by EFRAG. Recognising the breadth of new elements in this sustainability statement, we have provided the following guide to help our readers navigate the content:ElementExample DescriptionSection Headers ESRS 2 General...Indicates the specific European Sustainability Reporting Standard (ESRS) being addressed.Sub-Section HeaderBP-1General basis for...Refers to the specific reporting requirement under the sub-topic.Supplementary Subheadings Time horizonsAdditional titles or descriptive labels that are included under the sub-section header to provide further context or highlight specific focus areas within the sub-section.Disclosure Requirement (DR)Refers to the specific reporting requirement paragraph number under the sub-topic. This defines the exact information the company must disclose to meet ESRS standards.The following options for expressing the specific reporting requirement paragraph numbers exist in our statement: Single Paragraph DR Reference5cA single paragraph reference within a subsection. Consecutive Paragraph DR Reference9a-bA consecutive paragraph reference within a subsection. In such cases, the reporting requirements can be combined and addressed together.Combination of DR References29b, dA combination of non-consecutive data points from different parts of the subsection. In such cases, the reporting requirements can be combined and addressed together.ESRS 2 General disclosures67 Basis of preparation69 Sustainability governance71 Strategy, business model, and value chain74 Double materiality assessment IRO-2 Index of material disclosuresESRS standardDRDescriptionPage numberESRS 2BP-1General basis for preparation of sustainability statementBP-2Disclosures in relation to specific circumstancesGOV-1The role of the administrative, management and supervisory bodiesGOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodiesGOV-3Integration of sustainability-related performance in incentive schemesGOV-4Statement on due diligenceGOV-5Risk management and internal controls over sustainability reportingSBM-1Strategy, business model and value chainSBM-2Interests and view of stakeholdersSBM-3Material impacts, risks, and opportunities and their interaction with strategy and business modelIRO-1Description of the process to identify and assess material impacts, risks and opportunitiesIRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statement E1E1.GOV-3Integration of sustainability-related performance in incentive schemesE1-1Transition plan for climate change mitigationE1.SBM-3Material impacts, risks, and opportunities and their interaction with strategy and business modelE1.IRO-1Description of the processes to identify and assess material climate-related impacts, risks and opportunitiesE1-2Policies related to climate change mitigation and adaptionE1-3Actions and resources in relation to climate change policiesE1-4Targets related to climate change mitigation and adaptionE1-5Energy consumption and mixE1-6Gross Scopes 1,2,3, and Total GHG emissionsE2E2.IRO-1Description of the processes to identify and assess material pollution-related impacts, risks and opportunitiesE2-1Policies related to pollutionE2-2Actions and resources related to pollutionE2-3Targets related to pollutionE2-4Pollution of airE4E4.SBM-3Material impacts, risks and opportunities and their interaction with strategy and business modelE4.IRO-1Description of processes to identify and assess material biodiversity and ecosystem-related impacts, risks and opportunitiesE4-2Policies related to biodiversity and ecosystemsE4-3Actions and resources related to biodiversity and ecosystems E4-4Targets related to biodiversity and ecosystemsE4-5Impact metrics related to biodiversity and ecosystems changePage 67Page 67Page 68Page 69Page 69Page 70Page 67Page 71Page 73Page 77Page 75Page 65Page 88Page 83Page 85Page 86Page 84Page 87Page 89Page 93Page 94Page 97Page 97Page 97Page 98Page 98Page 101Page 100Page 100Page 100Page 101Page 101IRO-2 Index of material disclosures continuedESRS standardDRDescriptionPage numberS1S1.SBM.2Interests and views of stakeholdersS1-SBM-3Material impacts, risks and opportunities and their interaction with strategy and business modelS1-1Policies related to own workforceS1-2Processes for engaging with own workforces and worker's representatives about impactsS1-3Processes to remediate negative impacts and channels for own workforce to raise concernsS1-4Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related to own workforce, and effectiveness of those actionsS1-5Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities S1-6Characteristics of the undertaking's employeesS1-8Collective bargaining coverage and social dialogueS1-9Diversity metricsS1-10Adequate wagesS1-14Health and safety metricsS1-16Remuneration metrics (pay gap and total remuneration)S1-17Incidents, complaints and severe human rights impactsS2S2.SBM-2Interests and views of stakeholdersS2.SBM-3Material impacts, risks and opportunities and their interaction with strategy and business modelS2-1Policies related to value chain workersS2-2Processes for engaging with value chain workers about impactsS2-3Processes to remediate negative impacts and channels for value chain workers to raise concernsS2-4Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actionS2-5Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities S4S4.SBM-2Interests and views of stakeholdersS4.SBM-3Material impacts, risks and opportunities and their interaction with strategy and business modelS4-1Policies related to consumers and end-usersS4-2Processes for engaging with consumers and end-users about impactsS4-3Processes to remediate negative impacts and channels for consumers and end-users to raise concernsS4-4Taking actions on material impacts on consumers and end-users, and approaches to 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S4-5Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities G1G1.GOV-1The role of the administrative, supervisory and management bodiesG1.IRO-1Description of the processes to identify and assess material impacts, risks, and opportunitiesG1-1Business conduct policies and corporate cultureG1-2Management of relationships with suppliers G1-3Prevention and detection of corruption and briberyG1-4Incidents of corruption or briberyG1-6Payment practicesPage 73Page 110Page 110Page 111Page 111Page 112Page 113Page 114Page 115Page 116Page 116Page 117Page 118Page 118Page 73Page 120Page 120Page 121Page 121Page 122Page 122Page 73Page 124Page 124Page 125Page 125Page 125Page 125Page 128Page 128Page 128Page 129Page 129Page 130Page 130Basis of preparationBP-1 General basis for preparation of the sustainability statement5a-bii The sustainability statement for the period from 1 January 2024 to 31 December 2024 has been prepared according to the requirements of the EU’s Corporate Sustainability Reporting Direc-tive (CSRD) and EFRAG's European Sustainability Reporting Standards (ESRS). Information in the sustainability statement has been prepared on the same consolidated basis as DFDS A/S’ 2024 financial statements; the consolidated quantita-tive CSRD data comprises the parent company DFDS A/S and the subsidiaries it controls. The Group does not have material associates.5cThe sustainability statement includes the majority of DFDS' value chain with regard to impacts, risks, and opportunities. The reporting covers DFDS’ value chain from the point our cus-tomer’s goods start their transportation journey until they are delivered. Thus, any re-source extraction or manufacturing of goods in the upstream and any use of transported goods by end-users are deemed outside the boundaries of reporting. In the double materiality assessment (DMA), we recognise potential impacts, risks, and op-portunities (IROs) in activities that are currently outside our boundaries. As part of the DMA review process, we will reassess the boundar-ies annually to ensure that it is reflective of our business and our responsibilities. 5d-e In regard to intellectual property and know-how, we have not omitted any information. The report does not include matters in the course of negotiation, unless these have already been pub-licly disclosed and are deemed relevant to report.BP-2 Disclosures in relation to specific circumstances Time horizons 9a-bIn the CSRD report, time horizons are defined as follows: Short-term is up to 1 year, medium-term is 1-5, and long-term 5+ years. The definition is aligned to the time horizons applied in DFDS' enterprise risk management (ERM) system.Value chain estimation10a-d Estimates and judgements used in report-ing are reassessed on a yearly basis. We use a spend-based approach for our Scope 3 reporting, in which carbon emissions are estimated based on the categorisation of invoices. Please see the descriptions in the accounting policies in each section for more detailed information on the esti-mations. Changes in estimates are described in the period in which the estimated data is revised. Sources of estimation and outcome uncertainty11a Where quantitative metrics and monetary amounts are subject to uncertainty, it is be men-tioned and included in our accounting policies. This also includes any assumptions, approxima-tions, and judgements made for measurements. In the 2024 report we have identified no metrics subject to a high-level of uncertainty.Ekol Logistics acquisitionIn November 2024, DFDS acquired the Turkish lo-gistics company, Ekol Logistics. Key ESG metrics from Ekol's operations have been incorporated into this report for the period from 15 November to 31 December, 2024. Given that Ekol has similar operations to DFDS in terms of activities and geography, it has been assessed that the double materiality assessment (DMA) already performed for DFDS at the time of acquisition is adequate. Scope 3 estimationAn estimation has been utilised on part of our Q4 Scope 3 spend data, due to the liquidation of a spend consolidation tool, which has been utilised for past reporting, and in Q1-Q3 of this year. Disclosures stemming from other legislation or generally accepted sustainability reporting pronouncements15 The sustainability statement is based on the ESRS reporting requirements, as well as the EU taxonomy requirements. The other standardised framework for reporting includes the use of the Greenhouse Gas (GHG) Protocol for our ESRS E1 re-porting on GHG emissions. We utilise the Taskforce on Climate-related Financial Disclosures (TCFD) framework for our ESRS E1 risk scenario analysis. DFDS has been a proud signatory of the UN Global Compact since 2015 and is committed to the Sustainable Development Goals (SDGs); 13 - Climate Action, 14 - Life Below Water, 15 - Life on Land, 3 - Good Health, 5 - Gender Equality, and 17 - Partnerships for the Goals. We are guided by these SDGs when defining ESG strategy and utilise them as a framework and inspiration for driving positive impact and fostering engagement across our operations.GOV-5 Risk management and internal controls over sustainability reporting36a-b To mitigate risks and ensure clear controls in sustainability reporting under the CSRD, DFDS established a dedicated CSRD Reporting Team within Group Finance. The team interprets the CSRD requirements, ensuring a uniform approach across all components. The scope encompasses the entire CSRD. The risk assessment approach for sustainability reporting is an internal process within the CSRD Reporting Team.36c The key risks identified for sustainability reporting and their mitigation strategies are as follows:Data completeness and data quality: a chal-lenge faced by DFDS as an organisation, on lack of complete or accurate data in various areas. The mitigation strategies for this risk are in line with the general DFDS strategy to digitise and standardise, to gain better data completeness and quality. For data complete-ness, various controls from outside teams on data inputs as well as controls from the CSRD Reporting Team are implemented. To miti-gate data quality risks, we are maturing the reporting processes with data owners through training and dialogue to ensure awareness of reporting requirements. Differences in land-based versus sea-based data: a risk exists in how different systems Basis of preparationand processes used for sea versus land operations can lead to data quality risks. To mitigate the risk, we have ensured that differ-ent data collection methods are designed for land and sea operations to ensure accurate data inputs exist from both sources. Systems and alignment: A current risk related to sustainability reporting is the reliance on manual reporting methods. A long-term mitiga-tion plan is based on the implementation of a system for all sustainability reporting.36d The findings of the risk assessment and in-ternal controls have led to an increased empha-sis on training prior to reporting. We ensure that the functions responsible for reporting receive sufficient information to perform the task along with support during reporting processes by the CSRD Reporting Team. As data is delivered, the CSRD Reporting Team performs internal controls.36eThe first year of sustainability reporting established a baseline understanding of sustain-ability reporting risks for DFDS. The Audit Com-mittee (AC) and the Board of Directors oversee these risks, ensuring adequate supervisory func-tions. Both the Board of Directors and the AC were periodically informed about the reporting status, risk assessments, and internal controls relating to CSRD reporting. These supervisory functions will continue.GOV-1 The role of the administrative, management, and supervisory bodies 21a-b, d-e The table beside provides an overview of key quantitative metrics related to Board of Directors composition, gender diversity, and independence, reflecting our efforts to ensure a balanced and inclusive governance structure.21c The AGM-elected members of the DFDS' Board of Directors and the Executive Manage-ment possess a range of experience relevant to the sectors, products, and geographic locations in which the undertaking operates.Claus V. Hemmingsen has experience as the for-mer CEO of Maersk Drilling and was Vice CEO of A.P. Møller-Mærsk A/S, bringing significant lead-ership in global logistics and maritime industries.Klaus Nyborg brings expertise from his role as CEO of Pacific Basin Shipping Ltd., with extensive knowledge in international shipping and trans-port logistics.Minna Aila contributes expertise in sustainability, public affairs, and corporate relations, which are crucial for managing the company's reputation and engagement in various markets.Anders Götzsche and Dirk Reich have relevant ex-perience in finance and international logistics, es-sential for the financial oversight and operational efficiency of the company in diverse markets.21 a-b, d-eInformation, roles, and responsibilities of the administrative, management, or supervisory bodiesMetricValueNumber of Executive MembersThe Executive Management consists of two executive members, the CEO and CFO.Number of Non-Executive MembersThe Board of Directors consists of nine non-executive members of which six are AGM-electedRepresentation of employees The Board of Directors consists of three staff representatives. Board of Directors Gender Diversity RatioThe strategic focus areas on diversity is mirrored in the Board of Directors. Diversity in the board is measured in terms of gender and nationality and on both parameters the target of equality is met.In 2024, the representation of women was maintained at 33%, as was the share of non-Danish directors.Percentage of Independent Board MembersFour out of six AGM elected directors (67%) are independent which is unchanged from last year.Jill Lauritzen Melby has extensive background in finance and accounting, supporting the compa-ny's need for financial acumen across different markets.These members collectively cover a wide array of competencies, including international manage-ment, sustainability, public affairs, financial oversight, and logistics, all of which are critical to the company's global operations and diverse market presence.22a In DFDS, the Board of Directors has the ulti-mate oversight of sustainability. The Board of Di-rectors reviews the overall sustainability approach, the methodology and outcome of the DMA, targets and performance in the approval of the annual sustainability report. The AC has a special focus on the governance, internal controls, and procedures related to sustainability reporting, and the Remu-neration Committee oversees the ESG incentives for the Executive Management. The work in both committees inform and supplement the Board of Directors oversight.22b The rules of procedure of the Board of Directors specifies compliance and risk manage-ment in the list of tasks. The AC charter includes responsibility for sustainability reporting.22c The Executive Management Team (EMT) ensures executive ownership of the ESG agenda and is actively involved in selecting sustainability priorities and driving implementation of relat-ed action plans. Prior to the Board of Directors approval, the EMT reviews the results of the DMA. The DMA and resulting IROs are facilitated by the CSRD Reporting Team. The methodology and out-come is presented to the EMT for their review and approval. The management’s role has not been delegated to a specific position or committee, and no dedicated controls of procedures have yet been applied. 22d As for the sustainability reporting in general, the Board of Directors has ultimate oversight of target setting and the progress on targets. Target setting originates from the division or function responsible for the IROs the target relates to. The EMT reviews and decides on proposed targets and monitors the progress towards them on an ongoing basis.23 The EMT ensures appropriate skills and expertise in sustainability matters in key positions in DFDS and mandate the utilisation of external expertise as needed. In some areas, the EMT has formed boards or committees to ensure the cross-functional expertise needed for those areas.23a-b The key sustainability-related expertise deemed relevant in DFDS and in alignment with the identified IROs include: decarbonisation, health &amp; safety, people matters related to own workforce, responsible procurement, biodiversity, and sustainability reporting. The EMT and the Board of Directors meet regularly with in-house Sustainability governanceexperts including the VP of Decarbonisation, the Director of Sustainability, and the Head of CSRD Reporting, and can thereby determine the appro-priateness of the expertise in these functions.GOV-2 Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies 26 The Board of Directors work in accordance with the company’s articles of association, the rules of procedure of the Board of Directors as well as an established annual cycle of focus ar-eas to ensure that all major governance aspects are reviewed at least once annually. The Board of Directors approve the ESG strategy as part of the corporate strategy and is actively involved in the approval of long-term targets. As a part of its strategy review, the Board of Directors reviewed DFDS’ climate strategy and transition plans for the Ferry and Logistics Divi-sions, including the deployment of increasingly emission-friendly propulsion technologies. The Board of Directors is updated on strategic ESG topics and progress at least twice a year. Leading up to the first CSRD report for the financial year 2024, the Board of Directors, the AC and the EMT have received information more frequently. From 2025, the expectation is for each of the bodies to perform an annual review of the updated DMA and resulting IROs, including due diligence, results and effectiveness of policies, actions, metrics, and targets. From 2025, it is our ambition to establish closer ties between the IROs and strategic processes, due diligence processes for major transactions, and risk management in general. The full list of IROs has been reviewed and approved by man-agement and the Board of Directors.GOV-3 Integration of sustainability-related performance in incentive schemes 29a DFDS' remuneration policy sets forth the requirements in respect of the remuneration of the EMT and the Board of Directors. This includes the mandate for the Renumeration Committee, whose responsibility is to review and provide recommen-dations of the remuneration of the EMT and Board of Directors. The remuneration policy principles the remuneration design, the total remuneration by components, how each component supports the achievement of the strategy, and the long-term interest and sustainability of DFDS. Total target remuneration is determined by the role, experience, skills, and sustained perfor-mance level, aligning with market practices and business needs. Short-term incentives are based on annual business performance metrics, while long-term incentives emphasise sustained value creation, and that benefits are tailored to the position and local market. Remuneration is reviewed annually. 29b, d The CEO and CFO are the members of the EMT, who have specific ESG-related targets linked to their remuneration. The CEO has short-term bonus incentives in which female representation, safety, and decarbonisa-tion each have a 10% weight. The CFO has a short-term ESG incentive which groups female representation, safety, and decar-bonisation with a weight of 10%. 29cWhile ESG incentives are in place as outlined above, the specific target metrics are not published.29e The Remuneration Committee is overall responsible for the annual review of the remunera-tion terms, including performance metrics applied to short-term incentives (content, weight, and scale to reflect the business priorities), and an an-nual review of the long-term incentive grant levels and terms in advance of grants being delivered. In addition, the policy is reviewed on an annual basis to ensure its appropriateness.Sustainability governanceGOV-4 Statement on due diligenceCore elements of due diligenceParagraphs in the sustainability statementsPage referencea) Embedding due diligence in gover-nance, strategy and business model ESRS 2 GOV-2 ESRS 2 GOV-3 ESRS 2 SBM-3 b) Engaging with affected stakeholders in all key steps of the due diligence ESRS 2 GOV-2 ESRS 2 SBM-2 ESRS 2 IRO-1 ESRS 2 GOV-3 G1-1 G1-3 G1-4 E1-2 E2-1 E4-2 S1-1 S2-1 S4-1 c) Identifying and assessing adverse impacts ESRS 2 IRO-1E1 IRO-1 E2 IRO-1 E4 IRO-1 ESRS 2 SBM-3 E1 SBM-3 E4 SBM-3 S1 SBM-3 S2 SBM-3 S4 SBM-3 G1 IRO-1 d) Taking actions to address those adverse impacts E1-3 E2-2 E4-3 S1-4 S2-4 S4-4 e) Tracking the effectiveness of these efforts and communicating E1-4 E2-3 E4-4 S1-5 S2-5 S4-5 Page 69Page 69Page 77Page 69Page 73Page 75Page 69Page 128Page 129Page 130Page 84Page 97Page 100Page 110Page 120Page 124Page 75Page 86Page 97Page 100Page 77Page 85Page 101Page 110Page 120Page 124Page 128Page 87Page 97Page 100Page 112Page 122Page 125Page 89Page 98Page 101Page 113Page 122Page 125Strategy, business model, and value chainSBM-1 Strategy, business model and value chain Sustainability matters in strategy40ai-ii, e-f DFDS operates a comprehensive European transport network, moving goods via ferry, road, and rail while offering tailored logistics solutions. The Ferry Division runs fixed-schedule routes across five key regions: the North Sea, Mediterranean, Channel, Baltic Sea, and Strait of Gibraltar. Strategically located port terminals enhance freight services for forwarders, hauliers, and heavy goods manufacturers. Complementing this, the Logistics Division delivers door-to-door solutions, including full and part loads, tempera-ture-controlled options, warehousing, and just-in-time concepts, supported by DFDS’ ferry routes and a European road, rail, and container network. As part of the "Move Together Towards 2030" strategy, sustainability considerations are inte-grated into DFDS’ corporate strategy, driving sus-tainable and responsible growth. Environmental, social, and governance principles are included in operations and strategic decisions, ensuring progress toward reducing environmental impact, fostering safety and inclusivity, and upholding transparency. This approach reflects DFDS’ com-mitment to creating lasting value for stakeholders and the communities it serves. In addition, sustainability is integral to our com-mercial operations, as we provide decarbonised transport solutions to customers through both direct and indirect emission reductions across our route network. 40gThere are a few challenges which DFDS faces in sustainability, especially within the green transition. In the ferry and logistics industry, we face challenges such as the availability of alternative fuels, technol-ogy, and infrastructure development. The limited availability of alternative fuels, the substantial investment and time required for new technologies, and the need for extensive infrastructure upgrades, especially in less developed regions, collectively pose significant challenges to transitioning away from traditional fossil fuels and achieving consistent operations across our network. Despite these chal-lenges, DFDS remains committed to advancing our sustainability goals by actively exploring innovative solutions, and collaborating with industry partners. The ferry and logistics industry face challenges on the social side as well, such as gender balance and safety due to the inherent nature of the in-dustry. While we actively work towards improving gender diversity and can see positive changes, the transformation in achieving a more balanced gender split takes time. Safety remains an inher-ent risk in our industry, and we continuously strive to prioritise and enhance safety measures to protect our workforce. 45c, ci There have been no material changes to strategy or business model in the reporting year. The "Moving Together Towards 2030" strategy was introduced late 2023.Key figures for DFDS in 202440aiii Largest countries by headcountCountryEmployee headcountUK3,828Türkiye3,251Denmark1,743Poland1,397France1,241Other5,976Total17,43640b Total revenue by significant activities DKK millionRevenueFerry Division16,489Logistics Division13,253Non-allocated11Total29,753Sustainability in DFDSIntegrated in our "Moving together towards 2030" strategyEnvironmentalSocialGovernanceGreen transformationWe are committed to finding solutions to decarbonise our operation and industry and to address key environmental high-impact areas.Responsible and caring employerWe are commited to creating a safe and inclusive workplace with a focus on the well-being of all our employees and supporting their physical and mental health.Responsible business practicesWe support and report in line with recognised ESG disclosure frameworks to be transparent about our impact on society, customers, and the environment.How we bring the strategy to lifeDecarbonisationRenewable energyUse and reuse of resourcesBiodiversityDiverse and inclusive workplaceSafe place to work Engaging leadersStrong policy frameworkWhistleblower mechanismsResponsible procurementIncentivised pay on ESGStrategy, business model, and value chainBusiness model and value chain 42a-c DFDS' business model revolves around ferry, road and rail transport and complementa-ry logistics solutions. The value chain has been mapped by a review of our activities, resources and relationships. The process included desk research, interviews with internal stakeholders, and input by external consultants. The output of our business model is value creation for several stakeholders. DFDS is facilitating business and trade by transporting goods, connecting people in countries and regions separated by sea, and is a provider of vital infrastructure of ferry routes. In performing our business, we create stable jobs and safe workplaces, proactively drive the green transformation, and deliver return on invested capital to shareholders.The features of our value chain include source extraction in the upstream and any use of transported goods by end-users. Similarly, resource extraction related to and manufacture of vessels, trucks and other equipment in the upstream and the refitting or scrapping in the downstream. These activities are deemed to be outside the boundaries of the report based on relevance and impact. Depending on the offering and customer needs, DFDS operations span from transport to port, over port handling and sea voyage, to transport from port. The main business actors include our freight customers, passengers, partners, and suppliers of freight solutions predominantly in truck trans-portation and rail solutions.Strategy, business model, and value chainSBM-2Interests and view of stakeholdersStakeholder engagement 45b, dStakeholder engagement is a natural part of our day-to-day business. We engage and part-ner with suppliers and customers to rethink busi-ness processes and find new ways of collaborating to gain viable traction in the green transformation. Our people make the difference throughout the network, and it is through engagement with our people that we adapt operations to keep goods and people moving in continually changing circum-stances. We engage with the financial community, primarily institutional investors and analysts, as an ongoing dialogue facilitated by Investor Relations. The interests and views of all our stakeholders provide key inputs in our strategy processes, which in turn impacts our business model. The EMT takes an active role in the stakeholder engagement. The Board of Directors are informed about the views and interests of stakeholders as part of the general strategy and risk management processes, and specifically for their approval of the DMA.Stakeholder engagementStakeholder Engagement occursHow it is organisedPurposeOutcome taken into accountCustomersRegular interactionAccount management and day-to-day interactionOrder fulfilment and customer satisfaction. Understanding the demand for green transport solutions.Customer feedback is used to improve our product offeringEmployeesRegular interactionDevelopment activities, surveys, day-to-day interaction with managerTo ensure employee wellbeing, engagement, and developmentEmployee feedback lead to actions to ensure that DFDS is a great place to workInvestors and ESG analystsRegular interactionInterim reporting and ad hocEnsure transparent market communication and dialogueInvestor feedback is part of the corporate decision making processRegulatorsAdherence to regulatory requirementsDFDS may consult regulators or consultantsEnsure understanding of regulatory mattersChanges in regulation or understanding thereof impacts business decisions, procedures, and reportingNGOsRegular interactionAd hoc meetingsSeeking information or collaboration on common goalsNGO feedback informs projects and business decisionsESG rating agenciesAnnual interactionReporting on ESG frameworksCreate transparency and share DFDS ESG dataDemand for data and information informs our reporting practicesPeers and marketRegular interactionNetwork activities and desk researchKnowledge sharing with peers on ESG matters and finding inspirationPeer feedback informs ESG strategy and reporting and may affect business decisionsDouble materiality assessmentDouble materiality assessment:process and outcomeIn line with ESRS requirements, DFDS conducted its first double materiality assessment (DMA), mark-ing a significant milestone in our journey to align sustainability efforts with both stakeholder expec-tations and organisational priorities. This exercise not only reinforced the foundation of our existing ESG strategy but also expanded our understand-ing of the impacts and risks integral to our business operations, stakeholders, and the environment.This first-of-its-kind assessment is built on our prior ESG risk evaluation methods. It introduced a broader perspective by integrating our impact considerations into a risk matrix. Recognising the pioneering nature of this effort, we adopted a relatively conservative scope and threshold for the DMA process. This approach en-sures an accurate and reliable representation of our impacts, risks, and opportunities (IROs) as a baseline for continuous improvement in future assessments.Key findings and alignment with corporate strategyThe DMA identified the most material topics, encompassing areas of importance to our stakeholders as well as those representing potential risks and opportunities for our op-erations. Notably, the highest-impact topics and risks identified (E1 and S1) are already embedded within our corporate risk manage-ment framework, emphasising their importance as core organisational risks.While certain topics were assessed as having lower materiality in the current assessment, it is important to note that these are not regardedas unimportant. Rather, they are relatively less significant to our business at this stage compared to other IROs. We remain committed to monitoring these areas and reassessing their significance on an annual basis to adapt to evolving circumstances.Materiality matrix and methodologyOur materiality matrix provides a high-level overview of the most critical topics resulting from the DMA. To ensure alignment with organisational objectives and stakeholder priorities, each ESRS topic was evaluated at a sub-topic level. The following sections detail our methodology, providing transparency into our assessment pro-cess, and outline the detailed results for each topic identified through the DMA.Double materiality assessmentIRO-1 Description of the process to identify and assess material impacts, risks, and opportunities Methodology and process Preparation, scoping, and mapping53aOur DMA process methodology is based on the guidance made available in the ESRS disclosure requirements. Our interpretation of the legislation guides the development of the process methodology, from the choices in stakeholder engagement to the threshold decisions. No preconceived assumptions were applied to the methodology or identification of IROs in our process.We seek inputs from a variety of stakehold-ers, encompassing both internal and external perspectives, as we strive to consider as many viewpoints and considerations as possible. Our aspiration is to continue enlisting the collabora-tion and support between external and internal stakeholders simultaneously, to mitigate any potential biases and knowledge gaps in our process and inputs. 53b Our DMA process follows a four-step process, guided by the ESRS disclosure requirements. Where relevant, we ensure compatibility with our organisation's ways of working. The decision was made for impacts to be assessed on a general geographic scope.For the initial step in our DMA process, we map out our business model and value chain. This enabled us to clearly identify our own operations versus those within our value chain. Consequently, each identified IROs can be categorised based on whether it originated from our own operations or the broader value chain.To identify relevant stakeholders for the DMA analysis, we sought the input of external experts, including NGOs, relevant agencies, and unions. These experts represented potential affected stakeholders and provided valuable input to help us map and analyse our impact.Assessing materialityScoring: Impact materiality 53b As by ESRS standards, we utilise the parameters of scale, scope, irremediability, and likelihood to assess the materiality of an impact. For each identified impact, the following assessment scale methodologies are applied: To identify scale, we assess inherent impact on society or the environment. To assess scope, we use parameters based on either a portion of a potentially or existing affected stakeholder group, or a quantified geographical area. Double materiality assessmentWhen identifying irremediability, our assess-ment scale is based on the ability for damage to be mitigated or reversed. Where impacts are potential, the factor of like-lihood is included in the final scoring. For topics with an actual impact, likelihood is not included in the final score. In calculating the final score, an average is calcu-lated of all the above-mentioned parameters. An important exception is in the human rights-related topics, wherein severity (the combination of scale, scope, and irremediability) takes precedence over likelihood in the final score calculation. A predetermined threshold was established, and where impacts identified scored above the thresh-old, they were considered impact material.Connections of impacts and dependencies with risks and opportunities53c DFDS conducted mapping workshops to identify IROs that could be potentially material to the organisation. The purpose of these work-shops was to jointly identify impacts, risks, and opportunities to determine if any topics would simultaneously have both impacts and risks or opportunities. Additionally, the workshops aimed to identify any existing dependencies.Scoring: Financial materialityAs by ESRS standards, the financial materiality of a risk or opportunity is based on size of financial effect and likelihood of the event. The following methodologies were applied:The size of the financial effect is aligned with our Enterprise Risk Management (ERM) system and parameters. The likelihood scoring for risks and opportunities equals that of impact materiality. In calculating the final score, we calculate an average of size and likelihood. A predetermined threshold was established, and where risks and opportunities identified scored above the threshold, they were consid-ered material.Decision making process and internal control procedures 53d A CSRD Steering Committee was estab-lished for the development of the initial DMA for DFDS. It served as the control and decision-mak-ing body for the methods used throughout the process. Key decisions including identifying stakeholder representatives, scoring of IROs, reviewing the material, and so forth, were under the Steering Committee's mandate. Controls included sign-offs from stakeholders and a thor-ough review of methods by the CSRD Reporting Team, which was specifically tasked with owning and managing the process to ensure its integrity and accuracy.53e The ERM and DMA processes are inter-connected, particularly through the financial materiality assessment. The DMA uses ERM thresholds to evaluate financial impacts, ensuring consistency. The ERM team has provided inputs during the DMA process, aiding in the identifica-tion of financial effects. High-priority ESG topics identified through the DMA are incorporated into the overall risk profile, ensuring a comprehensive and up-to-date risk management framework. This integration allows the organisation to effectively manage significant risks and maintain a robust overall risk profile.Integration of DMA process in overall management processes53f The process to identify, assess, and manage risks and opportunities is largely linked to the DMA process as described, in which management is informed, performs a review and signs off before seeking the Board of Directors approval.53g As part of this process, we establish our assessment boundaries and thresholds:The assessment dimensions for identifying impact materiality and financial materiality are based on the ESRS standards.Our core principle is to assess based on inherent risk.All topics and assessment criteria are included in our DMA process.For impact materiality, our thresholds are based on the OECD guidelines for multinational enterprises, and the UN guiding principles. In addition, we have distinguished between miti-gating actions and positive impacts, ensuring that we do not present mitigating actions as positive impacts.For financial materiality, we followed the al-ready established thresholds in the ERM. Double materiality assessmentSBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model Location in VCTime horizonOperation48a-cSub-topicSub-sub topicDisclosure reporting Impact, Risk, or OpportunityOwn operationsValue chainShort-termMedium-termLong-termFerryLogisticsE1Climate changeClimate change adaptationCosts from indirect effects from climate related hazards that could lead to disruption of the supply chain, day-to-day working of employees and users of ports and harbours.RCosts for clean-up and repair after hazards as well as upfront investments to protect the infrastructure.RClimate change mitigationBurning fuels to run trucks or ships as well as energy consumption related to administrative buildings generates GHG emissions.ANICosts related to Emission Trading Systems (ETS) or other climate regulations (existing or future) could significantly impact financial resources.RRisk of stranded assets as uncertainty surrounding the fuel choice of the future still exists. DFDS could risk having vessels in the fleet that do not meet decarbonisation requirements or investing in vessels with new technologies that will not become the future choice.RBranding opportunity from selling green products, especially to clients with sustainability targets and/or limited opportunities to reduce GHG emissions in their own operations.OEnergy useConsumption of fuels in the ferry fleet and across value chain for production of vessels and equipment generates large amounts of GHG emissionsANIConsumption of fuels and energy in other primary activities (mainly DFDS’ logistics activities) and across value chain for production of trucks and equipment generates significant GHG emissions.ANISignificant investments needed to retrofit, redesign, or replace fleet to decarbonise operations.In addition to substantial costs, risk of market adopting different technologies.RLimited or potential limited availability of green fuels risk DFDS not meeting customer require-ments and decarbonisation targets.RDouble materiality assessmentLocation in VCTime horizonOperation48a-cSub-topicSub-sub topicDisclosure reporting Impact, Risk, or OpportunityOwn operationsValue chainShort-termMedium-termLong-termFerryLogisticsE2PollutionPollution of airNon-GHG pollutants are emitted to air through our vessel voyages, contributing to air pollution.ANIE4Biodiversity and ecosystemsDirect impact drivers of biodiversity lossClimate changeThe greenhouse gas emissions associated with our operations lead to effects on biodiversity and ecosystems.ANIOtherOur organisation operates a significant number of vessels, which generate substantial underwater noise during voyagesPNIS1Own workforceWorking conditionWork-life balance Impacts on work-life balance and wellbeing from overtime/working schemes ANIHealth and safetySafety and accident concerns of ship crews, truck drivers, and terminal and warehouse workersPNIEqual treatment and opportunities for allGender equality Both seafarers and logistics faces challenges attracting and retaining womenANIMeasures against violence and harassment in the workplaceBullying and harassment is known to occur in the maritime and logistics sectorPNIDouble materiality assessmentLocation in VCTime horizonOperation48a-cSub-topicSub-sub topicDisclosure reporting Impact, Risk, or OpportunityOwn operationsValue chainShort-termMedium-termLong-termFerryLogisticsS2Workers in the value chainWorking conditionsSecure employmentInsecure employment for certain workers, leaving risks for human rights ANIHealth and safetyNature of work subjecting workers to excessive hours, impacts on work-life balance and wellbeingANIHealth and safetySafety for ship crews, truck drivers, and value chain workers due to nature of industry workRANIEqual treatment and opportunities for allGender equality and equal pay for work of equal valueNegative impacts more likely to disproportionately affect the underrepresented gender in the value chainANIForced labourRisk of fines, repercussions and reputational damage in potential forced labor in the value chainRPNIS4Consumers and end-usersInformation-related impacts for consumers and/or end-usersPrivacyIf exposed to cyber-attacks, DFDS might be involved in a leakage of private customer information and derived financial risk RPNIPersonal safety of consumers and/or end-usersHealth and safetySafety of passengers through ship-related accidents. Accidents related to products and services of DFDS can be financial risk through legal proceedings and fines, reputational risk, and customer loss RPNIDouble materiality assessmentLocation in VCTime horizonOperation48a-cSub-topicSub-sub topicDisclosure reporting Impact, Risk, or OpportunityOwn operationsValue chainShort-termMedium-termLong-termFerryLogisticsG1GovernanceCorporate cultureNot applicableRisk of negativities in corporate culture affecting risk management, productivity, innovation, etc. RProtection of whistleblowers Not applicableLacking awareness of the whistleblower system entails that unlawful behaviour may not reportedRManagement of relationships with suppliers including payment practices Not applicablePoor supplier management can lead to negative impacts, including contract terms, pressure on price and lead time, payment practices, and payment conditionsPNICorruption and bribery Prevention and detectionincluding trainingTransportation sector has an increased risk for corruptionPNI48 f, h Based on residual risk after mitigating actions, the risk severity assessment has returned low to medium scores for the sustainability-relat-ed risk items in the ERM process. We consider low to medium scores to reflect a high resilience of the business overall.For information on our resilience analysis of E1 Climate Change, see page 85.In the 2024 report, all IROs are covered by the ESRS Disclosure Requirements.59 DFDS has built the expertise in the CSRD Reporting Team to translate the IROs into relevant disclosure requirements. The CSRD Reporting Team has involved relevant stakeholders across DFDS to inform these judgements and have sought external assistance as relevant. Non-material ESRS topics ESRS E3 Water and marine resources DFDS' core operations focus on transportation and do not involve significant water-intensive activities or marine resource use.ESRS E5 Resource use and circular economy Waste management and the circular economy are not within the scope of material impact for our operations. We recognise that new building of vessels and the subsequent scrapping/recycling have significant impact on resource use and cir-cular economy. In our assessment, we found the topic non-material due to the infrequency of new builds and scrapping.A inherent part of our business model is to ensure that our vessels are properly maintained and re-newed in due time before they become inefficient and worn out. Consequently, we aim to resell for longer time use, and hardly ever recycle ships. In the rare case that a ship must be recycled in the future, we will use an approved yard and carry out the work in line with EU ship recycling regulations and the principles of the IMO Hong Kong Interna-tional Convention.ESRS S3 Affected communitiesDFDS' transport operations is found to have limited impact on local communities.ESRSEnvironment82 E1 Climate change96 E2 Pollution99 E4 Biodiversity and ecosystems102 EU TaxonomyE1 Climate change The ferry and logistics industries are significant contributors to the causes of climate change and must play a key role in addressing its impacts. At DFDS, we recognise the urgent need to transition to sustainable practices and technologies to minimise our environmental impact. Through strategic investments and collaborations, we are working toward decarbonising our operations and supporting the broader industry shift toward a net zero future. Our approach to decarbonisation focuses on four main techniques: efficiency, electrification, alternative fuels, and circularity.SBM-3Material IROs table for E1 Climate change ImpactsDescriptionImpact, Risk, or OpportunityClimate change adaptationCosts from indirect effects from climate related hazards that could lead to disruption of the supply chain, day-to-day working of employees and users of ports and harbours. RCosts for clean-up and repair after hazards as well as upfront investments to protect the infrastructure. RClimate change mitigation Burning fuels to run trucks or ships as well as energy consumption related to administrative buildings generates GHG emissions. ANICosts related to Emission Trading Systems (ETS) or other climate regulations (existing or future) could significantly impact financial resources. RRisk of stranded assets as uncertainty surrounding the fuel choice of the future still exists. DFDS could risk having vessels in the fleet that do not meet decarbonisation requirements or investing in vessels with new technologies that will not become the future choice. RCommercial opportunity from selling green products, especially to clients with sustainability targets and/or limited opportunities to reduce GHG emissions in their own operations.OEnergyConsumption of fuels in the ferry fleet and across value chain for production of vessels and equipment generates large amounts of GHG emissionsANIConsumption of fuels and energy in other primary activities (mainly DFDS’ logistics activities) and across value chain for production of trucks and equipment generates significant GHG emissions.ANISignificant investments needed to retrofit, redesign, or replace fleet to decarbonise operations. In addition to substantial costs, risk of market adopting different technologies. RLimited or potential limited availability of green fuels risk DFDS not meeting customer requirements and decarbonisation targets. RESRS E1 Climate changeE1-1 Transition plan for climate change mitigation14 DFDS' transition plan for climate change miti-gation is defined in our decarbonisation strategy, "Moving to Green". Our transition plan is split into three pillars; decarbonisation at sea, decarboni-sation on land, and "getting our house in order". All three pillars of the transition plan support the goal to be net zero by 2050. By 2030, our goals on land rely on a combination of efficiency measures and aggressive electrification. At sea, we plan to introduce alternatively-fuelled vessels by the end of 2030, along with a significant emphasis on both technical and operational efficiency improvements. This is necessary because zero emission fuels and technologies for shipping are less mature than the technologies already avail-able on land."Getting our house in order" relates to our small-est emission footprint, our everyday activities. 16b DFDS' commitment to achieving net zero emissions is structured into two distinct phases: core decarbonisation techniques and secondary techniques for long-term impact. This approach is underpinned by the adoption and implemen-tation of key principles to drive sustainable transformation across our operations.Core decabonisation techniquesOur core strategies focus on enhancing efficien-cy and transitioning to cleaner energy sources, which we execute through the following initiatives:Efficiency: Transitioning to do more with fewer resources. Through smart design, innovative technology, and mindful consumption practic-es, we aim to optimise energy use across our operations.Electrification: Reducing reliance on fossil fu-els is critical to our decarbonisation strategy. We are committed to harnessing renewable and clean energy sources to power our opera-tions while minimising environmental impact.Alternative fuels: Biofuels and e-fuels represent the future of sustainable logistics. Our decar-bonisation strategy requires the use of innova-tive fuel solutions that offer viable alternatives to fossil fuels, helping to significantly reduce our emissions.Circularity: Adopting a circular mindset is essential for rethinking resource use. By mini-mising waste and focusing on resource reuse, we aim to embed circularity into our opera-tions. However, achieving this requires deep collaboration across the value chain, making it a long-term focus area.We have made substantial progress in electrifica-tion, efficiency improvements, and the adoption of alternative fuels. These are our primary decar-bonisation levers, where we possess significant expertise and can operate independently. While cir-cularity remains a critical component of our vision, it necessitates extensive collaboration and is an area where we are building capacity for future impact.Secondary techniques for long-term impactTo complement our core strategies, we recog-nise the need for secondary measures, including carbon capture and offsetting. These tech-niques will play a role in addressing residual emissions that cannot be eliminated through our initiatives alone, ensuring we achieve net zero in the long-term.ESRS E1 Climate change16a, g Our pathway to 2050 includes 1.5°C and well below 2°C strategies. However, we do not have targets or a transition plan which is explicitly aligned with limiting to 1.5°C in line with the Paris agreement, and we are currently not excluded from the EU Paris-aligned benchmarks. We strive to adopt the most ambitious plan possible, how-ever, the main obstacle to making a firm commit-ment is the uncertainty that exists regarding the maturity and availability of renewable fuels and associated shipping technologies - engines and propulsion systems. Added to this, is the lack of knowledge and procedure for the safe handling, storage, and distribution of high-potential ship-ping fuels such as green ammonia.16d We acknowledge the potential locked-in greenhouse gas emissions associated with our key assets. The majority of our assets are designed to operate on fossil fuels until the end of this decade, contributing to greenhouse gas emissions over their lifecycle. Our legacy assets (vessels) are a critical focus area for our locked-in emissions, and for those, we consider sustainable, certified biofuel as a viable transi-tional solution.16c The climate mitigation action plan (as referenced in E1-3.28), requires capital expendi-tures (CapEx) for its implementation. The most significant CapEx include vessel newbuilds and vessel conversion to facilitate the switch to alter-native fuels or batteries. Additionally, continuing to invest in e-trucks to our fleet and the electri-fication of our terminals will incur CapEx on an ongoing basis. The CapEx required to the action plan related to the vessels is seven billion DKK in the years 2026-2030. The amount and timing of investments are subject to change, based on the availability of alternative fuels, funding opportu-nities, and regulatory developments.16e, h "Moving to Green" is a key strategic focus in DFDS and one of our five strategic pillars. As we deliver on these ambitions, the alignment of our economic activities to the EU taxonomy is likely to increase. However, our CapEx plan is not specifically aimed at expanding taxonomy align-ment or upgrading taxonomy-eligible activities to taxonomy-aligned within any specified period. We consider the transition to green as essential to continue our operations and serve our customers, and therefore, large investments associated with new, alternatively powered vessels, are included in our long-term CapEx planning. 16i, j The decarbonisation of our business is a shared responsibility for everyone at DFDS, and there are several teams involved in guiding and driving our climate plans. In 2023, we launched a new organisational unit, Decarbonisation, to accelerate progress in reducing emissions across all of our commercial activities.Any strategic decision-making related to decar-bonisation is brought before the Decarbonisation Board, bringing together key stakeholders and the CEO. It monitors and ensures the progress of decarbonisation targets, and works to prioritise resources across key departments at DFDS to achieve our ambitions. The Decarbonisation Board prioritises investment into new projects based on a standardised KPI framework that takes into account aspects such as financial returns, scalability, technical risk, and, relative abatement cost, to ensure that we get the most value from our investments.E1-2 Policies related to climate change mitigation and adaptation21 DFDS' Climate Policy outlines our commitment to reaching net zero by 2050. The policy includes general objectives such as improving energy efficiency, transitioning into sustainable fuels, and reducing emissions from sea- and land-based activities. The policy is used as a general frame-work for DFDS, to ensure that environmental and climate-related concerns are being prioritised throughout the business. The policy's scope ap-plies globally to all DFDS employees and covers all assets owned and controlled by DFDS. It also extends to third-party service providers and other supply chain activities. Accountability for implementing the Climate Policy lies with all leadership levels to carry out the objectives of the policy. In addition, the policy outlines the role of the Decarbonisation team as the primary responsible for target and pathway setting, as well as communication. The policy also reflects DFDS' alignment with the UN Global Compact's environmental principles.The Climate Policy is available for all internal and external stakeholders, on our intranet and our website, respectively. In addition, considerations on climate change are included in our corporate Code of Conduct.The policy addresses climate change mitigation through its clear commitment to reducing emissions through efficiency and the transition to sustainable fuels. Climate change adaptation is also addressed by techniques to enhance resilience, such as improving infrastructure and transitioning to renewable energy. Energy efficiency targets are set across both maritime- and land-based operations. Renewable energy deployment is part of DFDS actively working towards the transition of the fleets and operations to renewable sources.ESRS E1 Climate changeSBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model19a-b, AR7b At DFDS, climate-related risks are assessed within the broader enterprise risk management (ERM) framework. The scope of resilience analysis is embedded within the overall risk management process, focusing primarily on short-term climate risks and their financial implications. Identified risks are addressed with mitigation actions, which are continuously moni-tored to ensure the organisation remains resilient to climate challenges. This approach ensures a continuous assessment of resilience through the evaluation of climate-related risks as part of the company’s standard risk assessment. In 2024, our climate risk analysis has primarily concentrat-ed on our own operations. AR8a The areas of uncertainty in our resilience analysis primarily stem from the evolving nature of climate-related risks and their potential financial impact on business operations.The setting and evaluation of our strategies are considered in the results of the ERM process, as a general practice that ensures our strategies are aligned with identi-fied risks and opportunities.Our vessels represents the largest area of uncer-tainty, particularly regarding the technological developments and investments needed for the green transition. This includes uncertainties relat-ed to alternative fuel availability, technological advancements, and pricing. A major part of our strategy is focused on transitioning to the vessels of tomorrow, ensuring we remain resilient and adaptable to future challenges.19c Our resilience analysis in 2024 demon-strated progress towards our targets. However, higher costs led to the closure or postponement of several alternative fuel projects. The lack of sustainable fuels remains a significant risk for our organisation and impacts our planned infrastruc-ture for future ferry projects. Read more on page 51AR8b Our strategy and business model are de-signed to adapt to climate change over the short-, medium-, and long-term, due to our inherent oper-ational flexibility and ongoing risk management. We integrate short-term climate risks into our broader risk management framework, ensuring constant awareness of significant near-future climate impacts. Our network's flexibility, through adjustable shipping routes, modal shifts, and operational optimisation based on evolving condi-tions, enables us to effectively address anticipat-ed challenges while maintaining resilience and continuity for our customers.Physical risksFerryLogisticsShort-term(12-36 months)Medium-term(3-5 years)Long-term(5+ years)ChronicChanging temperature (air, freshwater, marine water)Sea level riseHeat stressAcuteStormsTransition risksFerryLogisticsShort-term(12-36 months)Medium-term(3-5 years)Long-term(5+ years)TechnologyThe costs associated with building, acquiring, and adapting to low-carbon technology for both our assets and broader infrastructure investments, pose a significant risk to our financial resources.Policy + Legal Costs stemming from Emission Trading Systems (ETS) or other current and future climate regulations could have a substantial impact on our financial resources.Market + Reputation There is a risk of not meeting customer demand fast enough due to limited availability of green fuels, as well as the costs and challenges of transitioning to low-carbon technologies in a timely manner.ESRS E1 Climate changeIRO-1 Description of the processes to identify and assess material climate-related impacts, risks and opportunitiesProcess to assess climate-related impacts20a The process to identify impacts on climate change in our organisation is based on our double materiality assessment (DMA). In addition to the workshops and interviews, research supporting our understanding of how the transportation sec-tor impacts climate change, was a fundamental part of understanding the impact we have as an industry player.Process to assess climate-related risks and opportunitiesAR 13a In 2024, we conducted our first climate-scenario based risk assessment. While previously, climate change risk was looked at on a short-term view, this was the first year in which we used sce-narios and as such expanded our corporate view of climate change risks facing us in the future.This inaugural analysis provided us with a baseline understanding of how to effectively use climate scenarios. This initial assessment using a scenario analysis concentrated on our own operations and our customers from a value chain perspective.As a result, we now have foundational knowledge that will guide our future efforts. Moving forward, we plan to deepen our assessments by examin-ing individual business areas and assets more thoroughly. This will enable us to identify specific vulnerabilities and opportunities, ensuring that we are better prepared to mitigate risks and capitalise on potential benefits associated with climate change.Our commitment to expanding our climate risk assessment capabilities reflects our dedication to sustainability and resilience. By continuously improving our understanding and management of climate-related risks, we aim to safeguard our op-erations and support our customers in navigating the evolving landscape of climate change.AR 13b-d The RCP 8.5 scenario, developed by the IPCC, represents a high-emission future where greenhouse gas emissions continue to rise significantly throughout the 21st century. It is primarily driven by rapid population growth, high energy demand, and a reliance on fossil fuels. The key inputs include assumptions on low climate policy interventions, low technological advancements, no policy interventions, and minor mitigation efforts. This scenario can be categorised as a "worst case" for future climate impacts, with projections for major changes and situations in temperatures, sea-levels, weather, and ecosystems. The International Energy Agency's (IEA) Net Zero Emissions by 2050 scenario, outlines a road map for achieving global carbon neutrality. It is a scenario in which rapid decarbonisation across energy systems, the scaling of renewable energy, electrification, and technological advancements are made. Key assumptions include significant policy actions, investments into clean energy, and rapid technological advancements. The scenario can be categorised as a "best-case" for future climate impacts, with the rapid decarbonisa-tion efforts slowing down the effects of climate change on matters such as temperature and weather conditions. 20bi-bii We utilised climate scenarios such as the Representative Concentration Pathway (RCP) 8.5 to identify potential high-emission climate-related hazards. This involved examining how extreme weather events may increase in frequency and severity. We focused on assess-ing how these hazards could disrupt logistics, infrastructure, and the supply chain, placing emphasis on regions where our operations are most exposed to such risks. Our use of a high emission climate scenario analysis informed our understanding of physical risks under varying timelines. In a high-emission scenario like RCP 8.5, we anticipate increased exposure to severe weather patterns, including intense storms and prolonged heatwaves, which could impact business functions. This mode of analysis allows us to prioritise adaptive strategies, focusing on critical assets and operations that are most vulnerable to climate-related disruptions.20ci-cii We used the International Energy Agency (IEA) Net Zero Emissions by 2050 scenario to guide our process for identifying climate-related transition events. This included evaluating the im-pact of decarbonisation policies, shifts in energy sources, and advancements in renewable energy and electrification. By aligning our assessments with a pathway that limits global warming to 1.5°C, we were able to identify key regulatory, technological, and market shifts that could affect our operations, such as stricter emission regu-lations and the phasing out of fossil fuels. Under the Net Zero by 2050 scenario, we analysed the timeline of decarbonisation initiatives, technolog-ical developments, and energy transition policies. In the short-term, we foresee focus on rising compliance costs and initial capital expenditures for low-carbon solutions. In the medium- and long-term, we consider the broader impacts of electrification, renewable energy integration, and potential disruptions in supply chains as industries transition to cleaner technologies.AR 11c The acute and chronic climate-related hazards indicate the physical risks which DFDS faces due to climate change. As a result of these climate-related hazards, DFDS faces the risks of:Increased operational costs: Both direct and in-direct costs are expected to rise due to frequent climate-related hazards. This includes higher costs for repairs and maintenance of infrastruc-ture damaged by extreme weather events.Flexibility and adaptation needs: The need for flexibility in operations will increase, requiring additional spending to adapt to frequent and unpredictable climate-related disruptions. This includes investments in technology and processes that enhance operational resilience.21 In our assessment of transition risks, we found that both our ferry and logistics operations are affected by each identified risk. ESRS E1 Climate changeE1-3 Actions and resources in relation to climate change28, 29a Vision and targets – net zero by 2050:We have the ambition to decarbonise our oper-ations as soon as it is technically and financially feasible to do so. To ensure we reach this goal, we have set minimum targets for decarbonisation of our vessel, road, and terminal operations. Read more on our decarbonisation targets on page 89Our actions in 2024:In 2024, we continued advancing our efforts to re-duce GHG emissions across our fleet, achieving key investment decisions and initiating pilot projects that will drive further progress in coming years. On the technical front, we made strides in vessel upgrades, including securing investment decisions for dynamic propeller curve optimisation projects. In our shore power initiatives, we expanded our pipeline for shore power projects with one land-side and five vessel-side investments, to be executed in 2025. To enhance data-driven decision-making, we have onboarded 11 vessels onto a data logging platform, improving our ability to monitor and optimise vessel performance. These initiatives, alongside ongoing efforts such as continuous hull coating improvements, reflect our commitment to reducing the overall environmental footprint of our operations. Further implementation, approvals, and pilot projects of all initiatives are set to con-tinue in 2025.Logistics decarbonisation initiatives in 2024, were focused on further deployment of e-trucks, installa-tion of charging stations, and continued develop-ment of a more robust data foundation for the green transition. During Q2, another 10 e-trucks were deployed in Germany and planning is ongoing for the deployment of an additional 100 e-trucks during Q3 2024– Q2 2025. In 2024, another charging facility in Vlaardingen with a capacity of 300kW was added. In addition, DFDS invested in a mobile EV charging station, which allows for both a more efficient operation of the e-trucks on the one hand, and on the other hand provides more flexibility to implement e-trucks in locations without existing charging stations. The solution will be located in Cuxhaven, Germany, to bridge the waiting time until a permanent charging station is installed and ready to use.Future actions:We are committed to decarbonise as fast as we can, given financial and technical constraints. We have set detailed, year-on-year targets from now until 2030, for our vessel, road, and terminal operations. Due to the disparate techniques required to decarbonise different parts of our operation, and their relative maturity, these three areas have individual pathways to 2030 - all in support of our ultimate goal to reach net zero by 2050. Read more on decarbonisation pathways and targets on page 89Pathway for vessels To achieve a targeted 45% reduction in well-to-wake (WtW) CO2e emission intensity of vessel operations by 2030, we are focusing on key levers: Tonnage plan:We are committed to launching six alternatively fueled vessels by end 2030. These vessels of tomor-row will be powered by low- and zero-emission fuels, supported by extensive collaborations such as: Partnering with authorities to establish risk-based approval processes.Coordinating with ports to develop bunker standards, safety protocols, and fueling procedures.Collaborating with equipment suppliers to monitor and source innovative fuels and technologies.For shorter routes, such as the Channel, battery-electric vessels will be deployed, while longer routes will prioritise alternative fuels. Operational efficiencyThe Every Minute Counts programme is a combi-nation of schedule optimisation and slow steaming on all our network routes. The programme aims to reduce emissions from our existing vessels while maintaining high service standards. Improvements in efficiency are varied, from reducing turnaround time in port terminals, improving schedules, to enabling lower speed on voyages. These measures lead to a decrease in fuel consumption, saving energy usage, and will remain integral during and beyond the transition to non-fossil fuels. Technological upgrades: In order to enhance the operational efficiency and long-term sustainability of our fleet, we continually invest in technology that improves the operational efficiency of our existing fleet. Key initiatives include hull modifications such as improved hull coatings, upgrading propellers, and implementing advanced weather reporting systems for optimised route planning. While we prioritise upgrades for older vessels, we aim to improve the general efficiency of our fleet, and where technology has been tested, we plan to expand their implementation. By continuously assessing market development, we aim to ensure our investments simultaneously decrease fuel consumption and deliver improved performance. Shore power: We aim to transition our vessels to shore power by 2030, which would enable vessels to connect to electricity while in port, instead of running on fuel. This transition will both positively mitigate our docking energy efficiency and fuel usage, and benefit the environment surrounding our terminals. Pathway for road transport We have set an ambitious goal to achieve a 75% reduction in well-to wheel (WtW) CO2e emission intensity by 2030. To achieve the target, we use the following techniques: Efficiency: Optimising our operations is based on limiting empty runs while simultaneously improving the efficiency of our services across our network. Techniques to improve our road transport efficiency include: Streamlining route planning to reduce the number of vehicles required. Developing driver behaviour programmes to improve driving efficiency. Modal shifts, such as moving volumes from road to rail or sea.Consolidating truck loads. Electrification: We are continuing to increase the size of our e-truck fleet across multiple markets in Eu-rope, and play an active role in supporting the development of suitable charging infrastructure for long-distance trucking. Available charging infrastructure is the main barrier to e-truck ESRS E1 Climate changedeployment and adoption. As the charging network grows, the proportion of our fleet that is electric will increase.Hydrogen:Hydrogen fuel cell electric vehicles (HCEVs) are being developed by a number of manufacturers as a solution for longer distance haulage and special applications that are currently not achievable with battery electric vehicles (BEVs). We see a potential role for both HCEVs and/ or hydrogen combustion engines in our pathway to 2030.Hydrotreated vegetable oil (HVO): HVO offers an immediate opportunity to reduce our greenhouse gas emissions from road trans-port. Whilst we do not see HVO as a sustainable fuel in the long-term, it has the advantage of quickly and relatively cheaply lowering our carbon footprint, and can be used in existing trucks. We are committed to source fuel that meets stringent sustainability criteria.Pathway for terminal operations In 2024 we achieved a milestone and established targets for our terminal operations, which is a 75% reduction in well-to-wheel (WtW) CO2e emission intensity by 2030. With a similar framework as our road transport decarbonisation techniques, the following techniques will be deployed: Efficiency: Efficiency is at the core of our approach to ter-minal decarbonisation, as it is in other areas of our operation. Initiatives in support of terminals efficiency include:Dual cycling: a technique where loading and unloading is performed simultaneously, reducing empty trips and improving turnaround time of vessels, so that they can sail slower and still be on schedule.Optimised trailer planning: using space on the terminal in such a way as to reduce unnecessary moves.Electrification: The key transition technique for terminals is a shift from fossil fuels to electric terminal vehicles. Compared to other parts of our operation, terminals emit relatively little, but they are the place where road and sea converge, and where we foresee the greatest need for a well-managed electrification programme. With this in mind, we plan for producing, consuming and providing renewable energy at ter-minals. In 2024, we began a large project to design and pilot micro grids at some of our key terminals.Hydrogen:We aim to continue investigating hydrogen appli-cations for our terminal operations, similarly to our road transportation, as part of a broader shift to sustainable energy sources.Gap: The current 2030 pathway for terminals shows a gap between the top-down targets and the bottom-up initiatives that we have currently iden-tified. We are committed to identifying concrete initiatives to close this gap.FundingWe are actively seeking diverse funding opportuni-ties, including EU and national sources, to support the ambitions of our "Moving to Green" strategy.AR21 The pathways set for both vessel and land are largely dependent on the available funding we can receive, as well as the maturity and availabili-ty of technologies and fuels.29ci-iii, 16c The significant CapEx and OpEx required to implement the action plan for climate mitigation are related to future investments in new vessels and the ongoing investment in e-trucks and electric equipment for terminals. See note 3.1.2 "non-current tangible assets" in the financial state-ments. In the EU taxonomy reporting, the signifi-cant CapEx required to implement the action plan for climate mitigation relate to economic activities 6.6 freight transport services by road, 6.10 sea and coastal freight water transport, and 6.16 infrastruc-ture enabling low-carbon water transport.GOV-3 Integration of sustain-ability-related performance in incentive schemes 13 DFDS' remuneration policy integrates climate considerations into the CEO's bonus scheme. Additionally, ESG factors are generally included in the CFO's remuneration scheme. The CEO has a direct climate-related decarbonisation bonus incentive of 10%, while the CFO has a general ESG incentive of 10%, with one-third attributed to decarbonisation.The decarbonisation incentive focuses on the continuous pursuit of CO2e reduction targets and the ongoing development of various initiatives. Currently, no specific targets can be disclosed.ESRS E1 Climate changeE1-4 Targets related to climate change mitigation and adaptationDFDS has set a target for net zero emissions by 2050 across all our operations. Our 2030 targets focus on two main operational areas: vessels and land. This targeted approach allows us to plan effectively, tailor solutions to operational realities, and measure progress in detail. The operational differences between our land-based and sea-based activities necessitate this approach, as each area requires different decarbonisation strategies. We further split land by type of operation in order to set decarbonisation pathways in pursuit of our targets. Prioritising distinct targets over a unified organisational target ensures we can implement actionable and relevant plans to achieve our goals. General disclosures covering all targets in E1-432, AR30c All of our current GHG emission targets are based on a range between the 1.5°C pathway and the well below 2°C. While we strive to meet the 1.5°C target, we acknowledge that not all our operations can currently align with this ambition. However, we remain committed to reg-ulatory target compliance. We use the methodol-ogies and assumptions of the Paris Agreement as frameworks to inform our target setting process. We also incorporated scientific evidence, such as the IPCC Sixth Assessment Report, to ensure our targets are grounded in the latest research. We collect and analyse existing internal data to make robust methodological assumptions. Ac-knowledging the impacts, risks, and opportunities (IROs) posed by climate change, we deliberately establish our targets using data from our oper-ations. We review our approach regularly and ensure its alignment with our business operations and regulatory requirements. The responsibility for setting targets lies within the Decarbonisation Team, who lead the definition process. The Decarbonisation Board, Executive Management Team (EMT), and the Board of Directors hold responsibility for reviewing and approving targets. 34b All our targets, including achieving net zero by 2050 and specific 2030 targets for vessels, road, and terminals, include carbon dioxide, methane, and nitrous oxide. These targets are aligned with our GHG inventory boundaries.Our 2030 targets do not account for, or rely on GHG removals, carbon credits, or avoided emissions. The pathways illustrate how we can achieve our 2030 CO₂e emission intensity targets. Each diagram presents a scenario estimating fuel and energy consumption across DFDS' opera-tions. The composition of fuel and energy then determines how emissions are distributed across different Scopes.Scope 1 emissions pertain to DFDS’ direct fuel consumption within our operation, also described as combustion emissions or Tank-to-Well/Wheel emissions. Scope 2 emissions cover the upstream emissions from electricity, consisting of the emissions up until delivery to DFDS. In the pathways shown, the electricity is covered by Renewable Energy Certificates/ Guarantees of Origin, therefore the electricity is accounted as zero emission as per the EU Renewable Energy Directive. Scope 3 emissions cover the upstream emis-sions from fuels, consisting of the CO2e emis-sions from extraction, cultivation, processing, transport, and distribution of the fuel. A transition from liquid fuel to electricity will cause some shift in emissions between Scopes (from Scope 1 to Scope 2), but the Well-to-Wake/Wheel approach we apply ensures that DFDS’ 2030 targets results in CO2e emission savings across all Scopes.For a detailed breakdown of the Scope shares associated with each GHG emission target, refer to the individual pathway details on the following pages.ESRS E1 Climate changeVessel targets: 34f, AR30a-b The following pathway depicts the core decarbonisation levers and their overall quantitative contributions to reach our 2030 target. Read more on the specifics of vessel decarbonisation techniques on page 8734e The baseline year is 2008, chosen in line with the IMO baseline year, which was used for the 2030 intensity target introduced in the 2023 IMO GHG Strategy. We do not currently adjust or correct our baseline for weather abnormalities, instead we account for weather abnormalities in explaining our progress to our targets. The baseline was normalised to accurately represent activities and external factors influencing emis-sions. Due to high variation from M&amp;As in previous years, we did not use 3-year averages. We aim to identify the most accurate baseline values to plan our operations and decarbonisation initiatives effectively.34b In the baseline year for vessels the consump-tion consists only of conventional fossil fuels. Most of the emissions come from fuel combustion, and are therefore in Scope 1, at around 85%, and the last 15% is related to upstream emissions, in Scope 3. By 2030, the uptake of alternative fuels reduces CO2e emissions from fuel combustion, while they are expected to have similar or higher upstream emissions than fossil fuels. The implementation of shorepower removes emissions from both Scopes 1 and 3, and since it is our intention to procure re-newable electricity or cover electricity purchases with Renewable Energy Certificates/ Guarantees of Origin, zero emissions are calculated in Scope 2. This results in approximately 80% of emissions in Scope 1 and 20% in Scope 3.1From 2023, we have de-veloped our pathway from a unit of TtW (Tank-to-Wake) CO2e to WtW (Well-to-Wake) CO2e. In addition, the baseline was updated, and shore-power was added as a decarbonisation lever.2Absolute emissions forecasts may change due to fluctuations in business operations and market conditions.3The increase in absolute emissions from 2008 to 2024 is due to an increase in transport work - in 2008 we did less than half the transport work we do today. We anticipate a lower growth rate between 2024 and 2030, and will still achieve a greater reduction in emissions intensity compared to absolute emissions. ESRS E1 Climate changeLand targets (road): 30f, AR30a-b The following pathway depicts the core decarbonisation levers and their overall quantitative contributions to reach our 2030 target. Read more on the specifics of road decarbonisation techniques on page 8734e The baseline year is 2022, chosen for its reliable and sufficient data. It was normalised to accurately represent activities and exter-nal factors influencing emissions. Due to high variation from M&amp;As in previous years, we did not use 3-year averages. We aim to identify the most accurate baseline values to plan our operations and decarbonisation initiatives effectively.34b In the baseline year for road, the consumption consists only of conventional fossil fuels. Most of the emissions come from fuel combustion, and are therefore in Scope 1, at around 74%, and the last 26% Is related to upstream emissions, in Scope 3. In 2030, the significant uptake of alternative fuels, in particular HVO, reduces CO2e emissions from combustion, while they are expected to have simi-lar or higher upstream emissions than fossil fuels. The implementation of e-trucks reduces emissions in both Scopes 1 and 3, and since it is our intention to procure renewable electricity or cover electricity purchases with Renewable Energy Certificates/ Guarantees of Origin, zero emissions are calculat-ed in Scope 2. This results in approximately 31% of emissions in Scope 1 and 69% in Scope 3. 134a Given our anticipated growth throughout the decade, we expect a greater reduction in emissions intensity rather than absolute emissions. Additionally, we foresee changes in the absolute values of our targets due to constant fluctuations in business operations and market conditions.ESRS E1 Climate changeLand targets (terminals): 30f, AR30a-b In 2024, we achieved a significant milestone in setting targets for our terminal ope-rations. The following pathway depicts the core decarbonisation levers and their overall quantitative contributions to reach our 2030 target.Read more on the specifics of terminal decarbonisation techniques on page 8834b Due to our terminal pathway being set in Q4, 2024, we are unable to disclose the Scope split of the combined target this year. 34e The baseline year is 2022, chosen for its reliable and sufficient data. It was normalised to accurately represent activities and external fac-tors influencing emissions. Due to high variation from M&amp;As in previous years, we did not use 3-year averages. We aim to identify the most accurate baseline values to plan our operations and decar-bonisation initiatives effectively.134a Given our anticipated growth throughout the decade, we expect a greater reduction in emissions intensity rather than absolute emissions. Additionally, we foresee changes in the absolute values of our targets due to constant fluctuations in business operations and market conditions.ESRS E1 Climate changeE1-5 Energy consumption and mix37-39Energy consumption and mixUnit2024Total fossil energy consumption MWh9,713,392Share of fossil sources in total energy consumption%98.6%Fuel consumption from crude oil and petroleum productsMWh9,665,424Fuel consumption from natural gasMWh12,430Consumption of purchased or acquired electricity, heat, steam, and cooling from fossil sourcesMWh35,536Total renewable energy consumptionMWh141,734Share of renewable sources in total energy consumption%1.4%Fuel consumption for renewable sources, including biomass (also comprising industrial and municipal waste of biologic origin, biogas, renewable hydrogen, etc.)MWh95,853Consumption of purchased or acquired electricity, heat, steam, and cooling from renewable sourcesMWh43,427Consumption of self-generated non-fuel energy MWh24,57Total energy consumption MWh9,855,130§ Accounting policiesEnergy consumption and mixWe monitor and report energy data in two streams: land-based operations and sea-based operations. Land-Based Operations: Energy for land-based operations is reported for each location. The data is derived from various sources: invoices, fuel or electricity consumption records, and/or meter readings. Both electricity consumption and any electricity generated through the use of on-site solar panels are accounted for through this process. Sea-Based Operations: Energy data for sea-based activities is collected for each voyage, using recorded fuel consumption, on-board meter readings, and/or documented fuel usage.Non-renewable energy shareThe non-renewable energy share is calculated as the proportion of total energy consumption derived from non-renewable sources. Energy from non-renewable sources can include fuel consumption from crude oil and petroleum products, natural gas, coal or coal products, and other fossil sources. Renewable energy shareThe renewable energy share is calculated as the proportion of total energy consumption derived from renewable sources. Energy from renewable sources can include fuel consumption from renewable sources including biomass, purchased or acquired electricity, heat, steam, and cooling from renewable sources as well as the consumption of self-generated non-fuel energy. The consumption of purchased or acquired electricity, heat, steam, and cooling is calculated as the proportion of total energy consumption derived from renewable sources where Renewable Energy Certificates (RECs) are present. DFDS adopts a market-based accounting approach for renewable energy, recognising purchased green electricity as renewable energy consumption. Renewable Energy Certificates (RECs) are utilised to identify the locations operating with renewable energy sources. This information forms the basis for determining the proportion of electricity sourced from non-renewable energy across our operations.Renewable energy shareTotal energy consumption is calculated as the sum of total fossil energy consumption and total renewable energy consumption. 40Energy intensity per net revenue Unit2024Total energy consumption from activities in high climate impact sectors per net revenue from activities in high climate impact sectorsMWh/MDkk33141Energy in high climate impact sectorsUnit2024Total energy consumption from activities in high climate impact sectorsMWh9,855,130§ Accounting policiesHigh climate impact sector42DFDS operations are all considered high climate impact sectors according to those listed in NACE Sections A to H. Specifically, DFDS’ activities are in Section H, which includes:Freight rail transportFreight transport by roadSea and coastal passenger water transportSea and coastal freight water transportWarehousing and storageWarehousing and support activities for transportation and cargo handlingEnergy Consumption per Net Revenue43 Energy consumption per net revenue ratio is calculated with the following formula: Energy intensity ratio =Total energy consumption from activities in high climate impact sectors (MWh)Net revenue from activities in high climate impact sectors (MDkk)ESRS E1 Climate changeE1-6 Gross Scope 1, 2, 3, and Total greenhouse gas emissionsAR 41 We are unable to disclose the breakdown of total GHG emissions by operating segments in this year’s annual report due to lack of data split availability for our Scope 3 emissions. We have plans to improve this going forward. GHG emission targets DFDS is dedicated to achieving net zero emis-sions across all operations by 2050. While we have not set company-wide targets for 2030, we have chosen to establish targets based on specific operational areas: vessels and land. We have not yet set specific targets for our non-commercial activities, including buildings and company cars.We are committed to enhancing data transparency and developing comprehensive organisational targets in the future. For detailed 2030 targets, please refer to section E1-4.GHG emission intensity 54GHG emission intensity based on net revenue GHG emission intensity per net revenue (tCO2e/MDkk) 2024 GHG emission intensity, location-based 134GHG emission intensity, market-based 134GHG emission intensity of our fleet route networkGHG emission intensity per GT-Mile (g CO2e/ GT mile)2024 GHG emission intensity - Own fleet112GHG emission intensity - Route network21248-49, 51-52 Breakdown of GHG emissions UnitComparative(2023)12024%N/N-1Scope 1 GHG emissions Gross Scope 1 GHG emissions '000 tCO2e2,5662,6182%Percentage of Scope 1 GHG emissions from regulated emission trading schemes%0%40%N/ABiogenic emissions of CO2e carbon (in Scope 1) '000 tCO2eN/A24N/A2Scope 2 GHG emissionsGross location-based Scope 2 GHG emissions '000 tCO2e121628%Gross market-based Scope 2 GHG emissions'000 tCO2e121528%Scope 3 GHG emissions by category **Total Gross (indirect) Scope 3 GHG emissions '000 tCO2e1,0551,34527%1 Purchased goods and services '000 tCO2e140314125%32 Capital goods'000 tCO2e156-57%3 Fuel and energy-related activities '000 tCO2e5946072%4 Upstream transportation and distribution '000 tCO2e30040635%6 Business traveling '000 tCO2e61169%Total GHG emissions ***Total GHG emissions derived from location-based method '000 tCO2e3,6333,97810%Total GHG emissions derived from market-based method'000 tCO2e3,6333,97710%1The comparative figures for 2023 presented in this table have not been subject to assurance. 2Biogenic emissions for 2023 cannot be disclosed, so no comparative change can be noted.3Fluctuations in scope 3 categories stem from a change in categorisation, the addition of entities, and a general increase in spend from 2023 to 2024. 1Emissions measured as gCO2per gross tonnage nautical mile for owned ferries in operation. 2Emissions measured as gCO2per gross tonnage nautical mile for ferries operating the route network.§ Accounting policies E1-6AR 39bAccounting policies – GHG emissions GHG emissions are calculated in accordance with the methodology set out in the GHG Protocol. To calculate our total GHG emissions, our consumption values are converted into carbon dioxide equivalents (CO2e) for both land and sea operations. This is done through the use of an online tool which is modelled based on the GHG Protocol. It incorporates a comprehensive and fact-based set of emission factors drawn from various European and regional databases as applicable for the CO2sources.GHG, Scope 1 (CO2e)Scope 1 GHG includes all direct emission sources where DFDS has operational control as defined by the GHG Protocol. This includes all use of fossil fuels for stationary combustion or transportation in owned, leased or rented assets. It also includes process emissions (e.g. chemical processes, industrial gases, direct methane emissions).GHG, Scope 2 – location based (CO2e)Location based Scope 2 GHG includes all indirect emissions related to purchased energy; electricity and heating/cooling where DFDS has operational control, as defined by the GHG Protocol – these are calculated based on the emission intensity of local grid area where the electricity usage occurs. GHG, Scope 2 – market based (CO2e)Market based Scope 2 GHG includes all indirect emissions related to purchased energy; REC covered electricity, and heating/cooling where DFDS has operational control, as defined by the GHG Protocol – these are calculated based on electricity consumption, including contractual purchases of renewable energy.GHG, Scope 3 (CO2e)Our determined Scope 3 emission categories are: Category 1: Emissions related to procured goods and services Category 2: Capital goods Category 3: Fuel- and energy-related emissions Category 4: Upstream transportation and distribution Category 6: Business travelScope 3 Spend-basedDFDS’ spend-based Scope 3 emissions are categorised and calculated using AI-powered software. Uploaded spend data is classified for categorisation, while calculations leverage the GHG Protocol framework and an extensive database of emission factors. Categories included in our spend-based approach: Category 1: Emissions related to procured goods and services Category 2: Capital goods Category 4: Upstream transportation and distribution Category 6: Business travelScope 3 Activity-basedDFDS’ activity-based Scope 3 emissions are categorised and calculated using the same process as GHG, Scope 1 and 2. The well-to-tank (WTT) activity-based data is related to our fuel and energy consumption, waste generation, and water consumption.Categories included in our activity-based approach are: fuel- and energy-related emissions (category 3).Estimations in 2024 Scope 3 figures AR 46h Part of the spend data for Q4 is based on an estimation due to the liquidation of our spend-consolidation tool. The spend estimate has been calculated using a linear regression forecasting method. This method has been applied to our existing spend data from 2022 up until end-Q3 2024. The estimated part of the Q4 2024 spend data is based on Q4 2023 data, with the % increase added. The estimation on Scope 3 accounts for 9% based on our overall Scope 3 spend. Biogenic emissions of CO2carbon from the combustion or biodegradtion of biomass, disclosed separately from Scope 1, Scope 2, and Scope 3.We consume renewable biomass-based fuel sources, for which we separately disclose the biogenic emissions associated with these fuels for each Scope in addition to our total emissions. These emissions are calculated using the same online tool that manages our GHG emissions calculations.Uncertainties and controls For sea-based data, our control process features an automated system that monitors and verifies data as it is transferred from our on-board system to an internal dashboard. This system identifies potential outliers and errors efficiently. To further ensure data accuracy and integrity, we are subject to regular external audits. For land-based data our control process features internal verification for reported data completion and accuracy. AR 45d We account for our renewable electricity usage by aligning our total electricity consumption from our locations with Renewable Energy Certificates (RECs) sourced from the countries where the electricity is consumed. Approximately 55% of our total electricity consumption is covered by green energy bundled with REC certification.GHG intensity Per net revenueAR 53The GHG intensity per net revenue is calculated using the following formulas: GHG intensity (location-based) = Total location-based GHG emissions (tCO2e)Net revenue (MDkk)GHG intensity (market-based) = Total market-based GHG emissions (tCO2e)Net revenue (MDkk)Per GT Mile The disclosure of GHG intensity based on the gross tonnage nautical-mile (GT- mile) performance of our own fleet and route network vessel voyages is calculated as the unit DFDS uses to quantify reduction of GHG emissions. This intensity is calculated by dividing the total GHG emissions, segmented by our fleet and route network, by the GT- miles sailed. E2 Pollution At DFDS, we understand that our impact on the pollution of air is an aspect of our environmental footprint. Efforts to lower CO₂e emissions, such as enhancing fuel efficiency, and optimising operations, simultaneously reduce the release of harmful air pollutants. This integrated approach underscores our dedication to responsible practices, cleaner air, and a healthier environment, ensuring our operations align with the goals of a sustainable future.SBM-3Material IROs table for E2 PollutionImpactsDescriptionImpact, Risk, or OpportunityPollution of airNon-greenhouse gas emission pollutants are emitted into the air during our vessel voyages, truck operations, and stationary combustion processes, contributing to air pollution.ANIESRS E2 PollutionIRO-1 Description of processes to identify and assess material pollution-related impacts, risks, dependencies and opportunitiesAR9 The ferry and logistics industries significant-lycontribute to global air pollution, with major impacts arising from fuel combustion such as vessel operations, the use of heavy machinery, and extensive transportation processes. Our materiality assessment identified emissions of particular concern, including sulphur oxides (SOx), nitrogen oxides (NOx), particulate matter with a diameter less than or equal to 10 mi-crometers (PM10), carbon monoxide (CO), black carbon (BC), and non-methane volatile organic compounds (NMVOCs).11a-b In our double materiality assessment (DMA), we conducted a general evaluation of pollution-related impacts, risks, and oppor-tunities across our own operations and value chain; however, we have not yet implemented the detailed screening of specific site locations, business activities, or conducted consultations with affected communities. The methodologies used in our assessment were broad and did not follow the phased LEAP approach or the detailed criteria specified for assessing material pollution-related impacts, dependencies, risks, and opportunities. We acknowledge these gaps and are committed to enhancing our processes in the future to align more closely with these requirements.E2-1 Policies related to pollution14-15 We are committed to minimising our environmental impact. The Climate Policy outlines our CO2e reduction ambitions, which simultaneously decrease the pollution of air from non-GHG pollutants. By reducing fuel consumption and CO2e emissions, we not only advance towards our goal of becoming net zero but also significantly reduce pollution impacts on air quality, contributing to cleaner air in the environment. While our policy demonstrates our dedication to sustainability and aligns with the UN Global Compact’s environmental principles, it does not currently address pollution risk manage-ment or potential emergency pollution incident impact. Additionally, while we incorporate environmental factors into our Enterprise Risk Management processes (ERM), we recognise the need to further develop our approach to managing pollution risks across our value chain and enhancing stakeholder engagement in our policy development and communication efforts. We are committed to addressing these areas to ensure full compliance with the relevant regula-tory requirements.62 Given that air pollution is a key material topic for DFDS and closely aligns with our decarbonisation strategy, we consider our current Climate Policy to be well-suited to address these challenges effectively.E2-2 Actions and resources related to pollution18, ESRS 62 DFDS is committed to net zero emissions by 2050 through enhanced energy efficiency, electrification, and sustainable fuels. While our decarbonisation efforts will reduce air pollution, we recognise that our current ESG strategy does not directly indicate specific resources and detailed plans for addressing other pollution forms and ecosystem restoration. This is due to our prioritisation of CO2e reduction as the most pressing sustainability challenge. As we evaluate the effectiveness of our current initia-tives, we will assess whether additional or distinct measures are necessary. Our truck fleet is classified under the high EURO emission standards, ensuring minimal pollution from fuel combustion. Additionally, the majority of our vessels are equipped with advanced scrubbers to significantly reduce sulphur oxide (SOx) emissions. Our vessels are also fitted with engines that comply with stringent nitrogen oxide (NOx) emission limits.ESRS E2 PollutionE2-3 Targets related to pollution22, 81 Our decarbonisation strategy focuses on reducing our CO2e emissions, which by a derivate effect will reduce our air pollution. Therefore, DFDS has not established specific targets for air pollution. Our current efforts are concentrated on decarbonisation, and we will continue to mon-itor the effectiveness of these measures. Should future evaluations indicate the need for specific air pollution targets, we will develop and disclose them in accordance with reporting requirements.E2-4 Pollution of air28a2024PollutantUnitEmissions LandEmissionsSeaEmissionsTotalNOxTonnes 1,891.751,468.0 53,359.7 SOxTonnes0.1 3,899.0 3,899.1 COTonnes420.12,908.0 3,328.1 BCTonnes18.4 65.0 83.4PM10Tonnes37.0 2,854.0 2,891.0 NMVOCsTonnes11.4 856.0 867.4 § Accounting policies30b We use the air pollutant calculation methodology found in the Stockholm Environment Institute and Climate and Clean Air Coalition (2022) A Practical Guide for Business Air Pollutant Emission Assessment. 30c For fuel consumption data, see accounting policies for E1-5, page 93Calculation of sea-based air pollutantsTo calculate air pollutant emissions from our vessel activity, we segregate data by fuel type and apply the relevant emission factors. For vessels equipped with scrubbers, we apply an additional emission factor to account for emission reductions.Calculation of land-based air pollutantsTo calculate air pollutant emissions from our land activity, we utilise a volume-based method where fuel is segregated by fuel type. We convert the volume of fuel consumed to kilograms (kg) of fuel, and then apply the relevant emission factors. 31 Our current methodology for calculating vehicle emissions does not account for specific vehicle types (i.e., Euro 5 versus Euro 6 trucks) or the distance traveled by each respective vehicle type. At present, we lack the visibility to correlate the total distance traveled in operations by each vehicle type, which has the ability to affect specific pollutants such as NOx which has reduced emissions when using a newer vehicle type i.e., Euro 6 trucks.E4 Biodiversity With the launch of our biodiversity strategy in 2024, we are adopting a strategic and targeted approach to strengthen biodiversity and minimise our impact on both land and sea. Our strategy is based on gathering data and engaging with stakeholders to continuously build our understanding of our impact on biodiversity. We are committed to expanding this knowledge, implementing measures where possible, and continuously adapting our strategy based on new insights and feedback.SBM-3Material IROs table for E4 Biodiversity ImpactsDescriptionImpact, Risk, or OpportunityDirect impact drivers of biodiversity lossThe greenhouse gas emissions associated with our operations lead to effects on biodiversity and ecosystems. ANIOur organisation operates a significant number of vessels, which generate substantial underwater noise during voyages. PNIESRS E4 BiodiversityIRO-1 Description of processes to identify and assess material biodiver-sity and ecosystem-related impacts, risks, dependencies and opportunities17a As a ferry and logistics company, we ac-knowledge our impact on the environment. This awareness has led us to identify two primary areas where our operations effect direct drivers of biodiversity loss: Climate Change and Underwa-ter Radiated Noise (URN). Climate Change:Our CO2e emissions contribute to climate change, which adversely affects bio-diversity by altering global weather patterns and temperatures. Our impact through climate change is detailed in our disclosures under ESRS E1. Underwater Radiated Noise (URN):Our organi-sation operates a significant number of vessels, which generate underwater noise during voyages. While this is a broader issue within the global ship-ping industry, we recognise our specific contribu-tion to negative impacts to biodiversity through the noise pollution caused by our fleet. We have identified these potential impacts through our double materiality assessment process. Our material impacts are associated with our vessel operations, which constitute the most significant portion of our emissions and noise pollution. Our biodiversity strategy, established in 2024, aims to enhance our ability to assess our direct impact on biodiversity and ecosystems. Due to the complexity and scope of the project, we have not yet conducted comprehensive assess-ments of the negative or positive impacts of our physical site locations. Nevertheless, the strategy highlights our commitment to developing our knowledge of our potential biodiversity impacts and mitigating our environmental footprint wher-ever feasible. 17b-e No dependencies, risks, or opportunities were identified.19 As a first step after the establishment of our biodiversity strategy, we have mapped our various physical locations to Natura 2000 sites, providing insights into where our operations intersect with or are in close proximity to biodiversity-sensitive areas. Notably, out of our terminals of operational control, we have identified that five are located within a 5 km radius of biodiversity-sensitive areas. This underscores the importance of under-standing the potential impact of our operations. Accurately identifying our direct impact on spe-cies and habitats presents significant challenges, both in the access to relevant data, as well as the complexity of operating in shared environments in many of our physical locations. As a result, we are currently unable to draw definitive conclusions about actual or potential negative effects of our operations on species and habitats. Given the inherent complexities and challenges in the shipping industry, we have determined that the impact from our vessels on biodiversity and ecosystems is more material than that from our physical site locations. Consequently, our primary focus has been on understanding and mitigating the effects of vessel operations. At this stage, we have not concluded whether biodiver-sity mitigation measures are necessary at our physical site locations. As our strategy evolves and our capabilities improve, we may extend our efforts to address potential impacts at these sites in the future. E4-2 Policies related to biodiversity and ecosystems22, 23a-b DFDS' Code of Conduct and Biodiversi-ty Policy serve complementary roles in promoting biodiversity. The Code of Conduct provides broad guidance for ethical behaviour, encouraging employees to consider biodiversity impacts. The Biodiversity Policy outlines specific objectives and actions to minimise environmental impact and support sustainability initiatives. Both are managed by the Group Sustainability team and aligned with the ESG Strategy. The Biodiversity Policy contains clear objectives focused generally on minimising biodiversity im-pact, integrating biodiversity considerations into business processes, and supporting research and conservation initiatives. The policy ensures proper ownership of biodiversity at DFDS, as well as outlines the commitment made towards regular assessments and reviews of the strategy and action plans. The policy applies to all DFDS operations. It encompasses all employees and key stakeholders. Biodiversity governance is embedded in DFDS' ESG Strategy, overseen by the Board of Directors and the Executive Management Team (EMT). The Group Sustainability team is responsible for policy maintenance and alignment with the Bio-diversity Strategy. The policy explicitly considers stakeholder interests by encouraging collab-oration with various groups, including external stakeholders, to enhance biodiversity-related knowledge and drive the agenda forward.The Biodiversity Policy outlines our commit-ment to the UN Sustainable Development Goals (SDGs), particularly SDG 14 (Life Below Water) and SDG 15 (Life on Land). All our policies are available to employees and external stakeholders through our intranet and website, respectively. The Code of Conduct is publicly accessible, and all employees receive mandatory Code of Conduct training.The biodiversity aspect relates to the material issue under the “other” subtopic of underwater radiated noise. Our ambitions are to continuously develop our understanding of our impacts and to drive our action plans and strategy, both of which include considerations of underwater radiated noise. The topic of climate change, identified as a direct driver of biodiversity loss, falls under our Climate and Environment Policy. By implementing changes to reduce our carbon footprint, we can reduce our broader environmental impact. Read more on climate change impact in section ESRS E1, page 83 23f Our Biodiversity Policy underscores our understanding that biodiversity is crucial for en-suring human well-being, climate resilience, and economic resilience. This policy also acknowl-edges the social consequences associated with impacts on biodiversity.24a,cThe current scope of our Biodiversity Policy does not have policies specific to our operational sites owned, leased, or managed which are near protected areas of biodiversity sensitive areas. In addition, we do not have spe-cific policies which relate to sustainable ocean or seas practices; however, our organisation adheres to all required standards and regula-tions set for our vessels regarding pollution and treatment of water.E4-3 Actions and resources related to biodiversity and ecosystems27 Our biodiversity strategy includes both short-term and long-term actions. For example, the installation of URN technology on new build vessels is an ambition we hope to complete in the ESRS E4 Biodiversityfuture. Part of our long-term ambitions is to ensure that future-generation vessels incorporate noise considerations to minimise their impact on marine biodiversity. This aligns with our sustainable fleet objectives, as we depend on a longer horizon of data collection and evaluations to guide operation-al decisions based on biodiversity considerations.For many years, we have been actively imple-menting various actions directly related to biodiversity on our vessels, such as adjusting our routes and reducing speed in the Mediterranean to avoid disrupting the habitat of endangered sperm whales, collaborating with the environmen-tal organisation ORCA to collect data and ob-serve animals on our route between Amsterdam and Newcastle, contributing to a research project studying bat migrations on either vessels or loca-tions, and participating in a project conducting long-term measurements of the ecological health of marine plankton with the Continuous Plankton Recorder Survey.Our actions encompass a broad range of op-erational areas, from our logistics operations at land-based facilities to our marine shipping routes. We consider both our upstream and down-stream potential impacts from our operations. Our primary focus is on our vessel voyages, as we recognise this operation has the highest likelihood of affecting biodiversity and ecosystems.A significant part of our biodiversity journey at DFDS involves developing and expanding our collaborative network with experts and peers. We aim to form partnerships that enable us to work together to understand our impact on biodiversity during our voyages and explore options for miti-gating any potential effects. These partnerships include, but are not limited to, collaborations with universities, biodiversity and scientific experts, networks, and industry peers.SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model &amp; E4-5 – Impact metrics related to biodiversity and ecosystems changeSBM-3 16, E4-5 35 As of 2024, DFDS has not yet conducted a comprehensive assessment of the potential negative impacts on biodiversity and ecosystems from our physical locations. Consequently, we do not currently maintain a list of material sites that may have potential effects on those areas. E4-4 Targets related to biodiversity and ecosystemsESRS 2 81 Since our biodiversity strategy and action plan were only introduced this year, our approach remains exploratory, allowing us to re-fine our commitments as we advance. While we have not yet set measurable outcome-oriented targets or established fixed timelines, as we are focused on implementing key actions as outlined in our policy.Our policy includes clear action steps, and we are committed to continuously reviewing the effectiveness of these actions in relation to sustainability-related impacts, risks, and opportunities. Through regular assessments, we aim to define our ambitions and track progress over time, ensuring that our approach remains aligned with long-term sustainability objectives as our strategy matures.ESRS Social 109 S1 Own workforce119 S2 Workers in the value chain123 S4 Consumers and end-usersS1 Own workforce Sustainable business is about people. We strive to “be a great place to work” in that we want to support the health, safety, and well-being of all our employees including their physical and mental health. We strive to be an inclusive and diverse workplace and believe that a diverse workforce makes better decisions. We believe that prioritising people is a way to attract and retain a diverse workforce. We want DFDS to be a company where all employees act according to our values and where we can rely on our colleagues’ knowledge and expertise as well as their ability to act with agility and solve problems as they arise.SBM-3Material IROs table for S1 Own workforce ImpactsDescriptionImpact, Risk, or OpportunityWorking conditionsImpacts on work-life balance and wellbeing from overtime/working schemesPNIANISafety and accident concerns of ship crews, truck drivers, and terminal and warehouse workersANIRPNIEqual treatments and opportunities for allBoth seafarers and logistics faces challenges attracting and retaining womenPNIBullying and harassment is known to occur in in the maritime and logistics sectors ANIESRS S1 Own workforceSBM-3Material impacts, risks and opportunities (IROs)14a In the process to identify and assess material IROs, the scope of disclosure includes all employ-ees in the DFDS workforce who could be materially impacted by our own operations and activities in our value chain. 14b Material negative impact occurrences are typically individual incidents. 14d Material risks arising from impacts on own workforce include serious accidents in the terminals during land and/or sea operations, cyber security risks, and potential GDPR related breaches. In the Moving Together Towards 2030 strategy, health &amp; safety is a key focus in the "Be a great place to work" part of the strategy. 14e Our transition plans for achieving greener and climate-neutral operations may come with a risk of material impacts on workers, including the handling of green fuels. Read more on transition plans page 8315 Through our extensive efforts within health &amp; safety, we have mapped the contexts and activi-ties that may lead to a greater risk of harm for our employees. For this purpose, we divide employ-ees in office and non-office workers, classifying non-office work as high risk. Non-office workers make up 65% of our workforce and are related to operations conducted on ferries, and at terminals, haulage and warehouses.S1-1Policies to manage material IROs19 DFDS has a range of policies in place to manage material impacts on our own workforce. These policies have been implemented to ensure the identification, prevention and mitigation of potential risks and impacts and to address opportunities. Depending on purpose and scope, the policies are owned and approved by relevant bodies as listed in the policies table. Ownership entails enforcement of policies and the responsibility to ensure that principles are integrated into practices and culture. Policies are rolled out via internal channels, including training sessions, introduction programmes, intranet, and other management communication such as townhall meetings. The policies are also publicly available on our website. Our policies are subject to review at regular intervals.21 Any commitment to relevant internationally recognised instruments is included in the last column of the policies table.Human rights20aAs a responsible employer, we are fully com-mitted to respecting human rights as defined by the UN Guiding Principles on Business and Human Rights and OECD guidelines for Multinational 19Policies related to own workforcePolicyObjective(s)Relation to IROsScopeOwnerAccount-abilityThird-party standards or initiativesOur Code of Conduct is our internal guideline for how employees should act responsibly, treat each other with respect, and respond to ethical issues. It is directly linked to the UN Global Compact’s ten guiding principles and covers topics like human rights, diversity and inclusion, anti-harassment and discrimination, environmental protection, anti-corruption, and bribery.Human rights, diversity &amp; inclusion, anti-harassment and discrimination, environmental protection, anti-corruption, and briberyAll DFDS employees PeopleBoard of DirectorsUN Global Compact’s ten guiding principlesLabour Code of ConductThis Labour Code of Conduct (LCoC), describes our minimum standard for critical working conditions of our employees. The aim is to prevent, remedy and account for any adverse human rights events across the company.Prevent, remedy and account for any adverse human rights issuesAll DFDS employeesPeopleEMTAt DFDS, we recognise the importance of human rights and are committed to conducting our business in compliance with the United Nations Guiding Principles on Business and Human Rights and the Organisation for Economic Co-operation and Development guidelines on responsible business conduct. The purpose of this policy is to establish a framework to ensure that human rights considerations are prioritised within DFDS.Working conditions, equal treatment and opportunitiesDFDS employees, across the value chain, and external stakeholdersPeopleBoard of Directors(27c) United Nations Guiding Principles on Business and Human Rights and the Organisation for Economic Co-operation and Development guidelines on responsible business conductAt DFDS, we hold the belief that respecting human rights is integral to our purpose, vision, and values. We prioritise the well-being and human rights of all individuals connected to our operations, including our employees, contractors and service providers, supply chain workers, customers, and the communities in which we operate. We firmly advocate for the freedom, safety, and dignity of every person.Modern slavery and trafficking (freedom, safety)DFDS employees, across the value chain, and external stakeholdersPeopleBoard of DirectorsIMPA ACT, UN Global Compact, UN Guiding Principles on Business and Human RightsInternational Bill of Human Rights (IBHR)International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work (ILOD), Rio Declaration on Environment and Development, UN Convention against CorruptionThe purpose of the Diversity, Equity, and Inclusion Policy is to establish a general framework to ensure we have a work environment that is truly inclu-sive, diverse, and free from any bias, discrimination, and harassment. We strive to be diverse and inclusive within the dimensions of ethnicity, gender, language, age, sexual orientation, religion, socioeconomic status, physical and mental ability, thinking styles, experience, and education.Work environment that is truly inclusive, diverse, and free from any bias, discrimination, and harassmentAll DFDS employeesHSSEEMTHealth &amp; Safety Policy How we conduct our Health &amp; Safety responsibilities is a cornerstone and an integral part of DFDS’s business. Throughout our operations, DFDS is committed to achieving the goal of: • Zero accidents • No harm to people • A safe and healthy working environment • Industry-leading service to our customers through a safe and healthy operationZero accidents No harm to people A Safe and Healthy working environment Industry-leading service to our customers through a safe and healthy operationAll DFDS employeesLegalEMTDFDS Compliance Line system is an additional means of reporting that enables both employees and external stakeholders to report existing or potential violations of law or regulations, certain parts of the DFDS Code of Business Conduct, or other serious irregularities directly to DFDS.Grievance mechanism. Potential breaches of Code of Conduct, laws and regulation.DFDS employees, across the value chain, and external stakeholdersT&amp;IBoard of DirectorsUnited Nations Guiding Principles on Business and Human Rights and the Organisation for Economic Co-operation and Development guidelines on responsible business conduct. Danish national regulationData protection policy (GDPR)This Data Protection Policy (“the Policy”) sets forth the required behaviours of DFDS employees in relation to processing Personal data. In addition to this Policy DFDS has put in place BU specific GDPR policies, procedures, and guidelines applicable to the business units.Personal data integrityAll DFDS employeesPeopleCTODanish national regulationCode of ConductHuman rightsModern Slavery ActDiversity, Equity, &amp; Inclusion PolicyWhistleblowerESRS S1 Own workforceEnterprises. We have formalised our commitment and processes in a Human Rights Policy. We perform human rights impact assessments (HRIA), which in the first instance was performed as part of the double materiality assessment, and serves as the foundation for our continued work with human rights and our efforts to create transparency. The entire organisation shares the responsibility of respecting and protecting human rights. The coordi-nation of human rights efforts at DFDS is entrusted to the Director of Sustainability. To further embed the efforts across the organisation, a dedicated Human Rights Review Group comprised of represen-tatives from Ferry, Logistics, Procurement, People, Health &amp; Safety (H&amp;S), Legal, and CSRD Reporting, will perform the next HRIA in 2025. Expertise from additional functions in DFDS will be included on an ad hoc basis based on impact findings. Forced labour22 DFDS is dedicated to eradicating modern slavery and human trafficking from our value chain and all aspects of our operations. We prior-itise transparency and awareness in these efforts. Through our HR policies and procedures, we not only ensure compliance with national laws but also uphold international conventions safeguard-ing employee rights, including those employed through third parties. The Human Rights Policy and Modern Slavery Report outline our approach and actions and explicitly address forced labour. Our Code of Conduct (CoC) further specifies what we expect of our employees in this regard.Workplace accidents23 We aim to ensure that robust safety pro-cesses, equipment, tools, and training are fully integrated into the way we work as governed by the H&amp;S Policy. The local H&amp;S organisations and Marine Standards department are responsible for implementing and integrating our "Safety-First" approach into existing procedures and processes on both land and sea.Discrimination24a We do not tolerate discrimination against any employee or job applicant based upon an individual’s race, religion, ethnic origin, gender, sexual orientation, gender identity, age, disability, or other characteristics. Policies aimed at elim-inating discrimination include the Human Rights Policy, the CoC, and the Diversity, Equity, and Inclu-sion (DEI) Policy. Everyone can report incidents they experience personally or witness happening to others, and we encourage open and honest communication.24b-c Our DEI Policy outlines a specific commit-ment to gender diversity to ensure the inclusion and ability to attract women to an industry with an overrepresentation of men.24d The procedure to implement policies to prevent and mitigate discrimination, and advance diversity and inclusion, include publication on the DFDS intranet and notification to all employees, office and non-office. The procedure for detection and action is handled in our whistleblower pro-cess, by managers or HR depending on how the case is reported.S1-2Engagement with people20b, 27a-c As part of our ongoing due diligence process, we engage with our employees and their representatives on material impacts. The respon-sibility for engagement falls under the Executive Vice President for People. Our key actions include an annual engagement survey and an annual appraisal process for all employees. The process supports the engagement, performance and development of the employee and is in line with DFDS's overall strategy and business goals. The annual engagement survey, MyVoice, is sent to all employees (office and non-office). Questions are grouped in three sets: Engagement, Diversity and Inclusion, and Health and Wellbeing. In 2024, the response rate was 80% and the aggregated engagement score was 6.7.Engagement also includes day-to-day inter-actions with managers and may occur at the initiative of the employee. All employees are encouraged to reach out to HR, the manage-ment team or the whistleblower system for any concerns or grievances. Both formal and informal channels are sources of information on employee perspectives, and they serve inform our decision-making processes. Our engagement with our workforce and the grievance mechanisms in place ensure that we mitigate actual or potential negative impacts, and act as needed to create positive impacts. S1-3Providing remedy and channels to raise concerns20c, 32a Our general approach to providing remedy for human rights impacts is part of our grievance mechanism process, in which the out-come of an issue raised through our whisteblower system may result in an action to remedy the mat-ter. Additionally, DFDS has outlined a procedure to assess and approve the provision of remedy for individuals or communities adversely affected by our business activities by way of the Human Rights Review Group. In cases where remedy would go beyond the normal operating procedures, the Review Group will assist in making recommenda-tions for the Executive Management Team (EMT) to approve. The review practice is planned to be initiated in 2025.32b Since 2015, DFDS has provided the possibil-ity of anonymously reporting any concerns over breaches of acceptable behaviour by or within the company through a Whistleblower System hosted by a third-party. Our Whistleblower Policy outlines the policy governing the system and handling of reports. Alongside the Whistleblow-er System, we encourage employees to report incidents or unacceptable behaviour to their local manager, HR or to a member of the EMT. Within the Whistleblower System, reports can be raised anonymously, and whistleblowers are safeguard-ed against potential retaliation.AR29-30, 32c The system is open for reporting by employees as well as third parties and can be easily accessed through our website. 32d The availability of the Whistleblower System is further supported by links on the DFDS intranet, QR-code stickers on physical locations and in ve-hicles. Communication and awareness activities include mention in the onboarding process of new employees, postings on the intranet, CoC roll-out and questions related to whistleblower in the annual employee survey, MyVoice.32e All cases are handled and treated confiden-tially by the assigned Whistleblower team. Appro-priate consequences are applied case by case, reflecting the severity of the issue. The Board of Directors receives regular updates on reports and findings from the Whistleblower System.33The awareness of and trust in the process to raise their concerns, is measured annually in the employee engagement survey, which in-cludes questions on the Whistleblower System. DFDS will not retaliate nor tolerate any form of retaliation from co-workers or partners against people for making a good faith report or parti-cipating in an investigation, as stated in our Whistleblower Policy.ESRS S1 Own workforceS1-4Taking action on material IROs37 Summarised description of action plans to manage IROs related to own workforceObjectiveGoalActionsEffectivenessHealth and Safety InitiativesReduce workplace accidents Performing safety training, conduct safety audits, upgrade safety equipmentSystems implemented to manage and measure health and safety both at sea and on land. Monitor accident rates, conduct employee surveysDiversity and Inclusion ProgrammesIncrease workforce diversity and an inclusive cultureDiversity perspective implemented in recruitment, promotion, and talent processes. Provide diversity training, diversity targets, financial incentives, new HR system implemented in 2024 will increase transparency on diversity mattersTrack diversity metrics, measure inclusion in engagement survey, gather employee feedback.Work-Life Balance InitiativesImprove work-life balanceChallenge stigma surrounding mental health challengesEvaluate employee satisfaction, monitor productivity38a DFDS takes action to address material impacts, manage risks and pursue opportunities in the following areas:Health &amp; safety We operate within our Safety First programme, which is a group-wide initiative to improve the knowledge of procedures regarding safety. At sea, we use SERTICA, a fleet management solution, on all DFDS vessels to manage and measure our H&amp;S performance. It is a system widely used by companies worldwide to optimise internal process-es concerning maintenance, procurement, HSQE (health, safety, quality, and environment), perfor-mance and to make decisions based on data. On land, a H&amp;S performance system, EcoOnline, has been implemented across all locations to ensure standardised reporting and data. Diversity, equity, and inclusion The equity, diversity, and inclusion (DEI) perspec-tives are included in recruitment, promotion, and talent processes. We apply a dedicated and structured approach as well as a focus on an inclusive culture. This includes target setting, financial incentives via bonus schemes, engage-ment surveys, management conferences, training sessions, toolboxes, and efforts to raise aware-ness and to make more unbiased decisions. The monitoring and measures implemented to improve DEI cover all layers of the organisation, including the Board of Directors and the EMT. Both, being diverse in terms of gender, nationality, age, and seniority. In December 2024, a new group-wide HR system was implemented, which will enable us to increase transparency on HR matters.Social dialogueWe encourage employees to elect employee representatives, and we engage with these rep-resentatives in good faith with full transparency. In areas where collective bargaining is prohibited by law, we will allow employees to develop alter-native ways to express their opinions and care for their rights. Training and development At DFDS, we believe that development hap-pens first and foremost through activities in the workplace. We offer formal and informal training programmes for leaders and employees. We also want to help our employees grow personal-ly. Performance management is structured by a recurrent annual appraisal process for all em-ployees. The process supports the engagement, performance and development of the employee and is in line with DFDS' overall strategy and business goals.HarassmentDFDS is dedicated to following up on all reported incidents and taking appropriate disciplinary actions when necessary. We treat all reports seri-ously and with care and all reported incidents are investigated thoroughly. We ensure trust and the possibility for anonymity in the reporting process. Regardless of who is involved, we follow up on every incident, to maintain a safe and inclusive workplace for all.Remedy38b Any material impacts brought to our attention through managers, HR, or the Whis-tleblower System are dealt with, including provid-ing remedy as deemed necessary. Records and reporting to document remedy is in place for the whistleblower process.38d The scores from the engagement survey serve as a measure to understand the status and effectiveness of employee engagement at DFDS.AR43 We recognise that transitioning to alter-native fuels for our vessels may bring negative impacts on our own workforce from a safety per-spective. When assessing alternative fuel types, we take aspects such as toxicity and handling into consideration.39 Processes to identify what action is needed and are appropriate in response to impacts on own workforce, include the annual engagement survey, MyVoice, the whistleblower system, re-ports from the H&amp;S systems, and general insights from managers.40a The actions for mitigating risk overlap with actions to address impacts. The opportunities identified are based on mitigation actions and are thus not included in the report as per the DMA methodology.ESRS S1 Own workforce41 It is the responsibility of the People division and the H&amp;S organisation to ensure that we have policies in place to mitigate negative impacts on our own workforce. The ferry and logistics industry involves inherent risks and essential tasks that must be managed, even under higher risk condi-tions. In situations where a trade-off is necessary, the safety of our workers remains our top priority, as outlined in our Health &amp; Safety Policy. 43 Resources allocated to manage material im-pacts include HR and H&amp;S systems for tracking performance and manage actions, dedicated teams and functions predominantly in the People division, and campaigns to address specific impacts and their related actions.S1-5Targets related to material IROs46 To manage and reduce material negative impacts on our workforce, we have implemented time-bound and outcome-oriented targets for gender diversity and health &amp; safety, respectively. Gender targetsWith the aim of improving gender diversity in DFDS, we have set targets for the underrepre-sented gender on various levels: For the highest management body (the Board of Directors), the gender target has been achieved with the underrepresented gender in two of the six board positions as elected by the Annual General Meeting. If and when the composition of the Board of Directors should no longer meet the target, a new target and target year will be implemented. For the Top Management (see definition in S1-9), the target is 25% share of the underrepresented gender by 2030. Across the DFDS group, our target is to have a 30% share of the underrepresented gender by 2030. Health &amp; safety targetThe key metric for health &amp; safety is Lost-time injury frequency (LTIF) presenting the number of registered work-related accidents disabling an employee to work for more than 24 hours per one million exposure hours. Our target for this metric is to see an ongoing decrease in injury frequency to the point of elimination.47a-c The target setting, the tracking of perfor-mance, and identifying improvements in the performance is undertaken by management in the People division. The process is informed by specialists, research, historical data and perfor-mance, and in dialogue with the EMT. As such, our own workforce or workforce representatives have not been directly involved.ESRS 2 81 For the material IROs related to work-life balance and bullying and harassment we have not set measurable targets. The IROs are addressed in our policies and actions and our ambition is for these impacts to be eliminated. For work-life balance the annual employee engagement survey, MyVoice, tracks relevant indicators by which we evaluate the progress. Likewise for bullying and harassment, with addi-tional indicators in the whistleblower system. 46 TargetsGender targets, female representationTargetTarget year2024Board of Directorsachieved- 33%Executive Management Team30%203029%Senior Management30%203019%All Managers30%203019%Deck &amp; Engine Managers20%20307%Office Managers40%203032%All employees30%203022%Office- -43%Non-office- -13%ESRS S1 Own workforceS1-6Characteristics of DFDS' employees50a Employees by gender2024HeadcountTotal Female3,905Male13,496Other35Total17,43650a Employees per country &gt;10%2024HeadcountTotal UK3,828Turkiye3,25150b Employees by contract type2024HeadcountFemaleMale Not declaredTotal - No. of permanent3,547 12,413 1915,979- No of temporary 337 1,057 15 1,409 - No. of non-guaranteed hours21 26 1 48No. of employees, total 3,905 13,496 35 17,43650c Employee turnover2024HeadcountTotalTotal no. of leavers2,566Rate of employee turnover18%§ Accounting policiesHeadcountHeadcount (HC) is the total number of employees, regardless of their contract type. The headcount is based on the number of employees on the 31st of December, 2024, as recorded in HR systems for land-based employees and seafarers respectively. Employees on long-term leave are excluded from the calculation.GenderLand-based data on gender categories varies between countries, depending on the local legislation. For some countries, the category 'other' and 'not declared' (grouped as ‘not declared’), has been recorded and included in the report. Seafarers are recorded as are male/ female in accordance with their certification and travel documents.Employees by countryLand-based employees (HC) reported by country. Seafarers are reported by flag in countries where the number of DFDS employees represent more than 10% of the total number of employees. Contract typesPermanent contracts: Contracts without ending day; that are valid until the employee or employer chooses to cancel it. Temporary contracts:Contracts with a fixed term. Non-guaranteed hours: Hourly paid employees such as student workersEmployee turnoverNumber of employees (HC) who have left DFDS, both voluntarily or due to other factors such as dismissal retirement, between 1st of January and 31st of December 2024. Employee turnover includes all employees, and contract types. Number of Employees Who LeftEmployee turnover rate:    × 100Average Number of EmployeesNumber of employees pr. 31/12/2023 + Number of employees pr. 31/12/2024Average number of employees:2ESRS S1 Own workforce50d The headcount is based on the number of employees at year end, as recorded in HR systems for land-based employees and seafarers respectively. The headcount refers to the total number of employees, regardless of whether they are on a full-time or part-time contract. Employees on long-term leave are excluded from the calculation. FTEs (full-time equivalents) are a measure of an employee's contractual working hours in relation to a full-time contract in the given position and country. The figure quantifies the workforce in terms of full-time positions. Employees on long-term leave are excluded from the calculation. The FTE number is calculated as an average for the reporting period.50f The total head count at the end of 2024 is 17,436. The most representative number in the financial statement is the average FTEs in 2024, which amounts to 14,121. As a cross-reference, the average no. of FTEs is lower due to part-time employment and that employees who joined DFDS in the Ekol International Transport acquisition on November 15, 2024, count in full in the head count but only impact the average by 1.5 months in the FTE number.S1-8Collective bargaining coverage and social dialogue63b DFDS has no agreements for representation by European Works Council (EWC), Societas Europaea (SE) Works Council, or Societas Cooperativa Europaea (SCE) Works Council. 60a CBA coverage2024HeadcountTotalNo. of employees with CBA6,053% of employees with CBA35%60b, 63a CBA and social dialogue2024Collective bargaining coverageSocial dialogue Coverage rateEEA countries &gt;10% Non-EEA countries &gt;10% EEA countries &gt;10% 0-19%Türkiye20-39%UKUK40-59%60-79%80-100% § Accounting policiesCollective Bargaining Agreements (CBA)CBA is calculated as the number of land-based employees and seafarers that are covered by a CBA between 1st of January and 31st of December 2024. CBA refers to agreements between employers and employees and/or employee representative organisation/group that regulate the terms and roles governing the relationship between the two parties. The data has been collected from local payroll systems. Social dialogueSocial dialogue refers to workers’ representatives including works councils, health and safety representatives, and trade union representatives as reported by local HR.FTE (full-time equivalents)FTE is the measurement of an employee's contractual working hours in relation to a full-time contract in the given position and country. The figure quantifies the workforce in terms of full-time positions. Employees on long-term leave are excluded from the calculation. The FTE number is calculated as an average for the reporting period.ESRS S1 Own workforceS1-9Diversity metrics66One of our primary priorities on the diversity agenda has been to increase the number of women in the business and across organisational layers. Except for in the People and Finance divisions, women leaders are still a minority in DFDS. We have a specific focus on increasing the number of women among office-based managers and for the deck and engine workers at sea. We have signed Danish Shipping's Charter for more women at sea and we run a female cadet programme in partner-ship with a maritime training institution.S1-10Adequate wages69 We are committed to ensuring that all employees earn fair wages. All salaries and benefits must at the least meet the specified minimum wage set by national law or the applicable collective bargaining agreement. For employees not covered by CBA, we are closely following market devel-opments and adjust salaries regularly and accordingly.We will investigate best practice and define relevant benchmarks with a view to update our pro-cesses to include an adequate wage benchmark in coming years. For 2024, no data on adequate wages is reported based on a lack of data availability.66a Gender distribution in management2024HeadcountNo.%Executive Management TeamFemale229%Male571%Not declared00%Senior ManagementFemale619%Male2681%Not declared00%All managersFemale46619%Male1,94581%Not declared10%66b Age distribution2024HeadcountTotal - No.Total - %Employees under age 303,300 19%Employees between age 30-50 8,939 51%Employees above age 50 5,19730%§ Accounting policiesExecutive Management Team (EMT)CEO, CFO, and selected executive/senior vice presidentsAR71 Senior ManagementEMT and all other Vice PresidentsAll ManagersTotal number of management positions (responsibility for at least one other employee)Age distributionThe age distribution data is caculated as the headcount as of December 31, 2024, as recorded in HR systems.ESRS S1 Own workforceS1-14Health and safety metrics88a Health and safety management system2024TotalPercentage of employees covered100%88b Fatalities2024Own employeesContractorsNumber of fatalities 0088e Lost-time injury frequency (LTIF) 2024Incidents/mio. hoursLandSeaTotalLost-time injury frequency (LTIF) 6.83.95.388c-d Recordable work-related accidents are not reported for 2024 due to insufficient data. Reporting of work-related accidents has been initiated in 2024. Further roll-out and awareness of the reporting tool is needed before the reported numbers can be considered representative.§ Accounting policiesHealth &amp; safety management systemHealth &amp; Safety management systems covers DFDS employees on land, and all crew working on the vessels. FatalitiesOwn employeesNumber of fatalities among employees caused by work-related injuries during 1st of January – 31st of December 2024. ContractorsNumber of fatalities among third-party contractors caused by work-related injuries while operating for DFDS during 1st of January – 31st of December 2024. Lost-time injury frequency (LTIF)LTIF is the number of registered work-related injuries disabling a seafarer to work for more than 24 hours per one million exposure hours. ESRS S1 Own workforceS1-16Remuneration metrics97a Gender pay gap for 2024 is not reported due to insufficient data. In 2024, a new HR system was implemented along with an action plan to improve the data foundation. This includes implement-ing job levels across the group and preparations for the Pay Transparency Act. It is our ambition to report on gender pay gap from 2025.97b The annual total remuneration ratio of the CEO to the average total remuneration for all em-ployees was 33 in 2024. DFDS recognises that the disclosure requires a ratio to the median remuneration. However, using an average provides equally useful information. It is our ambition to adjust the calculation to meet requirements from 2025.S1-17Incidents, complaints, and severe human rights impacts103d The number of cases reported through the DFDS whistleblower system in the reporting year. The line is open to own workforce and external parties. Given the anonymity option, it is not possible to distinguish between internal and external reports.104a-b No severe human rights issues and incidents connected to own workforce have occurred during 2024.103a-c Discrimination and complaints2024NumberTotal number of incidents of discrimination 22Number of complaints filed through channels for people in the undertaking's own workforce to raise concerns96Complaints to NCP0Total number of fines, penalties, and compensation for damages as a result of the incidents and complaints disclosed above 0§ Accounting policiesRemuneration ratio The remuneration ratio is calculated by dividing the annual total remuneration (including granted LTI for the CEO), by the average employee total remuneration (excl. CEO). Complaints and channels to raise concerns (103-104)103d Complaints and channels to raise concerns are measured as the number of cases reported through the DFDS whistleblower line in the reporting year. The line is open to own workforce and external parties. Given the anonymity option, it is not possible to distinguish between internal and external reports. Human rights issues and incidentsMeasured as the the number of reports in the whistleblower system that legal has assessed to be human rights issues and incidents. Human right issues connected to the value chain are not included.DiscriminationDiscrimination is measured as the number of incidents of discrimination that have been reported in our whistleblower system during January 1st – 31st of December 2024 (self-declared as 'Discrimination or Harassment'). Complaints to NCPThis is the number of complaints filed to National Contact Points (NCP) for OECD Multinational Enterprises as reported to the company by NCP. Amounts related to incidentsThese are measured as the fines, penalties, and compensation for damages, as a result of the incidents and complaints disclosed. S2 Workers in the value chain DFDS recognises the importance of fair labour practices and human rights throughout the supply chain. Supply chain sustainability is an integral part of DFDS’ Sustainable Procurement Programme and we aim to use our leverage to promote human rights, environmental care, good labour practices, and high ethical standards. We want to ensure transparency and accountability in our operations, highlighting our efforts to improve working conditions, promote fair wages, and prevent labour exploitation. A management system dedicated to assess and identify sustainability risks within the supply chain based on our spend, the suppliers’ country, and industry risk profile, is used. In parallel, we perform audits of third-party transport suppliers to ensure they live up to our Supplier Code of Conduct.SBM-3 Material IROs table for S2 Workers in the value chain ImpactsDescriptionImpact, Risk, or OpportunityWorking conditionsInsecure employment for certain workers, leaving risks for human rightsANINature of work subjecting workers to excessive hours, impacts on work-life balance and wellbeingANISafety for ship crews, truck drivers, and value chain workers due to nature of industry workRANIEqual treatments and opportunities for allNegative impacts more likely to disproportionately affect the underrepresented gender in the value chainANIOther work-related rights Risk of fines, repercussions and reputational damage in potential forced labor in the value chainRPNIESRS S2 Workers in the value chainSBM-3Material impacts, risks and opportunities (IROs)11a In the DMA process, the scope for mapping impacts, risks, and opportunities has included all value chain workers. In terms of disclosure, any value chain workers related to IROs found mate-rial are in scope. The most significant and direct impacts on workers in the value chain are found among workers directly involved in DFDS opera-tions. Value chain workers subject to material im-pacts include suppliers and third-party workers on DFDS sites, and downstream workers in logistics operations. Within these categories, we have an awareness of workers in risk of being particularly vulnerable, such as women, unregulated workers and lower-skill professions. 11b Based on the Human Rights Index, we have an awareness on our operations in Türkiye and Morocco for forced and compulsory labour im-pacts in the value chain.11c The material impacts occurrence is typically systemic to workers in the value chain in that the line of work within ferry and logistics operations come with health &amp; safety risks. Additionally, some impacts are related to individual incidents, typically also within health &amp; safety. Both types of occurrences are taken into consideration for mitigating actions and policies. 10b Material risks arising from impacts on value chain workers are related to Health &amp; Safety, which is included in the Moving Together Towards 2030 strategy.12-13 Other than as stated in previous para-graphs, we have not identified workers with particular characteristics that may be at greater risk of harm nor impacts that are linked to specific groups of workers.S2-1Policies to manage material IROs16 DFDS has a range of policies in place to man-age material impacts related to our value chain. Generally, these policies have been implemented to ensure the identification, prevention and miti-gation of potential risks and impacts and to ad-dress opportunities. Depending on purpose and scope, the policies are owned and approved by relevant bodies as listed in the table. Ownership entails enforcement of policies and the responsi-bility to ensure that principles are integrated into practices and culture. Policies are rolled out via relevant channels and are publicly available on our website. Our policies are subject to review at least annually. Throughout the value chain section, these policies are referenced as relevant.Human rights17a Our human rights commitment and approach is described under Own Workforce and encom-passes workers in our value chain. Read more on human rights page 11016Policies related to workers in the value chainPolicyObjective(s)Relation to IROsScopeOwnerAccount-abilityThird-party standards or initiativesHealth &amp; Safety Policy How we conduct our Health &amp; Safety responsibilities is a cornerstone and an integral part of DFDS’ business. Throughout our operations, DFDS is committed to achieving the goal of: • Zero accidents • No harm to people • A Safe and Healthy working environment • Industry-leading service to our customers through a safe and healthy operationZero accidents No harm to people A Safe and Healthy working environment Industry-leading service to our customers through a safe and healthy operationAll DFDS employeesHSSEMTAt DFDS, we recognise the importance of human rights and are committed to conducting our business in compliance with the United Nations Guiding Principles on Business and Human Rights and the Organisation for Economic Co-operation and Development guidelines on responsible business conduct. The purpose of this policy is to establish a framework to ensure that human rights considerations are prioritised within DFDS.Working conditions, equal treatment and opportunitiesDFDS employees, across the value chain, and external stakeholdersPeopleBoard of Directors(27c) United Nations Guiding Principles on Business and Human Rights and the Organisation for Economic Co-operation and Development guidelines on responsible business conductAt DFDS, we hold the belief that respecting human rights is integral to our purpose, vision, and values. We prioritise the well-being and human rights of all individuals connected to our operations, including our employees, contractors and service providers, supply chain workers, customers, and the communities in which we operate. We firmly advocate for the freedom, safety, and dignity of every person.Modern slavery and trafficking (freedom, safety)DFDS employees, across the value chain, and external stakeholdersPeopleBoard of DirectorsIMPA ACT, UN Global Compact, UN Guiding Principles on Business and Human RightsInternational Bill of Human Rights (IBHR)International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work (ILOD), Rio Declaration on Environment and Development, UN Convention against CorruptionDFDS Compliance Line system is an additional means of reporting that enables both employees and external stakeholders to report existing or potential violations of law or regulations, certain parts of the DFDS Code of Business Conduct, or other serious irregularities directly to DFDS.Grievance mechanism. Potential breaches of Code of Conduct, laws and regulation.DFDS employees, across the value chain, and external stakeholdersLegalBoard of DirectorsUnited Nations Guiding Principles on Business and Human Rights and the Organisation for Economic Co-operation and Development guidelines on responsible business conduct. Danish national regulationThrough DFDS’ Sustainable Procurement Programme, we endeavor to work with suppliers who share a similar commitment to responsible business practices. DFDS’ Supplier Code of Conduct includes the values and the requirements that we expect our suppliers to live up to when conducting business in an environmentally responsible, ethical, and social way. Our Supplier Code of Conduct describes what behaviours we value, and how we expect suppliers to respond to ethical issues.Human rights, diversity &amp; inclusion, anti-harassment and discrimination, environmental protection, anti-corruption, and briberyDFDS suppliersProcure-mentEMTIncorporates the IMPA ACT fundamentals and is based on the UN Global Compact and Guiding Principles on Environment, Labour Practices, Business Ethic and Human RightsBoard of directors / EMT: Executive Management Team / HSS: Health, Safety &amp; SecurityHuman rightsModern Slavery ActWhistleblowerSupplier Code of Conduct (SCoC)ESRS S2 Workers in the value chain17b The key channels for engagement with value chain workers include our grievance mechanism, our supplier audits, and the general dialogue in the supplier relationship.17c DFDS has a procedure to assess and approve the provision of remedy for individuals or commu-nities adversely affected by our business activi-ties. In cases where remedy would go beyond the normal operating procedures, the Review Group will assist in making recommendations for the Executive Management Team to approve.Forced labour18 DFDS is dedicated to eradicating modern slavery and human trafficking from our supply chain and all aspects of our organisation. We prioritise transparency and awareness in these efforts. Through our HR policies and procedures, we not only ensure compliance with national laws but also uphold international conventions safe-guarding employee rights, including those em-ployed through third parties. Our Human Rights Policy and Modern Slavery Report addresses trafficking, and forced labour.DFDS has a Supplier Code of Conduct (SCoC).AR15 The SCoC sets the minimum expectations from suppliers and is based on our commitment to recognised global standards and to the United Na-tions Global Compact’s principles, including the International Bill of Human Rights, International Labour Organisation’s Declaration on Fundamen-tal Principles and Rights at Work, the Rio Decla-ration on Environment and Development, and the United Nations Convention Against Corruption, and made operational by the United Nations Guid-ing Principles on Business and Human Rights.19 Our policies are aligned with relevant interna-tionally recognised instruments as included in the policies table. Through our supplier audits, we occasionally observe cases of non-conformity with our SCoC which in turn is non-respect of UN Guiding Princi-ples, the ILO Declaration, or the OECD Guidelines, which involve value chain workers. The nature of these cases ranges from not having a grievance mechanism to other work-related rights such as adequate housing or water and sanitation.S2-2Engagement with value chain workers22a As outlined in the SCoC, we expect our suppliers to establish a process of continuous due diligence in relation to their actual and potential adverse impacts. The process shall: a) regularly assess potential and actual impacts on the areas of fundamental responsibility, b) integrate impact assessment findings across relevant internal processes and functions, so as to ensure the prevention and mitigation of identified adverse impacts; and c) account for and report to DFDS how impacts are being addressed. The feedback from these processes in turn inform our decisions and activities aimed at managing actual and potential impacts.22b During audits of suppliers, we engage with business owners and their workers either directly or through a third-party performing the audit on our behalf. In-person audits and remote audits are performed at intervals ranging from bi-annually to every two years depending on the perceived risk of the supplier in question. The high risk indicators taken into account include the risk of human rights violations and the size of DFDS' annual spend related to the supplier. The outcomes of the audit and feedback from the process are relevant inputs for how we manage actual and potential impacts.22c The management in Group Procurement have the operational responsibility for ensuring engagement with value chain workers. Ultimate-ly, the EMT ensures executive ownership of the ESG agenda and is actively involved in selecting sustainability priorities and driving the implemen-tation of related action plans.S2-3Providing remedy and channels to raise concerns27a We typically become aware of how we cause or contribute to material negative impacts through our audits. When this is the case, we col-laborate with the supplier to remedy the impact and ensure compliance with our SCoC. If negative impacts come to our knowledge through our whistleblower system, it follows the whistleblower procedures.27b-c We expect our suppliers to have a reporting system to ensure that employees can voice griev-ances anonymously and without fear of reprisals on any aspect of our SCoC. All grievances should be investigated in a fair and timely manner. We ex-pect that suppliers account for and report to DFDS any relevant impact or breach to the SCoC. We also welcome anyone within or outside of DFDS to report any potential or actual violations of this SCoC. Concerns can be reported directly to DFDS representative, managers or through the DFDS whistleblowing system.27d All cases are handled and treated confi-dentially by the assigned Whistleblower team, and appropriate consequences are applied case by case, reflecting the severity of the issue. The Board of Directors receives regular updates on reports and findings from the whistleblower system. Suppliers and workers in the value chain are made aware of the whistleblower system in the SCoC.28 We review the awareness of the whistleblower system as part of our audit process.DFDS will not retaliate nor tolerate any form of retaliation against people for making a good faith report or participating in an investigation, as stated in our whistleblower policy.ESRS S2 Workers in the value chainS2-4Taking action on material IROs31 Summarised description of action plans to manage IROs related to value chain workersObjectiveGoalActionsEffectivenessHealth &amp; Safety Suppliers are expected to provide a safe, secure, and healthy working environment for all of their workforceReduce workplace accidents Our Supplier Code of Conduct sets the minimum expectations from suppliers. Suppliers are assessed and/or audited for compliance with SCoC.Assessments and audits track the effectiveness and adherence with our SCoC.Human and labour rightsSuppliers are expected to manage adverse impacts on human and labour rightsCreating a working environment where value chain workers are treated with dignity and respectOur Supplier Code of Conduct sets the minimum expectations from suppliers. Suppliers are assessed and/or audited for compliance with SCoC.Assessments and audits track the effectiveness and adherence with our SCoC.Business ethicsSuppliers should establish adequate processes to conduct their business with highest ethical standards.Our Supplier Code of Conduct sets the minimum expectations from suppliers. Suppliers are assessed and/or audited for compliance with SCoC.Assessments and audits track the effectiveness and adherence with our SCoC.31, 32a, 34a Our action plans to manage material IROs related to value chain workers are centred around our SCoC, our supplier assessment pro-cesses, and the audits we perform directly or with the help of third parties. These actions are aimed at unveiling non-conformance, enabling a dialogue to plan actions, and improve the working conditions.AR 32We consider actual impacts on our value chain from decisions to terminate business relationships and seek to address any negative impacts that may result from termination. Given the diverse nature of our business relationships across DFDS, such decisions are influenced by various factors, and we do not have a standardised process for evaluating and addressing these impacts.32b, 33c Any material impacts brought to our at-tention through the whistleblower system are dealt with, including providing remedy as deemed neces-sary. Records and reporting to document remedy is in place for the whistleblower process. We engage with suppliers through the EcoVadis platform, a tool for managing ESG risk and com-pliance, for performance improvements. The ef-fectiveness of actions and initiatives are assessed through our audits and whistleblower reports.33a The processes to identify the need for action in terms of value chain workers relies on our supplier assessments and supplier audit findings.33b In our supplier audits, any non-conformities are assessed for severity. DFDS will allow a certain time to rectify the matter depending on the sever-ity of the finding and in particular, severe cases the supplier relationship may be discontinued.35 It is the responsibility of the Procurement and the Health &amp; Safety organisation to ensure that we have policies and procedures in place to miti-gate any negative impact on workers in the value chain. The ferry and logistics industry involves inherent risks and essential tasks that must be managed, even under higher risk conditions. The safety of our workers remains our top priority, as outlined in our Health &amp; Safety Policy. 38 Resources allocated to manage material im-pacts include Health &amp; Safety (H&amp;S) systems for tracking audit performance and manage actions, as well as dedicated teams predominantly within Procurement. The People division is involved in internal safety and third-party haulage audits.S2-5Targets related to material IROs41DFDS has ambitions to increase the SCoCcoverage for all recurring suppliers and the ESG as-sessment of prioritised suppliers. We are currently working to improve the tracking of these metrics for future target setting. Meanwhile, the effectiveness of our policies is tracked in our supplier audits and in sustainable procurement. Read more on sustainable procurement on page 129S4 Consumers and end-users In DFDS’ operations, our key consumers and end-users are the passengers on our ferries. Our aim is to offer superior service in meeting their transport needs. We recognise the importance of ensuring a high level of service quality, safety, and customer satisfaction. It involves transparent reporting on customer feedback mechanisms, safety protocols, and measures to enhance the passenger experience. We are committed to prioritising the needs and expectations of our passengers, fostering trust and loyalty and strengthening our position as a customer-centric and responsible operator in the maritime industry.SBM-3Material IROs table for S4 Consumers and end-users ImpactsDescriptionImpact, Risk, or OpportunityInformation-related impacts for consumers and/or end-usersIf exposed to cyber-attacks, DFDS might be involved in a leakage of private customer information and derived financial riskRPNIPersonal safety of consumers and/or end-usersSafety of passengers through ship-related accidents. Accidents related to products and services of DFDS can be financial risk through legal proceedings and fines, reputational risk, and customer lossRPNIESRS S4 Consumers and end-usersSBM-3Material impacts, risks and opportunities (IROs)10aThe scope of consumers and end-users likely to be materially impacted by DFDS’ own operations, value chain, and business relation-ships, encompasses passengers on DFDS ferry routes. Passengers include individuals using our services to cover their transportation needs. The passengers that are also part of our freight and logistics value chain, such as truck drivers employed by a third-party, are covered in S2, workers in the value chain. Throughout their journey with DFDS, the key po-tential impacts to our passengers are related to safety. For the customer relationship in general, the right to privacy related to the customer data we receive is a potential risk. 10b Negative impacts are rare and incident-based. 10d Material risks include GDPR non-compliance leading to fines and financial risk related to acci-dents affecting passengers.9a-b In the Moving Together Towards 2030 strategy, Health &amp; Safety is a key focus in the "Be a great place to work" part of the strategy, which also extends to the safety of passengers onboard our vessels.S4-1Policies to manage material IROs 15 DFDS has a range of policies in place to man-age our material impacts on our passengers, in-cluding Health &amp; Safety, Data protection, Human Rights, Modern Slavery, Whistleblower, and Code of Conduct as presented under Own workforce. Read more on policies on page 110These policies have been implemented to ensure the identification, prevention and mitigation of po-tential risks and impacts and to address opportuni-ties. Depending on purpose and scope, the policies are owned and approved by relevant bodies as listed in the table. Ownership entails enforcement of policies and the responsibility to ensure that principles are integrated into practices and culture. Policies guide the actions of DFDS staff when interacting with passengers. The policies are also publicly available on our website. Human rights16a Our human rights commitment and ap-proach is described under Own Workforce and encompasses workers in our value chain. Read more on human rights on page 110The Code of Conduct outlines that DFDS employeesshould treat passengers "with respect, dignity, fairness, and courtesy". The DFDS Data Protection ESRS S4 Consumers and end-usersPolicy states that a passenger (Data Subject) has the right to request information in which Personal data relating to him/her is processed and for what purpose. The CoC protects consumers against violations of competition law.16b Key engagement with passengers is the direct contact to DFDS staff in customer services, at the terminal, and during their journey on our vessels. We perform surveys to gauge passenger experiencesand receive their feedback on an ongoing basis.16c DFDS has a procedure to assess and approve the provision of remedy for individuals or commu-nities adversely affected by our business activities. In cases where remedy would go beyond the normal operating procedures, the Review Group will assist in making recommendations for the Executive Management Team (EMT) to approve.17 Policies are aligned with relevant internation-ally recognised instruments as included in the policies table. We have recorded no cases of non-respect of humanrights involving passengers in the reporting year.S4-2Engagement with consumers and end-users20a-b We perform surveys to gauge passenger experiences and receive their feedback on an ongoing basis. To further inform the DMA and our work with IROs we have engaged with a passenger association for insights.20c The leadership of Passenger has the operational responsibility for ensuring engage-ment with passengers. Ultimately, the EMT ensures executive ownership of the ESG agenda and is actively involved in selecting sustainability priorities and driving implementation of related action plans.S4-3Providing remedy and channels to raise concerns25aWe typically become aware of how we cause or contribute to material negative impacts through our interactions with passengers during the journey or in dialogue with customer service. When this is the case, we collaborate with the passenger to remedy the impact. If negative impacts come to our knowledge through our Whistleblower System, it follows the whistle-blower procedures. 25b-c The specific channels for consumers to raise concerns or needs, include customer care and customer complaints resources on our website for passengers. The DFDS Whistleblower System is open to all external parties.25d The effectiveness of these channels is assessed based on response times recorded and tracked for customer queries and complaints.26 The number of cases brought up with customer care teams indicate that passengers are aware of the channels available. In addition, we include complaints data in our review of customer surveys.DFDS will not retaliate nor tolerate any form of retaliation against people for making a good faith report or participating in an investigation, as stated in our Whistleblower Policy.S4-4Taking action on material IROs30, 31a, 32b, 33a Actions and resources to manage IROs related to consumers include guidelines for data ethics and GDPR, our commitment to the health &amp; safety of our passengers, and we need to ensure safety with proper lane traffic planning and clear signage and dedicated walkways. HSSE Terminals has performed detailed safety analyses of selected terminals and implemented a plan. We continue to underline the importance of safety reporting and to improve the safety focus.31b, 32c Any material impacts brought to our attention through the Whistleblower System are dealt with, including providing remedy as deemed necessary. Records and reporting to document remedy is in place for the whistleblower process.32a Our approach to identifying action needed in response to material impacts is guided by our policies and internal training in customer care.34 It is the responsibility of the Passenger teams and the Health &amp; Safety organisation to ensure that we have policies and procedures in place to mitigate any negative impact on passengers. The ferry operation has some inherent risks and the safety of passengers takes precedence as stated in our Health &amp; Safety Policy.S4-5 Targets related to material IROs41For the reporting period, DFDS did not adopt any specific targets related to end-users nor any tracking of effectivenes of policies or actions. This decision was based on an assessment of our current operational capabilities and strate-gic priorities. While no formal targets were set, we remain committed to continuous improve-ment and are exploring future opportunities to establish targets.ESRS Governance 127 G1 Business conductG1 Business conduct DFDS is committed to conducting business in a responsible, ethical, and transparent manner to meet stakeholders’ expectations of high business integrity standards. Our approach to business integrity is embedded in our corporate values, policies, and procedures. Providing maritime transport and logistics services means that we are in close contact with many people throughout our value chain. Corruption is an inherent risk to our business, and we mitigate this by having clear policies for employees and suppliers on how to act. While we actively engage in dialogues with governments and authorities with respect to infrastructure issues of common interest, we do not support or provide donations to individual political parties or politicians. We believe that engaging in partnerships and industry organisations and taking an industry perspective serves the company and our stakeholders best, just as we actively share knowledge and data to move the industry forward.SBM-3Material IROs table for G1 Business conductImpactsDescriptionImpact, Risk, or OpportunityCorporate cultureRisk of corporate culture affecting risk management, productivity, and innovationRProtection of whistleblowers Lacking awareness of the whistleblower system entails that unlawful behaviour may not be reportedRManagement of relationshipsPoor supplier management can lead to negative impacts, including contract terms, pressure on price and lead time, payment practices, and payment conditions PNICorruption and bribery Shipping and logistics sectors have an increased risk of bribery and corruptionPNIESRS G1 Business conductGOV-1 The role of the administrative, management and supervisory bodies5a The responsibility for business conduct ulti-mately lies with the Board of Directors. Business conduct is outlined in our Code of Conduct (CoC)and is part of the culture at DFDS, as guided by the tone at the top in our Executive Management Team (EMT). The ownership of the CoC is with the People Division. For the annual review and up-date, multiple internal stakeholders are involved including Legal, Health &amp; Safety, and People. The CoC is approved by the Board of Directors.5b Members of the Board of Directors have expertise in business conduct and sustainability matters, either directly or in capacity of C-level positions in other organisations. DFDS has legal competencies in the administrative bodies of the organisation. The EMT demonstrates ongoing awareness of business conduct matters and DFDS has training programmes available for topics related to business conduct.IRO-1 Processes to identify and assess material impacts, risks, and opportunties (IROs)6 In the process to identify material IROs, the criteria used, include activity type (ferry and logistics, respectively) and whether the IRO is related to own operations or the value chain. In relation to business conduct matters, the criteria also includes the countries we operate in, known business conduct risks in the ferry and logistics industry, and the nature of transactions.G1-1 Business conduct policies and corporate culture7 DFDS has a range of policies in place to man-age material impacts related to business conduct and corporate culture, including Whistleblower Policy, CoC and Supplier Code of Conduct (SCoC) as presented under S1 Own workforce. Read more on policies page 110Data ethicsDFDS is committed to protect any data collected when we conduct business. This could be personal data, or other types of data, pertaining to our cus-tomers, suppliers, business partners and employees. Our operations and connections with third-parties are increasingly being powered by data and technol-ogy. Our ambition is to improve business value and increase efficiency, therefore usage of data is funda-mental to achieve these goals. As such, it is crucial that we handle data with care and comply with all applicable laws and standards related to data, data privacy, and the ethical use of data. To this extent, DFDS implemented the Data Ethics Pol-icy in 2021. In 2023, the policy was revised to further strengthen the overall policy framework. In this latest revision, we expanded the description of the data we collect, how we use it, and the policies we have in place to ensure responsible handling and use of data. The Data Ethics Policy sets out the overall guide-lines and principles for how data ethics are consid-ered and included in the use of data, including personal data, and the design and implemen-tation of technologies. Being a transport and logistics provider, we use data to maintain and improve our customer experience and our opera-tional efficiency. We are committed to ensure that employees, customers, and business partners can entrust us with their data whether it is personal data or other business data. We are determined to handle this data in a sustainable and responsible manner. We recognise that digital development entails both responsibility and transparency. The Data Ethics Policy supplements our Data Pro-tection Policy and Privacy Notice which sets out the overall requirements for our handling of personal data, and our Information Security Policy and IT policies, which describes how we look after DFDS’ data, including relevant security standards for data storage, access management, and safe IT usage. The purpose of our Data Ethics Policy is to ensure a fair balance between, the many benefits that the use of data and new technology offers, and the conse-quences that the use of data can have on an individ-ual, a business and society in short- and long-term.Our data ethics review 2024 in reference to The Danish Financial Statements Act §99d is available on our website: https://assets.ctfassets.net/mivicpf5zews/2qJItDbT1v4SHYd53BYSzT/1d6fbc2c3cb22e4211097efff6d29ded/dfds-data-ethics-review-2024-01.pdfPrivacy Employees can at any time request information on how we use their personal data and what data we have collected. Security cameras are only installed as a safety measure, and employee privacy is always considered before installation and use. Training programmes on GDPR are conducted to foster understanding and compliance across the Group.9DFDS' corporate culture builds on our CoC. In an organisation of more than 17,400 employees, spread across land and sea, regions, cultures, and professional roles, a significant amount of effort is needed to maintain a strong corporate culture. The EMT oversees and approves the communication activities and interactions to promote corporate culture, including onboarding of new employees and training, supporting our CoC and DFDS culture. The operational responsibility lies with the People division.The annual employee survey, MyVoice, serves as a measure to evaluate the corporate culture.10a-b Our mechanism for identifying, report-ing and investigating concerns about unlawful behaviour takes its departure in the Board of Directors, whose work is governed by DFDS Articles of Association and the Rules of Procedure for the Board of Directors. In accordance, the Board of Directors' annual cycle holds all material governance aspects, including major risks and oversight of financial procedures and reporting. The Board of Directors is supported by three board committees, each having three directors as members, and the Audit Committee has partic-ular oversight of financial processes. The Board of Directors is evaluated annually and at intervals the evaluation is performed by an external party. The CoC outlines how employees are expected to react if they should become aware of behaviour in contradiction of the CoC, including instructions on who to inform or to report via the whistleblow-er system. The Whistleblower System is open to internal and external stakeholders. 10c-d The Whistleblower System offers the possi-bility to report material irregularities (with certain limitations as stipulated by local regulation). DFDS will not retaliate nor tolerate any form of retaliation against people for making a good faith report or participating in an investigation, as stat-ed in our Whistleblower Policy and in adherence with national law. 10e DFDS is committed to investigate business conduct incidents reported in the Whistleblower System promptly, independently, and objectively.10g Business conduct training is considered mandatory and specific online training is assigned ESRS G1 Business conductto the relevant employees. The suite of training opportunities is open to all employees and it is the responsibility of each manager to suggest and oversee the non-mandatory training as relevant.10hDFDS is committed to eliminating corruption and bribery, as further described in G1-3. We ac-knowledge that facility payments are a known chal-lenge in the ferry and logistics industry. Given that DFDS' activities are mainly in the European area, we consider the risk to be lower based on Transparency Internationals Corruption Perception Index. We rec-ognise that these risks still exist and that we also op-erate in areas outside the EU where the index scores indicate higher levels of risk of corruption. Based on an industry generic view, the functions we consider at risk in DFDS can be seen in the table below. G1-2 Management of relationships with suppliers15a Supply chain sustainability is an integral part of DFDS’s Sustainable Procurement Programme. We impact our supply chain through promoting human rights, environmental care, good labour practices, and high ethical standards. Our SCoC incorporates the IMPA Act (International Marine Purchasing Association) fundamentals and is based on the UN Global Compact and Guiding Principles on Environment, Labour Practices, Business Ethic and Human Rights. DFDS’s SCoC sets the standard for our supply chain to operate in accordance with ethical business principles and conform to all applicable international laws, rules, and local regulation. We expect our suppliers to adhere to our principles and standards and to develop and implement relevant management systems appropriate for a company of their size in line with our SCoC. We use a dedicated management system to assess and identify sustainability risks within our supply chain. The monitoring of our supply chain is performed in three steps:We assess our supply chain on ESG risksbased on the three criteria: spend, supplier’s country of origin and industry.We engage and thoroughly evaluate suppliers within a target group of suppliers on Environment, Human &amp; Labour Rights, Ethics and Sustainable Procurement. Target group suppliers are suppliers that amount to annual spend &gt;10mDKK and/or suppliers that are flagged as high risk in the first step. Based on this evaluation, suppliers receive scores accordingly.Based on the suppliers’ score and in connec-tion to our post assessment policy, we further Entity specificSustainable procurement2024Supplier Code of Conduct commitment64%ESG assessment of suppliers &gt;10 mDKK100%Sustainable Procurement training completion98%engage suppliers on improvements and corrective actions. Our ESG supplier evaluation programme enables us to better address higher-risk areas in our sup-ply chain and engage in a constructive dialogue with our suppliers to develop more innovative and sustainable products and/or services. In parallel, we perform audits of third-party trans-port suppliers to ensure they adhere to our SCoC. Read more on engagement with value chain workers on page 121We expect our suppliers to sign our SCoC, and would revert to sanctions to the point of terminating the relationship with a supplier who violates the Code or refuses to take part in a remediation plan. To ensure awareness of sustainability matters, all DFDS buyers and category managers are in scope for sustainable procurement training. 15b When selecting suppliers, we perform a supplier risk assessment as outlined in 15a. G1-3 Prevention and detection of corruption and bribery18a DFDS has procedures in place to prevent and address allegations or incidents of corruption and bribery. The CoC instructs employees on expected 10hFunctions at DFDS that are most at risk in respect of corruption and briberyFunctionRiskProcurementThis function often involves large contracts and significant financial transactions, making it a prime target for bribery.Customs and border ControlInteractions with customs officials can be a hotspot for bribery, as employees might offer payments to expedite shipments or avoid inspections.Freight forwarding and shippingThis area involves numerous third-party interactions, including with port authorities and shipping agents. Bribes might be used to secure favourable shipping routes or to bypass regulations.Sales and marketingSales teams might engage in bribery to win contracts.Finance and accountingCorruption can occur through fraudulent invoicing, or manipulating financial records to cover up illicit payments.ESRS G1 Business conductactions in terms of preventing and reporting incidents of corruption and/or bribery. Any alle-gations or incidents are addressed by legal in a similar process as for whistleblower reports. In terms of detection, we rely on employees to report allegations or incidents. 18b The investigation of any corruption and/or bribery allegations and incidents reported in the Whistleblower System or brought to the atten-tion of the legal team via internal channels are performed by the whistleblower responsible in the legal team. As such, the investigation is not separate from the chain of management involved in the prevention of corruption and/or bribery.18c The process to report outcomes of any such investigations is part of the whistleblower report-ing process.20 Anti-corruption and anti-bribery policies are part of our CoC. The CoC is presented to all new employees as part of their onboarding pro-gramme. Any updates to the CoC are communi-cated to all DFDS employees.21aTraining in the CoC, which covers the anti-corruption and anti-bribery policies, is mandatory for all employees. The nature of the training is an online course for all office-based employees and seafarers (63%) to be completed on-demand. Training of non-office land-based employees (37%) is performed in-person by managers. Training com-pletion is tracked in the training portals for land-based office workers and seafarers respectively. Since this training was implemented in the second half of 2024, we will start reporting figures in 2025.21b Given that the CoC training is mandatory for all employees, the functions-at-risk targeted by training programmes is 100%. 21c The CoC training is mandatory for the admin-istrative and management bodies. The Board of Directors approve any updates to the CoC but are not required to complete the training.G1-4 Incidents of corruption and bribery24a DFDS has had no convictions for violation of anti-corruption or anti-bribery laws in the re-porting year and consequently received no fines for such violation.G1-6 Payment practices14 DFDS has implemented a strategic initiative, which aims to optimise payment efficiency and reinforce our commitment to timely transactions and payments on time. This is achieved by align-ing standard payment terms across suppliers. In recognition of the importance of flexibility, especially for SMEs, deviation from standard payment terms may be approved on a case-by-case evaluation. The aim is to simultaneously streamline procurement processes while maintaining transparency and fairness in our supplier relations.33a The average number of days to pay invoices from the date when the contractual term of pay-ment starts (invoice date) is 42 days.33b Standard payment terms across suppli-ers are current month + 63 days. Additionally, minimum acceptable payment terms are current month +30 days to ensure a balance between supplier relationship and financial sustainability.33c DFDS does not have any outstanding legal proceedings for late payments. § Accounting policiesSupplier Code of Conduct commitment Suppliers who have signed DFDS’ Which one is right? Supplier Code of Conduct (SCoC) is the percentage of current suppliers contracted by Group Procurement based on registration in DFDS’s sustainable procurement database. ESG assessment of suppliers Percentage of current suppliers contracted by Group Procurement with a spend &gt;10 mDKK undergoing ESG assessment based on registration in EcoVadis database. Sustainable Procurement training of buyers/category managers DFDS buyers and category managers trained in Sustainable Procurement is the completion rate of employees in scope for the training. The completion rate is based on registrations in the training system.Code of Conduct training The employees in scope of the Code of Conduct training covers all employees in DFDS during 2024. Of the total, employees in scope for online training are office-based employees on land and seafarers. Non-office employees on land receive in-person training. Ekol is not included.Number of convictions for violation of anti-corruption and anti-bribery lawsThe number of convictions for violation of anti-corruption and anti-bribery laws includes all convictions as a result of legal proceedings against DFDS in the reporting year. Amount of fines for violation of anti-corruption and anti-bribery laws The amount of fines paid for violation of anti-corruption and anti-bribery laws includes fines paid as a result of legal proceedings on these matters against DFDS in the reporting year. Number of legal proceedings outstanding for late payments The number of legal proceedings outstanding for late payments includes all legal proceedings against DFDS relating to late payments of business partners that are outstanding at year end. 33d Average number of days to pay invoices The average number of days to pay invoices has been collected across entities. ESRS Appendix132 ESRS 2 General disclosure indexGeneral disclosure indexDisclosure RequirementDatapointSustainability statements | AppendixSFDR referencePillar 3 referenceBenchmark regulation referenceEU Climate Law referenceSectionPageESRS 2 GOV-121 (d)Board's gender diversityIndicator number 13 of Table #1 of Annex 1Commission Delegated Regulation (EU) 2020/1816 ( 27 ), Annex IISustainability statementESRS 2 GOV-121 (e)Percentage of board members who are independentDelegated Regulation (EU) 2020/1816, Annex IISustainability statementESRS 2 GOV-430Statement on due diligenceIndicator number 10 Table #3 of Annex 1Sustainability statementESRS 2 SBM-140 (d) iInvolvement in activities related to fossil fuel activities Indicator number 4 Table #1 of Annex 1Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 (28) Table 1: QualitativeDelegated Regulation (EU) 2020/1816, Annex IINot applicable to DFDS- ESRS 2 SBM-140 (d) iiInvolvement in activities related to chemical production Indicator number 9 Table #2 of Annex 1Delegated Regulation (EU) 2020/1816, Annex IINot applicable to DFDS-ESRS 2 SBM-140 (d) iiiInvolvement in activities related to controversial weaponsIndicator number 14 Table #1 of Annex 1Delegated Regulation (EU) 2020/1818 ( 29 ), Article 12(1) Delegated Regulation (EU) 2020/1816, Annex IINot applicable to DFDS-ESRS 2 SBM-140 (d) ivInvolvement in activities related to cultivation and production of tobacco Delegated Regulation (EU) 2020/1818, Article 12(1) Delegated Regulation (EU) 2020/1816, Annex IINot applicable to DFDS-ESRS E1-114Transition plan to reach climate neutrality by 2050Regulation (EU) 2021/1119, Article 2(1)Sustainability statementESRS E1-116 (g)Undertakings excluded from Par-is-aligned BenchmarksArticle 449a; Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Template 1: Banking book-Climate Change transition risk: Credit quality of exposures by sector, emissions and residual maturityDelegated Regulation (EU) 2020/1818, Article12.1 (d) to (g), and Article 12.2Sustainability statementESRS E1-434GHG emission reduction targetsIndicator number 4 Table #2 of Annex 1Article 449a; Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Template 3: Banking book – Climate change transition risk: alignment metricsDelegated Regulation (EU) 2020/1818, Article 6Sustainability statementESRS E1-538Energy consumption from fossil sources disaggregated by sources (only high climate impact sectors)Indicator number 5 Table#1 and Indicator n. 5 Table #2 of Annex 1Sustainability statementESRS E1-537Energy consumption and mixIndicator number 5 Table#1 of Annex 1Sustainability statementPage 68Page 68Page 70Page 83Page 84Page 89Page 93Page 93General disclosure index continuedDisclosure RequirementDatapointSustainability statements | AppendixSFDR referencePillar 3 referenceBenchmark regulation referenceEU Climate Law referenceSectionPageESRS E1-540-43Energy intensity associated with activities in high climate impact sectorsIndicator number 6 Table #1 of Annex 1Sustainability statementESRS E1-644Gross Scope 1,2, 3 and TotalGHG emissionsIndicators number 1 and 2 Table #1 of Annex 1Article 449a; Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Template 1: Banking book – Climate change transition risk: Credit quality of exposures by sector, emissions and residual maturityDelegated Regulation (EU) 2020/1818, Article 5(1), 6 and 8(1)Sustainability statementESRS E1-653-55Gross GHG emissions intensityIndicators number 3 Table #1 of Annex 1Article 449a Regulation (EU) No 575/2013; Commission Implementing Regulation (EU) 2022/2453 Template 3: Banking book – Climate change transition risk: alignment metricsDelegated Regulation (EU) 2020/1818, Article 8(1)Sustainability statementESRS E2-428Amount of each pollutant listed in Annex II of the E-PRTR Regulation emitted to air, water and soilIndicator number 8 Table #1 of Annex 1 Indicator number 2 Table #2 of Annex 1 Indicator number 1 Table #2 of Annex 1 Indicator number 3 Table #2 of Annex 1Sustainability statementESRS 2 - SBM 3 - E416 (a) iIndicator number 7 Table #1 of Annex 1Sustainability statementESRS 2 - SBM 3 - E416 (b)Indicator number 10 Table #2 of Annex 1Sustainability statementESRS 2 - SBM 3 - E416 (c)Indicator number 14 Table #2 of Annex 1Sustainability statementESRS E4-224 (b)Sustainable land/agriculture practices or policiesIndicator number 11 Table #2 of Annex 1Not applicable to DFDS-ESRS E4-224 (c)Sustainable oceans/seas practices or policiesIndicator number 12 Table #2 of Annex 1Sustainability statementESRS E4-224 (d)Policies to address deforestationIndicator number 15 Table #2 of Annex 1Not applicable to DFDS-ESRS 2 - SBM3-S114 (f)Risk of incidents of forced labourIndicator number 13 Table #3 of Annex INot applicable to DFDS-ESRS 2 - SBM3-S114 (g)Risk of incidents of child labourIndicator number 12 Table #3 of Annex INot applicable to DFDS-Page 93Page 94Page 94Page 98Page 101Page 101Page 101Page 100General disclosure index continuedDisclosure RequirementDatapointSustainability statements | AppendixSFDR referencePillar 3 referenceBenchmark regulation referenceEU Climate Law referenceSectionPageESRS S1-120Human rights policy commitmentsIndicator number 9 Table #3 and Indicator number 11 Table #1 of Annex ISustainability statementESRS S1-121Due diligence policies on issues addressed by the fundamental International Labor Organisation Conventions 1 to 8Delegated Regulation (EU) 2020/1816, Annex IISustainability statementESRS S1-122Process and measures for preventing trafficking in human beingsIndicator number 11 Table #3 of Annex ISustainability statementESRS S1-123Workplace accident prevention policy or management systemIndicator number 1 Table #3 of Annex ISustainability statementESRS S1-332 (c)Grievance/complaints handling mechanismsIndicator number 5 Table#3 of Annex ISustainability statementESRS S1-1488 (b) and (c)Number of fatalities and number and rate of work-related accidentsIndicator number 2 Table #3 of Annex IDelegated Regulation (EU) 2020/1816, Annex IISustainability statementESRS S1-1488 (e)Number of days lost to injuries, accidents, fatalities or illnessIndicator number 3 Table #3 of Annex ISustainability statementESRS S1-1697 (a)Unadjusted gender pay gapIndicator number 12 Table #1 of Annex IDelegated Regulation (EU) 2020/1816, Annex IISustainability statementESRS S1-1697 (b)Excessive CEO pay ratioIndicator number 8 Table #3 of Annex ISustainability statementESRS S1-17103 (a)Incidents of discrimination Indicator number 7 Table#3 of Annex ISustainability statementESRS S1-17104 (a)Non-respect of UNGPs on Business and Human Rights and OECDIndicator number 10 Table #1 and Indicator n. 14 Table #3 of Annex IDelegated Regulation (EU) 2020/1816, Annex II Delegated Regulation (EU) 2020/1818 Art 12 (1)Sustainability statementESRS 2-SBM3-S211 (b)Significant risk of child labour or forced labour in the value chainIndicators number 12 and n. 13 Table #3 of Annex ISustainability statementESRS S2-117Human rights policy commitmentsIndicator number 9 Table #3 and Indicator n. 11 Table #1 of Annex 1Sustainability statementESRS S2-118Policies related to value chain workersIndicator number 11 and n. 4 Table #3 of Annex 1Sustainability statementPage 110Page 110Page 111Page 111Page 111Page 117Page 117Page 118Page 118Page 118Page 118Page 120Page 120Page 121General disclosure index continuedDisclosure RequirementDatapointSustainability statements | AppendixSFDR referencePillar 3 referenceBenchmark regulation referenceEU Climate Law referenceSectionPageESRS S2-119Non-respect of UNGPs on Business and Human Rights principles and OECD guidelines Indicator number 10 Table #1 of Annex 1Delegated Regulation (EU) 2020/1816, Annex II Delegated Regulation (EU) 2020/1818, Art 12 (1)Sustainability statementESRS S2-119Due diligence policies on issues addressed by the fundamental International Labor Organisation Conventions 1 to 8Delegated Regulation (EU) 2020/1816, Annex IISustainability statementESRS S2-436Human rights issues and incidents connected to its upstream and downstream value chainIndicator number 14 Table #3 of Annex 1Not applicable to DFDS-ESRS S4-116Policies related to consumers and end-usersIndicator number 9 Table #3 and Indicator number 11 Table #1 of Annex 1Sustainability statementESRS S4-117Non-respect of UNGPs on Business and Human Rights and OECD guidelinesIndicator number 10 Table #1 of Annex 1Sustainability statementESRS S4-435Human rights issues and incidentsIndicator number 14 Table #3 of Annex 1Not applicable to DFDS-ESRS G1-110 (b)United Nations Convention against Corruption Indicator number 15 Table #3 of Annex 1Sustainability statementESRS G1-110 (d)Protection of whistle-blowersIndicator number 6 Table #3 of Annex 1Sustainability statementESRS G1-424 (a)Fines for violation of anti-corruption and anti-bribery lawsIndicator number 17 Table #3 of Annex 1Delegated Regulation (EU) 2020/1816, Annex II)Sustainability statementESRS G1-424 (b)Standards of anti-corruption and anti-briberyIndicator number 16 Table #3 of Annex 1Not applicable to DFDS-Page 121Page 121Page 124Page 125Page 128Page 128Page 130Independent auditor’s limited assurance report on the Sustainability StatementTo the stakeholders of DFDS A/SLimited assurance conclusionWe have conducted a limited assurance engagement on the sustainability statement of DFDS A/S (the “Group”) included in the Management’s Report (the “Sustainability Statement”), page 62 – 135, for the financial year 1 January – 31 December 2024.Based on the procedures we have performed and the evidence we have obtained, nothing has come to our attention that causes us to believe that the Sustainability Statement is not prepared, in all material respects, in accordance with the Danish Financial Statements Act paragraph 99 a, including: compliance with the European Sustainability Reporting Standards (ESRS), including that the process carried out by the management to identify the information reported in the Sustainability Statement (the “Process”) is in accordance with the description set out in the section "Double Materiality Assessment"; andcompliance of the disclosures in the subsection "EU Taxonomy" in the environmental section of the Sustainability Statement with Article 8 of EU Regulation 2020/852 (the “Taxonomy Regulation”).Basis for conclusion We conducted our limited assurance engagement in accordance with International Standard on Assurance Engagements (ISAE) 3000 (Revised), Assurance engagements other than audits or reviews of historical financial information (“ISAE 3000 (Revised)”) and the additional requirements applicable in Denmark.The procedures in a limited assurance engagement vary in nature and timing from, and are less in extent than for, a reasonable assurance engagement. Consequently, the level of assurance obtained in a limited assurance engagement is substantially lower than the assurance that would have been obtained had a reasonable assurance engagement been performed.We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our conclusion. Our responsibilities under this standard are further described in the Auditor’s responsibilities for the assurance engagement section of our report. Our independence and quality managementWe are independent of the Group in accordance with the International Ethics Standards Board for Accountants’ International Code of Ethics for Professional Accountants (IESBA Code) and the additional ethical requirements applicable in Denmark. We have also fulfilled our other ethical responsibilities in accordance with these requirements and the IESBA Code.Our firm applies International Standard on Quality Management 1, which requires the firm to design, implement and operate a system of quality management including policies or procedures regarding compliance with ethical requirements, professional standards and applicable legal and regulatory requirements.Management’s responsibilities for the Sustainability StatementManagement is responsible for designing and implementing a process to identify the information reported in the Sustainability Statement in accordance with the ESRS and for disclosing this Process as included in the section "Double Materiality Assessment" of the Sustainability Statement. This responsibility includes:understanding the context in which the Group’s activities and business relationships take place and developing an understanding of its affected stakeholders;the identification of the actual and potential impacts (both negative and positive) related to sustainability matters, as well as risks and opportunities that affect, or could reasonably be expected to affect, the Group’s financial position, financial performance, cash flows, access to finance or cost of capital over the short-, medium-, or long-term;the assessment of the materiality of the identified impacts, risks and opportunities related to sustainability matters by selecting and applying appropriate thresholds; andmaking assumptions that are reasonable in the circumstances.Management is further responsible for the preparation of the Sustainability Statement, which includes the information identified by the Process, in accordance with the Danish Financial Statements Act paragraph 99 a, including: compliance with the ESRS;preparing the disclosures as included in subsection "EU Taxonomy" within the environmental section of the Sustainability Statement, in compliance with Article 8 of the Taxonomy Regulation;designing, implementing and maintaining such internal control that management determines is necessary to enable the preparation of the Sustainability Statement that is free from material misstatement, whether due to fraud or error; andthe selection and application of appropriate sustainability reporting methods and making assumptions and estimates that are reasonable in the circumstances. Inherent limitations in preparing the Sustainability StatementIn reporting forward-looking information in accordance with ESRS, management is required to prepare the forward-looking information on the basis of disclosed assumptions about events that may occur in the future and possible future actions by the Group. Actual outcomes are likely to be different since anticipated events frequently do not occur as expected.Auditor’s responsibilities for the assurance engagementOur responsibility is to plan and perform the assurance engagement to obtain limited assurance about whether the Sustainability Statement is free from material misstatement, whether due to fraud or error, and to issue a limited assurance report that includes our conclusion. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence decisions of users taken on the basis of the Sustainability Statement as a whole. As part of a limited assurance engagement in accordance with ISAE 3000 (Revised) we exercise professional judgement and maintain professional scepticism throughout the engagement. Our responsibilities in respect of the Process include:Obtaining an understanding of the Process, but not for the purpose of providing a conclusion on the effectiveness of the Process, including the outcome of the Process; Considering whether the information identified addresses the applicable disclosure requirements of the ESRS; and Designing and performing procedures to evaluate whether the Process is consistent with the Group’s description of its Process, as disclosed in the section "Double Materiality Assessment" of the Sustainability Statement. Our other responsibilities in respect of the Sustainability Statement include: Identifying where material misstatements are likely to arise, whether due to fraud or error; and Designing and performing procedures responsive to disclosures in the Sustainability Statement where material misstatements are likely to arise. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control.Summary of the work performedA limited assurance engagement involves performing procedures to obtain evidence about the Sustainability Statement. The nature, timing and extent of procedures selected depend on professional judgement, including the identification of disclosures where material misstatements are likely to arise, whether due to fraud or error, in the Sustainability Statement.In conducting our limited assurance engagement, with respect to the Process, we: Obtained an understanding of the Process by performing inquiries to understand the sources of the information used by management; and reviewing the Group’s internal documentation of its Process; andEvaluated whether the evidence obtained from our procedures about the Process implemented by the Group was consistent with the description of the Process set out in the section "Double Materiality Assessment".In conducting our limited assurance engagement, with respect to the Sustainability Statement, we: Obtained an understanding of the Group’s reporting processes relevant to the preparation of its Sustainability Statement including the consolidation processes by obtaining an understanding of the Group’s control environment, processes and information systems relevant to the preparation of the Sustainability Statement but not evaluating the design of particular control activities, obtaining evidence about their implementation or testing their operating effectiveness; Evaluated whether the information identified by the Process is included in the Sustainability Statement;Evaluated whether the structure and the presentation of the Sustainability Statement are in accordance with the ESRS;Performed inquiries of relevant personnel and analytical procedures on selected information in the Sustainability Statement;Performed substantive assurance procedures on selected information in the Sustainability Statement;Where applicable, compared disclosures in the Sustainability Statement with the corresponding disclosures in the financial statements and Management’s Report;Evaluated the methods, assumptions and data for developing estimates and forward-looking information;Obtained an understanding of the Group’s process to identify taxonomy-eligible and taxonomy-aligned economic activities and the corresponding disclosures in the Sustainability Statement.Hellerup21 February 2025PricewaterhouseCoopersStatsautoriseret RevisionspartnerselskabCVR no 33771231Rasmus Friis JørgensenState AuthorisedPublic Accountantmne28705Thomas Wraae HolmState AuthorisedPublic Accountantmne30141</mrv:SustainabilityReport>
   <mrv:DescriptionofTheTaxonomyRegulation contextRef="ctx-1" id="s8__8__10" xml:lang="en">EU TaxonomyThe taxonomy is a classification and reporting system that identifies sustainable economic activities as defined by EU. It is a cornerstone in the EU’s sustainable finance framework and an essential tool for market transparency. According to the regulation DFDS is required to disclose the proportion of our activities that are taxonomy-el-igible and taxonomy-aligned in terms of revenue, capital expenditures (CapEx), and operating expenditures (OpEx). DFDS’ Taxonomy-related disclosures have been assessed and prepared in accordance with Regu-lation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020. Eligible economic activities In 2024 we have made a high-level assessment of eligibility. We conclude that the climate change mitigation technical screening criteria remains relevant for assessing our economic activities. In determining the activities to include in the EU Taxonomy report, our methodology is rooted in a high-level analysis of our core service offerings. The activities represent the focal points of our operations, ensuring relevant and impactful report-ing. 5 activities in the Climate Delegated Act have been identified as eligible for DFDS: Freight rail transport (CCM 6.2) Freight transport services by road (CCM 6.6) Sea and coastal freight water transport, ves-sels for port operations and auxiliary activities (CCM 6.10) Infrastructure enabling low-carbon water trans-port (CCM 6.16) Acquisition and ownership of buildings (CCM 7.7) Our ocean transport operations are represented through activity 6.10, covering our vessels, and 6.16, covering our terminal operations. For the logistics solutions on land, we are covering freight by truck through activity 6.6 and by rail through activity 6.2. Activity 7.7 covers our ownership of warehouses and office buildings. In 2024, the taxonomy-eligible share of our revenue was 84% (2023: 84%), of which non-aligned was 61% (2023: 58%). The taxonomy-eligible share of operational expenses (OpEx) was 100% (2023: 100%) of which non-aligned was 78% (2023: 74%), whereas the taxonomy-eligible share of capital ex-penditures (CapEx) was 96% (2023: 96% of which non-alinged was 74% (2023: 78%). Aligned economic activities DFDS has analysed its compliance level with the technical screening criteria and the Do-No-Sig-nificant-Harm (DNSH) criteria for the above-men-tioned activities. Our assessment shows alignment within 4 economic activities: Freight rail transport (CCM 6.2), Freight transport services by road (CCM 6.6), Sea and coastal freight water transport, vessels for port operations and aux-iliary activities (CCM 6.10), and Acquisition and ownership of buildings (CCM 7.7). Alignment has been determined to 22% for revenue (2023: 26%), 22% for OpEx (2023: 26%) and 22% for CapEx (2023: 18%). Revenue linked to aligned activities comprise freight transport by rail (DKK 470m), revenue derived from vessels (DKK 6,055m) as well as rev-enue generated by e-trucks (DKK 49m). Aligned OpEx constitutes maintenance and servicing cost for owned ships and trucks (DKK 287m). CapEx linked to aligned activities include invest-ments and improvements in vessels (DKK 891m) and e-trucks acquisitions (DKK 37m). No additions related to acquisitions were considered aligned.Looking forward As the taxonomy-alignment requirements are still evolving, we expect our taxonomy reporting to continue developing. Read more on CapEx related to transition to green on page 84Read more on CapEx related to climate action plan on page 88Eligibility and alignment overviewUnits202420231RevenueAlignedDKK million6,5756,966Aligned%2226Eligible, non-alignedDKK million18,28615,917Eligible, non-aligned%6158Non-eligibleDKK million4,8924,422Non-eligible%1616TotalDKK million29,75327,304OpExAlignedDKK million287299Aligned%2226Eligible, non-alignedDKK million1,010846Eligible, non-aligned%7874Non-eligibleDKK million--Non-eligible%00TotalDKK million1,2971,145CapExAlignedDKK million927778Aligned%2218Eligible, non-alignedDKK million3,3613,414Eligible, non-aligned%7478Non-eligibleDKK million166184Non-eligible%44TotalDKK million4,4544,3761	2023 restated due to updated methodology for calculating revenue for vessels aligned for sea and coastal freight water transport (6.10), presenting more reliable and repevant information. OpEx and CapEx restated as a result of IFRS 16 restatement.Proportion of revenue from products or services associated with taxonomy-aligned economic activities 2024Substantial contribution criteriaDNSH criteria ('Does Not Significantly Harm')Proportion of taxonomy-aligned or eligible of revenue, 2023Category(enabling activity or transitional activity)RevenueProportion of RevenueClimate change mitigationClimate change adaptationWater and marine resourcesPollutionCircular economyBiodiversity and eco-systemsClimate change mitigationClimate change adaptationWater and marine resourcesPollutionsCircular economyBiodiversity and eco-systemsMinimum safeguardsEconomic activitiesCode(s)DKK million%%%%%%%Y/NY/NY/NY/NY/NY/NY/NPercentE/TA. TAXONOMY-ELIGIBLE ACTIVITIESA.1 Environmentally sustainable activities (Taxonomy aligned)Freight rail transportCCM 6.2470 2Y N N/EL N/EL N/EL N/EL YYYYYYY3TFreight transport services by roadCCM 6.649 0Y N N/EL N/EL N/EL N/EL YYYYYYY0TSea and coastal freight water transport, vessels for port operations and auxiliary activitiesCCM 6.106,055 20Y N N/EL N/EL N/EL N/EL YYYYYYY23TRevenue of environmentally sustainable activities (Taxonomy-aligned) (A.1)6,57522220 0000YYYYYYY26Of which enabling- 0000000YYYYYYY0EOf which transitional6,575 222200000YYYYYYY30TA.2 Taxonomy-Eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) Freight rail transportCCM 6.2145 0ELELN/ELN/ELN/ELN/EL0 Freight transport services by roadCCM 6.612,64643ELELN/ELN/ELN/ELN/EL42 Sea and coastal freight water transport, vessels for port operations and auxiliary activitiesCCM 6.104,908 16ELELN/ELN/ELN/ELN/EL14 Infrastructure enabling low-carbon water transportCCM 6.12588 2ELELN/ELN/ELN/ELN/EL2 Revenue of Taxonomy-eligible but not environmen-tally sustainable activities (not Taxonomy-aligned activities) (A.2)18,286 61610000058 Total (A.1+A.2)24,861848400000B. TAXONOMY-NON-ELIGIBLE ACTIVITIESRevenue of Taxonomy-non-eligible activities (B)4,892 16Total (A+B)29,753100Y	Yes (taxonomy-eligible and taxonomy-aligned activity with the relevant environment objective)N	No (taxonomy-eligible and taxonomy-aligned activity with the relevant environment objective) N/EL	Not eligible (taxonomy-non-eligible activity for the relevant environment objective)EU TaxonomyProportion of CapEx from products or services associated with Taxonomy-aligned economic activities 2024Substantial contribution criteriaDNSH criteria ('Does Not Significantly Harm')Proportion of taxonomy-aligned or eligible of CapEx, 2023Category(enabling activity or transitional activity)CapExProportion of CapExClimate change mitigationClimate change adaptationWater and marine resourcesPollutionCircular economyBiodiversity and eco-systemsClimate change mitigationClimate change adaptationWater and marine resourcesPollutionsCircular economyBiodiversity and eco-systemsMinimum safeguardsEconomic activitiesCode(s)DKK million%%%%%%%Y/NY/NY/NY/NY/NY/NY/NPercentE/TA. TAXONOMY-ELIGIBLE ACTIVITIESA.1 Environmentally sustainable activities (Taxonomy aligned)Freight transport services by roadCCM 6.6371Y N N/EL N/EL N/EL N/EL YYYYYYY0TSea and coastal freight water transport, vessels for port operations and auxiliary activitiesCCM 6.1089121Y N N/EL N/EL N/EL N/EL YYYYYYY14TAcquisition and ownership of buildingsCCM 7.70 0Y N N/EL N/EL N/EL N/EL YYYYYYY3N/ACapEx of environmentally sustainable activities (Taxonomy-aligned) (A.1)92722220 0000YYYYYYY18Of which enabling-0000000YYYYYYY0EOf which transitional891212100000YYYYYYY14TA.2 Taxonomy-Eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) Freight transport services by roadCCM 6.61,347 30ELELN/ELN/ELN/ELN/EL29Sea and coastal freight water transport, vessels for port operations and auxiliary activitiesCCM 6.101,023 23ELELN/ELN/ELN/ELN/EL27Infrastructure enabling low-carbon water transportCCM 6.16481 11ELELN/ELN/ELN/ELN/EL8Acquisition and ownership of buildingsCCM 7.7510 11ELELN/ELN/ELN/ELN/EL17CapEx of Taxonomy-eligible but not environmen-tally sustainable activities (not Taxonomy-aligned activities) (A.2)3,361 75740 0 0 0 0 78Total (A.1+A.2)4,288 969600000B. TAXONOMY-NON-ELIGIBLE ACTIVITIESCapEx of Taxonomy-non-eligible activities (B)166 4Total (A+B)4,454 100Y	Yes (taxonomy-eligible and taxonomy-aligned activity with the relevant environment objective)N	No (taxonomy-eligible and taxonomy-aligned activity with the relevant environment objective) N/EL	Not eligible (taxonomy-non-eligible activity for the relevant environment objective)EU TaxonomyProportion of OpEx from products or services associated with Taxonomy-aligned economic activities 2024Substantial contribution criteriaDNSH criteria ('Does Not Significantly Harm')Proportion of taxonomy-aligned or eligible of OpEx, 2023Category(enabling activity or transitional activity)OpExProportion of OpExClimate change mitigationClimate change adaptationWater and marine resourcesPollutionCircular economyBiodiversity and eco-systemsClimate change mitigationClimate change adaptationWater and marine resourcesPollutionsCircular economyBiodiversity and eco-systemsMinimum safeguardsEconomic activitiesCode(s)DKK million%%%%%%%Y/NY/NY/NY/NY/NY/NY/NPercentE/TA. TAXONOMY-ELIGIBLE ACTIVITIESA.1 Environmentally sustainable activities (Taxonomy aligned)Freight transport services by roadCCM 6.620YNN/ELN/ELN/ELN/ELYYYYYYY0ESea and coastal freight water transport, vessels for port operations and auxiliary activitiesCCM 6.1028422Y N N/EL N/EL N/EL N/EL YYYYYYY26TOpEx of environmentally sustainable activities (Taxonomy-aligned) (A.1)28722220 0000YYYYYYY26Of which enabling-0000000YYYYYYY0EOf which transitional284222200000YYYYYYY26TA.2 Taxonomy-Eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) Freight transport services by roadCCM 6.6653 1ELELN/ELN/ELN/ELN/EL1 Sea and coastal freight water transport, vessels for port operations and auxiliary activitiesCCM 6.10358 28ELELN/ELN/ELN/ELN/EL23OpEx of Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) (A.2)1,0107878 0 0 0 0 0 74 Total (A.1+A.2)1,297 10010000000B. TAXONOMY-NON-ELIGIBLE ACTIVITIESOpEx of Taxonomy-non-eligible activities (B)- 0Total (A+B)1,297100Y	Yes (taxonomy-eligible and taxonomy-aligned activity with the relevant environment objective)N	No (taxonomy-eligible and taxonomy-aligned activity with the relevant environment objective) N/EL	Not eligible (taxonomy-non-eligible activity for the relevant environment objective)EU TaxonomyNuclear and fossil gas related activitiesRowNuclear energy related activities1The undertaking carries out, funds or has exposures to research, development, demonstration and deployment of innovative electricity generation facilities that produce energy from nuclear processes with minimal waste from the fuel cycle.NO2The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear installations to produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production, as well as their safety upgrades, using best available technologies.NO3The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that produce electricity or process heat, including for the purposes of district heating or industrial processes such as hydrogen production from nuclear energy, as well as their safety upgrades.NOFossil gas related activities4The undertaking carries out, funds or has exposures to construction or operation of electricity generation facilities that produce electricity using fossil gaseous fuels.NO5The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined heat/cool and power generation facilities using fossil gaseous fuels.NO6The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat generation facilities that produce heat/cool using fossil gaseous fuels.NOEU Taxonomy§ Accounting policiesIdentification of taxonomy eligible and aligned economic activitiesWe have determined the taxonomy-eligible economic activities (the numerator for the taxonomy-eligible KPIs) by the following process: Identifying economic activities and processes across the business of the DFDS Group. Evaluating whether the identified economic activities in the DFDS Group are covered by the economic activity descriptions included in the taxonomy. We have determined the taxonomy-aligned economic activities (the numerator for the taxonomy-alignment KPIs) by the following process: Assessing the substantial contribution to one or more of the climate and environmental objectives Evaluating the “Do No Significant Harm” (‘DNSH’) criteria to the other objectives Determining compliance with the minimum safeguards for social and governance standards (assessed on Group level) Determining compliance with the technical screening criteria per eligible activity. Substantial contribution The economic activities identified as aligned all contribute to climate change mitigation based on the assessment and documentation carried out. 6.2 Freight and rail transport The contribution stems from zero direct tailpipe CO2e emissions from trains and wagons and none are dedicated to the transport of fossil fuels. Revenue is determined by splitting rail service revenue by diesel and electric trains. 6.6 Road transport The contribution stems from zero-emission heavy-duty vehicles emitting less than 1g CO2e/kWh and low-emission heavy-duty vehicles emitting less than half of the reference CO2emissions of vehicles in their sub-group. To determine alignment, we define the e-trucks meeting the criteria and include the part of the transportation that has been carried out by the e-trucks in question. 6.10 Sea and coastal freight The contribution stems from vessels that are exclusively operating coastal and short sea services designed to enable the modal shift of freight on land to sea. The sea freight produces lower CO2e emissions than the average reference CO2e emission defined for heavy vehicles in accordance with Article 11 of Regulation 2109/1242. In addition, vessels with an attained value below the Energy Efficiency Design Index (EEDI) or Energy Efficiency Existing Ships Index (EEXI) value, respectively, are considered equivalent.Note that this is a transitional alignment that applies until year 2025 (included). 7.7 Acquisition and ownership of buildings The contribution is related to the energy performance of the building as documented by energy performance certificates and related documents.Do no significant harm For each eligible criteria we have assessed whether the economic activity has a negative impact on any of the other climate and environmental objectives. We have assessed each activity’s alignment with every DNSH criteria by either investigating internally if our operations comply with the stated criteria, or if we are complying with other EU regulations and environmental standards. We only report alignment for economic activities when we have reliable data proving that no negative impacts have been identified. Climate change adaptation Across the four aligned activities, the climate risk and vulnerability has been assessed in the climate risk scenario analysis performed in 2024. Sustainable use and protection of water and marine resources Pollution to water has been assessed and found not to have material impact. Transition to a circular economy Documentation received from rail service providers for waste management plans. Truck manufacturers have provided details of the recyclability aligned to EU regulation. Vessels are compliant with MARPOL, EU regulation No. 1257/2013, and commitment to Hong Kong Convention. § Accounting policiesPollution prevention and control Certificates from train service suppliers to document the use of electric propulsion in the delivery of the service. For e-trucks data on tyres according to Euro classes determine whether they do significant harm. In some locations, e-trucks are fitted with different types of tyres according to seasons/weather conditions. In cases where e-trucks are fitted with non-compliant tyres for a part of the year (or the full year), they will not be considered aligned. Vessels follow sulphur and NOx requirements and measures to minimise toxicity of anti-fouling paint is in place. Protection and restoration of biodiversity and ecosystems Ballast water treatment in place on vessels, measures to prevent invasive species and noise vibration limitations in place.Minimum safeguards Our economic activities are carried out in compliance with the Minimum Safeguards. DFDS has policies and processes in place to ensure that human rights are respected within our own operations as well as the value chain, including third-party workers, hauliers, and seafarers. As such we comply with the minimum labour and human rights standards. Taxation is governed by our Group Tax Policy. The foundation on how DFDS makes decisions and interacts with stakeholders is described in our Code of Conduct, which also includes how we deal with fair competition and bribery/corruption.Calculations The taxonomy-eligible KPIs have been calculated as followed: Eligible Revenue KPI= Eligible Revenue / Total Revenue Eligible OpEx KPI= Eligible OpEx / Total OpEx as defined by the EU Commission Eligible CapEx KPI= Eligible CapEx/ Total CapEx The taxonomy-alignment KPIs have been calculated as followed: Aligned Revenue KPI = Aligned Revenue / Total Revenue Aligned OpEx KPI= Aligned OpEx / Total OpEx as defined by the EU Commission Aligned CapEx KPI= Aligned CapEx / Total CapEx The denominator for the taxonomy KPIs has been determined as followed: Total Revenue is aligned with note 2.2 Revenue Total OpEx is aligned with the OpEx definition by the EU Commission, which covers direct expenditures relating to the day-to-day servicing of assets or property, plant and equipment (maintenance and repairs, short-term leases, R&amp;D, utilities and administrative expenses). Total CapEx is defined as additions to tangible and intangible assets reported in note 3.1.1 Non-current intangible assets (excluding Goodwill since not defined as an intangible asset, cf. IAS 38), note 3.1.2 Noncurrent tangible assets and note 3.1.3 Leases. Reconciling to line items: addition on acquisition of enterprises, additions (except for development projects and assets under construction), transfers (only from development projects and assets under construction), addition/remeasurement. Double counting: DFDS has no economic activities that contributes to several environmental objectives. DFDS has ensured that allocation to Revenue, OpEx and CapEx KPIs across identified economic activities are not double counted. This has been verified by enabling controls such as reconciling the taxonomy KPIs to the consolidated financial statements. Disaggregation of KPIs: The identified economic activities are not subject to disaggregation of taxonomy KPIs.</mrv:DescriptionofTheTaxonomyRegulation>
   <mrv:StatementOfTheDiversityPolicies contextRef="ctx-1" id="s8__8__12" xml:lang="en">Diversity, equity, and inclusion The equity, diversity, and inclusion (DEI) perspec-tives are included in recruitment, promotion, and talent processes. We apply a dedicated and structured approach as well as a focus on an inclusive culture. This includes target setting, financial incentives via bonus schemes, engage-ment surveys, management conferences, training sessions, toolboxes, and efforts to raise aware-ness and to make more unbiased decisions. The monitoring and measures implemented to improve DEI cover all layers of the organisation, including the Board of Directors and the EMT. Both, being diverse in terms of gender, nationality, age, and seniority. In December 2024, a new group-wide HR system was implemented, which will enable us to increase transparency on HR matters.</mrv:StatementOfTheDiversityPolicies>
   <gsd:NameOfReportingEntity contextRef="ctx-1" id="s8__8__20" xml:lang="en">DFDS A/S </gsd:NameOfReportingEntity>
   <gsd:NameOfSubmittingEnterprise contextRef="ctx-1" id="s8__8__21" xml:lang="en">DFDS A/S </gsd:NameOfSubmittingEnterprise>
   <fsa:AverageNumberOfEmployees contextRef="ctx-1" decimals="0" id="s8__8__57" unitRef="pure">14121</fsa:AverageNumberOfEmployees>
   <fsa:AverageNumberOfEmployees contextRef="ctx-57" decimals="0" id="s8__9__57" unitRef="pure">13191</fsa:AverageNumberOfEmployees>
   <sob:StatementByExecutiveAndSupervisoryBoards contextRef="ctx-1" id="s8__8__185" xml:lang="en">Statement by the Executive Board and the Board of Directors223Independent Auditors’ Reports 224ReportsStatement by the Executive Board and the Board of Directors The Board of Directors and Executive Board have today considered and adopted the Annual Report of DFDS A/S for the financial year 1 January – 31 December 2024.The Consolidated Financial Statements and the Parent company Financial Statements have been prepared in accordance with IFRS Accounting Standards as adopted by the EU and further requirements in the Danish Financial Statements Act. Management’s Report has been prepared in accordance with the Danish Financial Statements Act. In our opinion, the Consolidated Financial Statements and the Parent Company Financial Statements give a true and fair view of the financial position at 31 December 2024 of the Group and the Parent Company and of the results of the Group and Parent Company operations and cash flows for 2024.In our opinion, Management’s Report includes a fair review of the development in the operations and financial circumstances of the Group and the Parent Company, of the results for the year and of the financial position of the Group and the Parent Company as well as a description of the most significant risks and elements of uncertainty, which the Group and the Parent Company are facing.Additionally, the Sustainability Statement, which is part of Management’s Report, has been prepared, in all material respects, in accordance with paragraph 99 a of the Danish Financial Statements Act. This includes compliance with the European Sustainability Reporting Standards (ESRS) including that the process undertaken by Management to identify the reported information (the “Process”) is in accordance with the description set out in the section "Double Materiality Assessment". Furthermore, disclosures in the subsection "EU Taxonomy" in the environmental section of the sustainability statement are, in all material respects, in accordance with Article 8 of EU Regulation 2020/852 (the “Taxonomy Regulation”).The year 2024 marks the initial implementation of paragraph 99 a of the Danish Financial Statements Act concerning compliance with ESRS. As such, more clear guidance and practice are anticipated in various areas, which are expected to be issued in the coming years. Furthermore, the Sustainability Statement includes forward-looking statements based on disclosed assumptions about events that may occur in the future and possible future actions by the Group. Actual outcomes are likely to be different since anticipated events frequently do not occur as expected.In our opinion, the annual report of DFDS A/S for the financial year 1 January to 31 December 2024 with the file name DFDS-2024-12-31-en.zip is prepared, in all material respects, in compliance with the ESEF Regulation.We recommend that the Annual Report be adopted at the Annual General Meeting.</sob:StatementByExecutiveAndSupervisoryBoards>
   <sob:PlaceOfSignatureOfStatement contextRef="ctx-1" id="s8__8__186" xml:lang="en">Copenhagen</sob:PlaceOfSignatureOfStatement>
   <sob:DateOfApprovalOfAnnualReport contextRef="ctx-1" id="s8__8__187">2025-02-21</sob:DateOfApprovalOfAnnualReport>
   <cmn:NameAndSurnameOfMemberOfExecutiveBoard contextRef="ctx-42" id="s8__8__188" xml:lang="en">Torben Carlsen</cmn:NameAndSurnameOfMemberOfExecutiveBoard>
   <cmn:NameAndSurnameOfMemberOfExecutiveBoard contextRef="ctx-43" id="s8__8__190" xml:lang="en">Karen Boesen</cmn:NameAndSurnameOfMemberOfExecutiveBoard>
   <cmn:TitleOfMemberOfExecutiveBoard contextRef="ctx-42" id="s8__8__189" xml:lang="en">President &amp; Ceo</cmn:TitleOfMemberOfExecutiveBoard>
   <cmn:TitleOfMemberOfExecutiveBoard contextRef="ctx-43" id="s8__8__191" xml:lang="en">Executive Vice President &amp; Cfo</cmn:TitleOfMemberOfExecutiveBoard>
   <cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-44" id="s8__8__192" xml:lang="en">Claus V. Hemmingsen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
   <cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-45" id="s8__8__193" xml:lang="en">Klaus Nyborg</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
   <cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-52" id="s8__8__202" xml:lang="en">Minna Aila</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
   <cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-46" id="s8__8__194" xml:lang="en">Anders Götzsche</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
   <cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx-44" id="s8__8__196" xml:lang="en">Chairman</cmn:TitleOfMemberOfSupervisoryBoard>
   <cmn:TitleOfMemberOfSupervisoryBoard contextRef="ctx-45" id="s8__8__197" xml:lang="en">Vice Chair</cmn:TitleOfMemberOfSupervisoryBoard>
   <cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-51" id="s8__8__201" xml:lang="en">Marianne Henriksen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
   <cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-49" id="s8__8__199" xml:lang="en">Kristian Kristensen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
   <cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-48" id="s8__8__198" xml:lang="en">Jill Lauritzen Melby</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
   <cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-50" id="s8__8__200" xml:lang="en">Lars Skjold-Hansen</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
   <cmn:NameAndSurnameOfMemberOfSupervisoryBoard contextRef="ctx-47" id="s8__8__195" xml:lang="en">Dirk Reich</cmn:NameAndSurnameOfMemberOfSupervisoryBoard>
   <arr:AddresseeOfAuditorsReportOnAuditedFinancialStatements contextRef="ctx-1" id="s8__8__204" xml:lang="en">TO THE SHAREHOLDERS OF DFDS A/S</arr:AddresseeOfAuditorsReportOnAuditedFinancialStatements>
   <arr:OpinionOnAuditedFinancialStatements contextRef="ctx-1" id="s8__8__205" xml:lang="en">Our OpinionIn our opinion, the Consolidated Financial Statements and the Parent Company Financial Statements give a true and fair view of the Group’s and the Parent Company’s financial position at 31 December 2024 and of the results of the Group’s and the Parent Company’s operations and cash flows for the financial year 1 January to 31 December 2024 in accordance with IFRS Accounting Standards as adopted by the EU and further requirements in the Danish Financial Statements Act.Our opinion is consistent with our Auditor’s Long-form Report to the Audit Committee and the Board of Directors.What we have auditedThe Consolidated Financial Statements and Parent Company Financial Statements of DFDS A/S for the financial year 1 January to 31 December 2024 comprise income statement and statement of comprehensive income, balance sheet, statement of change in equity, statement of cash flows and notes, including material accounting policy information for the Group as well as for the Parent Company. Collectively referred to as the (“Financial Statements”).</arr:OpinionOnAuditedFinancialStatements>
   <arr:DescriptionOfQualificationsOfAuditedFinancialStatements contextRef="ctx-1" id="s8__8__206" xml:lang="en">Basis for opinionWe conducted our audit in accordance with International Standards on Auditing (ISAs) and the additional requirements applicable in Denmark. Our responsibilities under those standards and requirements are further described in the Auditor’s responsibilities for the audit of the Financial Statements section of our report. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.IndependenceWe are independent of the Group in accordance with the International Ethics Standards Board for Accountants’ International Code of Ethics for Professional Accountants (IESBA Code) and the additional ethical requirements applicable in Denmark. We have also fulfilled our other ethical responsibilities in accordance with these requirements and the IESBA Code. To the best of our knowledge and belief, prohibited non-audit services referred to in Article 5(1) of Regulation (EU) No 537/2014 were not provided. AppointmentWe were first appointed auditors of DFDS A/S on 23 March 2021 for the financial year 2021. We have been reappointed annually by shareholder resolution for a total period of uninterrupted engagement of 4 years including the financial year 2024.</arr:DescriptionOfQualificationsOfAuditedFinancialStatements>
   <arr:KeyAuditMattersAudit contextRef="ctx-1" id="s8__8__207" xml:lang="en">Key audit mattersKey audit matters are those matters that, in our professional judgement, were of most significance in our audit of the Financial Statements for 2024. These matters were addressed in the context of our audit of the Financial Statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters.AcquisitionsThe Group acquired FRS Iberia/Maroc (‘FRS’) on 10 January 2024 and Ekol Transport Anonim Sirketi (‘Ekol’) on 15 November 2024.The Group prepared a purchase price allocation (‘PPA’) for the FRS acquisition as well as a preliminary PPA for the Ekol acquisition, resulting in various assets and liabilities being separately valued. In order to determine the fair value of the separately identified assets and liabilities as part of the acquisitions, the valuation methodologies require input based on assumptions about the future and use of discounted cash flow forecasts. The significant judgements and estimates involved in the PPA mainly related to assessing the fair value of customer relationships and property, plant and equipment including right-of-use assets. The preliminary PPA for Ekol is based on the information currently available and hence includes higher estimation uncertainty due to the recent acquisition. We focused on the PPAs because it involves the identification of the acquired assets and liabilities and determination of their respective fair values, which requires complex and subjective judgements and estimates by Management, which are material for the Consolidated Financial Statements. Reference is made to note 5.5 in the Consolidated Financial Statements How our audit addressed the Key Audit MatterAs part of our audit, we assessed whether the acquisitions made during 2024 met the criteria of a business combination.We reconciled the purchase prices paid to the Share Purchase Agreements and verified the cash paid to documentation for bank transfers. We audited the acquisition balance before purchase price adjustments.We tested the PPA adjustments made by Management by assessing the main judgements and estimates made as well as the methodologies and models applied in determining assets and liabilities assumedat fair value. We tested the main data and challenged significant assumptions made by Management. We also tested the mathematical accuracy of the models used.We involved our internal valuation experts in assessing the valuation methodologies and the significant assumptions used by management.Finally, we assessed the disclosures relating to business combinations.Valuation of goodwill, terminals, ferries and other related assetsThe carrying amount of non-current tangible assets (including right of use assets) as well as intangible assets is significant to the Consolidated Financial Statements. Management monitors the carrying value of the above-mentioned assets based on defined cash generating units (CGUs) and performs impairment tests, if any indication of impairment or reversal of previous impairments exist. Furthermore, goodwill is tested once a year for impairment. Management’s assessment of the recoverability of the carrying amount of the above-mentioned assets is based on value-in-use calculations. Furthermore, Management obtains independent broker valuations to assess the fair value less cost to sell of ferries and other ships. Bearing in mind the generally long-lived nature of the above-mentioned assets, the significant assumptions in estimating the value-in-use calculations are the scenarios applied, revenue, costs, EBIT-margins, future investments, and growth expectations. The impairment tests performed did not lead to impairments or reversals of impairments being recognised in the Consolidated Financial Statements. We focused on this area as the amounts involved are significant and because Management is required to perform estimates and exercise judgements and because of the inherent complexity in estimating the value-in-use. Reference is made to note 3.1.4 in the Consolidated Financial Statements.How our audit addressed the Key Audit MatterAs part of our audit, we challenged the impairment indicator assessment performed by Management. We considered the appropriateness and challenged the CGUs defined by Management as well as the methodology used by Management to assess the carrying amount of non-current assets assigned to CGUs. We carried out risk assessment procedures in order to obtain an understanding of IT systems, business processes and relevant controls regarding data and assumptions used in the impairment models. For the controls, we assessed whether they were designed and implemented to effectively address the risk of material misstatement. For selected controls that we planned to rely on, we tested whether they were performed on a consistent basis.We performed detailed testing of Management’s impairment tests for goodwill and for the individual CGUs where indicators of impairment were identified. We tested the mathematical accuracy of impairment models prepared by Management, and challenged the significant assumptions affecting the future cash flows, including assumptions related to scenarios applied, revenue, costs, EBIT-margins, future investments and growth expectations, etc.In assessing the discount rates and the overall methodology applied, we involved our valuation specialists.Further, we tested the mathematical accuracy of the impairment models prepared by Management.We also assessed the disclosures of these matters in the Consolidated Financial Statements.</arr:KeyAuditMattersAudit>
   <arr:StatementOnManagementsReviewAuditorsReportOnAuditedFinancialStatements contextRef="ctx-1" id="s8__8__208" xml:lang="en">Statement on the Management’s ReportManagement is responsible for Management’s Report (pages 1 - 61 and pages 233 - 234).Our opinion on the Financial Statements does not cover Management’s Report, and we do not as part of the audit express any form of assurance conclusion thereon.In connection with our audit of the Financial Statements, our responsibility is to read Management’s Report and, in doing so, consider whether Management’s Report is materially inconsistent with the Financial Statements or our knowledge obtained in the audit, or otherwise appears to be materially misstated.Moreover, we considered whether Management’s Report includes the disclosures required by the Danish Financial Statements Act. This does not include the requirements in paragraph 99 a related to the Sustainability Statement covered by the separate auditor’s limited assurance report hereon. Based on the work we have performed, in our view, Management’s Report is in accordance with the Consolidated Financial Statements and the Parent Company Financial Statements and has been prepared in accordance with the requirements of the Danish Financial Statements Act, except for the requirements in paragraph 99 a related to the Sustainability Statement, cf. above. We did not identify any material misstatement in Management’s Report.</arr:StatementOnManagementsReviewAuditorsReportOnAuditedFinancialStatements>
   <arr:StatementOfExecutiveAndSupervisoryBoardsResponsibilityForFinancialStatements contextRef="ctx-1" id="s8__8__209" xml:lang="en">Management’s responsibilities for the financial statements Management is responsible for the preparation of consolidated financial statements and parent company financial statements that give a true and fair view in accordance with IFRS Accounting Standards as adopted by the EU and further requirements in the Danish Financial Statements Act, and for such internal control as Management determines is necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error.In preparing the Financial Statements, Management is responsible for assessing the Group’s and the Parent Company’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless Management either intends to liquidate the Group or the Parent Company or to cease operations, or has no realistic alternative but to do so.</arr:StatementOfExecutiveAndSupervisoryBoardsResponsibilityForFinancialStatements>
   <arr:StatementOfAuditorsResponsibilityForAuditAndAuditPerformed contextRef="ctx-1" id="s8__8__210" xml:lang="en">Auditor’s responsibilities for the audit of the financial statementsOur objectives are to obtain reasonable assurance about whether the Financial Statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs and the additional requirements applicable in Denmark will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these Financial Statements.As part of an audit in accordance with ISAs and the additional requirements applicable in Denmark, we exercise professional judgement and maintain professional scepticism throughout the audit. We also:Identify and assess the risks of material misstatement of the Financial Statements, whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control.Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Group’s and the Parent Company’s internal control.Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by Management.Conclude on the appropriateness of Management’s use of the going concern basis of accounting and based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Group’s and the Parent Company’s ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditor’s report to the related disclosures in the Financial Statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditor’s report. However, future events or conditions may cause the Group’s or the Parent Company to cease to continue as a going concern.Evaluate the overall presentation, structure and content of the Financial Statements, including the disclosures, and whether the Financial Statements represent the underlying transactions and events in a manner that gives a true and fair view.Plan and perform the group audit to obtain sufficient appropriate audit evidence regarding the financial information of the entities or business units within the group as a basis for forming an opinion on the Consolidated Financial Statements. We are responsible for the direction, supervision and review of the audit work performed for purposes of the group audit. We remain solely responsible for our audit opinion. We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit.We also provide those charged with governance with a statement that we have complied with relevant ethical requirements regarding independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear on our independence and, where applicable, actions taken to eliminate threats or safeguards applied.From the matters communicated with those charged with governance, we determine those matters that were of most significance in the audit of the Financial Statements of the current period and are therefore the key audit matters. We describe these matters in our auditor’s report unless law or regulation precludes public disclosure about the matter.</arr:StatementOfAuditorsResponsibilityForAuditAndAuditPerformed>
   <arr:AuditorsReportOnXbrlTagging contextRef="ctx-1" id="s8__8__211" xml:lang="en">Report on compliance with the ESEF Regulation As part of our audit of the Financial Statements we performed procedures to express an opinion on whether the annual report of DFDS A/S for the financial year 1 January to 31 December 2024 with the filename DFDS-2024-12-31-en.zip is prepared, in all material respects, in compliance with the Commission Delegated Regulation (EU) 2019/815 on the European Single Electronic Format (ESEF Regulation) which includes requirements related to the preparation of the annual report in XHTML format and iXBRL tagging of the Consolidated Financial Statements including notes.Management is responsible for preparing an annual report that complies with the ESEF Regulation. This responsibility includes:The preparing of the annual report in XHTML formatThe selection and application of appropriate iXBRL tags, including extensions to the ESEF taxonomy and the anchoring thereof to elements in the taxonomy, for all financial information required to be tagged using judgement where necessaryEnsuring consistency between iXBRL tagged data and the Consolidated Financial Statements presented in human-readable format; andFor such internal control as Management determines necessary to enable the preparation of an annual re-port that is compliant with the ESEF Regulation.Our responsibility is to obtain reasonable assurance on whether the annual report is prepared, in all material respects, in compliance with the ESEF Regulation based on the evidence we have obtained, and to issue a report that includes our opinion. The nature, timing and extent of procedures selected depend on the auditor’s judgement, including the assessment of the risks of material departures from the requirements set out in the ESEF Regulation, whether due to fraud or error. The procedures include:Testing whether the annual report is prepared in XHTML formatObtaining an understanding of the company’s iXBRL tagging process and of internal control over the tag-ging processEvaluating the completeness of the iXBRL tagging of the Consolidated Financial Statements including notesEvaluating the appropriateness of the company’s use of iXBRL elements selected from the ESEF taxonomy and the creation of extension elements where no suitable element in the ESEF taxonomy has been identifiedEvaluating the use of anchoring of extension elements to elements in the ESEF taxonomy; andReconciling the iXBRL tagged data with the audited Consolidated Financial Statements.In our opinion, the annual report of DFDS A/S for the financial year 1 January to 31 December 2024 with the filename DFDS-2024-12-31-en.zip is prepared, in all material respects, in compliance with the ESEF Regulation.</arr:AuditorsReportOnXbrlTagging>
   <arr:SignatureOfAuditorsPlace contextRef="ctx-1" id="s8__8__212" xml:lang="en">Hellerup</arr:SignatureOfAuditorsPlace>
   <arr:SignatureOfAuditorsDate contextRef="ctx-1" id="s8__8__213">2025-02-21</arr:SignatureOfAuditorsDate>
   <cmn:NameOfAuditFirm contextRef="ctx-53" id="s8__8__214" xml:lang="en">PricewaterhouseCoopersStatsautoriseret Revisionspartnerselskab</cmn:NameOfAuditFirm>
   <cmn:NameOfAuditFirm contextRef="ctx-54" id="s8__8__215" xml:lang="en">PricewaterhouseCoopersStatsautoriseret Revisionspartnerselskab</cmn:NameOfAuditFirm>
   <cmn:IdentificationNumberCvrOfAuditFirm contextRef="ctx-53" id="s8__8__216">33771231</cmn:IdentificationNumberCvrOfAuditFirm>
   <cmn:IdentificationNumberCvrOfAuditFirm contextRef="ctx-54" id="s8__8__217">33771231</cmn:IdentificationNumberCvrOfAuditFirm>
   <cmn:NameAndSurnameOfAuditor contextRef="ctx-53" id="s8__8__218" xml:lang="en">Rasmus Friis Jørgensen</cmn:NameAndSurnameOfAuditor>
   <cmn:DescriptionOfAuditor contextRef="ctx-53" id="s8__8__220" xml:lang="en">State AuthorisedPublic Accountant</cmn:DescriptionOfAuditor>
   <cmn:IdentificationNumberOfAuditor contextRef="ctx-53" id="s8__8__222">mne28705</cmn:IdentificationNumberOfAuditor>
   <cmn:NameAndSurnameOfAuditor contextRef="ctx-54" id="s8__8__219" xml:lang="en">Thomas Wraae Holm</cmn:NameAndSurnameOfAuditor>
   <cmn:DescriptionOfAuditor contextRef="ctx-54" id="s8__8__221" xml:lang="en">State AuthorisedPublic Accountant</cmn:DescriptionOfAuditor>
   <cmn:IdentificationNumberOfAuditor contextRef="ctx-54" id="s8__8__223">mne30141</cmn:IdentificationNumberOfAuditor>
   <arr:AuditorsReportOnSubstainabilityReport contextRef="ctx-1" id="s8__8__226" xml:lang="en">Independent auditor’s limited assurance report on the Sustainability StatementTo the stakeholders of DFDS A/SLimited assurance conclusionWe have conducted a limited assurance engagement on the sustainability statement of DFDS A/S (the “Group”) included in the Management’s Report (the “Sustainability Statement”), page 62 – 135, for the financial year 1 January – 31 December 2024.Based on the procedures we have performed and the evidence we have obtained, nothing has come to our attention that causes us to believe that the Sustainability Statement is not prepared, in all material respects, in accordance with the Danish Financial Statements Act paragraph 99 a, including: compliance with the European Sustainability Reporting Standards (ESRS), including that the process carried out by the management to identify the information reported in the Sustainability Statement (the “Process”) is in accordance with the description set out in the section "Double Materiality Assessment"; andcompliance of the disclosures in the subsection "EU Taxonomy" in the environmental section of the Sustainability Statement with Article 8 of EU Regulation 2020/852 (the “Taxonomy Regulation”).Basis for conclusion We conducted our limited assurance engagement in accordance with International Standard on Assurance Engagements (ISAE) 3000 (Revised), Assurance engagements other than audits or reviews of historical financial information (“ISAE 3000 (Revised)”) and the additional requirements applicable in Denmark.The procedures in a limited assurance engagement vary in nature and timing from, and are less in extent than for, a reasonable assurance engagement. Consequently, the level of assurance obtained in a limited assurance engagement is substantially lower than the assurance that would have been obtained had a reasonable assurance engagement been performed.We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our conclusion. Our responsibilities under this standard are further described in the Auditor’s responsibilities for the assurance engagement section of our report. Our independence and quality managementWe are independent of the Group in accordance with the International Ethics Standards Board for Accountants’ International Code of Ethics for Professional Accountants (IESBA Code) and the additional ethical requirements applicable in Denmark. We have also fulfilled our other ethical responsibilities in accordance with these requirements and the IESBA Code.Our firm applies International Standard on Quality Management 1, which requires the firm to design, implement and operate a system of quality management including policies or procedures regarding compliance with ethical requirements, professional standards and applicable legal and regulatory requirements.Management’s responsibilities for the Sustainability StatementManagement is responsible for designing and implementing a process to identify the information reported in the Sustainability Statement in accordance with the ESRS and for disclosing this Process as included in the section "Double Materiality Assessment" of the Sustainability Statement. This responsibility includes:understanding the context in which the Group’s activities and business relationships take place and developing an understanding of its affected stakeholders;the identification of the actual and potential impacts (both negative and positive) related to sustainability matters, as well as risks and opportunities that affect, or could reasonably be expected to affect, the Group’s financial position, financial performance, cash flows, access to finance or cost of capital over the short-, medium-, or long-term;the assessment of the materiality of the identified impacts, risks and opportunities related to sustainability matters by selecting and applying appropriate thresholds; andmaking assumptions that are reasonable in the circumstances.Management is further responsible for the preparation of the Sustainability Statement, which includes the information identified by the Process, in accordance with the Danish Financial Statements Act paragraph 99 a, including: compliance with the ESRS;preparing the disclosures as included in subsection "EU Taxonomy" within the environmental section of the Sustainability Statement, in compliance with Article 8 of the Taxonomy Regulation;designing, implementing and maintaining such internal control that management determines is necessary to enable the preparation of the Sustainability Statement that is free from material misstatement, whether due to fraud or error; andthe selection and application of appropriate sustainability reporting methods and making assumptions and estimates that are reasonable in the circumstances. Inherent limitations in preparing the Sustainability StatementIn reporting forward-looking information in accordance with ESRS, management is required to prepare the forward-looking information on the basis of disclosed assumptions about events that may occur in the future and possible future actions by the Group. Actual outcomes are likely to be different since anticipated events frequently do not occur as expected.Auditor’s responsibilities for the assurance engagementOur responsibility is to plan and perform the assurance engagement to obtain limited assurance about whether the Sustainability Statement is free from material misstatement, whether due to fraud or error, and to issue a limited assurance report that includes our conclusion. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence decisions of users taken on the basis of the Sustainability Statement as a whole. As part of a limited assurance engagement in accordance with ISAE 3000 (Revised) we exercise professional judgement and maintain professional scepticism throughout the engagement. Our responsibilities in respect of the Process include:Obtaining an understanding of the Process, but not for the purpose of providing a conclusion on the effectiveness of the Process, including the outcome of the Process; Considering whether the information identified addresses the applicable disclosure requirements of the ESRS; and Designing and performing procedures to evaluate whether the Process is consistent with the Group’s description of its Process, as disclosed in the section "Double Materiality Assessment" of the Sustainability Statement. Our other responsibilities in respect of the Sustainability Statement include: Identifying where material misstatements are likely to arise, whether due to fraud or error; and Designing and performing procedures responsive to disclosures in the Sustainability Statement where material misstatements are likely to arise. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control.Summary of the work performedA limited assurance engagement involves performing procedures to obtain evidence about the Sustainability Statement. The nature, timing and extent of procedures selected depend on professional judgement, including the identification of disclosures where material misstatements are likely to arise, whether due to fraud or error, in the Sustainability Statement.In conducting our limited assurance engagement, with respect to the Process, we: Obtained an understanding of the Process by performing inquiries to understand the sources of the information used by management; and reviewing the Group’s internal documentation of its Process; andEvaluated whether the evidence obtained from our procedures about the Process implemented by the Group was consistent with the description of the Process set out in the section "Double Materiality Assessment".In conducting our limited assurance engagement, with respect to the Sustainability Statement, we: Obtained an understanding of the Group’s reporting processes relevant to the preparation of its Sustainability Statement including the consolidation processes by obtaining an understanding of the Group’s control environment, processes and information systems relevant to the preparation of the Sustainability Statement but not evaluating the design of particular control activities, obtaining evidence about their implementation or testing their operating effectiveness; Evaluated whether the information identified by the Process is included in the Sustainability Statement;Evaluated whether the structure and the presentation of the Sustainability Statement are in accordance with the ESRS;Performed inquiries of relevant personnel and analytical procedures on selected information in the Sustainability Statement;Performed substantive assurance procedures on selected information in the Sustainability Statement;Where applicable, compared disclosures in the Sustainability Statement with the corresponding disclosures in the financial statements and Management’s Report;Evaluated the methods, assumptions and data for developing estimates and forward-looking information;Obtained an understanding of the Group’s process to identify taxonomy-eligible and taxonomy-aligned economic activities and the corresponding disclosures in the Sustainability Statement.Hellerup21 February 2025PricewaterhouseCoopersStatsautoriseret RevisionspartnerselskabCVR no 33771231Rasmus Friis JørgensenState AuthorisedPublic Accountantmne28705Thomas Wraae HolmState AuthorisedPublic Accountantmne30141</arr:AuditorsReportOnSubstainabilityReport>
   <arr:AddresseeOfAuditorsReportOnSubstainabilityReports contextRef="ctx-1" id="s8__8__227" xml:lang="en">To the stakeholders of DFDS A/S</arr:AddresseeOfAuditorsReportOnSubstainabilityReports>
   <arr:DescriptionOfQualificationsOfAssuranceEngagementPerformedSubstainabilityReport contextRef="ctx-1" id="s8__8__228" xml:lang="en">Limited assurance conclusionWe have conducted a limited assurance engagement on the sustainability statement of DFDS A/S (the “Group”) included in the Management’s Report (the “Sustainability Statement”), page 62 – 135, for the financial year 1 January – 31 December 2024.</arr:DescriptionOfQualificationsOfAssuranceEngagementPerformedSubstainabilityReport>
   <arr:OpinionOnSubjectMatterOfAssuranceReportSubstainabilityReport contextRef="ctx-1" id="s8__8__229" xml:lang="en">Based on the procedures we have performed and the evidence we have obtained, nothing has come to our attention that causes us to believe that the Sustainability Statement is not prepared, in all material respects, in accordance with the Danish Financial Statements Act paragraph 99 a, including: compliance with the European Sustainability Reporting Standards (ESRS), including that the process carried out by the management to identify the information reported in the Sustainability Statement (the “Process”) is in accordance with the description set out in the section "Double Materiality Assessment"; andcompliance of the disclosures in the subsection "EU Taxonomy" in the environmental section of the Sustainability Statement with Article 8 of EU Regulation 2020/852 (the “Taxonomy Regulation”).</arr:OpinionOnSubjectMatterOfAssuranceReportSubstainabilityReport>
   <arr:StatementOfAuditorsResponsibilitySubstainabilityReport contextRef="ctx-1" id="s8__8__230" xml:lang="en">Auditor’s responsibilities for the assurance engagementOur responsibility is to plan and perform the assurance engagement to obtain limited assurance about whether the Sustainability Statement is free from material misstatement, whether due to fraud or error, and to issue a limited assurance report that includes our conclusion. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence decisions of users taken on the basis of the Sustainability Statement as a whole. As part of a limited assurance engagement in accordance with ISAE 3000 (Revised) we exercise professional judgement and maintain professional scepticism throughout the engagement. Our responsibilities in respect of the Process include:Obtaining an understanding of the Process, but not for the purpose of providing a conclusion on the effectiveness of the Process, including the outcome of the Process; Considering whether the information identified addresses the applicable disclosure requirements of the ESRS; and Designing and performing procedures to evaluate whether the Process is consistent with the Group’s description of its Process, as disclosed in the section "Double Materiality Assessment" of the Sustainability Statement. Our other responsibilities in respect of the Sustainability Statement include: Identifying where material misstatements are likely to arise, whether due to fraud or error; and Designing and performing procedures responsive to disclosures in the Sustainability Statement where material misstatements are likely to arise. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control.</arr:StatementOfAuditorsResponsibilitySubstainabilityReport>
   <arr:SignatureOfSubstainabilityAuditorsPlace contextRef="ctx-1" id="s8__8__231" xml:lang="en">Hellerup</arr:SignatureOfSubstainabilityAuditorsPlace>
   <arr:SignatureOfSubstainabilityAuditorsDate contextRef="ctx-1" id="s8__8__232">2025-02-21</arr:SignatureOfSubstainabilityAuditorsDate>
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   <cmn:NameOfAuditFirmSubstainability contextRef="ctx-56" id="s8__8__234" xml:lang="en">PricewaterhouseCoopersStatsautoriseret Revisionspartnerselskab</cmn:NameOfAuditFirmSubstainability>
   <cmn:IdentificationNumberCvrOfAuditFirmSubstainability contextRef="ctx-55" id="s8__8__235">33771231</cmn:IdentificationNumberCvrOfAuditFirmSubstainability>
   <cmn:IdentificationNumberCvrOfAuditFirmSubstainability contextRef="ctx-56" id="s8__8__236">33771231</cmn:IdentificationNumberCvrOfAuditFirmSubstainability>
   <cmn:NameAndSurnameOfSubstainabilityAuditor contextRef="ctx-55" id="s8__8__237" xml:lang="en">Rasmus Friis Jørgensen</cmn:NameAndSurnameOfSubstainabilityAuditor>
   <cmn:DescriptionOfSubstainabilityAuditor contextRef="ctx-55" id="s8__8__239" xml:lang="en">State AuthorisedPublic Accountant</cmn:DescriptionOfSubstainabilityAuditor>
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   <cmn:NameAndSurnameOfSubstainabilityAuditor contextRef="ctx-56" id="s8__8__238" xml:lang="en">Thomas Wraae Holm</cmn:NameAndSurnameOfSubstainabilityAuditor>
   <cmn:DescriptionOfSubstainabilityAuditor contextRef="ctx-56" id="s8__8__240" xml:lang="en">State AuthorisedPublic Accountant</cmn:DescriptionOfSubstainabilityAuditor>
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   <gsd:InformationOnTypeOfSubmittedReport contextRef="ctx-1" id="s1__72__15">Annual report</gsd:InformationOnTypeOfSubmittedReport>
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   <gsd:ReportingPeriodStartDate contextRef="ctx-1" id="s1__72__20">2024-01-01</gsd:ReportingPeriodStartDate>
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